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      "fallacy", a very detailed analysis has been conducted.
      The annual percent of the total flow for each com-
      munity has been multiplied by the MMSD debt service
      for the same year.  This procedure was carried out for
      all 21 years between 1985 and 2005.  The 21-year
      average for each community is compared to the 21-year
      average originally calculated in Table 61 of the
      Fiscal Appendix.  As shown in the table below, there
      is a difference of 3% between the Table 61 average
      charges and the charges resulting from the detailed
      analysis conducted to respond to this MMSD comment.

                          Detailed     Fiscal       Percent
                          Analysis    Appendix     Difference

      Caddy Vista         $   38      $    43         13 %
      Germantown             717          741          3
      Menomonee Falls      1,666        1,714          3
      Mequon               1,165        1,206          3
      Muskego                608          629          3
      New Berlin           1,729        1,783         _3

      Total               $5,923      $ 6,116          3 %

      All costs in Thousands.

347.  The comment period was extended two weeks beyond the
      minimum period designated by the EPA and DNR regulations
      to take into account the complexity of the document.

348.  Appendix VII, Water Quality, has been revised to
      include additional water quality analyses.  The water
      quality discussions in Chapters 3 and 5 of the main
      body of the EIS have also been revised to include
      cross-referencing to Appendix VII and to Appendix V,
      Combined Sewer Overflow.

349.  In the Final EIS, cross-referencing has been extensively
      used, and the readability of the document has been
      improved.  EPA's regulations for the preparation of an
      EIS require that the Table of Contents follow the
      Executive Summary.

350.  Comment noted.  Duplication has been reduced in the
      Final EIS.  CEQ regulations require a summary of
      environmental impacts in Chapter III: Alternatives.

351.  The purpose of the EIS is to examine the environmental
      consequences of the Master Facilities Plan and alter-
      natives to the plan.  While several sections of the
      EIS contain general discussions of the policies of
      some guiding legislation, such as the Clean Water Act

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     CChapters 2 and 4)  and the policies of local communities
     as they relate to development (Secondary Growth Appendix),
     the EIS must focus upon the proposal at hand.  Discussing
     broader policy issues is outside the scope of the EIS.

352. Flexibility, as defined on page IV-85 of Appendix II
     Jones Island and IV-58 of Appendix III South Shore,
     does not preclude innovative or alternative technologies.
     The land application of sludge is an alternative tech-
     nology to landfilling, for example.  Innovative and
     alternative (I/A) technology is not automatically ruled
     out as "infeasible".   Many I/A systems would be familiar
     to engineers,  designers, contractors or plant operators.
     Also, feasibility is only one of many criteria used to
     evaluate the technical merits of an alternative.

     Numerous advanced wastewater treatment processes do
     exist.  However, they can be very expensive, difficult
     to operate, unreliable, or may not consistently meet
     effluent discharge limits.  If an alternative is not
     feasible (i.e., is impossible or impractical, and does
     not have a proven history), then the expenditure of
     money to plan, design and construct such a facility
     would not be funded by the EPA and DNR.

     Typically,  the most successful WWTPs operate using the
     well-proven and well-tested activated sludge process
     (using air or High Purity Oxygen, HPO) to achieve
     secondary treatment limits.

353. This EIS represents an independent evaluation of the
     environmental impacts of the Master Facilities Plan.
     Except for the evaluation of interceptor extensions,
     the planning that was undertaken in the MFP was
     limited to a 20-year period (1985-2005) by EPA Construction
     Grants Program regulations (40 CFR 30).  For this
     reason the EIS has limited its analysis to this 20-
     year period.

354. The MMSD's Industrial Waste Pretreatment Program is
     discussed in Appendix II, Jones Island, Appendix III,
     South Shore, Appendix IV, Solids Managementand the
     Addendum to the Solids Management Appendix.  It would
     be highly speculative to predict the results of the
     MMSD's Industrial Waste Pretreatment Program without
     the benefit of EPA's  categorical standards.  The MMSD
     will not make any projections for this same reason.
     The analysis of Water Quality Impacts and Solids
     Management Alternatives is based on a "worst case"
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      analysis, i.e.,  no industrial pretreatment,  therefore,
      actual impacts could be less with the implementation
      of the MMSD's Industrial Waste Treatment Program.

      Section 4.3,  Priority Pollutants, of the revised
      Appendix VII, Water Quality discusses some of the
      water quality impacts of metals and toxic substances.
      All available MMSD data for priority pollutants were
      incorporated  into the EIS.

355.  It was not the intent or the responsibility of the EIS
      to discuss water use in the planning area.  In Chapter
      6 of the MMSD-MFP, water use and water conservation
      measures are  discussed.  Water use accounts for only
      the base flow to the MMSD WWTPs.  Under peak wet
      weather conditions, up to 900 MGD can flow through the
      MMSD system,  while the base flow is only 18% (166  MGD)
      of this total flow.  Seventy-two percent of the peak
      flow is caused by inflow and infiltration (I/I)  or
      stormwater and is not related to water use by commercial,
      industrial or residential consumers.

356.  The MMSD's Infiltration and Inflow (I/I)  Report was
      prepared separately from the Master Facilities Plan
      and was approved by EPA and DNR.  This report, not
      the EIS, determined the cost-effective level of I/I
      removal.

      The MMSD is currently in the process of adopting a
      plan for repairing and rehabilitating separated sewers
      and interceptor sewers in its service area.   This  plan
      will be based upon the results contained in the Sewer
      System Evaluation Survey (SSES) Report which is also
      being finalized by MMSD at this time.  The adoption of
      a rehabilitation plan and SSES Report by MM.SD at some
      future date may require an ammendment to the adopted
      plan and may also require further environmental review
      by EPA and DNR.

357.  On May 19, 1980, the EPA promulgated its regulations on
      Hazardous Waste Management Systems in the Federal
      Register (45  FR 33063-33588).  These regulations
      addressed several areas:

      -40 CFR 260:    General

      -40 CFR 261:    Identification and Listing of
                     Hazardous Waste

      -40 CFR 262:    Standards Applicable to Generators
                     of Hazardous Waste

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-40 CFR 263:   Standards for Transporters of
               Hazardous Waste

-40 CFR 264,   Standards Applicable to Owners and
        265:   Operators of Hazardous Waste Treatment,
               Storage, and Disposal Facilities

                 —Financial Requirements
                 —Underground Injection

-40 CFR 122,   Consolidated Permit Regulations
        123,
        124,
        125:

Both, the DNR and the EPA recognize that improper handling
and disposal of toxic and hazardous materials are
serious problems.  Both agencies have adopted regulations
to correct these problems.  The Hazardous Waste regulations
will minimize adverse environmental impacts by these
materials.  The MMSD and Milwaukee industries are
required to meet the provisions set forth in these
regulations, all the other EPA regulations listed in
Title 40 of the Code of Federal Regulations and all
the DNR regulations listed in the Natural Resources
Chapters of the Wisconsin Administrative Code.

Although metals can be toxic to plants or animals,
some are also essential trace elements which provide
beneficial results.  For example, small amounts of
zinc, nickel and copper are required by man.  This
point is discussed further in the Addendum to Appendix
IV, Solids Management in the section on Public Health.

The MFP and the alternatives which are evaluated in
the EIS do not allow these pollutants to pass through
treatment facilities untreated.  In fact, some industrial
discharges to the sewer system have been decreasing
(this is shown in the Addendum to Appendix IV, Solids
Management).  The MMSD intends to eliminate the discharge
of toxic and hazardous materials to its sewers.

Both agencies have regulations for landfilling solid
waste (including sludge), and the EPA has published
numerous reports on landfills.  Research on land-
filling and leachate control as well as land spreading
of sludge will continue.  The MMSD's Industrial Waste
Pretreatment Program will regulate what industries can
discharge to the sewer system.  All discharges, including
toxic and hazardous substances (e.g., PCBs and radio-
active wastes) are monitored.  PCBs and radioactive

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     ^wastes are not allowed in the MMSD sewer system.  The
      Nuclear Regulatory Commission is also responsible for
      radioactive wastes and has strict regulations for
      their disposal.  An extensive study for all 129
      pollutants on the EPA's priority pollutant list was
      done for MMSD WWTPs1 influent, sludge, and for several
      local water treatment plants' (WTP) intake and treatment
      levels.  A discussion of this MMSD study is presented
      in Appendix VII, Water Quality,  Section 4.3.

      Your five points are well taken.  The alternatives
      presented in the MFP and EIS were developed to achieve
      the results set forth in your comment.

358.  The Draft EIS addressed sediment pollutant management
      in Appendix V, Combined Sewer Overflow, Section 5.1.
      The statement in the Appendix is meant to be interpreted
      in light of historical loadings  to the Inner and Outer
      Harbors' sediments.  Local water quality management
      agencies were designated in the  Areawide Water Quality
      Management (208) Plan prepared by SEWRPC.  For more than
      one year, the DNR and MMSD have  been negotiating their
      respective responsibilities for  correcting the problems
      associated with heavily-polluted sediments in the lower
      reaches of the three rivers.

3591.  The revised Water Quality Appendix (VII) and the
      Combined Sewer Overflow Appendix CIV) each present de-
      tailed analyses which discuss the quantity of pollutants
      being added to the receiving waters,  the resultant
      water quality, and the degree to which instream water
      quality standards will be met.

      Within the combined sewer service area, the combined
      sewer overflow abatement alternatives offer a wide
      range of levels of urban storm water treatment.  The
      Complete Sewer Separation Alternative includes no
      treatment of storm runoff by the WWTPs.  Under the
      Inline Storage and Modified GST/Inline Storage Alternatives,
      an intermediate level of stormwater capture and treatment
      would be provided.  Under the Modified Total Storage
      Alternative, all storm water would be captured and
      treated at the Jones Island and  South Shore WWTPs.
      Appendix V, Combined Sewer Overflow,  discusses the
      water quality impacts of each alternative.  The analyses
      indicate that the treatment of storm water runoff
      results in substantial water quality benefits.

360.  Comment noted.  For more discussion about the fiscal
      impacts of the program, please see the Fiscal/Economic
      Impacts Appendix and its Addendum.

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361.  Proper maintenance of sewers by local municipalities
      should minimize infiltration and inflow CI/D to the
      sewer system.  Under the MMSD's Recommended Plan, a
      portion of the I/I would be eliminated.  The projected
      I/I rates are used for planning purposes and could be
      revised as new data become available.  Proper main-
      tenance by repair and rehabilitation is not a permanent
      solution to the I/I problem.  Enforcement of municipal
      ordinances which prohibit I/I discharges to the sewer
      system are also important factors in attempting to
      reduce I/I.

362.  The effects of Jones Island effluent ammonia-nitrogen
      concentration on the Outer Harbor are addressed in the
      revised Appendix VII, Water Quality, Section 4.1.2.
      The results of this new analysis are also incorporated
      into Chapter 5 of the main text of the Final EIS.

363.  The water quality discussion in Chapter 5 has been
      revised to incorporate the results of the new Appendix
      VII, Water Quality.  The phosphorus load to the Outer
      Harbor is expected to decrease by about 20% under
      future conditions.  There will be increased flows from
      the South Shore WWTP under future alternatives, and
      the phosphorus load from that WWTP may more than
      double.  Only the Jones Island WWTP discharges its'
      effluent to the Outer Harbor.

364.  Under the current U.S. District Court Order, the CSO
      abatement alternatives are sized for the largest storm
      on record.  If this storm was exceeded, the storage
      facilities could become filled to capacity, and excess
      flow from the combined sewers would be discharged to
      the rivers.

365.  Comment noted.

366.  Comment noted.  Other industries discharging metals
      and toxic wastes could also face expensive pretreatment
      programs.

367.  An Industrial Waste Pretreatment Program is part of
      the MMSD Recommended Plan.  Portions of the program
      are already being developed.  Industries will be
      required to pretreat (at their own cost) their discharges
      to the MMSD's sewer system and remove any toxic,
      hazardous, or radioactive wastes.  Since this program
      is not fully developed and implemented, an in-depth
      evaluation of its impacts on water quality and sludge
      disposal can not be presented in the EIS.   The EIS
      provides a worst-case situation, i.e., no industrial

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      pretreatment.   industry is one of  the major  dischargers
      of metals to the MMSD sewer system as shown  below.
      Residential, domestic,  background,  and  unknown  sources
      account for the remainder.

      Metal          Industrial Contribution  to  MMSD  WWTPs

      Cadmium                       45-70%

      Chromium                      85-90%

      Copper                        50-65%

      Nickel                        65-80%

      Lead                          70-75%

      Zinc                          55-85%

      Presently, the MMSD distributes its $30 million
      annual treatment cost to the system's users  by  way
      of an EPA approved,user charge system which, by
      definition, does not subsidize the industries.   Of
      the MMSD's 29.6 million 1980 operation  and maintenance
      budget, 9.2 million, or 31%, was paid by the industrial
      class.

      Current state law requires that MMSD construction
      costs be financed by the Milwaukee County property
      tax.  For a discussion of the industrial capacity
      share of improvements, see reply 501 of the  CAC
      comments.

368.  The MMSD Recommended Plan for the  South Shore
      WWTP involves a complete landscaping of MMSD
      property.  This is discussed in Section 11.0:
      Recreational-Dual Use in the Addendum to Appendix III,
      South Shore.  The MMSD's landscaping plan involves
      extensive planting of trees and plants.

369.  Agreed.  Public works contractors  would have to
      be aware of local public nuisance  ordinances and
      minimize noise associated with construction  near
      residential areas.

      The trucking of sludge from the South Shore  WWTP
      would be reduced by up to 50%.  Most other
      transportation operations would not change.   Since
      the trucking of sludge from the South Shore  plant
      has the highest daily frequency, this reduction
      causes a significant beneficial impact.  Therefore,

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      the noise, dust and exhaust could be cut in half
      by the MMSD Recommended Plan for the South shore WWTP.
      This is discussed in Section 12.0:  Transportation
      and Access in the Addendum to Appendix III, South Shore.

370.  The reference of this comment is unclear.

371.  The water quality discussion in Chapter 3 has been
      revised in the Final EIS.  Bypasses do degrade water
      quality conditions and annual loadings from the bypasses
      can be found in Chapter 3.

372.  The low flow water quality analysis for most pollutants
      is conducted at the WWTP discharge point because that
      is where the greatest impacts will occur.  For non-
      conservative pollutants such as ammonia and biochemical
      oxygen demand, the analysis also considers downstream
      reaches.  In addition, the discussion of combined sewer
      overflows includes impacts on all CSO-affected reaches,
      the Inner Harbor, and the Outer Harbor.

373.  An expanded discussion of Lake Michigan's water quality
      and future impacts on the Lake are presented in Chapter
      4 of the revised Appendix VII, Water Quality.  The
      discussion indicates that, although Lake Michigan has
      very good water quality overall, there are indications
      of deterioration, and localized problems do exist.

374.  Figure 4.2 of the Draft EIS excluded streams affected
      by combined sewer overflows.  Those stream reaches
      have been added to the figure in the Final EIS.  All
      CSO affected streams violate the fecal coliform and
      dissolved oxygen standards.

375.  The following table shows the existing proportion of
      the total watershed loads contributed by point and
      nonpoint pollution sources:

                                 Percent of Total Load
Sediment

Nitrogen

Phosphorus

Biochemical
Oxygen Demand
Fecal Coliform
Source:  SEWRPC Technical Report No. 21, Sources of Water
         Pollution in Southeastern Wisconsin:  1975.
                               3-57
5
Point
Nonpoint
Point
Nonpoint
Point
Nonpoint
Point
Nonpoint
Point
Nonpoint
lilwaukee
River
0
100
10
90
14
86
10
90
60
40
Menomonee
River
1
99
18
82
32
68
24
76
87
13
Kinnickinnic
River
10
90
35
65
62
38
67
33
98
2

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376.  Given that the geographic location of households
      influences the total allocation of public services
      (i.e., budgets, personnel),  the primary determinant
      of the magnitude of each public service needed  is
      the number of households.

377.  Tourism, conventions and sporting events do bring
      external income into the area.   To a small extent,
      increased activity in these  sectors would help
      offset the impact of the costs  of the MFP.

378.  The MMSD User Charge Program charges for flow,  BOD,
      and suspended solids.  Toxics are not allowed in the
      sewer system based on EPA's  categorical standards.  MMSD's
      future user charge program could charge for toxics.

379.  Agreed.  Comment noted.

380.  This has been revised in the Final BIS*

381.  The supplemental EIS on the  MMSD's Site Specific
      Analysis addresses the specific impacts of the  proposed
      ultimate disposal facilities.  Environmental impacts
      that are of a general nature are discussed in Appendix
      IV, Solids Management and its Addendum.

382.  The "affected" environment at the MMSD WWTPs are
      discussed in Appendix II, Jones Island, and, Appendix
      III/ South Shore (and their  associated Addenda).  The
      future EIS supplement on MMSD's Site Specific Analysis
      will discuss the "affected"  environment surrounding
      specific disposal facilities.

383.  The MMSD intends to utilize  this incinerator during
      the planning period.  Otherwise, screenings, grit,
      and scum would have to be taken to a landfill.

384.  See response to 370.  The discharge of toxic substances
      to the MMSD sewer system will be regulated
      by the EPA's categorical standards for 21 types
      of industry.  Discharges of  toxic substances will
      not be allowed during the planning period.  The
      Addendum to Appendix IV, Solids Management addresses
      industrial wastes, priority  pollutants including
      heavy metals, toxic and hazardous substances, public
      health and water quality. These sections contain a
      more thorough discussion of  toxic substances.

385.  This is MMSD's conclusion restated.

386.  Discing of farmland is a normal agricultural practice.


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      Grasslands are not used for agriculture and would
      therefore not be disced.

387.  Agreed.  However the point being made is that the
      impacts are related to the quantity of land disturbed,
      if the land is of equal quality.

388.  Metals are readily bound by soil.  Leachate may
      eventually reach surface or groundwater if not collected
      However, before the design of a landfill is approved,
      an adequate leachate collection and treatment system
      must be developed.

389.  (a)   The MMSD determined that a three-day storage
           capacity would be sufficient for the on-site
           storage of sludge at the Jones Island WWTP.  The
           EPA and DNR feel that this would be sufficient on-
           site capacity due to land constraints at Jones
           Island.  Although transportation of sludge from
           the WWTP could be delayed due to a strike or
           inclement weather, the EPA, DNR and MMSD believe
           that this problem could be mitigated within three
           days.  When MMSD operators went on strike in
           November, 1979, MMSD technical and managerial
           personnel immediately took over operation of MMSD
           facilities.  Snowstorms have, at the most, inhibited
           movement of Milwaukee traffic for one or two days.
           Also, if rail transportation is used, no delay due
           to weather should occur.  If, for some reason,
           the MMSD's sludge landfill is inoperative, and
           other municipal landfills in the region refuse to
           accept MMSD sludge, the sludge from the Jones
           Island WWTP could be applied to agricultural land
           or stored in the MMSD's proposed sludge storage
           facility.

      (b)   Ammonia impacts to the Inner Harbor are discussed
           in the revised Water Quality (Section 4.1} and CSO
           Appendices (Sections 5.1.4.3 and 5.1.5.1) and
           their associated Addenda.  The discussion of Water
           Quality in the Jones Island Appendix II only
           summarizes the results contained in these appendices.
           The Water Quality Appendix is referenced in Appendix
           II.  Air quality problems due to increased ammonia
           discharged into the Outer Harbor would be insignificant,
           It is doubtful that odor threshold levels would be
           exceeded due to increased discharges of ammonia.

390.  Cost and energy consumption (which is included
      in the O&M cost) are the only significant quantitative
      differences in alternatives.  All the systems were

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      designed to give the same level of environmental-
      protection.  This is a fundamental principle for cost-
      effective analysis.   Each alternative would deliver
      a given level of protection and the system with the
      lowest cost is the most effective at meeting that
      level of protection; i.e., a "best-buy".   The six systems
      for wastewater treatment are different in layout
      and/or processes used.  This is described in the
      alternatives Chapter CIV) of the Appendix.  Other
      alternatives addressed disinfection and location of
      the expanded facilities.  The alternatives considered
      in the EIS are not,  "six versions of the  same system".

391.  The table on page 111-26 presents a 12-month average
      of effluent flows and concentrations, along with
      monthly characteristics.  This is a common method
      of presenting results.  Removal efficiencies
      are also given so the reader may understand at what
      level of efficiency  the plant is operating.  For
      a given parameter (e.g., BOD5)  the average discharge
      is 19 mg/1 (the standard is 30 mg/1 on a  monthly
      basis), and the discharge ranges from a low of 8 to
      a high of 25 mg/1.  The effluent limit for BOD^ at the
      Jones Island WWTP was never exceeded, and the WWTP
      removed 94% of all BOD,- entering the plant.

      These data represent existing conditions  at. the
      plant which is the intention of Chapter III:
      Existing Conditions.  Chapter V:  Affected Environment
      compares the effluent with Outer Harbor water quality
      which would be "affected".  Chapter IV discusses
      the environmental consequences during the planning
      period of the projected effluent discharge to the Outer
      Harbor.

      Presentation of the  data in their form is standard for
      any EIS and follows  scientific format.  The tables
      summarize portions of data from the years 1975 to 1979.

392.  A cost-benefit analysis for ozone versus  chlorine
      disinfection has been done.  Please consult sections
      starting on pages IV-75, V-95, V-99, VI-107, VI-113,
      VI-116, VI-117 and VI-118 in Appendix II, Jones Island.

      Chlorine has a well-proven history as a disinfectant
      while ozone disinfection is not as reliable.  The Table
      following presents a summary comparison of ozone
      versus chlorine disinfection.
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                SUMMARY COMPARISON OF OZONE AND
                      CHLORINE DISINFECTION
      CHARACTERISTICS OF A          CHLORINE       OZONE
       GOOD DISINFECTANT
      Non toxic to aquatic life        -             +

      Does not form hazardous          -             +
        side products

      Side products formed are         -             +
        hazardous to human health

      Has a residual disinfecting      +             -
        effect

      Has a method to measure          +             4-
        residual

      Disinfectant is available        +             +

      Is toxic to microorganisms       +             +

      Controls odors and taste         +             +

      Does not impart odors or                       +
        taste

      Non corrosive

      Toxic to microorganisms          +             +
        at ambient temperature

      (+}   has that characteristic
      (-)   does not have that characteristic

      When the MMSD considered the six alternatives for Jones
      Island, chlorine was included as the disinfection
      alternative since it was determined more cost-effective
      than ozone.  If ozone was used to disinfect the effluent,
      then the total costs could be determined by subtracting
      the cost for chlorine and inserting the cost for ozone.
      Disinfection is part of the total system for wastewater
      treatment .

393.  Industrial pretreatment is discussed on page IV-46 in
      Appendix II, Jones Island, Appendix III, South Shore,
      Appendix IV, Solids Management and in the Addendum to
      the Solids Management Appendix.  The EIS has taken a

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      worst case situation.   The MMSD's Industrial Waste
      Pretreatment Program Report (October 19801  makes  no
      projections based on pretreatment.   Therefore,  developing
      a "best-case" situation would be highly speculative.

394.  Ammonia, which has a characteristically sharp and
      pungent odor, can be recognized at a concentration
      of 46.8 ppm in the atmosphere.  The un-ionized form
      of ammonia is toxic to fish and can contribute to the
      depletion of dissolved oxygen in the Outer  Harbor,
      but since it is dissolved in the wastewater, it should
      not present any significant odor problems.   Due to
      the toxicity of ammonia to fish and other aquatic
      life, the EPA and DNR are considering requiring some
      level of ammonia removal for the Jones Island WWTP.
      Methane will not cause problems because it  is odorless.

395.  The MMSD's reasons for choosing landfill are discussed
      in their Facility Plan (Solids Management Facility
      Plan Element).  Codisposal and incineration are not
      cost-effective and increase air pollutant emissions.
      Land application is the MMSD's recommended  plan for
      the South Shore WWTP.   the MMSD's Total Solids
      Management Plan for landfill and land application of
      sludge allows for flexibility in case one system is
      inoperative for environmental, technical or legal
      reasons.  These alternatives for sludge disposal  are
      discussed in Appendix IV, Solids Management.

396.  The effects of relocating the Jones Island  WWTP outfall
      on the Outer Harbor water and sediment quality are
      discussed in detail in Section 5.1.6.1 of the Combined
      Sewer Overflow Abatement Appendix.   The relocation
      analysis was performed as a sensitivity analysis  for
      the assumptions used to evaluate CSO loadings.   A
      second review of the impact of the Jones Island outfall
      on the Outer Harbor and nearshore Lake Michigan water
      quality is given in Section 4.1.1 of the Water Quality
      Appendix.  The results from these evaluations will be
      incorporated into the EIS's main text.

397.  The EPA and DNR have raised this question with the
      MMSD.  As a result, the MMSD has provided more in-
      formation about possible methods for the proposed
      ammonia discharge levels.  The Final EIS addressed
      ammonia removal in the Addendum to the Jones Island
      Appendix.  The following table summarizes available
      methods for ammonia control.

398.  The alternatives evaluated in the MFP and EIS provide
      for substantial reductions in the discharge of untreated


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      or inadequately treated wastewater to Milwaukee's
      rivers and Lake Michigan.  SEWRPC's areawide water
      quality management plan sets forth recommendations to
      improve inland water quality throughout the entire
      southeast Wisconsin region.  The discharging of pollutants
      which cause harm to the environment will be reduced in
      the future.  Also, the EPA and DNR are required by law
      to impose effluent limits to maintain desired water
      quality standards.

399.  There has been considerable public concern expressed
      about odors occurring in the populated vicinity of the
      South Shore WWTP.  The EPA and DNR are aware of this
      serious odor problem which has existed since the South
      Shore WWTP was expanded in 1974 to achieve secondary
      treatment of wastewater.  The two north sludge lagoons,
      the sources of a number of complaints, were constructed
      in 1973.  It has been suggested that detailed odor and
      air quality studies be performed at the WWTP to determine
      the causes and magnitude of the problem in addition to
      the odors' effects on public health and property values.
      Such studies could not be completed in time to incorporate
      them into the EIS.  Furthermore, the EPA and DNR do not
      intend to conduct a site specific study on odors at
      South Shore since this would only determine the extent
      of previous problems and would have no value in assess-
      ing impacts of future alternatives under consideration
      for the South Shore WWTP.  As there are no baseline
      data recording the odor/air situation at South Shore
      before the WWTP was constructed, any studies now would
      not validly demonstrate the differences between the
      situation before construction and the present situation.
      Without the benefits of a site specific study on the
      public health of nearby residents, it is not possible
      to verify that the South Shore WWTP is the source of
      these problems.  Recent EPA studies done elsewhere
      conclude that residing near a WWTP does not present
      significant health problems.  This information is
      discussed in the Addendum to Appendix III, South Shore.

      A study on property values near the South Shore WWTP
      was conducted by the South Milwaukee Tax Assessor
      in 1978.  The results of this study are presented
      in the South Shore Appendix.

      Further information regarding the sources of odors in
      a wastewater treatment system, the substances that
      produce odors and gases, and methods for mitigating
      odor problems can be found in the Addendum to Appendix
      IV, Solids Management.
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The north sludge lagoons were emptied by the MMSD
in 1979 as a result of many complaints from nearby
residents.  The MMSD intends in the near future to remove
these two lagoons and landscape the area adjoining
South Milwaukee.  This intention is documented in the
August 15, 1980 letter from the MMSD to State Represen-
tative Chester Gerlach.  With the implementation of the
MMSD Recommended Plan, which includes enclosed process
buildings, odors caused by the South Shore WWTP should
be mitigated.  The EPA and DNR feel that any adverse
impacts to nearby residents should be kept at a minimum
and will consider this situation when making their
decisions on the South Shore WWTP.

One comment alleged that the South Shore WWTP has
been and is in violation of the Oak Creek zoning
code.  The specific ordinance is zoning code
17.38 (8) (C), and reads as follows:

     "(8) PERFORMANCE STANDARDS, NOXIOUS AND
     ODOROUS MATTER, Ml, M2 and M3 DISTRICTS.

     (C) M3 District"*

     "No activity or operation shall cause, at
     any time, the discharge of matter across
     lot lines in such concentrations as to be
     noxious.  The emission of odorous matter
     in such quantities as to be readily
     detectable without the use of instruments
     at any point along lot lines, when diluted
     in the ratio of one volume of odorous air
     to 20 volumes of clean air, is prohibited."

     *M3 is a Heavy Manufacturing District which
     is the zoning designation of South Shore
     WWTP.

The Oak Creek City Planner was contacted in an attempt
to determine if any violations were being committed
by the South Shore WWTP.  That discussion gave no
indication that the treatment plant was in violation
of Oak Creek zoning ordinances, and there was no
indication that any action was pending on this matter.
He stated that all complaints of this type Codors)
are forwarded to the DNR.  Public Health complaints
should be directed to the State Department of Health
and Social Services.
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400.  The South Shore WWTP has disinfected wastewater effluent
      with chlorine for a number of years and,  to date/  has
      not experienced spills that would threaten the health
      and safety of citizens living or working  near the  WWTP.
      The WWTP is equipped with facilities and  trained per-
      sonnel that minimize the dangers associated with
      handling chlorine gas.  Section 3.0 of the Addendum to
      Appendix II, Jones Island discusses chlorine disinfection
      as well as other disinfection methods. This section
      also includes a discussion on safety and  proper handling
      in addition to the environmental affects  of chlorine
      gas as a disinfectant.

401.  Comment noted.  Spurs are inspected before use and
      receive necessary maintenance to allow safe use.

402.  Comment noted.  MMSD safety procedures mitigate this
      occurrence.

403.  Comment noted.  This recommendation, along with the
      others (401, 402) , is appreciated and should be in-
      corporated into the MMSD's Operation and  Maintenance
      (O&M)  plans for the South Shore WWTP.

404.  The expansion alternatives for the South  Shore WWTP are
      discussed in Appendix III, South Shore of the EIS.  The
      alternatives discussed in Appendix III would be the
      same for any local, subregional or regional system-wide
      plan.

405.  The June 3,  1980,"Citizens Report on the  Milwaukee
      Water  Pollution Abatement Program" articulates citizen
      concerns about the Master Facilities Plan, not the EIS.
      These  concerns affected the Draft EIS, but it is the
      responsibility of the MMSD to respond to  those comments.

406.  A detailed discussion of alternatives to  the plan
      recommended in the Draft EIS is included  in the appendices
      to the Draft EIS.  The ACCESS Committee was organized
      by the MMSD for input to the MPP.  Any questions about
      the ACCESS Committee should be directed to the MMSD.  We
      are unaware of any studies performed by citizens groups
      on codisposal, "self-energizing furnaces", compost, etc.

407.  The EIS consultant cannot supply information on MMSD
      reports.   In addition, it is unclear what report you
      refer  to.

408.  The Draft EIS contains no conclusions. The methodologies
      and assumptions used for the EIS analyses are identified
      throughout the document.


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409.  In its analysis of the land application of sludge,  the
      EIS used the information set forth in EPA and DNR
      regulations.  It is not the purpose of the EIS to
      determine the validity of those regulations.

410.  Currently, the MMSD service area sewer system is over-
      loaded by excessive infiltration and inflow (I/I).   By
      2005 it is expected that this I/I would result in peak
      daily flows in the system of 900 MGD.  This flow would
      far exceed the capacity of the existing Metropolitan
      Interceptor Sewer (MIS)  system and the Jones Island
      and South Shore WWTPs.  The MMSD has undertaken two
      studies in order to determine the most cost-effective
      means of reducing this I/I versus increasing the con-
      veyance and treatment capacity of the sewer system.
      The first study, the I/I Study, concluded that it would
      be cost-effective to remove 48% of the I/I.  After
      removal of the excessive I/I, the peak daily flow in
      the system would be reduced to 705 MGD.  The second
      study, a Sewer System Evaluation Survey (SSES) , was
      undertaken in order to gather more detailed information
      on the sources of I/I and to then re-evaluate the cost-
      effectiveness of removing the I/I.  A draft report  on
      this study has concluded that only a 13% removal in
      I/I is actually cost-effective.  Accordingly, the ex-
      pected peak daily flow has been tentatively revised to
      820 MGD.  The final SSES report is expected in April
      of 1981.

      Based on present information, the EPA and DNR believe
      that deep tunnels can be designed and operated to pro-
      tect groundwater.  For further detailed discussion  on
      the possible impacts and mitigating measures as well
      as a discussion of further information needed before
      a final decision is made, please see the CSO Appendix
      Addendum.

      The Master Facilities Plan evaluated several alter-
      natives based on an estimated 705 MGD peak daily flow.
      Systems which could treat this flow without storage
      were evaluated but found undesirable because of
      limited space at existing treatment plants, the large
      capital cost to expand plant capacities, and the inherent
      problems with operating an activated sludge treatment
      system at widely fluctuating flow rates.  A system  of
      near surface storage facilities throughout the MIS
      system at critical points was also evaluated.  This
      system was less desirable because large tracts of land
      would be required throughout the city to build such
      facilities and the unit cost per volume of storage  was
      significantly higher for these small localized facilities
      compared to a deep tunnel and cavern storage system.

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      Furthermore,  these localized facilities did not offer
      any possibility for integration with CSO abatement
      systems.   Preliminary analysis has shown that the deep
      tunnel and cavern storage system is even more cost-
      effective at the higher flow rate of 820 MGD estimated
      in the draft SSES report.

411.  High quality fresh water is extremely important to the
      planning  area.  The impacts of groundwater and surface
      water quality are discussed in the EIS; the Water
      Quality and CSO Appendices in particular.  Water use
      is discussed in Chapter 6 of the MMSD Wastewater System
      Plan.

412.  An extensive review of existing water quality conditions
      was presented in Chapter 3 of Appendix V.  To provide a
      basis for relating future water quality conditions to a
      known situation, predicted water quality conditions
      under CSO abatement alternatives were compared to these
      existing  conditions.  A comparison to water quality
      standards was used as an additional method of assessing
      the water quality impacts of CSO abatement alternatives,
      since these standards are related to specific water
      uses.

413.  Comment noted.  An index is included in the Final EIS.

414.  The older sections of the Milwaukee Metropolitan Sewerage
      District  contain sewers which were built to convey
      both human sanitary wastes and storm water.  Under mild
      to moderate storm conditions most of the sewage and
      storm water is conveyed to Jones Island WWTP for treatment.
      However,  large or intense storms cause an overflow of
      wastewater into local rivers.  This was an acceptable
      practice  at the time the sewers were built and was
      considered a better approach to sewage treatment than
      forcing the storm water to back up into homes or over-
      loading the WWTP.  Any sewer which conveys both storm
      water and sanitary wastewater is a combined sewer.  Any
      hydraulic event which causes a combined sewer to dis-
      charge to a natural water body, such as the Milwaukee
      River, without treatment is a combined sewer overflow
      (CSO) .

      Many of the pollutants found in sanitary sewage are
      found in  combined sewer overflows, but they are in
      lower concentrations because they have been diluted
      with relatively "clean" storm water.  These pollutants
      can cause a deterioration in the receiving stream water
      quality because they overload the stream's natural
      ability to assimilate pollutants.  The nutrients,


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      such as phosphorus and nitrogen,  encourage algae growth.
      The organic material decays causing oxygen depletion
      and odor problems.  Various metals enter  the  stream
      which may be toxic to aquatic life.  Solids from the
      combined sewer overflow may be aesthetically  unappealing
      and contribute to the sediment load.  Pathogens common
      to sewage make the water unhealthy for human  use.

      Each of the combined sewer overflow abatement plans
      evaluated in the CSO Appendix treat the storm water in
      a different manner.  Because of these differences,  each
      alternative would have a different impact on  water
      quality.  For this reason, water  quality  impacts of
      various CSO abatement alternatives must be considered
      in the EIS.

415.  The comment/question is unclear.   Surface water quality
      discussions related to CSO may be found in Chapters 3
      and 5 of the CSO Appendix.  The impacts of the various
      alternatives on groundwater quality are presented in a
      separate geotechnical report, which is presented in
      the CSO Addendum to the Final EIS.

416.  Under any system level alternative, a two-branched
      tunnel would have to be built.  The single most impor-
      tant problem with the current system is its inability
      to convey and treat the large quantities  of infiltration
      and inflow (I/I) .  The present Jones Island and South
      Shore WWTPs are capable of effectively treating waste-
      water during dry weather.  However, during wet weather,
      bypasses occur, and flows to the plants increase dramati-
      cally due to I/I, such that the plants are no longer
      capable of effective treatment.  Table 4-3 of Appendix
      V compares existing and future flows to the wastewater
      treatment plants.  By the end of  the planning period,
      dry weather flow will reach 166 MGD.  Maximum design
      wet weather flow  (the treatment capacity  required if no
      storage is provided) is 900 MGD.   Within  the  combined
      sewer system, regulating devices  presently bypass all
      flows in excess of 114 MGD, thus  I/I from the separated
      system contributes 620 of the peak 900 MGD flow, or
      68.9% of the flow.  This contribution must receive
      major consideration in the design of a new system.
      Furthermore, the present secondary treatment  capacity
      of the Jones Island and South Shore WWTPs are 140 MGD
      and 120 MGD respectively.  Also,  much of  Jones Island
      is over 50 years old.  There is no independent analysis
      of the MMSD's I/I Report since it was prepared by the
      MMSD and approved by the DNR prior to the EIS process.
      This program is described on page 4-30 of Appendix V.  In
      summary, the program compared the cost of various I/I


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      reduction methods with the cost of treating the flow to
      be removed by each method.  The results of the analysis
      showed that up to 200 MGD (32%)  could theoretically be
      removed from the peak flow at a reasonable cost.   These
      treatment and storage systems were evaluated using a
      maximum design flow of 700 instead of 900 MGD.  (These
      estimates have been updated by the Draft SSES released
      in January, 1981.  The preliminary results suggest that
      only 13% or 80 MGD can be cost effectively eliminated
      from the system.)

      Full development of the program alternatives can be
      found in Chapter 3 of the EIS and Chapter 4 of Appendix
      V.

417.  Comment noted.  See response number 416.

418.  The issue of peaking of wet weather flows in the separated
      sewer area was addressed in the I/I study which has been
      approved by the DNR.  The flow volumes and peaking
      factors used in the MFP and the EIS were based on the
      values presented in that study.  Further refinement of
      these flows is being undertaken in the Sewer System
      Evaluation Survey (SSES) and will be reviewed by the
      EPA and the DNR when the Final SSES Report is adopted
      by the MMSD.

419.  It is the present policy of EPA that construction grant
      dollars can only be used to build or improve public
      facilities.  It is the MMSD's legal opinion, however,
      that private property costs could be financed district-
      wide.

420.  The intent of the comment is unclear.  If this is a
      request for the location of the I/I section, it begins
      on page 4-30, Section 4.3 of Chapter 4, CSO Appendix V.
      If the comment is questioning why the screening of I/I
      should be a part of the Alternative Screening Chapter,
      it is because I/I is an integral part of the screening
      evaluation.

421.  A delineation of the five joint CSO/Clear Water Storage
      Alternatives and their costs is given in Chapter 4,
      Section 4.4 and following.  A summary of alternative
      costs is given in Table 4-16.  Development of the final
      alternatives begins in Section 4.5.

422.  The point of the comment is unclear.  The first 38
      pages of Chapter 5 present the data analyses necessary
      to provide a basis for comprehensive discussion of the
      water quality and pollutant loading section which


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      begins on page 39.   The conclusion referred to  in the
      comment is one of many descriptive statements representing
      the conclusions reached by the water quality and pollutant
      loading analysis.

423.  The point of the comment is unclear.  The values cited
      appear on page 5-45 and refer to the percentages of
      Outer Harbor sediment metal loadings and concentrations
      (under the different action alternatives1 compared to the
      No Action values.  The value of 93% is incorrect and
      has been changed to the correct value of 101%.

424.  On pages 5-99 and 5-103 (Appendix V), there are direct
      references to the use of Chicago data.  Other data from
      Chicago were evaluated in the EIS process, even though
      direct reference is not made in the text.  Further
      references are made in response number 669.

425.  This comment/question does not provide enough information
      for the EPA and the DNR to formulate a response.

426.  The economic impact of polluting an aquifer is  dependent
      upon the degree of  pollution and use of the water.
      If the source of pollution is localized and there is a
      localized cone of depression, pollutants would  migrate
      to, and be removed  by, the wells causing the depression.
      If these wells were used for drinking water, an alternate
      source of water or  casing the well may be required.  If
      the pollutants are  widespread, those wells which supply
      potable water would require casing and possibly deepening
      or abandonment.  For those abandoned wells a new water
      source would be required.  For wells using an aquifer
      for industrial purposes, the economic impact could be
      less severe.  Those wells could also be cased in the
      Niagaran dolomite strata.

427.  Appendix VIII, Interceptor Alignment, Chapter 5 discusses
      the alternatives and costs relating to the Menomonee
      Falls-Germantown Interceptor system.  The effects of
      the various alternatives on water quality are given in
      Appendix VII, Water Quality, Section 1.2.3, Section
      3.1.4 and Section 3.2.3.3.

428.  Page 5-151, CSO Appendix V, Chapter 5, Section  5.16.1,
      "the typical amount of spoil expected from each of the
      alternatives-would, if piled 90 feet high, cover 2.8
      million feet   (approximately the area of 15 city blocks)."

429.  The purpose of the Jones Island discharge relocation
      analysis is to evaluate the sensitivity of the  CSO
      analysis, not to evaluate the assumption that the Jones


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      Island outfall will be moved.   It is a test of the
      sensitivity of the CSO evaluation methodology, not an
      evaluation of the impacts of outfall relocation.   A
      detailed evaluation of outfall relocation is given in
      Section 4.1.1 of the revised Appendix VII, Water  Quality.

430.  The Milwaukee water intakes are located well beyond the
      Outer Harbor breakwater and were not impacted by  the
      various CSO abatement alternatives.   The MMSD presents
      a discussion of the potential impacts of Jones Island
      outfall relocation beyond the Outer  Harbor (MMSD  Data
      Support File - Environmental Assessment, Volume 2,
      August 1980}.  The MMSD consultants  concluded from
      their preliminary analysis there was a relatively low
      hazard to public health for discharging effluent  outside
      the Outer Harbor.  The worst case situation of dis-
      charging unchlorinated effluent (i.e., a chlorination
      breakdown)  could result in high fecal coliform counts
      at the Howard Avenue intake and Bradford Beach.  Chlori-
      nation  of the drinking water, which is routinely done,
      would reduce coliform counts to acceptable levels.  The
      EPA and DNR concluded that there was no reason for
      further examination.

431.  The Water Quality Appendix has been  rewritten. The new
      appendix should better address public concerns.

432.  All of the alternatives set forth in the Master Facilities
      Plan (MFP)  and the EIS will improve  the water quality
      conditions of the areas surface waters.  If the MMSD
      Recommended Plan is implemented, the water quality of
      streams currently receiving wastewater treatment  plant
      effluent and bypass discharges will  be substantially
      improved.  Assuming implementation of the 208 Plan
      recommended measures, the MMSD Recommended Plan would
      achieve both existing DNR and 208 recommended water
      quality standards for these streams.  Water quality
      conditions of the Inner Harbor and Outer Harbor will be
      improved by the abatement of combined sewer overflows
      (CSO).  Pollutant loadings into the  bottom sediments of
      the Harbors will also be substantially reduced.

      However, further analysis is necessary before it  can be
      determined whether in-stream measures will be needed to
      meet water quality standards in the  Inner Harbor  and to
      identify which in-stream measures would be cost-effective.
      The Areawide Water Quality Management Plan, prepared by
      SEWRPC, designated water quality management responsibilities
      for local agencies.  The water quality benefits of the
      plan alternatives are described in detail in Appendix
      V, Combined Sewer Overflow, and in the revised Appendix


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      VII, Water Quality.

433.  EPA, DNR, SEWRPC, and the MMSD are just some of the
      Federal, State, regional and local agencies responsible
      for maintaining and upgrading water quality.  The Soil
      Conservation Service CSCS),  the International Joint
      Commission CUC)  are local and international agencies
      responsible for maintaining  and upgrading water quality.
      The water quality benefits of the MFP are discussed
      throughout this EIS.

434.  New sewer construction will  affect only the sand and
      gravel aquifer.  These sewers will exfiltrate if built
      above the groundwater table  and infiltrate if built
      below.  Assuming that this is the same situation as now
      exists, no net benefit is perceived.

435.  The DNR and the MMSD disagree about who is responsible
      for removing heavily-polluted sediments in the Inner
      and Outer Harbor.  The U.S.  Army Corps of Engineers
      removes sediments from the lower reaches of the Inner
      Harbor, the central shipping channel, and dock area of
      the Outer Harbor to maintain navigation.  However,  the
      upper reaches of the Inner Harbor have not been dredged
      in over ten years.

      The MMSD has recommended that arrangements be made to
      give an existing agency all necessary powers, duties,
      and financing capabilities to determine what specific
      in-stream measures (such as dredging) are required;
      and then to implement those  measures to maintain water
      quality standards  (MMSD, CSO Facility Plan, Chapter GF,
      page 6-F-32 March 1979).

      The DNR has taken the position that the MMSD is required
      under the terms of the Dane  County Stipulation to im-
      plement a program to correct the problems caused by
      the heavily-polluted sediments currently present in
      the harbor area.

436.  The agencies disagree with the contention that substantial
      increases in chloramine formation, as a result of
      chlorine disinfection, would not be prevented.  Sulfur
      dioxide  (S02) instantaneously reacts with chloraxnines
      in the following way:

      S02 + NH2Cl + 2H20 	> Cl~ + SO4= + NH4+ + 2H+

      Therefore, dechlorination of the effluent with SO- destroys
      chloramines.

      The EPA-approved method for measuring residual chlorine

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      converts all chioramines to free chlorine and then determines
      both free and combined/available chlorine as residual.
      Therefore, any effluent standard which limits residual
      chlorine also limits chloramines.

      The question of chlorine toxicity has been answered in
      response number 405.  Ammonia toxicity and the zone of
      mixing in the Outer Harbor have been discussed in the
      revised Appendix VII, Water Quality, Chapter 4,  Section
      4.1.2.

437.   A force main can only exfiltrate because of the pressure
      exerted on the walls of the main.  Due to this pressure,
      force mains are usually constructed of cast iron with
      tightly sealed  joints to minimize exfiltration.
      Because of the natural filtering effect of the types of
      soils in the planning area, the only possibility of
      adverse effects are to homes which rely on very shallow
      wells constructed near a leak in the force main.  For
      these reasons, this situation is virtually nonexistent.

438.   Historically, the MMSD and its' contractors have assumed
      responsibility for the correction of construction-
      related impacts on commercial and residential wells.

439.   Total pollutant loadings to the Inner Harbor and the
      Outer Harbor are set forth in Chapter V of Appendix V,
      Combined Sewer Overflow.  The loadings include contributions
      from upstream sources, WWTPs, and sources in the combined
      sewer service area.  Specific loadings to the Outer
      Harbor and Lake Michigan are presented in the revised
      Appendix VII, Water Quality.

440.   The agencies acknowledge the importance of this con-
      sideration in interceptor construction.  This would
      apply to the Underwood Creek, Franklin-Muskego,  Oak
      Creek North, and Root River Interceptor systems which
      pass through a floodplain.  There are also post-construction
      recommendations available in Appendix VIII, Interceptor
      Alignment.

441.   Collective loading of sediments to a stream would only
      occur if two or more of the following interceptors were
      built at the same time: Root River Interceptor,  Hales
      Corners Interceptor, Franklin-Muskego Interceptor, and
      the Franklin Northeast Interceptor.  Additive effects
      of sediment arising from the construction of the four
      interceptors could occur, although the effects would be
      slight.  Each of the four interceptors is crossing a
      tributary of the Root River.  The Franklin-Muskego
      Interceptor could affect Tess Corners Creek; however,


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      the water flows through the Whitnall Park Pond before
      entering the Root River and would experience some
      degree of settling in the pond.   The Hales Corners
      Interceptor crosses another small tributary, the Hales
      Corners tributary, which flows through several ponds
      before entering the Root River.   Again,  settling of the
      sediment would occur.

      Therefore, besides those effects associated with the
      construction of each individual  interceptor, some
      additive effects from the construction of all four
      interceptors could occur, but these would be slight.

442.  This question can be addressed by a site specific
      analysis of a particular wetland.  It is difficult to
      assess the impacts of varying amounts of drawdown on a
      wetland.  It is difficult to determine if drawdown
      would actually occur, and to what degree.

443.  When private wells were affected by MMSD activities,
      (e.g., construction of the Hales Corners Interceptor),
      the MMSD undertook responsibility for supplying water.
      These problems occurred over a short period of time.

444.  Recycling wastewater effluent is not cost-effective,
      environmentally sound or socially acceptable.  If
      effluent is to be used for potable, commercial or
      industrial use, it would have to meet water use standards,
      which are much more restrictive than WPDES effluent
      limits and would greatly increase the costs for a new
      WWTP.  Direct reuse of treated effluent (after wastewater
      and water treatment) could pose a public health threat
      if used for drinking water and would also be unacceptable
      to the public.

445.  Whether a sewer will infiltrate or exfiltrate is
      dependent on the internal vs. external pressure dif-
      ferential at the structure wall.  Water will always
      move from the zone of high pressure to the zone of
      lower pressure.  Pressure differential will depend upon
      depth of the structure below the groundwater table
      (piezometric surface) and the depth of flow within the
      structure.  The design of the facility will control the
      rate of this movement.  Force mains are usually designed
      using cast iron, although concrete is also used.
      Because flows in a force main are pumped under pressure,
      infiltration is nearly impossible.  Due to this pressure,
      joint construction is usually specified to withstand
      internal design pressures without leaking.  Existing
      sewers are generally pre-cast concrete in 10 to 20 foot
      sections.  Manholes are required every 400 feet and at
      each major direction charge.  While joint material is

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      available to eliminate leakage, concrete pipes often
      crack after several years due to settling,  frost heave,
      or other causes, and tend to leak.  Rock tunnels are
      bored through relatively impervious rock and generally
      require no structural support.  Water movement occurs
      via discontinuities in the rock (cracks, fissures,
      bedding planes, etc.}.  Tunnels are constructed at
      depths 250 feet or more, thus the general possibility
      for infiltration is greater than exfiltration.  Water
      movement has successfully been controlled by permeability
      modifications such as grouting or lining.  Whether  one
      structure is more susceptible to infiltration or ex-
      filtration is dependent on site specific considerations
      and therefore cannot be judged on a general basis.

446.  The MMSD does not presently operate any sludge landfills.
      The Water Quality section of the Addendum to Appendix
      IV, Solids Management compares ranges of typical leachates,
      Extraction Procedure (EP) toxicity maximum contaminant
      levels, drinking water standards and predicted MMSD
      leachate characteristics (based on the EP test).

447.  The impacts to both the quality and quantity of groundwater
      in the planning area as a result of the deep tunnel
      system have been evaluated in much further detail for
      the Final EIS.  Further information regarding the
      groundwater analysis is included in the Addendum to the
      CSO Appendix.

448.  This information is difficult to present.  It could be
      developed in the EIS supplements for the MMSD Site
      Specific Analysis for locating sludge disposal facilities.

449.  Recharge water sources would depend on the requirements
      of the necessary NPDES permit for such a system.

450.  This general question could be better answered on a
      specific basis.  Any construction of lakefills at the
      Jones Island or South Shore WWTPs would not displace
      enough of Lake Michigan to lead to any flooding.
      Stream crossings would be involved with the construction
      of interceptors; however, the only impacts would be
      short-term localized erosion.  Flooding caused by
      these crossings is unlikely.  The construction of
      conveyance, storage or treatment facilities would
      probably have no long-term impact on flooding.

451.  Air pressure tunnelling is very expensive and considered
      extravagant for a project such as that proposed by  the
      MMSD.  Historically, the MMSD and its contractors have
      assumed liability for construction related damages.


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452.  "Generally good quality"  refers to the fact that the
      characteristics of the groundwater are such that it can
      be used as a potable water source with minimal or no
      treatment required.

453.  Fecal coliform bacteria are contained in the waste of
      warm-blooded animals.  Wastes from animals such as
      livestock and wildlife are often deposited on the soil,
      thus storm runoff from these areas may contain fecal
      coliform.  However/ background levels of fecal coliform
      are usually quite low in unpolluted water bodies.
      Excessive levels of fecal coliform, as exhibited in the
      MMSD planning area, are contributed from sources such
      as inadequately-treated sewage, sewage flow relief
      devices, combined sewer overflows, leaking sewers, and
      malfunctioning septic tank systems.  While livestock
      can also contribute high concentrations of fecal
      coliform, there are relatively few significant livestock
      operations in the planning area.

      The statement referred to in your comment has been
      deleted in the Final EIS.

454.  The EPA, in a 1978 Lake Michigan study, determined that
      Lake Michigan may be considered mesotrophic in its
      nearshore waters, and between oligotrophic and meso-
      trophic in the open waters.  The oligotrophic classification
      indicates a nutrient poor environment and thus generally,
      a condition of higher water quality.  A eutrophic
      classification indicates a nutrient rich environment
      and thus a condition of poorer water quality.  A mesotrophic
      classification indicates a point halfway between oligotrophic
      and eutrophic.  Therefore, "still quite clean" was
      used to describe the oligotrophic-mesotrophic status of
      Lake Michigan in non-technical terms.

455.  Appendix VII has been revised.  A discussion of Lake
      Michigan's water quality is presented in Section 4.0 of
      the revised Appendix.  While the overall water quality
      of Lake Michigan is very good, there is some indication
      of deterioration.  In addition, localized problems,
      especially in nearshore areas, do exist.

456.  Comment noted.  Considerable revisions have been made
      to clarify the document and facilitate its use.

457.  Comment noted.  The development and screening of alternatives
      appears in Chapter 3 of the Final EIS.

458.  Apart from the runoff and air pollution documentation
      which appears in Chapter 4 of the Secondary Growth


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      Impacts Appendix,  the EIS assumes that implementation
      of the 208 Plan would prevent future development from
      encroaching on floodplains,  environmental corridors,
      and prime agricultrual land.

459.  When issuing the Notices of  Intent to prepare an EIS,
      the EPA determined that analyzing the secondary impacts
      resulting from the fiscal impacts of MMSD actions (e.g.,
      migration of households from the City of Milwaukee to
      suburban communities) was not required.

      However, the following factors would play an important
      role in assessing the degree of city to suburb migration.

      1.)   The SEWRPC population forecast for the SMSA for
           1980 was 84,000 higher  than the 1980 preliminary
           census.  The 1980 SEWRPC forecast for Milwaukee
           County was almost 54,000 higher than the 1980
           preliminary census.

      2.)   Under current Wisconsin Statutes, Milwaukee County
           must provide the funds  requested by the MMSD for
           the contruction of capital improvements to the
           MMSD sewerage system.

      3.)   Under the current contract formula, communities
           outside Milwaukee County have much lower charges
           for capital costs than  communities within Milwaukee
           County.

      4.)   The MMSD is likely to receive less than 75% grant
           funding for its capital improvement program.

      5.)   The legality of district-wide financing of the CSO
           abatement is being challenged by a group of suburban
           communities.

           In view of the above factors the following assumptions
           describe a "worst case" situation for the City of
           Milwaukee:

           1.)  The City of Milwaukee would finance its own CSO
                abatement and sewer rehabilitation.

           2.)  The current contract formula remains unchanged.

           3.)  The MWPAP is only  25% funded.

           4.)  The current estimated cost of the MFP is too
                low.

           5.)  Bonds are issued at a 8% interest rate.

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           6.)   The future population in the planning area does not
                reach SEWRPC forecast levels and excessive sewer
                capacity is provided in outlying suburbs,  which
                could accommodate city-suburban migration.

      If all of these above conditions prevailed,  the City of
      Milwaukee's 1985-20Q5 average annual equalized tax rate
      for the MWPAP would be about $9.80 per $1000 equalized
      value.  Under the same assumptions, the average annual
      equalized tax rate for the typical Milwaukee County suburb's
      rate would be about $4.30 per $1000.  Although most suburbs
      outside Milwaukee County do not use the property tax for
      cost distribution, charges to these suburbs would be
      smaller than the charges to Milwaukee County suburbs.  As
      a result, the average annual tax to finance the MFP
      (1985-2005)  on a $50,000 house in the City of Milwaukee
      would be $490.  The average annual tax on the same $50,000
      house located in a Milwaukee County suburb (other
      than Shorewood) would be about $215.  This average
      annual difference between the City and suburbs amount to
      $5,700 over the 1985-2005 planning period.  Household
      charges in suburbs outside Milwaukee County would be
      even less than the household costs for suburbs in the
      County, further widening the tax differential between the
      City and suburbs.

460.  Construction of the interceptors and the provision for
      additional treatment capacity could aid in the growth
      of industry in the areas which will receive sewer
      service.  For a discussion of the fiscal impacts of the
      MFP on industry, see the Fiscal/Economic Appendix.

461.  The fiscal impacts of the MFP are analyzed in the
      Fiscal/Economic Appendix.  This Appendix evaluates the
      impacts of various methods of cost distribution, one of
      them being the existing contract formula.

462.  It is generally the geographical location of interceptors,
      not the size of a wastewater treatment plant, which
      aids in determining the location of future growth.
      Additionally, residential, commercial, and industrial
      flows account for only about 20% of the total flow to
      the treatment plants in the MMSD (the remaining 80% is
      infiltration/inflow).  It is possible, however, that
      excess capacity can be provided by building interceptors
      to undeveloped areas to serve forecast populations,
      if there is a subsequent areawide population shortfall.

463.  This may turn out to be the case, however, the system
      is designed not only for sanitary flow, but also for
      the peak flows that occur as a result of infiltration


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      and inflow (I/I)  during wet weather.

      These wet weather flows are determined by the condition
      and length of the sewers.  For example, the I/I introduced
      through roof leaders, foundation drains,  sump pumps and
      cracked laterals is independent of the household size.

464.  Agreed.  Assuming the comment refers  to the staging of
      interceptor construction, it is a possible mitigating
      measure to secondary growth impacts.   Staging of treatment
      plant construction would have little  effect on future
      development trends.  Other methods of guiding development
      are available, such as delineation of sewer service
      areas and limiting the provision of other public services.

465.  It means that the cost differences among alternatives
      exist within an accuracy range of +30 and -15 percent.
      If all the costs are uniformly inaccurate (or accurate),
      the differences among alternatives would be unchanged.
      If the costs turn out to be inaccurate to varying degrees,
      the differences among alternatives would very likely
      change.

466.  Comment noted.

467.  Table 3.18.  The average annual debt  service (listed
      in the table) is $86,137,000 (Mosaic).  The peak year
      debt service is $97,917,000 (1990).  The peak year
      debt service is 13.7% greater than the average year.
      See Table 19 in the Fiscal/ Economic  Appendix for
      greater detail.

      The 6% interest rate assumption was realistic at the
      time the analysis was conducted.  For an analysis of
      higher interest rates see Chapter 5 as well as Appendix
      X and the Addendum to Appendix X, Section 3.0.

468.  Tables 3.19 and 3.20 are now referenced to the following
      four tables in the Fiscal Impact Section of Chapter 5
      which give the assumptions used in the Fiscal Impact
      Analysis:

           Assumption of the Fiscal Analysis Local Alternative

           Assumption used in Fiscal Impacts Analysis for
           the Regional Alternative

           Assumption used in the Fiscal Impacts Analysis
           Mosaic Alternative

           Assumptions used in the Fiscal Analysis for the
           Combination Alternative

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469.  Table 3.20.  See pages 47 and 49 in the Fiscal/ Economic
      Appendix for household income definition.

470.  See the Fiscal/Economic Appendix for detailed information.

471.  Table 4.10.  The commentor refers to information
      regarding present and future numbers of households and
      average household sizes.  The number of individual
      households and their respective sizes is a critical
      factor in determining population trends.  In turn,
      population trends influence where sewerage facilities
      are located.

472.  Table 4.21 is presented in the Draft EIS for informational
      purposes.  The information requested is not necessary
      for evaluation of the fiscal impacts of the MFP.

473.  Agreed.

474.  The MMSD recommended district-wide financing of all
      MFP components on June 5, 1980.

475.  The intent is to show the impacts of the mentioned
      methods of financing, not to develop a refined schedule
      of financing the program.  This will be the responsibility
      of the MMSD and Milwaukee County and, possibly, the
      State Legislature.  The risks associated with issuing
      bonds are discussed in Chapter 5.

476.  Comment noted.  These tables are incorporated into one
      table in the Final EIS.

477.  Comment noted.  The correction has been made.  The fiscal
      analysis was carried out to ascertain if the County's
      debt limit would be exceeded.  Once the debt limit is
      reached, the MFP could no longer be financed by issuing
      bonded debt.

478.  The order of discussion has no bearing on whether an
      alternative is viable or not.

479.  The property tax levy would be the only current legal
      means available.

480.  Yes.

481.  They have been moved to the end of the fiscal section.

482.  No discussion, anywhere in the EIS, ever assumes that
      the County can exceed its debt limit.

483.  This section has been deleted.  It has been replaced

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      with the "Individual Community Financing Alternative",
      which shows the costs to other communities without CSO
      costs.

484.  Comment noted.  The table has been revised.

485.  Comment noted.

486.  Both the negative and positive impacts of the MFP have
      been presented in the EIS.

487.  Comment noted.

488.  The "worst case" in this analysis refers to where the
      money would have been spent,  had it not been used to
      finance the MFP.  (See Section 3.0 of the Appendix X
      Addendum for a worst case analysis concerning interest
      rates and funding assumptions.)

489.  Comment noted.  For more information on the sensitivity
      of interest rates see page 93 of Appendix X as well as
      Appendix X Addendum, Section 3.0.

490.  The survey focused on industrial corporations, but
      three commercial enterprises were also interviewed.  A
      mix of local manufacturing companies were surveyed
      based on size, industry, and location.   The statistical
      validity of the survey was not stated in the study.

491.  This statement has been deleted.

492.  Table deleted.

493.  For a thorough discussion of the impacts on households
      see Appendix X.

494.  During the last five years, construction cost inflation
      and property value inflation have averaged 8% and 10%,
      respectively.  The EIS maintained this relationship
      between the two rates, but increased them in an analysis
      in Appendix X to 10% and 12%  to analyze the effect of
      a slightly worse inflation situation.

495.  These comments and questions are answered in Sections
      5.0 and 6.0 of the Appendix X Addendum.

496.  These comments are addressed in Section 7.0 of the
      Appendix X Addendum.

497.  At the time the fiscal analysis was conducted, 6%
      interest on municipal bonds was reasonable. However,


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      the EIS provided an interest rate sensitivity analysis
      on page 93 of Appendix X.  This analysis shows tax
      rates for 6, 7, 8,  and 9%  interest rates.   In addition,
      the discussion stated "For every one percentage point
      increase in the interest rate paid on the  bonds,  the
      average annual debt services increases 8%."  Finally,
      Section 3.0 of the  Appendix X Addendum analyzes worst
      case conditions, including higher interest rates.

498.  These comments are  addressed by the Individual Community
      Financing Alternative (Section 2.0}  in the Appendix X
      Addendum.

499.  Fiscal impacts to fixed and low income residents are
      discussed in Section 10.0  of the Appendix  X Addendum.
      Because of inflating property values and the regressive
      nature of the property tax, the EIS agrees that low-
      income households will be  among the most burdened.
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500.  The Fiscal/Economic Appendix made no conclusions.
      This Appendix identified fiscal impacts.  The Appendix
      does not deal with the subject of cost effectiveness.

501.  Section 3 of Public Law 96-483, known as the Stafford
      Amendment, replaces the eliminated Industrial Cost
      Recovery Program CICR}.  The section reads:

              PUBLIC LAW 96-483—Oct. 21, 1980

      Sec.3. Section 201 of the Federal Water Pollution
      Control Act is amended by adding at the end thereof
      the following new subsection:  "(k) No grant made
      after November 15,  1981, for a publicly owned treatment
      works, other than for facility planning and the preparation
      of construction plans and specifications, shall be
      used to treat, store, or convey the flow of any industrial
      user into such treatment works in excess of a flow per
      day equivalent to fifty thousand gallons per day of
      sanitary waste.  This subsection shall not apply to
      any project proposed by a grantee which is carrying
      out an approved project to prepare construction plans
      and specifications for a facility to treat wastewater,
      which received its grant approval before May 15,
      1980.

      The MMSD has estimated that about $114 million of the
      MFP would become non-grant-eligible if this Stafford
      Amendment was implemented.

      If industry were billed directly for this industrial
      capacity, the ten major wet industries would have to
      pay $81 million of the $114 million.

      The other alternative would be to finance the $114
      million through local property taxes.  However, this
      may not be different from current expectations for the
      following reasons.

      The MFP was originally projected to be grant funded to
      about 36% because of a $60 million annual ceiling in
      available funds.  Funding expectations have since
      fallen, and the MMSD is currently expecting state and
      federal grants to fund less that 36% of the MFP.
      Consequently, in many of the construction years, the
      grant eligible costs far exceed the expected funding
      level.  For example, in 1984, the MMSD is scheduled to
      spend $270 million.  If it receives the full $60
      million in grants it has projected, the expenditures
      that year would be 22% funded.  Approximately $210
      million would not be grant funded.  Assuming that $114

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      million of the $270 million expenditure in .1984 was
      not eligible for grants and $156 million was eligible,
      the $60 million maximum expected amount of funding
      would be unaffected.  The $210 million would still
      have to be locally-financed.

      In sum, the grant eligible costs of the MFP are so
      much greater than the expected funding level, that
      altering the eligible amounts may not affect the
      funding at all.  However, it is possible that the
      mechanics of the funding process could function in
      such a way that the loss of $114 million in eligible
      costs would affect the funding level.  The worst case
      possible (which is unlikely) would be that the $114
      million loss in eligibility would bring about a $114
      million loss in grants.  If this occurred, and the
      MMSD opted to not charge industry directly, the esti-
      mated Milwaukee County property tax rate to finance
      the MFP would increase an additional 10%.

502.  The 1977-79 state budget bill provided for a 5-year
      phased exemption of Line A personal property from
      local taxation.  Manufacturers and commercial stock
      (.inventory) are included in the Line A category.  1980
      is the fourth year of the phase out period.  The 1980
      amount phased out is $846,536,375.  Seventy percent
      of the total value of Line A property is exempt, as of
      1980, from property taxation.  This value is $1,975,251,898
      The final 30%  (about another $846 million) will be
      exempted in 1981.  Thus, in 1981, 100% of the Line A
      property in Milwaukee County (about $2.8 billion in
      1980 dollars) will be exempt from property taxes.  The
      total impact of exempting all Line A property from
      taxation in Milwaukee County (as of 1981) will be
      about a 14% loss to the property tax base.  The MFP
      financial impact models incorporated this property tax
      base loss when they were constructed.

503.  Section 7.0 of the Appendix X Addendum lists the
      locally-assessed 1980 property tax rates for all
      Milwaukee County communities.  This section also shows
      the MFP as an increase to these local tax rates.

504.  Comment noted.

505.  All of the above models do assume the sale of general
      obligation bonds at 6% interest.

      The Milwaukee County debt limit is exceeded with all
      of these models, except 68B.  Model 68B was included
      to reveal a general relationship between inflation and


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      the debt limit.  When the inflation rate of the County
      property value is assumed higher than construction
      cost inflation, the County debt limit is not exceeded.

506.  A construction cost inflation rate of 15% per year is
      not realistic  (based on recent trends).   According to
      the Engineering News Record's Construction Cost Index,
      construction cost inflation has averaged about 8% per
      year since 1974.

      A analysis of higher interest rates indicates that
      every percentage point increase in bond rates beyond
      6% produces an 8% increase in the Milwaukee County tax
      rate (see page 93 of Appendix X).  Further analysis of
      higher interest rates can be found in Section 3.0 of
      the Addendum to Appendix X.

      Section 5.0 of the Addendum to Appendix X reveals the
      effect on the Milwaukee County debt limit of its
      Capital Improvements Program.

      Section 6.0 of the Addendum to Appendix X estimates
      the tax rates required to finance the MFP when the
      debt limit is reached.

507.  The Engineering News Record cost index indicates
      that construction costs have increased an average of
      about 8% per year since 1974.  Milwaukee County equalized
      property value was $11.171 billion in 1974, and $19.748
      billion in 1980.  The difference between these figures
      represents an average annual growth rate of about 10%.
      Comparing indices, then, would mean assembling a model
      with an 8% construction inflation rate and a 10%
      property value inflation rate.  Because the difference
      between these two rates is 2 percentage points, the
      result would be the same as using 10% for construction
      and 12% for property value, as assumed.in the fiscal
      model 68B.

508.  Incorporation of Milwaukee County's 1981-85 Capital
      Program into the County debt analysis can be found in
      Section 5.0 of the Addendum to Appendix X.

509.  During the last 5 years, property value  inflation has
      been consistently higher than construction inflation.
      Milwaukee County property value inflation has been
      about 10%, while construction inflation  has been
      around 8%.  Consequently, the EIS inflation analysis
      maintained this ratio between these two  variables.
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510.  Section 6.0 of the Addendum to Appendix X shows the
      effect of financing the MFP after the debt limit is
      reached.

511.  This information is presented in the requested form in
      Section 7.0 of the Addendum to Appendix X.

512.  Comment noted.

513.  It should be, and is, a total clear water program.
      The paragraph following describes the clear water
      program which includes elimination of excessive quan-
      tities of infiltration and inflow from the sanitary
      sewers.

514.  It is the amount of infiltration and inflow to a sewer
      system that is cheaper to remove than to convey and
      treat.  Beyond the cost-effective level, it becomes
      cheaper to treat the water than to remove it.

515.  Comment noted.  The correction has been made.

516.  The interest rate assumed was 7%.  Section 2.0 of the
      Addendum to Appendix X provides a more comprehensive
      discussion.

517.  The statement is correct.  The table has been deleted.

518.  Comment noted.

519.  Comment noted.

520.  This "worst case" scenario refers to an assumption
      that money would have been spent had it not been used
      to pay taxes.  A worst case analysis regarding interest
      rates can be found in Section 3.0 of the Addendum to
      Appendix X.

521.  Tables 66, 67, and 68 all indicate the changes in
      gross output, earnings, and employment by year.  In
      addition, the conclusion on page 123 recognizes the
      time difference between expenditures and payback by
      stating "...the basic situation of positive economic
      impacts,  overlapped, and followed by a long period of
      negative economic impacts."

522.  Appendix V, page 5-148, addresses the sites.

523.  The MMSD and contractors are responsible.

524.  It is the responsibility of the MMSD and the contractor
      to minimize noise and dust.


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525.  Ths MMSD and its contractors are responsible.  However,
      by constructing in the rock formation, dewatering
      should be minimized and only minimal drawdown is
      expected.

526.  Ths MMSD and its contractors are responsible.  Blasting
      would only be performed in drop shafts where irregular
      rock formations (e.g., large boulders) are encountered.
      The tunnels would be driven by tunnel boring machines
      (TBM), and therefore no blasting would be required.

527.  Blowers and pumps would be located only at access
      sites.  These sites are expected to be located in non-
      residential areas.

528.  Currently, these tanks (near the Jones Island WWTP)
      are being used to a lesser degree, because less fuel
      is brought in by boat.  As leases to this land expire,
      the Milwaukee Harbor Commission has not renewed them,
      and will remove the storage tanks.  However, gasoline
      seepage would occur only by a catastrophic accident,
      and therefore is not considered to be a real hazard to
      tunnel workers.

529.  This is a legal issue which would be resolved by the
      MMSD and the contractor in court.  Because of the
      proposed tunnel depths, the possibility of such an
      occurrence is unlikely for the tunnels.

530.  The MMSD and its contractors are responsible.

531.  Additional alternatives for the South Shore WWTP (#8
      and #9) were developed in the EIS.  These alternatives
      were not considered in the MMSD June, 1980, Facility
      Plan for South Shore.  Because this plan  (along with
      the Jones Island Facility Plan) requires further re-
      finement before preceding to design, advanced facility
      planning is required.  The MMSD's Advanced Facility
      Planning  CAFP) efforts are incorporated into the Final
      EIS.  The EPA and DNR are aware of the Fish and Wildlife
      Service's concerns (as discussed in a June 17, 1980
      letter from Mr. Richard A. Hoppe to Mr. Eugene Wojcik).
      Mr. Anthony S. Earl,  then secretary of the DNR, stated
      the DNR's policy towards the MMSD's proposed lakefills
      at their two wastewater treatment plants.  All information
      provided by the Corps of Engineers and Fish and Wildlife
      Service was used for the Draft EIS.

      Section 30.12 of the Wisconsin Statutes outlines the
      statutory requirements for lakefill.  Strict interpretation
      of Section 30.12 supports the opinion that the MMSD


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cannot fill the lake without further action by the
Wisconsin Legislature.  However, the MMSD feels that
they have power to fill the lake under Section 62.61
CD Cd) Wisconsin Statutes.  Program Requirements
Memorandum 176-4 CPRM 76-4): Coordination of Con-
struction Grants Program with EPA-Corps of Engineers
Section 404/Section 10 Permit Programs was followed in
the preparation of Appendix II,  Jones Island and
Appendix III, South Shore of the EIS.The Corps of
Engineers regulatory program has guidelines for the
preparation of environmental assessments.  Although
the EIS does not contain the eight separate sections
(outlined below), it does address the relevant issues:
CD  Project description
(2)  Environmental setting without the project
C3)  Relationship of the proposed action to land use
     plans
C4)  Probably impact of the proposed action on the
     environment
(5)  Any probable adverse environmental effects which
     cannot be avoided
(6)  Alternatives to the proposed action
C7)  The relationship between local short-term uses
     of man's environment and the maintenance and
     enhancement of long-term productivity
(8)  Any irreversible and irretrievable commitments
     of resources which would be involved if the
     proposed action should be implemented.

The EIS, in addition to the Environmental Assessment
prepared by the MMSD, should be sufficient to meet the
regulations referred to.  No Corps of Engineers personnel
have expressed any indication of inadequacy for the
EIS with respect to their requirements.

The EIS addresses the Corps requirements within the
constraints of the overall project.  A structured
analysis could be contained in an additional appendix
specifically addressing lakefills, but  this information
could be obtained from the EIS.

The MMSD would have to file a permit application with
the Corps,and the specific environmental information
could be included in a more structured format at
that time.  The analysis required for the permit is
the MMSD's responsibility since they would be the permit
applicant.
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      Landfill leachate will be specifically addressed in
      the supplemental EIS on the Site Specific Analysis of
      the MMSD's Total Solids Management program.

532.  The EPA and DNR have revised the Water Quality Appendix
      VII to include recent data developed by Drs. Lee,
      Remsen and Brooks of the University of Wisconsin-
      Milwaukee on the mixing zones of the Jones Island
      effluent in the Outer Harbor (Lee et al., "An Analysis
      of Water Quality and Movement Associated with the
      Sewerage Effluent in Milwaukee Harbor and Adjacent
      Lake Michigan" Final Report to MMSD, Center for Great
      Lakes Studies, College of Engineering and Applied
      Science, University of Wisconsin-Milwaukee, December
      15, 1980.). The study evaluates the circulation patterns
      and hydraulic residence time of the Outer Harbor,
      defines nitrification processes in the Outer Harbor
      and models the effects of discharging various ammonia-
      nitrogen concentrations from Jones Island into the
      Outer Harbor.  The study indicates that although the
      Outer Harbor has an average hydraulic retention time
      of approximately 1.5 to 2.0 days, very complex double
      circulation patterns within the Harbor may retain
      water for longer periods.  These circulation patterns
      make the estimated retention time of 1.5 to 2.0 days
      conservatively low.  Free-floating, nitrifying bacteria
      are relatively low.  Most nitrification occurs in the
      bottom sediments.  The modeling data indicate that
      Jones Island effluent ammonia-nitrogen concentrations
      in the range of 6 mg/1 to 18 mg/1 have a negligible
      effect on dissolved oxygen levels.  Dissolved oxygen
      decreases in the most heavily imparted zones of the
      Outer Harbor are 0.2 mg/1.  However, the study notes
      that some low dissolved oxygen levels may develop in
      the north and south sections of the Outer Harbor
      because of the double-gyre circulation pattern in
      these areas.  The EPA and DNR have incorporated an un-
      ionized ammonia-nitrogen evaluation, based upon data
      from Lee et al. in the revised Water Quality Appendix
      VII, Chapter 4, Section 4.1.2.   A discussion of the
      un-ionized ammonia-nitrogen concentrations from the
      South Shore WWTP is presented in Chapter 4 of the same
      revised appendix, Section 4.2.

533.  The EPA and DNR agree with the Department of the
      Interior that residual chlorine levels should be set
      as low as practicable below the present limit of 0.5
      mg/1.  Other disinfection techniques are addressed in
      the Addendum to Appendix II, Jones Island.
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534.  Priority pollutant metals (cadmium, chromium, copper,
      lead, nickel, and zinc)  are presently below EPA maximum
      water quality criteria limits in both the Jones Island
      and South Shore WWTP effluents.  Given that industrial
      pretreatment programs limit these pollutants at their
      source, future loads are expected to have less impact
      than present loads.  A complete discussion of this
      issue is given in the revised Water Quality Appendix
      VII, Section 4.3.

535.  At present, no WPDES limits for metals exist.  The
      WPDES permits for MMSD plants have effluent limits for

           BOD5                      30 mg/1 (monthly)
           Suspended Solids          30 mg/1 (montlhy)
           Phosphorus                1.0 mg/1 (monthly)
           Fecal Coliform            200#/100ml (monthly)
           pH                        6.0 to 9.0 (daily)
           Free available chlorine   0.5 mg/1 (daily)
           Cproposed)

      Although water quality standards exist for other
      pollutants (e.g. metals, ammonia), no WPDES limits
      exist for these substances.   Metal discharges do not
      cause the water quality standards to be exceeded.   The
      MMSD's Industrial Waste Pretreatment Program should
      reduce industrial discharges of WPDES limited and
      other pollutants.  Existing WWTP metal removal effi-
      ciencies appear to be sufficient, and side-stream
      treatment for metals does not appear to be warranted.

      However, ammonia does appear to be a water quality
      problem in the Outer Harbor.   (This issue is discussed
      in Section 4.1.2. in the revised Appendix VII, Water
      Quality.)  Therefore, some form of ammonia-nitrogen
      control appears to be necessary.  Various nitrogen
      control measures, especially side-stream treatment,
      are discussed in Section 12.0 of the Addendum to
      Appendix II,  Solids Management.

      Increased pollutant loads at MMSD WWTPs due to CSO
      abatement have been taken into the design considerations
      for new facilities.  Side-stream treatment does not
      appear to be warranted.   The metal loads caused by CSO
      abatement are a small portion  (e.g., less than 5% for
      Cd, Cu, Zn, Ni, and 22% for Pb) of the total metal
      loads to the plants.  The WWTPs should be able to
      remove these metals since present removal efficiencies
      for these metals are adequate  (Cd:  77%; Cu:  68%;
      Zn:  74%; Ni:  18%; Pb:   73%) and are expected to
      improve during the planning period based on pilot
      studies  (Cd:   80%, Cu:  80%, Zn:  89%, Ni:  21%,  Pb:
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      93%).   Therefore, side-stream treatment for metals
      may not be warranted, but nitrogen control Cby side-
      stream treatment! may be necessary.

536.  The numbers in Table 4.5 of the DraftEIS apply to the
      MMSD planning area.  These figures have been supplied
      by the 208 Water Quality Planning Agency, the Southeastern
      Wisconsin Regional Planning Commission.  These figures
      represent their 2000 Land Use Plan.  The figures
      cannot be inconsistent with the 208 Plan for environmental
      corridor preservation because they are part of that
      plan.

537.  Specific discharge locations will not be identified
      until  final design is undertaken and the exact locations
      of the tunnels and caverns are determined.  It is
      expected that most of the groundwater pumped from
      excavation will be discharged directly to nearby storm
      sewers or drainage ditches,provided the water does not
      contain high concentrations of sediment or other
      pollutants.  The volume of groundwater to be pumped
      would  be minimized by grouting  the water-bearing
      fissures of the work.

      At no  time would polluted groundwater be directly
      discharged to surface waters without treatment.
      Temporary ponding will be used to reduce sediment
      loads  to surface waters.  More elaborate treatment
      facilities would be necessary if oil, gasoline, or
      other  hazardous materials pollute the groundwater
      during normal construction activities or in the case
      of accidental spills.  These control measures will be a
      part of contract specifications.

538.  The revised Water Quality Appendix VII incorporates
      the most recent data available.  These revisions make
      the water quality values uniform throughout the EIS.

539.  The EIS has chosen Wisconsin DNR and 208 recommended
      water  quality standards as the source of comparison
      for present and future impacts.  These comparisons are
      made throughout the revised Water Quality Appendix
      VII.

540.  Cadmium, copper, and hexavalent chromium levels in the
      Jones  Island and South Shore WWTP effluent as well as
      in the Inner Harbor, the Outer Harbor, and nearshore
      Lake Michigan waters are discussed in Section 4.3 of
      the revised Water Quality Appendix VII.  Lead and
      mercury methylation, in terms of the benthic community,
      are briefly discussed in the CSO Appendix V, Chapter
      5.  The discussion is limited because data on existing

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      methyl mercury and methyl lead concentrations are
      limited.

541.  A discussion of the impacts of instream measures is
      given in Chapter 5 of the CSO Appendix V.  A discussion
      of attainable water quality conditions, with and
      without instream measures, would require knowledge of
      the effects of sediment stabilization on the bound
      pollutants in the Inner and Outer Harbor sediments.
      The effects of pollutant release from a richly organic,
      highly polluted sediment undergoing stabilization are
      unknown.  It should be noted that the portions of
      three rivers comprising the Inner Harbor have been granted
      variances from the fish and aquatic life standards.

542.  The suggestions by the Department of the Interior for
      mitigating measures for the parks and recreation
      impacts have been incorporated into Chapter 5 of the
      Final EIS.

543.  A sentence stating that the mineral resources will not
      be affected has been added to Section 5.2.13, Resource
      Consumption, of the Final EIS.

544.  Section 5.2.11, Recreation and Aesthetics, has been
      revised to include a discussion of the effects of the
      MFP on parks and the Bureau of Land Management islands.

545.  Alternatives to lakefill were analyzed and discussed
      in the Jones Island Appendix  (Section IV-K) and the
      South Shore Appendix  (Section IV-G).  The potential
      problems of dredging in the Outer Harbor were also
      presented.  The EPA Recommended Plan for lakefill is
      presented in Chapter 3 and discussed in detail in
      Chapter 5 of the Final EIS.

546.  Appendix VII, Water Quality, has been revised to
      incorporate additional Lake Michigan analyses.
      Direct pollution sources to Lake Michigan are presented
      in Section 4.2 of the revised Appendix VII, Water
      Quality.  Table 33 in the section presents total
      pollutant loads directly discharged to the Lake.
      Localized effects concerning nutrient enrichment of
      the nearshore zone and ammonia discharges from the
      South Shore WWTP are also discussed.  The Lake Michigan
      impacts which would result from relocation of the
      Jones Island WWTP outfall outside of the Outer Harbor
      are described in detail in Section 4.1.1 of the revised
      Appendix VII.   The impacts evaluated include increased
      nutrient enrichment, ammonia toxicity effects, and
      public health concerns.  In Section 4.2, the total
      phosphorus loads to Lake Michigan from the Milwaukee


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      area under both existing and future conditions are
      compared to the estimated existing and future target
      phosphorus loads for the entire Lake presented by the
      International Joint Commission.

547.  A detailed analysis of the entire Lake Michigan ecosystem
      would require substantial data collection concerning
      lake currents, pollutant transport mechanisms, pollutant
      loadings, and aquatic biology.  The consideration and
      comparison of other Lake Michigan pollution abatement
      projects would require extensive data on all point, as
      well as nonpoint, source pollutant loadings.  These
      issues are beyond the scope of this EIS as set forth
      in the Notices of Intent (Appendix I).  However, other
      agencies (e.g., the International Joint Commission, or
      IJC) are evaluating means of reducing pollution in the
      Great Lakes.  Some IJC data have been incorporated into
      this EIS.

548.  Appendix VII, Water Quality, has been revised to
      include additional state-of-the-art analyses and to
      provide additional quantification of the water quality
      impacts of the various alternatives.  For example, an
      extensive review of inland lake impacts, using trophic
      state index models, is presented in Section 3.3 of the
      revised Appendix VII.

549.  Descriptions of the methodologies used in Appendix V
      were presented in the introductions to individual
      sections.  These include the following:  Section 5.1.2,
      in which the quantification of combined sewer and
      storm sewer flows are described; Section 5.1.3, including
      Table 5-1,  in which pollutant concentrations are described;
      Sections 5.1.4.2.1 and 5.1.4.2.2 in which pollutant
      loadings to the Inner Harbor and Outer Harbor are described;
      Sections 5.1.4.3.1 and 5.1.4.3.2 in which the water
      qualities of the Inner Harbor and the Outer Harbor are
      described;  Section 5.1.4.4 in which loadings to the
      sediment and sediment quality are discussed; and the
      individual sensitivity analyses.  Additional descriptions
      of methodology for new analyses are set forth in the
      Final EIS.   The Addendum to Appendix V, Combined
      Sewer Overflow, includes several paragraphs which
      further explain the methodologies.

550.  "Silty loam" has been changed to "silt loam" in the
      Final EIS.

551.  The discussion of the Universal Soil Loss Equation
      CUSLE} and consequently the "C" factor has been removed.
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552.  Comment noted.  The correction has been made.

553.  Comment noted.  It was assumed when suggesting mitigating
      measures that such measures would include good con-
      servation techniques.  The recommendation that these
      practices meet the requirements set forth in the
      Milwaukee County Soil and Water Conservation District
      Technical Guide has been added to the Final EIS.

554.  This recommendation could become part of the EPA
      Recommended Plan for Solids Management.  The practice
      of good conservation techniques is inherent in a
      sludge application program regulated by the DNR and
      the EPA.

555.  There is no reference to the alteration of creek channels,
      floodplains, or drainage patterns on the page to which
      you refer.

556.  Pollution control facilities for borrow areas will be
      addressed by the MMSD during Step II, or design (i.e.
       construction plans ).

557.  Per capita water consumption and flow reduction devices
      were evaluated in the MMSD Facilities Plan (WSP Chapter
      6).  The MMSD feels that the maximum reduction obtainable
      is a 1Q% reduction in base flow.  A conservative
      portion of this amount was used in the design flows
      generated by the MMSD and subsequently used in the
      EIS.  The problems plaguing the present sewerage
      system do not lie in the base flow, but rather in flows
      that enter the system via inflow and infiltration
      during wet weather events.  In the design year, base
      flow is expected to be 166 MGD, whereas peak flows
      could reach 900 MGD.  Thus, facilities are designed
      for peak flows.

      The State of Wisconsin has passed legislation, effective
      January 1, 1979, requiring all new construction to
      contain water conserving plumbing fixtures.  The law
      requires low-flush water closets, low-flow shower-
      heads and low-flow faucets in newly constructed buildings.

558.  The MMSD property does border residential property
      directly to the north; however, the plant is only visible
      to those homes adjacent to the lake and MMSD property.
      Almost any method of expansion at the plant would have
      an equivalent visual effect on nearby residents.  The
      MMSD's proposed landscaping should mitigate the aesthetic
      impacts of the plant expansion.
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559.  The format required by the Council on Environmental
      Quality for preparing environmental impact statements
      places the Table of Contents after the Executive
      Summary.  For clarification, the Table of Contents in
      the Final EIS is situated in front of the Summary.

560.  The MMSD adopted the Master Facilities Plan in June,
      1980.  The Draft EIS was published approximately five
      months later.  In compliance with the Wisconsin
      Environmental Protection Act, the Draft EIS did not
      contain recommendations.  The DNR will act upon the
      proposed MFP after the requirements of WEPA have been
      met.  The Final EIS identifies the EPA's recommendation
      and the reasons for the recommendation.

61.   Appendix IV, Solids Management (and its Addendum)  is
      predicated on a "worst case" situation.  Historical
      sludge data are used for all analyses, although the
      MMSD Industrial Waste Pretreatment Program will cause
      heavy metal influent loads to the plants to decrease
      during the planning period.  Historical conditions
      (and the No Action Alternative)  present the "worst
      case".

562.  New analyses concerning impacts to groundwater quality
      and quantity appear in the Addendum to Appendix IV,
      Combined Sewer Overflow.

563.  The impact of escalating energy costs was evaluated in
      Appendix VII, Interceptor Alignment.  The MMSD did not
      escalate the costs of alternatives over the life of
      the project because EPA regulations prohibit applying
      inflation rates to the cost analyses.  An evaluation
      of cost escalation was not made in the EIS because the
      selection of any inflation rate would be arbitrary,
      and would be applied to all alternatives.  Thus, such
      an evaluation would not affect the overall relationship
      in costs between various alternatives.

564.  The Clean Water Act of 1977 set up provisions for
      federal grant assistance for innovative and alternative
      (I/A) methods of wastewater treatment.  I/A technology
      received full consideration during the MMSD facilities
      planning process and the EIS process.  One I/A alternative
      which was found to have significant cost and energy
      savings was the land application of sludge.  The MMSD
      is not committed to any set form of sludge disposal
      for the planning period.  Sludge could be landfilled,
      or land applied or a codisposal facility could be
      built if necessary.  Another reason for giving I/A
      technology full consideration is that the EPA could
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      fund up to 85% (as opposed to the traditional 75%)  for
      the design and construction of those portions of
      wastewater conveyance,  storage, and treatment facilities
      utilizing I/A technology.

      The MMSD Master Facilities Plan allows for flexibility
      in the use of energy.   Both the Jones Island and South
      Shore WWTPs would would generate methane to supply a large
      portion of their energy needs.  The need for fossil
      fuels would be minimized by the elimination of Milorganite
      production.  Sludge could be transported by rail or
      truck for ultimate disposal, thereby utilizing different
      forms and amounts of energy.  The sludge could be
      combined with solid waste to form refuse derived fuel
      (RDF).  The RDF could be burned in special combustion
      units to generate energy.  Alternatives minimizing
      energy consumption and relying on alternative forms of
      fuel, such as methane gas, received full consideration.

      A 20-year planning period is typically used as the
      time frame for facilities planning and is required by
      the EPA (40 CFR 35, Appendix A: Cost-Effectiveness
      Analysis Guidelines),  because it is difficult to make
      projections of of population levels and wastewater flows
      and loads more than 20 years into the future.

565.  Comment noted.

566.  The EIS addresses SEWRPC population projections in
      Chapter IV of the Secondary Growth Impacts Appendix
      entitled "Population Forecasts". The risks associated
      with a population shortfall are discussed in that
      chapter.

567.  The Muskego Northwest WWTP discharges to Big Muskego
      Lake, not Little Muskego Lake.  However, nonpoint
      source loadings of pollution are important for both
      lakes.  The analyses of alternatives for Big Muskego
      Lake assume that nonpoint sources of pollution are
      controlled as recommended in the Areawide Water Quality
      Management (208)  Plan.

568.  While a deep tunnel electrical generation system may,
      at first, seem feasible, it contains several flaws
      which are of such severity as to eliminate such a pro-
      posal from further consideration.  These flaws are as
      follows:

      1.   Construction of tunnel at 600 foot depths: The
           Maguoketa shale is not water-tight, but rather is
           a leaky aquiclude which passes water at a rate of
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     0.00005 gal/day/ft2,in addition to water passed
     through uncased wells open to the Niagaran and
     sandstone formations.  While 600 feet of potential
     head is admittedly a more assuring deterent to
     exfiltration than 300 feet, the amount of in-
     filtration, as well as exfiltration, is also
     controlled by the head differential between
     internal and external pressures and would also
     increase significantly at a depth of 600 feet.
     While it is predicted that the Galena-Platteville
     aquifer is a more homogeneously tight formation
     than the Niagaran aquifer, less detailed information
     is available on this formation than the shallower
     formation.  The MMSD is presently gathering more
     detail on the shallower formations to enable the
     accurate prediction of potential problems during
     construction of the proposed tunnel project.
     Finally, the cost of the tunnel project at 600
     feet would increase significantly because all
     connections to the tunnel system (10 dropshafts
     plus return pumping facilities) would have to be
     extended an additional 300 feet (5700 additional
     vertical feet).

2.   Treating sewage in this tunnel system by means of
     oxygenation:  Oxygenation  (or aeration) is only a
     part of the entire treatment process necessary to
     meet treatment standards.  Oxygenation reduces the
     amount of organic material present in wastewater by
     promoting organic consumption by bacteria and
     microscopic organisms.  However, the process does
     not reduce the inorganic loads.  Further, oxygenation
     creates organic by-products (sludges) which must
     be removed for proper operation of the system.  These
     sludges are best removed by sedimentation which can-
     not occur in an environment as turbulent as an
     aerated chamber.  Finally, the flow and residue would
     have to be pumped separately to the surface for
     ultimate disposal.  Maintenance of a treatment
     facility is imperative to proper operation, and is
     a major task at conventional treatment plants.
     Operating such a system 600 feet below the ground
     surface would severely compound the problem of
     maintenance.

3.   Constructing a pumped storage reservoir with a
     hydroelectric power generating facility:  The 600
     feet of head created by constructing the tunnels
     at a depth of 600 feet could be used to produce
     electricity.  However, the water must then be re-
     turned to the surface.  Since both the generating
     and pumping equipment are not 100% efficient, the
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           amount of energy produced would not satisfy the
           demands of the proposed system, let alone produce
           excess energy.  If such a system were to be used
           only during peak electrical demand periods, the
           storage reservoirs would be most feasibly constructed
           ahead of the tunnel system.  Without such structures,
           energy generation could occur only during wet
           weather events, which would require the construction
           of large reservoirs within the central city area
           of Milwaukee to capture Milwaukee's sewage.  If the
           storage facilities were only as large as the present
           proposed storage cavern (1300 acre-feet), they would
           have to cover several acres.  These facilities would
           produce unacceptable aesthetic, odor, and land use
           impacts.

      4.   Constructing infiltration galleries to return water
           to the aquifer:  Once infiltration has entered
           the tunnel system, there is no way to prevent its
           being contaminated by raw sewage.  Therefore, the
           entire flow must be treated.  Returning these
           flows directly to the aquifer would be more damaging
           than exfiltration.

569.  Section 4.2.10 of the Main EIS, Archaeological and
      Historical Sites, has been rewritten as prescribed in
      the letter of January 10, 1981.

570.  Section 5.2.10 of the Main EIS, Archaeological and
      Historical Sites, has been rewritten.

571.  Section 5.13 of Appendix V, Combined Sewer Overflow,
      Historical/Archaeological Sites, has been rewritten.

572.  There are no known archaeological sites in this area.
      About 40 acres of the existing South Shore site is
      lakefill,and most of the remaining area has been
      previously disturbed.  EPA and DNR are not aware of
      the potential for destruction of archaeological and
      historical sites referred to in your letter.  If
      archaeological sites are encountered during the expansion
      of the South Shore WWTP, construction would cease
      until the State Historic Preservation Officer could
      determine the significance of the site.  Sites eligible
      for inclusion on the National Register of Historic
      Places would be avoided or recovered in compliance
      with the current National Advisory Council procedures.

573.  A section discussing secondary growth impacts on
      historical and archaeological resources appears in
      Section 3.0 of the Addendum to Appendix IX, Secondary
      Growth Impacts.
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574.  At the time of the Draft EIS, the best estimate of the
      probable I/I removal rate was detailed in the MMSD I/I
      analysis as 48%.  This value included a 60% removal
      rate and 80% effectiveness of removal procedures.  A
      draft of the SSES report released on February 6, 1981,
      indicates that the actual I/I removal would probably
      be closer to 13%.  The increased flows due to the de-
      crease in I/I removal would be accommodated in the
      deep tunnel storage system by expansion of the under-
      ground storage facilities.  This increase, however,
      further justifies the elimination of a flow-through
      system because of the increased capacity requirements
      at the plants.  Expansion of the tunnels represents an
      increased cost for construction and an increased
      energy requirement for annual pumping from storage and
      treatment.  To some extent, these increased costs
      would be mitigated by a reduction in the costs of
      repairing and rehabilitating the sanitary sewers in
      the MMSD service area.

575.  The geotechnical consultant's report addressing the
      issue of deep tunnel storage and its effect on groundwater
      quality is included in the Addendum to Appendix V,
      Combined Sewer Overflow.

576.  The correction is made in the Addendum to Appendix V,
      Combined Sewer Overflow.

577.  This comment first refers to Exhibit B of the submitted
      SEWRPC material, an October 10, 1980 letter from
      SEWRPC to DNR.  This letter primarily addresses the
      preliminary draft of the EIS.  Subsequently, a meeting
      was held on December 10, 1980, between SEWRPC, EPA,
      and DNR to discuss the remaining issues outlined in
      the 10/10/80 SEWRPC comment letter.  These issues were
      resolved at that meeting, before publication of the
      Draft EIS.

      The comment also refers to Exhibit C of the submitted
      SEWRPC material, which suggests wording revisions to
      page 2-23 of Appendix IX.  As a result, page 2-13 of
      the Appendix reads as follows  Cunderlined portions are
      those revisions suggested by SEWRPC and incorporated
      into the text):

      "Secondary Impacts (Germantown and Northwest Side)

      The level of population and housing units projected
      under an action alternative is consistent with the
      Regional Plan.  It is not/ however, in accord with
      the City of Milwaukee's more recently prepared forecasts
      for the Northwest Side.  There is a difference of
      20,000 people between the City of Milwaukee and SEWRPC

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forecasts for the Northwest Side in the year 2000.
This number is about equal to the forecast increment
for Germantown by 2000.  Thus, these alternatives
could have the effect of facilitating development in
Germantown without allowing the northwest side of the
City of Milwaukee to develop to its full capacity, as_
envisioned in the City forecast.  However, development
in Germantown would essentially conform to the agreement
achieved among the involved communities as participants
in the preparation of the regional land use plan for
year 2000.

"Effects of Population Shortfall

The Regional Plan specifically identifies policies of
revitalizing the Central City and maintaining the
existing population of the City.  In the event of a
population shortfall, these alternatives could lead to
a pattern of development that is contrary to this
policy.  In addition, the pattern of development may
leave a great deal of undeveloped land in the Northwest
Side of Milwaukee while Germantown becomes more developed.

"Mitigation Prospects

Other alternatives which could mitigate some of the
secondary effects include a smaller local plant expansion,
a joint venture with Menomonee Falls, or a smaller
connection to the 57-inch interceptor.  These may
suffice through the entire planning period for a lower
population forecast, or at least until the 1990s.
Germantown could consider implementing local growth
controls which would reduce the overall level of
development.  Other institutional measures which could
be considered include a more restrictive 208 Plan
service area boundary for the year 2000 and staged
service area boundaries for 1985, 1990, and 2000.
Some of the mitigative measures would require  a major
revision of SEWRPC's adopted Regional Plan, as well
as the local plan developed by Germantown to implement
the Regional Plan recommendations.  Such revisions
would preferably be made in the same type of inter-
governmental discussion used to develop the Regional
Plan."

A suggestion by SEWRPC to revise a sentence on page 2-
18 was not incorporated.

The EIS discussion of the Franklin Northeast Interceptor
in the Secondary Growth Impacts Appendix concurs with
the statement that "the planned  (SEWRPC) population to

                        3-100

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      be served by the year 2000 in the Franklin Northeast
      Trunk Sewer Service area could not be accommodated by
      the developable acreage which would be served under
      the alternative to upgrade six existing pumping stations."
      However, the EIS analysis also indicated that whether
      or not the Franklin Northeast Interceptor is built
      should have no impact on the future population of the
      City of Franklin Ci.e., the City of Franklin will
      attain the same population with or without construction
      of the interceptor).   Additionally, as pages 2-22
      through 2-24 indicate, if the interceptor is constructed,
      a shortfall in the regional population could result in
      a scattered, non-contiguous pattern of development which
      would not conform to local and regional plans.

      The decision on whether or not to recommend construction
      of the Franklin Northeast Interceptor depends on the
      analysis of all the criteria outlined in Chapter 3 of
      the EIS, including consideration of the "need" for the
      interceptor, not solely on the secondary growth impacts
      of the interceptor.

      The analysis of the indirect fiscal impacts (resulting
      from future development in Franklin) of the Action and
      No Action Alternatives appears in the New Analysis
      section of the Addendum to Appendix IX, Secondary Growth
      Impacts.

578.   Based upon the cost-effectiveness analysis in the
      MMSD's June, 1980 Solids Management Report (SMR),
      the disposal of sludge on agricultural land has the
      lowest cost when evaluating each wastewater treatment
      plant (WWTP) on an individual basis.  When the MMSD
      paired the alternatives, they found that landfilling
      Jones Island sludge and land spreading South Shore
      sludge had the lowest total costs.  The EIS analysis
      also considered a total land spreading program and
      developed a landfill  contingency plan.  This contingency
      plan was considered by the DNR Solid Waste Bureau,
      and they determined that the landfill backup could be
      planned, designed and approved by the DNR after the
      land for the site was purchased.  The MMSD proposed
      nine-month storage facility could allow sufficient
      time for sludge storage during the preparation of the
      already purchased contingency site.  This contingency
      plan is discussed further in the"Flexibility"section of
      Appendix IV, Solids Management.

      The cost data developed in the SMR were used in the
      EIS analysis and any  revisions to SMR costs were
      incorporated into the EIS.  Milorganite production was


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      evaluated in the EIS Technical Memorandum on the Total
      Solids Management (TSM)  Program (June 1979)  and was
      not found to be cost-effective.  Milorganite inventories
      have been building up recently due to a lack of sales.
      In 1979, the MMSD applied sludge to approximately
      5,000 of the 62,000 acres approved by the DNR as part
      of the existing sludge spreading program for South
      Shore WWTP.  Major problems in continuing or expanding
      the program are not expected to occur.

579.  The requested changes to the values used in the main
      text of the Draft EIS have been incorporated into the
      Addendum to the CSO Appendix (Errata).  We cannot,
      however, be responsible for corrections necessary in
      the MMSD's CSO Facility Plan (page 8-71 and Table 8-24).

580.  Both the EPA and DNR recognize the value of wetlands
      and wildlife habitat as integral parts of the environment.
      The eight wetlands used in the preliminary screening
      of alternatives were considered for general comparative
      purposes only.  If marsh application of sewage effluent
      had been determined to be cost-effective and had been
      included in the more detailed analysis of the alternatives,
      a rigorous review of the environmental impacts upon
      wetlands would have been conducted.

581.  All of the air quality emission loads in the Final EIS
      have been checked and changes have been made where
      necessary.

582.  This page of the EIS has been revised to include infor-
      mation on the frequency of overflows.

583.  Comment noted.

584.  The reason for not including the number of septic
      tanks that would be eliminated with construction of
      each interceptor is that the data sources used for the
      EIS generally differed substantially.  No recent,
      detailed, septic tank survey information is available.

585.  This point has been clarified in Chapter 3 of the
      Final EIS.

586.  Comment noted.

587.  Comment noted.

588.  Response 577 discusses the EIS analysis of the Franklin
      Intercepter Service Area.
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589.  The EPA and DNR concur with your comment.  In Table 8
      of the revised Appendix VII, Water Quality, it is
      shown that abandonment of the Muskego Northeast WWTP
      would substantially reduce concentrations of bio-
      chemical oxygen demand, total nitrogen, total phosphorus,
      and chlorine in Tess Corners Creek.  In addition,
      Table 16 of the revised Appendix indicates that the
      concentration of total ammonia-nitrogen would be
      reduced upon abandonment of the plant.

590.  The water quality discussion in Chapter 5 has been
      revised to reflect the benefits of the elimination of
      malfunctioning septic systems.

591.  The corrections using SEWRPC data from the 1/12/81 K.
      Bauer letter were made to this section.  All resultant
      changes have been noted in the EIS Errata.

592.  This is a typographical error.  The correct value is
      "50.9".  The correction has been incorporated into the
      text.

593.  The additional analysis concerning relocation of the
      Jones Island WWTP outfall is in Section 4.1.1 of the
      revised Appendix VII, Water Quality.  Discussion of
      the impacts of increased ammonia discharge from the
      Jones Island WWTP is set forth in Section 4.1.2 of the
      revised Water Quality Appendix.

594.  Groundwater impact analysis of the deep tunnel and
      cavern system proposed by the MMSD has been considerably
      expanded in the Final EIS.  This additional analysis
      may be found in the Combined Sewer Overflow Appendix
      Addendum (in Volume 3 of this document) and in Chapters
      3 and 5 of the Final EIS.

595.  This sentence has been revised in the Final EIS.

596.  The discussion of wetlands in the section cited refers
      to possible disturbance of the wetland during the
      construction of a new pump station.  The only wetlands
      which are directly affected by discharge from the
      Muskego Northwest WWTP are the wetlands which surround
      Big Muskego Lake.  Discussion of effects of WWTP
      discharge to Big Muskego Lake is set forth in Section
      3.3.1 of the revised Appendix VII, Water Quality.

597.  While it is true that construction of the interceptors
      will accomplish all of the benefits you mention, the
      intent of this paragraph is to explain the effects
      of the interceptors on the development patterns outlined
      in the Year 2000 Land Use Plan.
                             3-103

-------
598.  Correction noted in Final EIS,  Chapter 5.

599.  A discussion of the benefits of eliminating malfunction-
      ing septic tanks is included in the Final EIS,  Chapter
      5.
                              3-104

-------
600.   Comment noted.   It was determined that available data
      did not warrant more conclusive statements than those
      given in the text.  EPA and DNR acknowledge the benefits
      of pollution abatement upon Southeastern Wisconsin
      recreational activities, however the degree of improve-
      ment is difficult to assess in quantitative terms.

601.   The Sludge Management Facilities Plan and the EIS do
      parallel each other, and criteria used to analyze
      alternatives did change from phase to phase.   However,
      these are not reasons to doubt the validity of the
      results of either report.  During each phase of the
      Facilities Plan analysis, the EPA, DNR, and EIS consul-
      tant reviewed all criteria and conclusions.  In each
      phase, analysis criteria were kept constant for all
      alternatives in order to produce valid relative rankings.
      Exchanges of information between the EIS and Facilities
      Planning Consultants were made on a regular basis
      during each analysis phase to refine criteria and
      assumptions and to insure consistancy between the two
      work efforts.  Due to this system of continuous analysis
      and review, the conclusions of both the EIS and Facilities
      Planning consultant were in total agreement through
      phase I and II.

      With regard to SEWRPC's specific comment, "... it
      appears that the low cost benchmark alternative which
      was the basis for an early screening, did not survive
      screening to the final evaluations to be considered
      feasible," the least cost alternatives in phase I were
      J16 and S12 based on cost per ton of sludge processed.
      These alternatives were carried through all phases of
      the analyses.

602.   The MFP described both the existing DNR and 208 Plan
      recommended water use objectives and supporting water
      quality standards.  The Wastewater System Plan Environmental
      Assessment determined the effects of wastewater treatment
      plant (WWTP) discharges under all flow conditions,
      which is consistent with the 208 Plan approach.  In
      addition, dissolved oxygen impacts were determined
      during low stream flow  (Q_, 10) conditions, which is
      consistent with the DNR approach for evaluating dissolved
      oxygen impacts.  However, only the 208 Plan recommended
      standards were used by the MMSD to evaluate the impacts
      to water quality of the various system-level alternatives.
      As stated on page 4 of the MMSD Summary Support Data
      File Environmental Assessment, Volume 2, August 1980,
      "The MMSD decided that the most appropriate water
      quality objectives to use in the MWPAP planning process
      were those consistent with the most likely future

                              3-105

-------
603. Comment noted.  Clarification has been made in the
     Errata section of the Addendum to the Local Alternatives
     Appendix.

604. The eight marshes mentioned in the EIS were identified
     by the MMSD.  The marshes are Wayne Marsh, Jackson
     Marsh, Cedarburg Bay, Vernon Marsh, Wind Lake Marsh,
     and Forest Hill Marsh.

605. Comment noted.

606. Based on preliminary planning figures developed by the
     MMSD, it appears that these two alternatives could be
     mutually exclusive.  The tentative land application
     site in Vernon has an area of 185 acres (Wastewater
     Systems Plan Planning Report Chapter 8).  The require-
     ments for infiltration/percolation systems for the
     Muskego Alternative B WWTP and the Regal Manors WWTP
     are 115 and 80 acres, respectively, or a total of 195
     acres.  Because these area requirements include buffer
     zones, it is possible that the total acreage requirements
     of the two systems could be reduced by sharing buffer
     zones.  Additionally, the system layouts could be
     modified.   If these two modifications were not possible,
     there is a 307-acre site located west of County Road F
     which could be used for the Regal Manors land application
     system.  That site was evaluated for land application
     of wastewater from the Muskego Northwest and New Berlin
     Southeast WWTPs.  Neither of these alternatives would
     be built if the Muskego Alternative B and Regal Manors
     land application WWTPs were built. Therefore, this land
     would be available.

607. Comment noted.

608. This issue is further evaluated in the Local Alternatives
     Appendix Addendum.

609. This issue has been further clarified in the Errata
     section of the Local Alternatives Appendix Addendum.

610. Clarification of this point has been made in the Errata
     Section of Addendum to Appendix V.

611. Clarification of this point has been made in the Errata
     Section of Addendum to Appendix V.

612. Clarification of this point has been made in the Errata
     Section of the Addendum to Appendix V.

613. Comment noted.


                              3-106

-------
614.  Comment noted.

615.  Comment noted.

616.  A complete annotation of this table can be found in
      the Table 1 which follows. The original footnotes were
      abridged in the interest of clarity and space in the
      text.

617.  The deposition of pollutants into the bottom sediments
      is described in more detail in the Errata Section of
      the Addendum to Appendix V, Combined Sewer Overflow
      Cpage 5-22, for the Outer Harbor only, and to page 5-
      29, for both the Inner Harbor and the Outer Harbor).

618.  In addition to metals, the impacts of hazardous substances
      in sediments are discussed in Section 5.1.5.2.1,
      Sediment Quality of Appendix V.  This section discusses
      sediment oxygen demand, methylation of mercury and
      lead and anaerobic decomposition.  Existing total
      phosphorus, sediment and chemical oxygen demand,
      organic nitrogen, ammonia, lead, cadmium, copper,
      zinc, and PCB concentrations in the sediments are
      discussed in section 3.2.5 of Appendix V.  EPA priority
      pollutants, some of which may pollute sediments, are
      discussed in Section 4.5 of the revised Appendix VII,
      Water Quality.

619.  The sentence is revised as follows:  "Based on sediment
      loadings of biochemical oxygen demand presented in
      Table 5-8, about 80% of the organic pollutants in the
      Inner Harbor sediments are contributed by combined
      sewer overflows under existing conditions.  Under
      future CSO abatement alternatives, the contributions
      of the total organic load, from the CSSA to the sediments
      would decrease by between 76% and 82% when compared to
      the total organic load contributed from the CSSA under
      the No Action alternative . "

620.  This phrase has been corrected in the Errata Section
      of the Addendum to Appendix V.

621.  The sentence is revised in the Errata Section of the
      Addendum to Appendix V.

622.  The impact of scouring on sediment oxygen demand (SOD)
      is quantified below in a table from Meinholz et al.,
      (1979a).  Under future alternative conditions, existing
      data and analytical techniques allow only the relative
      assessment of water quality impacts due to scouring.
                             3-107

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