APRIL, 1981
EIS810463F
       BOX 7921
      'IRONMENTAL PROTECTION AGENCY
      SORN • CHICAGO, II 60604 • WATER DIVISION

	'ARTMENT OF NATURAL RESOURCES
MADISON, Wl 53707 • BUREAU OF ENVIRONMENTAL IMPACT
       Environmental            Final
       Impact Statement   Executive Summary

       Milwaukee
       Water Pollution
       Abatement Program

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                        EPA-5-WI-MILWAUKEE-WWTP/INT
                     FINAL ENVIRONMENTAL IMPACT STATEMENT

                   MILWAUKEE METROPOLITAN SEWERAGE DISTRICT
                       WATER POLLUTION ABATEMENT PROGRAM
                             Prepared  by the



              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


                                REGION V


                           CHICAGO,  ILLINOIS

                                  and


                WISCONSIN  DEPARTMENT  OF NATURAL RESOURCES


                            MADISON,.WISCONSIN


                         with the assistance of


                 ESEI - ECOLSCIENCES  ENVIRONMENTAL GROUP


                            MILWAUKEE, WISCONSIN
                                APRIL 1981

SUBMITTED BY:
TOWARD S. DRUCKENMILLER
DIRECTOR
BUREAU OF ENVIRONMENTAL IMPACT
DEPARTMENT OF NATURAL RESOURCES
VALDAS V. ADAMKUS
ACTING REGIONAL ADMINISTRATOR
ENVIRONMENTAL PROTECTION AGENCY

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North Milwaukee  Library
3310 West  VII lard  Avenue
Milwaukee, Wl   53209

Oklahoma Library
350! West Oklahoma Avenue
Milwaukee, Wl   53215

Tippecanoe Library
3912 South Howe I I  Avenue
Milwaukee, Wl   53207

Oak Creek Publ ic Library
3620 South Howe!I Avenue
Oak Creek, Wl   53154

Shorewood Public Library
2030 East Shorewood Blvd.
Shorewood, WI   53211

Wauwatosa Publ ic Library
7635 West North Avenue
Wauwatosa, Wl   53213

West A!I is Publ ic Library
1508 South 75th St.
West AlI is, Wl  53214

Whitefish Bay  Library
5420 North Mar I borough Drive
Whitefish Bay, Wl  53217

MATC North CAmpus
5555 West Highland Road
Mequon, Wl  53092

Brown Deer PublIc Library
5600 West Bradley Rd.
Brown Deer, Wl  53233

Greendale Public Library
5666 Broad Street
Greendale, Wl  53129

Hales Corners Public Library
5335 South 107th St.
Hales Corners, Wl  53130

Milwaukee  Public Library
814 West Wisconsin Avenue
Milwaukee, Wl  53233

Atkinson Library
I960 W. Atkinson Avenue
Milwaukee, Wl  53209
 East Library
 1910 E.  North  Avenue
 Milwaukee, Wl   53205

 Finney  Library
 4243 West North  Avenue
 Milwaukee, Wl   53208

 Forest  Home Library
 1432 West Forest Home Avenue
 Milwaukee, Wl   53204

 LI ewe 11yn Library
 907 East RusselI  Avenue
 Milwaukee, Wl   53207

 Mil I  Road Library
 6431  North 76th  St.
 Milwaukee, Wl   53225

 MATC South Campus
 6665 South Howe I I Avenue
 Oak Creek, Wl   53154

Marquette University Library
 1415 West Wisconsin Avenue
 Milwaukee, Wl   53233

 Milwaukee School of Engineering
 1025 North Milwaukee Street
Milwaukee, Wl   53201
           New Berl in Publ ic Library
           14750 West Cleveland Avenue
           New Berl In, Wl  53150

           Capital Library
           7413 W. Capitol Dr.
           Miwalukee, Wl  53216
Martin Luther
310 W. Locust
Milwaukee, Wl
                         King Library
                         Avenue
                          53212
           Cudahy Memorial Library
           4665 S. Packard Avenue
           Cudahy, Wl  531 10

           South Mil waukee Publ ic
           Library
           1907 Tenth Avenue
           South Milwaukee, W! -53172

           Center Library
           2620 W. Center St.
           Milwaukee, Wl  53206

           Butler Publ ic Library
           12621 W. Hampton Avenue
           Butler, Wl  53007
Citizens Governmental
125 East Wei!s Street
Milwaukee, Wl  53202
Research Library
Legislative Reference Bureau Library
200 East Wei Is Street
Milwaukee, Wl  53202

Brookfield Public Library
1900 Calhoun Road
Brookfield, Wl  53005
Elm Grove Public Library
13600 WEst Juneau Blvd.
Elm Grove, Wl  53122

Maude Shunk Public Library
P. 0. Box 347
Menomonee Falls, Wi  53051

Muskego Public Library
WI82 S8200 Racine Avenue
Muskego, Wi  53150
           Duerrwaechter Memorial
           Library
           W 162 N I 1810 Park Ave.
           Germantown, Wl  53022

           Franklin Public Library
           9229 W. Loomis Avenue
           Franklin,  WI  53132

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    CHAPTER 1




EXECUTIVE SUMMARY

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CHAPTER 1 - EXECUTIVE SUMMARY

1.1  INTRODUCTION

This Final Environmental Impact Statement (FEIS) addresses
the Master Facilities Plan  (MFP) proposed by the Milwaukee
Metropolitan Sewerage District  (MMSD) for the sewerage
facilities within its planning area  (Figure 1.1).  The MMSD
must meet the effluent limits established by the United
States Environmental Protection Agency  (EPA) and the
Wisconsin Department of Natural Resources (DNR), and must
also comply with two court orders. The orders require the
MMSD to implement the following:

     Discharges of raw or inadequately treated wastewater to
     area waters must be eliminated

     Wastewater treatment plants must be improved to meet
     effluent limits so that receiving waters meet water
     quality goals

     The solids removed from the wastewater must be disposed
     of in an acceptable way.

These goals must be achieved within a court established
schedule.

To reduce the local costs of correcting its water pollution
problems, the MMSD applied to the EPA for federal grant
assistance under Section 201 of the Clean Water Act of 1977.
The provisions of this Act require that facilities must be
designed to incorporate the most economical means of meeting
established water quality goals while recognizing environmental
and social considerations.  The National Environmental
Policy Act of 1969 (NEPA) requires that an EIS must be
prepared for major federal actions which could significantly
affect the natural and man-made environments.  Approval of
the MFP has been determined to be such a major federal
action.

The DNR must also approve many aspects of the MFP.  The MMSD
has requested state grant funding for parts of the MFP.
Because of this state involvement, the Wisconsin Environmental
Policy Act (WEPA) requires the preparation of an EIS.

An EIS analyzes the proposed action, reasonable alternatives,
and their anticipated effects upon the environment.  To
minimize the duplication of efforts, this Final EIS was pre-
pared as a joint EPA/DNR document.
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The public is invited to comment on this Final EIS.  Comments
will be received from the date of its release through May
17, 1981.  As required by state law, a public hearing on the
Final EIS will be held in Milwaukee in May of 1981 to provide
a forum for public comment.  The comments and concerns
expressed by citizens, EPA and DNR will be used to develop a
Record of Decision for the MFP.  The Record of Decision will
set forth the EPA and DNR decision to approve, conditionally
approve, or disapprove the MFP.

1.1.1  The Problem

For the most part, the sewers in the MMSD service area are
adequate for conveying domestic and industrial wastewater.
The problem is the entry of groundwater (infiltration) and
storm runoff (inflow) through cracked or broken sewer pipes,
leaking manhole covers, faulty sewer connections, illegal
connections of sumps and tile drains, and other sources.
Infiltration and inflow (I/I) can greatly increase the flows
in the sewerage system resulting in bypasses and overflows
to area rivers and Lake Michigan.

During wet weather, the volume of wastewater and its rate of
entry into the sewerage system in the MMSD service area
often exceeds the sewers'  capacity to transport wastewater
to the treatment plants.  As a result, in a year of average
rainfall, 6.4 billion gallons of storm water and untreated
sewage overflow into area waters.  In addition, wastewater
flows to the area's treatment plants exceed their capacity,
resulting in violations of DNR effluent limitations.

There are two types of sewer systems conveying wastewater in
the MMSD planning area.  About 6% of the sewers in Milwaukee
County, serving approximately 47% of its population, are
combined sewers.  They were designed to transport the storm
runoff entering the system through roof leaders, street
drains, and other connections, as well as industrial and
domestic wastes.  To prevent sewer backups, the Metropolitan
Interceptor Sewer  (MIS) system is designed to allow untreated
wastewater from the combined sewers to overflow into surface
waters when the capacity of the MIS is exceeded.

Separated sewers serve other portions of the MMSD service
area.  With this type of system, storm water is collected in
one set of pipes and conveyed directly to the waterways.
Domestic and industrial wastewater is conveyed separately to
treatment facilities.  Ideally, the flows in the sanitary
sewers should not be affected by rainfall and infiltration
of groundwater.  However, some parts of the sanitary sewer
system have deteriorated, allowing storm water and groundwater
to seep into the sewers and manholes.  In many buildings,
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                                                                                           LEGEND
                                                                                        STUDY AREA BOUNDARY


                                                                                        COUNTY tINE



                                                                                        CORPO»ATE BOUNDARIES



                                                                                        WATER SIVERS, CREEKS, ETC



                                                                                        MAJOR HIGHWAYS




                                                                                      j  JONES ISLAND SERVICE AREA




                                                                                    ll  SOUTH SHORE SERVICE AREA




                                                                                        SOUTH MILWAUKEE SERVICE AREA



                                                                                  L— ™ 1  AREA WHICH CAN BE SERVED BY

                                                                                  ___ J  EITHER SOUTH SHORE OR JONES ISLAND
FIGURE


      l-l

DATE



 APRIL  1981
MMSD   SERVICE    AREA

AND   PLANNING    AREA
PREPARED  BY
                                                           SOURCE  MMSD
                                                                   EcolSciences
                                                                   ENVIRONMENTAL GROUP

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drains or sumps have been illegally connected to the sanitary
sewer.  As a result, I/I does enter the sanitary sewers.  To
prevent the backup of sewage into basements, sanitary sewers
are also equipped with flow relief devices which discharge
untreated sewage mixed with I/I into the area waterways.

In addition to causing combined sewer overflows and bypasses
from the separated sewers, excessively high flows impair the
operation of a wastewater treatment plant  (WWTP).  If the
flow to the Jones Island and South Shore plants exceeds
their capacity, wastewater must either be bypassed before
treatment or after partial treatment.  At Jones Island, the
preliminary treatment and solids handling facilities are
inadequate to handle flows greater than 140 million gallons
per day (MGD)  (6.1 m3/sec.).  The preliminary and primary
treatment facilities at South Shore can handle peak capacities
of 320 MGD (14 m-Vsec.).  Secondary facilities bypass waste-
water at flows over 240 MGD  (10.5 m3/sec.).

There are other sources of pollution to the waters of the
area.  Urban and rural runoff contains organic matter,
pesticides and heavy metals.  As part of their Water Quality
Management (208) Plan, the Southeastern Wisconsin Regional
Planning Commission (SEWRPC) has recommended that pollutant
loadings from non-point sources (urban and agricultural
runoff) be reduced by a minimum of 25%.  SEWRPC has designated
each community within the MMSD planning area responsible for
implementing the urban non-point source control measures to
achieve this reduction of runoff pollution by 25%.

Combined sewer overflows, bypasses from the separated sewers,
and non-point source loadings have resulted in the introduction
and accumulation of pollutants and disease-producing organisms
(pathogens) into area waters.  Water quality in the MMSD
service area is degraded by nutrients that stimulate plant
growth and by organic pollutants which deplete the level of
oxygen in the water.  A potential health hazard is created
by the pathogens and toxic substances including heavy metals.

1.1.2  Master Facilities Plan

The preparation of the Master Facilities Plan, which is also
referred to in this EIS as the Milwaukee Water Pollution
Abatement Program (MWPAP), has been required by state and
federal legislation and by two court cases.  The Federal
Water Pollution Control Act Amendments of 1972 and the Clean
Water Act of 1977 establish national water quality goals.
Patterned after the federal legislation, Chapter 147 of the
Wisconsin Statutes establishes the same goals.  The Clean Water
Act and Chapter 147 mandate the achievement by 1983 of fishable
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and swimmable levels of water quality in the waters of the
Nation and State.  Chapter 144 of the Wisconsin Statutes
requires the planning and approval of wastewater treatment
facilities designed to achieve these water quality standards.

In addition to federal and state guidelines, preparation of
the MFP has been governed by two court orders.  In December
1974, the MMSD challenged DNR effluent limitations for the
Jones Island and South Shore treatment plants.  In response,
the DNR initiated a counter suit.  These actions resulted in
a stipulation in the Dane County Circuit Court setting a
schedule of compliance for the MMSD.  The following deadlines
were established:

1.   Improvements to Jones Island and South Shore WWTPs must
     be completed by July 1, 1982

2.   The solids management program at the two WWTPs must be
     in operation by July 1, 1982

3.   All dry weather overflows and bypasses must be eliminated
     by July 1, 1982.

4.   All wet weather bypasses from the separated sewers must
     be eliminated by July 1, 1986

5.   The combined sewer overflow (CSO) problem must be
     corrected, and applicable water quality standards must
     be met by July 1, 1993.

In 1971, the States of Michigan and Illinois charged that
the MMSD and the City of Milwaukee were endangering the
public health by improper wastewater disposal.  The case was
heard in the United States District Court for the Northern
District of Illinois, and that court's decision was appealed
to the United States Seventh Circuit Court of Appeals.  The
result of these proceedings was the Court's reaffirmation of
the EPA and DNR effluent limitations, and the requirements
that all dry and wet weather bypasses from separated sewers
be eliminated by July 1, 1986 and that combined sewer overflows
cease by December 31, 1989.  The MMSD and the City of Milwaukee
have appealed the scope and schedule of the CSO abatement
project to the United States Supreme Court.  It is expected
that a decision will be rendered by the middle of 1981.

The MFP is a complex set of programs devised to comply with
federal and state legislation and the two court orders. The
requirements applicable to the plan include the following:

1.   Detailed evaluation of different approaches to wastewater
     treatment for the MMSD planning area shown in Figure
     1.1

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2.   Reduction of infiltration and inflow (I/I) by the
     rehabilitation of the sewer system.  A sewer system
     evaluation survey (SSES) is now being completed.
     The SSES provides detailed information about the
     sources of I/I and the costs of reducing these sources.
     The SSES is used to determine the level of I/I removal
     which will minimize the total cost of conveying and
     treating I/I

3.   Evaluation of alignments of interceptor sewer exten-
     sions to serve the areas designated in the Regional
     Land Use Plan

4.   Evaluation of methods to expand and rehabilitate the
     Jones Island and South Shore wastewater treatment
     plants

5.   Development of a total solids management program to
     determine methods to process and dispose of the solids
     removed from the wastewater

6.   Abatement of combined sewer overflows  (CSO) by the date
     established by the U. S. Supreme Court.

Numerous alternatives were developed for each component
project of the MFP.  In this summary, only those alternatives
found to be the most feasible will be discussed.

1.1.3  MMSD Recommended Plan and Feasible Alternatives

As part of the preparation and adoption of the Master Facilities
Plan, the MMSD, as required by federal and state regulations,
recommended alternatives for each major planning element.
These major elements are as follows:

1.   CSO Abatement and Peak Flow Attenuation

2.   Wastewater Treatment

3.   Solids Handling

4.   Wastewater conveyance.

1.1.3.1  CSO Abatement and Peak Flow Attenuation

The  I/I  study estimated that a 50% reduction of I/I would
be less expensive than expanding area wastewater treatment
facilities to treat the peak volume of I/I and wastewater.
However, even with this reduction, wet weather flows to the
wastewater treatment plants  (WWTPs) would exceed their
capacity.  Because the court orders require the elimination
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of all separated sewer bypasses, all flows tributary to this
system would require treatment. Since the peak flows would
exceed the capacity of the WWTPs, some storage would be
needed for wastewater volumes in excess of treatment plant
capacity.  The stored wastewater would be pumped to the
WWTPs when treatment capacity became available.

It was apparent that the facilities for storing excess flows
from the separated sewer service area could also be used to
abate CSO.  Therefore, the MMSD evaluated joint-use facilities.
The alternatives considered to be the most feasible for this
joint purpose are described in Table 1.1.  The MMSD recommends
the Inline Storage Alternative.

1.1.3.2  Wastewater Treatment

There are nine public wastewater treatment facilities in the
MMSD planning area.  Approximately 95% of the dry weather
wastewater flow in the planning area is tributary to the
Jones Island and South Shore WWTPs.  The remaining dry
weather flow is treated at public WWTPs in Thiensville,
Germantown, New Berlin, Muskego  (2 WWTPs), South Milwaukee,
and the Caddy Vista subdivision in Caledonia.

Three organizational strategies were used to evaluate waste-
water treatment for the MMSD planning area.  These strategies,
or system-levels, are described below:

1.    The Local System-Level;  The present localized approach
      to areawide wastewater treatment would continue.  The
      Jones Island and South Shore WWTPs would serve Milwaukee
      County and some communities outside the County (contract
      communities).  Other communities would operate their
      own wastewater treatment facilities.

2.    The Subregional System-Level;  The Milwaukee area would
      be divided into three smaller subregions. Each subregion
      would be responsible for operating its own wastewater
      treatment facilities.  The Subregional System-Level
      Alternatives were eliminated from consideration because
      of cost and impacts on water quality.

3.    The Regional System-Level;  The MMSD would be responsible
      for treating all wastewater flows in the planning area.
      The flows would be treated at one or more WWTPs.

Strategies for CSO abatement were evaluated independently of
the development of wastewater treatment strategies.  The
alternative considered to be the most feasible for each
public wastewater treatment facility in the planning area is
shown in Table 1.2.
                              1-6

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                           TABLE 1.1
                FACILITIES FOR CSO ABATEMENT AND
                     PEAK FLOW ATTENUATION
Remote    •     Complete sewer separation in 11%  of  the
Storage        CSSA.  No work on private property.
               Partial sewer separation* in 18%  of  the
               Combined Sewer Service Area (CSSA) .
               757 acre-feet of storage provided for excess
               flows at a cavern storage site near  58th
               and State Streets.
               Complete separation in 48% of CSSA;  excess
               flows tributary to 236 acre-feet  of
               near-surface storage.
               Excess flows from separated sewers stored
               at the storage cavern  at 58th and State
               Streets.

Jones     •     Complete separation in 11% of the CSSA.
Island         No private property work required.
Storage   •     Complete separation in 48% of the CSSA with
               necessary private property work.
               Partial sewer separation in 41% of the
               CSSA.  Excess flow stored in 437  acre-feet
               of near-surface storage.
               Excess flows from the  separated sewers
               stored in a 550 acre-feet cavern  near the
               Jones Island treatment plant.

CST       •     Complete sewer separation in 11%  of  the  CSSA.
Extension      No private property work.
               Partial sewer separation in 21% of the CSSA.
               Excess flows tributary to 235 acre-feet  of
               near-surface storage.
               No sewer separation in 68% of the CSSA.
               Excess flows tributary to 30-foot tunnels
               in bedrock and 1,334 acre-feet of cavern
               storage near Jones Island.
               Excess flow from separated sewers tributary
               to 30-foot diameter tunnels and cavern storage.

Inline    •     Complete separation in 11% of the CSSA.   No
Storage        private property work.
               Partial separation in  68% of the  CSSA.  Excess
               flows tributary to 20-foot diameter  tunnels
               in bedrock and 767 acre-feet of cavern storage
               near Milwaukee County  stadium.
          •     Partial separation in  21% of the  CSSA with
               235 acre-feet of near-surface storage.
          •     Excess flow from the separated sewers
               tributary to 20-foot diameter tunnels and
               cavern storage facility.

*Partial Separation - New pipes would be constructed to convey
storm water from street drains directly to a waterway.
Sewage and storm water from drains on private property
(e.g., roof leaders) would be combined and conveyed to  a
treatment facility.
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                          TABLE 1. 2
Jones
Island
South
Shore
Caddy Vista
Subdivision
Germantown
Muskego
Northeast
Muskego
Northwest
New Berlin
Regal
Manors
 MMSD RECOMMENDATIONS FOR WASTEWATER
TREATMENT PLANTS (LOCAL ALTERNATIVES)

 ,  Expand treatment capacity to 300 million
    gallons per day.
    Wastewater Treatment by Secondary  Activated
    Sludge Process.
    Disinfection by chlorination.
    Site expansion by filling in 9.5 acres of
    Lake Michigan and using approximately 9
    acres of Harbor Commission land.

    Expansion of South Shore to 250 million
    gallons per day.
    Wastewater Treatment by Secondary  Activated
    Sludge Process.
    Disinfection by chlorination.
    Site expansion by enclosing 30 acres of
    Lake Michigan.  At this time, 12 acres
    would be filled in.  The remaining 18 acres
    would be filled as needed.

    Existing facility would be demolished.
    An advanced wastewater treatment plant
    would be constructed on the site.
    Effluent would be discharged at the Root
    River.

    Abandon existing facilities.
    A new land application facility will be
    constructed on the site.

    Abandon existing facility wastewater flows
    would be pumped to Vernon, Wisconsin, treated
    in aerated lagoons and discharged  to infil-
    tration-percolation ponds.

    Facility would be abandoned.  Wastewater
    flows would be combined with flows from
    Muskego Northeast and treated at the Vernon
    site.

    New aerated lagoon facility built  at a
    site at Sunny Slope and Grange Streets.
    Effluent transported to infiltration-perco-
    lation site in Vernon.
South
Milwaukee
Thiensville
    No expansion.
    Operation and maintenance procedures would
    be improved.

    Expand wastewater treatment capacity.
    Treatment by existing processes.
    Discharge of erfluent to the Milwaukee River
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For the Local System-Level, all the WWTPs listed in the
table would be in operation.  For the Regional Alternative,
only the Jones Island and South Shore facilities would
continue operating.  The No Action Alternative (continuing
the present sewerage system with no improvements) was also
considered for comparison.

The MMSD's Recommended Alternative (referred to as the
Mosaic Alternative in this EIS) combines aspects of the
Local and Regional System-Levels. With the Mosaic Alternative,
the Jones Island and South Shore treatment facilities would
serve the entire planning area, except for South Milwaukee
which would operate its own facility.  All other public
WWTPs would be abandoned.  The MMSD recommends that two
private wastewater treatment plants,  School Sisters of Notre
Dame and Wisconsin Electric Power Company also continue
operations/ and that the Muskego Rendering Company operate
its own facilities for pretreatment of effluent before
discharge to the local sewer system.

1.1.3.3  Solids Handling

Closely related to the issue of expanding the Jones Island
and South Shore WWTPs is the problem of disposing of the
solids removed from the wastewater during treatment.  Most
of the solids from the Jones Island WWTP are now processed
into the fertilizer Milorganite  (about 70,000 tons per
year). Any solids in excess of the capacity of the Milorganite
process are landfilled (approximately 3,400 tons per year).

For most of the year, the solids from the South Shore WWTP
(approximately 33,500 tons) are applied to agricultural
land. However, after the growing season, when the ground is
frozen, the sludge must be landfilled (about 10,500 tons per
year).

The MMSD considered alternatives including landfill, land
application, incineration, and composting for disposal of
the solids from the two WWTPs.  For the Jones Island WWTP,
the MMSD proposes abandoning the production of Milorganite
because it is energy intensive and contributes to air pollution
in the Milwaukee area.  (Milorganite production has been
responsible for about 6% of Milwaukee County's annual input
of particulates to the air.)  Instead, landfilling of all
solids was recommended.  For the South Shore WWTP, land
application was recommended.  Solids from the South Shore
plant would be stored during the winter for land application
over the growing season.
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The MMSD is currently preparing a facilities plan which will
identify specific sites for solids disposal.  A supplemental
EIS on this facilities plan will be prepared by the EPA and
DNR.  The supplemental EIS will give special consideration
to the impacts of site specific alternatives on the natural
and man-made environments.  It is currently anticipated that
the Site Specific EIS supplement on agricultural spreading
and landfill will be completed in mid-1984.

1.1.3.4  Wastewater Conveyance

The MFP evaluates alternatives for conveyance of wastewater
to WWTPs from communities and areas served by MMSD.  The
particular facilities and their configurations vary under
each system-level alternative, and they are listed in Table
1.3.  The facilities are the following interceptors:  Franklin
Northeast, Underwood Creek, Root River, Hales Corners,
Franklin-Muskego, Oak Creek North, and Menomonee Falls-
German town .

1.2  THE DRAFT EIS

1.2.1  EIS Alternatives

1.2.1.1  CSO Abatement and Peak Flow Attenuation

There are many controversial aspects to the Inline Storage
alternative for abating CSO and attenuating peak flows.  The
partial and complete separation of sewers in the entire
combined sewer service area (CSSA) would disrupt traffic and
business. With partial and complete separation, urban runoff
which contains organic pollutants and heavy metals would
still be discharged into the lower reaches of the Milwaukee,
Menomonee and Kinnickinnic rivers, and instream water quality
standards might not be achieved.  Also, the public has
expressed concern over the potential for temporary and long-
term impacts to groundwater from cavern storage facilities.
In response to those concerns, the EIS has evaluated three
other alternatives for CSO abatement and peak flow attenuation.
These alternatives are described in Table 1.4.

                         TABLE 1.4

             EIS ALTERNATIVES FOR CSO ABATEMENT
                 AND PEAK FLOW ATTENUATION

Complete       •  All combined sewers completed separated
Sewer          •  Excess flow from the separated sewers
Separation        would be stored in 20-foot diameter tunnels
                  prior to transport to the WWTPs for treatment
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Local
Alternative
             TABLE 1.3
   INTERCEPTORS ASSOCIATED WITH
DIFFERENT SYSTEM-LEVEL ALTERNATIVES

   Northeast Side Relief System
   Underwood Creek
   Root River (Short Route)
   Franklin Northeast
   Oak Creek North
   Franklin-Muskego (Franklin branch only)
Regional
Alternative
   Northeast Side Relief System
   Underwood Creek
   Root River
   Hales Corners
   Franklin-Muskego
   Franklin Northeast
   Oak Creek North
   Menomonee Falls-Germantown
Mosaic
Alternative
 (MMSD's
Preferred
Alternative)
   Northeast Side Relief System
   Underwood Creek
   Root River
   Hales Corners
   Franklin-Muskego
   Franklin Northeast
   Oak Creek North
   Menomonee Falls-Germantown
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Modified       •  Complete sewer separation in 11% of the
GST/              CSSA.   Private property work required.
Inline         •  Partial sewer separation in 21% of the
                  CSSA.  Excess flows in the sanitary sewers
                  stored in 235 acre-feet-^- of near-surface
                  storage.
                  No sewer separation in 68% of the CSSA.
                  Excess flow tributary to 30-foot diameter
                  tunnels in bedrock and 1291 acre-feet of
                  cavern storage at Milwaukee County Stadium.
                  174 acre foot storage cavern at the Jones
                  Island WWTP.

Modified       •  Complete separation in 11% of the CSSA.
Total             No private property work.
Storage        •  No sewer separation in the remaining portions
                  of the CSSA.  The flows from 68% of the
                  CSSA would be tributary to 30-foot tunnels
                  in bedrock and 1291 acre-feet of cavern storage
                  at Jones Island.
                  Flows from the remaining 21% tributary to
                  715 acre-feet of near surface storage.

^Acre-foot - "The volume that would cover one acre to the depth
 of 1 foot."   (Webster's New Collegiate Dictionary, Springfield,
 MA; G & C Merriam Company, 1977.)
The costs of the alternatives for the abatement of CSO and
the attenuation of peak flows are shown in Table 1.5.

                         TABLE 1.5
   COSTS  (IN $ MILLIONS) OF CSO/PEAK FLOW ALTERNATIVES
Alternative
Capital Costs
Inline Storage        $1658.53
Complete Separation     1688.45
Modified CST/Inline     1664.98
Modified Total Storage  1682.56
Operation
   and
Maintenance

$ 27.01
  26.83
  27.97
  28.48
Net*
Present
Worth

$ 1899.86
  1968.22
  1931.50
  1956.44
*Net Present Worth includes the construction and materials
costs, financing costs and operating costs through the year
2005.

The cost estimates for these alternatives are within the margin
of error for the methods used in their calculation and are
therefore considered equivalent.  Thus, the decision to implement
one of the alternatives will be based on factors other than cost.
                              1-12

-------
1.2.2  Environmental Consequences

1.2.2.1  No Action Alternative

The alternatives considered in the MFP and EIS are complex
solutions for a number of problem areas which overlap to
varying degrees.  Several wastewater treatment plants in the
MMSD planning area cannot treat the flows they receive ade-
quately to meet the effluent limits imposed by their discharge
permits.  In many areas, these sewers and WWTPs are receiving
volumes of wastewater in excess of their capacities.  Deter-
iorating sewers and manholes, illegal connections of drains
and sumps, and in the case of combined sewers, connection with
the storm drainage system, all contribute to the problem of
overloaded sewers and treatment plants.

The results of this overloading include bypassing at the WWTPs,
bypassing from separated sewers, and overflows from combined
sewers.  These bypasses and overflows discharge raw or in-
adequately treated wastewater to area waterways.  These inputs
introduce disease-causing pathogens and toxic substances into
the waters of the planning area, degrading water quality.
These substances also impair plant and animal life, endanger
the public health, and limit the potential uses of the area
waters.

The failure of wastewater treatment systems to meet effluent
limitations and court-ordered clean-up deadlines in the case
of MMSD, could result in legal penalties including fines for
the responsible organizations.

In addition, sewer extensions for new development in all areas
served by the MMSD might be prohibited.  The Dane County Court
Stipulation establishes a wasteload allocation system to
remain in effect until the Jones Island and South Shore
WWTPs consistently comply with EPA and DNR effluent limitations,
The wasteload allocation system restricts the increment by
which annual flows and pollutant loadings to the Jones
Island and South Shore WWTPs may increase. If violations of
effluent limitations continue to occur, no new connections
would be allowed after 1986.

If sewer extensions are prohibited because of violations of
the Dane County Court stipulation, the demand for lots
suitable for septic tank development might increase, possibly
entailing the loss of prime agricultural land or wildlife
habitat.  In most cases, the scattered type of development
that occurs when lots of one acre or more are developed for
single-family residences would not be consistent with the
Regional Land Use Plan.
                               1-13

-------
With the No Action Alternative, the impacts outlined above
could occur.  The action alternatives described in Section 1.1.3
are designed to modify or eliminate the adverse impacts and
maximize the beneficial environmental impacts at the smallest
practicable monetary cost.  The environmental impacts of the
action alternatives are described below.

1.2.2.2  Action Alternatives

All of the action alternatives would share certain components.
In all cases, the sewers in Milwaukee County would be reinforced
and expanded based on the results of the sewer system evaluation
survey.  With any action alternative, the Jones Island WWTP
would be expanded to treat 300 million gallons of wastewater
each day and the South Shore WWTP 250 million gallons each
day.  Also, CSO and bypasses from the separated sewers would
be eliminated.

Because these program components would be the same for any
action alternative, some of the environmental impacts of the
alternatives would be very similar.  The elimination of
bypasses of untreated wastewater into area waters would
reduce the public health hazard from disease-producing
organisms, making the waters more useful for recreation.

With any action alternative, all wastewater treatment facilities
in the planning area would be capable of meeting effluent
limitations in the discharge permits.  As a result, all free-
flowing portions of the rivers of the area should meet the
water quality standards set for them by the DNR if SEWRPC's
nonpoint source control program is implemented.  Pollutant
loadings to the Inner and Outer Harbors would be reduced,
to varying degrees.  However, water quality standards in the
Inner Harbor might not be met because of pollutants accumulated
in the sediments  and pollution originating upstream of the
MMSD service area.

1.2.2.3  CSO Abatement and Peak Flow Attenuation

The four alternatives for CSO abatement/peak flow attenuation
which are considered in the EIS differ in the amount of
construction that would be needed and in the amount of storm
water that would receive treatment.  Figure 1.2 compares
the amount of storage required by these alternatives.  Figure
1.3 compares the percentage of the combined sewer service area
which would be affected by open-cut construction with the four
alternatives.  The alternatives that would treat the most
urban runoff would achieve the most improvement in water
quality because they would decrease total pollutant loads
and cause less disturbance  (via scouring) of sediments in
the receiving waters.

                              1-14

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Any action alternative would improve sediment quality, but
the sediments would remain highly polluted with organic matter
and toxic substances.  Disturbing the sediments (sediment
scour) re-introduces these pollutants into the water.
Levels of dissolved oxygen are lowered as the organic  matter
further decomposes. The Modified Total Storage Alternative
would result in treatment of the greatest percentage of
storm water and would eliminate CSO sediment scour, which is
the mechanism whereby the highly polluted bottom sediments
are resuspended by increased velocities in the vicinities of
CSO outfalls.  The Complete Separation Alternative would
treat the least amount of storm water and increase the
frequency of sediment scour near CSO outfalls.

The percentage of the CSSA that would be affected by each
facility for CSO abatement and peak flow attenuation is
shown in Figure 1.3.  The Complete Separation and Inline
Storage Alternatives would affect the greatest area and
Modified Total Storage the least.  Disruption of commercial
areas would result in a loss of business during construction.
This impact could be lessened by staging construction  activities
so that only a limited number of streets are disturbed at
any one time. Local construction firms are equipped to con-
struct new sanitary and storm sewers required under the
alternatives relying on complete or partial separation.  These
approaches are more labor-intensive than the construction of
large diameter tunnels in bedrock.  As a result, the complete
separation alternative creates the most potential employment
opportunities for the local labor force.  The Modified Total
Storage Alternative creates the least local employment
opportunities.  The use of local construction firms for
sewer separation alternatives would introduce more money
into the local economy than a deep tunnel system that  would
rely on firms from outside the local economy.

Both EPA and DNR, as well as the public, have expressed con-
cern that wastewater could seep out of large-diameter  tunnels
in the bedrock and contaminate deep groundwater; that  ground-
water could infiltrate the tunnels and lower local groundwater
levels; or that both events could occur.  These concerns have
received detailed analysis, which is described further in
Section 1.3.2.

1.2.2.4  Wastewater Treatment

With all action alternatives, the South Shore and Jones
Island WWTPs would be expanded as described in Table 1.1.
The improvements to the WWTPs would require about three
years of construction.  The construction would increase
turbidity and resuspend sediments in Lake Michigan due to
material washed from construction sites.  However, the
implementation of modern construction techniques would
minimize construction-related turbidity.

                              1-15

-------
The MMSD Recommended Alternatives for the expansion of these
WWTPs include lakefills which would remove small portions of
Lake Michigan habitat. This habitat is used for spawning and
feeding by some species of fish.   The construction would
also increase air pollution in Milwaukee County.  The yearly
increases in emissions are expected to be less than one
percent of the annual county-wide totals.

Some residents of the City of South Milwaukee have raised
concerns about the expansion of the South Shore treatment
plant. They have complained about odors from the South Shore
WWTP and feel that the expansion of the facility would
aggravate the problem.  Also, they are concerned that the
expansion would be unsightly and would disrupt the view of
Lake Michigan.  There is concern that, as a result of
these factors, property values near the plant may be affected.
Partially in response to these concerns, the Draft EIS
also evaluates two new alternatives:  one requiring only six
acres of lakefill and another that would require no lakefill
(see South Shore Appendix).

The South Shore WWTP might be more visible after its expansion
and would slightly affect the view of Lake Michigan.  Odors,
however, should be less of a problem than at present.  The
odors are created by inadequately processed solids reaching
the exposed sludge lagoons.  With the rehabilitation and
expansion of the facilities, the solids should be properly
treated and all solids handling processes would be enclosed.
As a result, odor problems should be reduced.

The issue of property value is more difficult to assess.
Records show that, historically,  property values near the
WWTP have not been depressed in comparison to other property
in South Milwaukee.  Therefore, there is no evidence to
indicate that property values would be affected by the
expansion of South Shore.

The MMSD recommended alternatives for the other public
treatment plants are listed in Table 1.2.  Implementation of
these alternatives could require the disruption of traffic
and access and could cause a slight increase in air pollution.
However, these impacts would be moderate and temporary.

The Local, Regional, and the MMSD Recommended System-Level
Alternatives would result in the abandonment of some or all
of the local WWTPs.  The cessation of effluent discharges
would change the character of some streams from permanent to
intermittent.  As a result, the biological communities
present in the affected rivers could change.
                              1-16

-------
Under the various System-Level Alternatives, at most, three
local treatment plants would discharge effluent to waterways
in the MMSD planning area:  Thiensville to the Milwaukee
River, Caddy Vista to the Root River, and South Milwaukee to
Lake Michigan.  Improved effluent from the Thiensville plant
should allow quality standards for that part of the Milwaukee
River to be met.  Bypassing at the Caddy Vista Plant would
be eliminated.  Effluent from the South Milwaukee treatment
plant should not have a large impact on Lake Michigan because
of its presently acceptable quality and relatively small
volume.

Under the various System-Level Alternatives, up to four of
the existing local WWTPs would be converted to treatment of
wastewater by some form of land application. With this type
of treatment, there would be some chance of groundwater
pollution.  This potential would be minimized by the careful
selection of sites with soils acceptable for wastewater
application and by the monitoring of sites.

1.2.2.5  Solids Handling

The MMSD recommends abandoning Milorganite production at the
Jones Island treatment plant because the Milorganite process
is energy intensive and contributes to local air pollution.
Instead, solids from Jones Island would be landfilled.  During
most of the year, the solids from the South Shore WWTP would
be applied to agricultural land.   During the winter months,
the solids would be stored for later agricultural application.

Both of these alternatives would require large amounts of
land.  In a supplemental EIS to be prepared by EPA and DNR,
Site Specific Analysis, the availability of sites and the
environmental impacts of these solids alternatives will be
studied in detail. If the necessary land is not available,
the solids management alternatives may require further
study.

Agricultural land would benefit from the organic matter and
nutrients contained in WWTP solids.  However, the solids
also contain small quantities of toxic substances such as
heavy metals and nitrate, and some public concern has been
voiced about the environmental impacts of these toxic substances,
The soils at solids application sites could retain the heavy
metals in WWTP solids, possibly threatening their future use
for agriculture.  In addition, nitrate, if applied in amounts
greater than can be removed by plant uptake, can contaminate
groundwater and may cause human and animal health problems.
                              1-17

-------
All farmers interested in receiving the solids from the
South Shore WWTP would have to be informed of the proper
management practices and potential hazards of solids
application.  This precaution and the adherence to DNR and
EPA regulations would reduce the potential for soil and
groundwater contamination.  Abandoning the Milorganite
process would reduce particulate emissions in Milwaukee
County by 6% and energy consumption at the WWTP by 57%.
However, abandoning the process would also cause the exist-
ing concentration of ammonia-nitrogen in the Jones Island
WWTP to approximately triple (from 6 mg/1 to 18 mg/1).
Increased levels of ammonia-nitrogen in the Outer Harbor
could be toxic to aquatic life.

Construction of an effluent outfall that would discharge
treated effluent directly into Lake Michigan could alleviate
this problem.  However, pollutant loading to Lake Michigan
would be increased by this action.  The MMSD has performed
a water quality study to determine how this increase in
ammonia would affect the Outer Harbor.  The MMSD also examined
alternatives that would reduce the ammonia in the effluent.
The results of this study are discussed further in Section
1.3.3.

1.2.2.6  Wastewater Conveyance

All the System-Level Alternatives were designed to serve the
same area.  The Local Alternative would include six inter-
ceptors , and the Regional and Mosaic Alternatives would include
eight interceptors.  The direct environmental impacts of these
interceptors would be related to their construction.  Traffic
and access to businesses and residences might be disrupted.
Air quality would be affected by vehicle fumes and dust.  Also,
groundwater levels could be lowered.  The elimination of septic
tanks and overloaded sewer systems should, in the long-term,
reduce groundwater pollution.

All the action alternatives would provide enough sewer
service to accomodate population up to the levels forecast
by the Southeastern Wisconsin Regional Planning Commission.
However, if the population does not grow to planned levels,
the expanded sewer service could encourage a scattered
pattern of development in some areas.  With a scattered
pattern of development, the costs of municipal services
(schools, general administration, and public safety, for
example) in Germantown, New Berlin and Oak Creek could
exceed the revenues from the increased tax base.
                              1-18

-------
1.2.2.7  Cost

The costs for the Final System-Level Alternatives are shown
in Table 1.6.  These costs assume the implementation of the
MMSD's Recommended Alternatives for the rehabilitation and
expansion of the Jones Island and South Shore WWTPs, and for
solids handling.

                       TABLE 1.6

            COSTS OF SYSTEM-LEVEL ALTERNATIVES
             ASSUMING DIFFERENT CSO SOLUTIONS
                      (IN $ MILLIONS)
Local
Regional
Mosaic:
MMSD
Recom-
mended
         CSO
         Component
         Inline Storage
         Complete Separation
         Modified CST/Inline
         Mod. Total Storage
         Inline Storage
         Complete Separation
         Modified CST/Inline
         Mod. Total Storage
Inline Storage
Complete Separation
Modified CST/Inline
Mod. Total Storage
                     Capital   O&M
                 Net
                 Present Worth
$1692.39
1722.31
1698.84
1716.42
$28.48
28.30
29.44
29.95
                                         1950,
                                         2018,
                                         1981,
                                         2006,
                         11
                         47
                         75
                         69
1658.84
1688.76
1665.29
1682.87
26.63
26.45
27.59
28.10
1658.53
1688.45
1664.98
1682.56
27.01
26.83
27.97
28.48
                                         1896.06
                                         1964.42
                                         1927.70
                                         1952.64
1899.86
1968.22
1931.50
1956.44
Current projections of the availability of Federal and State
funds for water pollution abatement projects indicate that a
maximum of approximately thirty-six percent of the MFP costs
would be funded by either the federal or state government.
The remaining portion of the costs would have to be financed
locally, probably by the issuance of municipal bonds.  To
finance the debt service on the bonds, Milwaukee County is
empowered to increase taxes on property within its boundaries.
Communities outside Milwaukee County would be charged annually
according to the existing Contract Formula.  Operation and
maintenance costs would be distributed separately and propor-
tionately by the User Charge System.
                              1-19

-------
Table 1.7 outlines the estimated average annual property tax
rates that would result from the implementation of the final
system-level alternatives.  These costs were determined
assuming that the MMSD would construct all elements of the
alternatives, including rehabilitation and relief work both
inside and outside the County, except that Muskego, South
Milwaukee, Germantown, New Berlin, Caddy Vista, and
Thiensville would construct their own facilities with the
Local Alternative.  For the Local Alternative,  no Federal
funding is assumed for this construction.

Historically, local communities have financed their own
sewer rehabilitation and connecting sewers to the Metropolitan
Intercepting sewer system.  The MMSD plans to include these
costs and the costs for CSO abatement in the City of Milwaukee
and Village of Shorewood with other MFP costs,  and to
distribute the debt service to all communities involved.
The ultimate acceptability and implementability of district-
wide financing will, in all likelihood, be resolved in the
courts.

1.2.3  Public Hearing and Comments

The Draft EIS was released to the public and to government
agencies on November 14, 1980.  This date marked the start
of the 45-day public comment period for the Draft EIS.  The
agencies held a public hearing on December 18,  1980 to provide
a forum for public comment.  Due to the requests of both
federal agencies and the public, the comment period was
extended from January 2, 1981 to January 12, 1981.  Although
the December 18, 1980 public hearing did not raise any
significant new issues, it, as well as the written comments
received, did highlight the areas of the MFP that concerned
the public.  The groundwater impacts of the deep tunnels and
cavern storage facility was a major concern of both citizens
as well as professional and agency commenters.   A second
significant issue concerned the economic impact on the
Milwaukee area of the MMSD Recommended Plan.  Aside from
these two major points, the comments also focused on issues
of concern in the Draft EIS such as effluent outfall relocation,
increased ammonia discharge, effects of land application of
sludge, and lakefill alternatives for plant expansion.

1.3  ADDITIONAL ANALYSES/ISSUES RESOLUTION

Since issuance of the Draft EIS, substantial new information
has become available through further EIS analyses, further
facilities planning work by MMSD, and the receipt of research
results from the University of Wisconsin-Milwaukee.  This
new information and the conclusions reached with respect to
major issues raised on the Draft EIS are outlined below.


                              1-20

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1.3.1  CSO Abatement and Peak Flow Attenuation

1.3.1.1  Groundwater Impacts

A significant issue associated with the CSO and Peak Flow
Attenuation Alternatives is the impact of a deep tunnel
system on groundwater.  Converse, Ward, Davis Dixon (CWDD),
a geotechnical consulting firm, was retained by the EIS
consultant to assess the impacts of transporting and storing
CSO and separated sewer bypasses in a tunnel and cavern
storage system in the Niagaran Dolomite Aquifer.  CWDD re-
viewed the existing data and tentatively concluded that no
significant adverse impacts would occur from either con-
struction or operation of the system provided the tunnel
alignment is carefully planned, constructed and monitored.
However, the following studies and mitigative measures
should be undertaken to ensure adequate protection of the
groundwater.

     Review the available data from the Tunnel and Reservoir
     Project (TARP) in Chicago, and determine if comparisons
     are possible between the Chicago and the Milwaukee
     environments.  If so, a more accurate prediction of
     infiltration should be made using this information.

•    Conduct site specific studies to determine the location
     of fault zones and cones of depression due to high
     rates of groundwater pumping before final tunnel align-
     ment is established.

     Utilize design and construction procedures such as
     tunnel lining to minimize infiltration or exfiltration
     during operation of the system.

     Establish a monitoring system which includes inspection
     and maintenance of structures to assure that any in-
     filtration or exfiltration will be detected in a timely
     manner and promptly corrected.

1.3.1.2  I/I Removal

Since the Draft EIS was issued, the MMSD has completed the
draft SSES report and the preliminary results indicate that
a cost-effective level for I/I removal may only be 13%.
This figure will not be finalized until the final SSES report
is adopted by the MMSD in May of 1981.  Because the final
SSES report was not available for incorporation into the
Final EIS, the analysis of alternatives presented in the final
EIS  assumes that 48% of I/I would be removed.  If the final
I/I removal level is less than 48%, as is suggested by the
draft SSES report, additional cavern storage will be re-
quired .

                               1-22

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1.3.2  Ammonia Discharge/Outfall Relocation

Since the issuance of the Draft EIS, the EPA and DNR received
the results of a study performed by the University of Wisconsin-
Milwaukee which evaluates the impacts on the Outer Harbor of
ammonia discharged in effluent from the Jones Island WWTP.
This report concludes that the increased ammonia discharge
would have no adverse effects on dissolved oxygen levels
in the Outer Harbor.  However, the toxic effects of the
ammonia discharges would still be a serious issue.  The dis-
charge plume containing potentially toxic concentrations of
un-ionized ammonia could extend up to 2600 feet from the Jones
Island outfall.  Therefore, EPA and DNR are recommending that
the MMSD develop and analyze alternatives to mitigate the
toxic effects of the ammonia discharge within the mixing zone.
At a minimum, the following conditions must be achieved:

(1)  The effluent mixing zone should be limited to a range
     of 900 to 1200 feet from the Jones Island outfall

(2)  The passage between the Inner and Outer Harbor should
     be free from a toxic barrier which could be harmful
     to aquatic life

(3)  The acute un-ionized ammonia nitrogen toxicity standard
     (0.4 mg/1) should be met within the limited mixing zone
     as well as at the point of discharge

(4)  The chronic un-ionized ammonia nitrogen toxicity
     standard  (0.4 mg/1) should be met at the boundary of
     the limited mixing zone.

Relocation of the Jones Island outfall from the Outer Harbor
into the open lake was also considered in order to mitigate
the ammonia impacts.  This action is not recommended because
it would merely transfer the water quality impacts to the
open waters of the Lake.  There are some estimates that
approximately 40 percent of the pollutants in the effluent
remain in the Outer Harbor and EPA and DNR believe this is
preferable to transferring these materials to the high
quality areas of the Lake.

1.3.3  Lakefills

The U.S. Fish and Wildlife Service has raised objections to
the proposed Lake Michigan lakefills.  Their concerns focus
on the adverse impacts lakefills would have on spawning
habitats in the near-shore areas of Lake Michigan.  While
this is a legitimate concern, the value of the affected areas
must be weighed against the improved water quality resulting
from the proposed project.
                               1-23

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In the case of Jones Island, any lakefill recommended would
replace a relatively unproductive area of Lake Michigan.
There is, however, some concern regarding the lakefill's
impact on navigation and operability of Slip Number 1 of the
Milwaukee Harbor Commission.  A recent wave analysis prepared
by MMSD has demonstrated that the 5.7 acre lakefill could
increase the wave energy input into Slip Number 1 by 56 to
60% over that entering under the existing configuration.
However, the wave reflection and surging in Slip Number 1
could be mitigated for both the existing and proposed shore
line configuration.  The MMSD recommends, and the EPA and
DNR concur, that a sophisticated mathematical model study or
a hydraulic model study, or both, should be undertaken to
refine the results in the preliminary report.  The models
should also evaluate the efficiencies of mitigation alter-
natives .

For the South Shore facility, the EPA and DNR concern for
the aquatic habitat is greater, since the proposed fill is
in the open water of Lake Michigan.  In addition, many
residents of South Milwaukee are concerned about potential
operational impacts of the South Shore facility which has
caused odor problems in the past.  However, it is EPA's
conclusion that the loss of approximately 400 feet of Lake
Michigan shoreline is reasonable considering the potential
water quality improvements that will result from an upgraded
South Shore Facility.  Although it would be technically
feasible to expand the South Shore facility without using
lakefill area, the resulting operational and reliability
factors introduced by such an alternative make the lakefill
alternative preferable from an environmental perspective.

1.3.4  Fiscal/Economic Impacts

Another significant issue raised in comments on the Draft
EIS concerned the ability of the Milwaukee economy to finance
a program as costly as that proposed.  While the Final EIS
presents an analysis of the fiscal impacts under varying
assumptions, the actual implementability of the plan will
hinge on the ability to finance it.

One aspect of the plan which could be affected in scope and
cost through additional analyses is the CSO element.  The
water quality impact studies which are required to establish
minimally acceptable water quality standards under the pro-
visions of the Clean Water Act require an analysis considering
environmental, technical, and economic impacts of attaining
water quality standards.  This analysis should be initiated
as soon as possible.
                              1-24

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The limitations of State funds and decreasing Federal con-
struction grant funds will result in a financial impact on
the Milwaukee area.  The EPA will continue to assist the DNR
and MMSD in evaluating funding options to the extent possible.

1.4  EPA PREFERRED ALTERNATIVE

1.4.1  CSO Abatement and Peak Flow Attenuation

While considerable analyses have been completed concerning
CSO abatement and peak flow attenuation, the complexity of
the system, difficulty in quantifying water quality impacts,
and changing assumptions such as the level of I/I removal
have made this the most difficult plan element to evaluate.

Based upon information available at this time, the EPA re-
commends the Modified Total Storage system to abate CSO and
attenuate peak flows from the separated sewer area.  The
level of protection provided by the Modified Total Storage
system could range from two to five years, to meet applicable
water quality standards.  The aspects of the Modified Total
Storage System providing a 2-year level of protection are
outlined below:

     Complete Separation in 11% of the CSSA with no private
     property work.

     No sewer separation in the remaining portion of the
     CSSA.

     68% of the CSSA tributary to 20-foot diameter tunnels
     and offline cavern storage at County Stadium and Jones
     Island.

     21% of the CSSA tributary to near surface storage.

The aspects of the Modified Total Storage system providing a
5-year level of protection are outlined below:

•    Complete separation in 11% of the CSSA with no private
     property work.

     No sewer separation in the remaining portion of the
     CSSA.

     88% of the CSSA tributary to 20-foot diameter tunnels
     and offline cavern storage at County Stadium and Jones
     Island.

     1% of the CSSA tributary to near surface storage.
                              1-25

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The total storage volumes necessary to meet applicable water
quality standards range from 1,400 acre-feet Cfor the two-
year level of protection) to 2,550 acre-feet (for the
five-year level of protection),  assuming a 13%  I/I removal
rate by implementation of SSES recommendations.

The volume of offline cavern storage is affected by several
factors and cannot be finalized until the MMSD,  EPA and DNR
resolve issues including the actual storage requirements
resulting from greater I/I flows, the specific  level of
protection necessary to meet applicable water quality
standards, and the specific sequencing of flow  through the
Jones Island and South Shore WWTP.

Although EPA has an estimate of the level of protection ne-
cessary to meet existing water quality standards, it is
recommended that additional water quality analysis be con-
ducted to definitively establish the minimum level of CSO
control required to meet the provisions of the  Clean Water
Act.  This analysis would evaluate the environmental, technical,
and economic impacts of attaining water quality standards.  The
analysis should use dynamic modeling techniques to address the
effects of all point and non-poing pollutant loadings, as
well as sediment oxygen demand.

The Modified Total Storage Alternative with a 2 to 5 year
level of protection for CSO is assumed to meet  applicable
water quality standards but will not meet the more stringent
requirements of the U.S. District Court Order to convey,
store, and treat the storm of record for the past forty
years.  Therefore, EPA's Preferred Alternative  to meet
minimum water quality standards will not be implemented if
the U.S. Supreme Court upholds the U.S. District Court Order.
The U.S. District Court Order alternative for CSO Abatement
and Peak Flow Attenuation would be a more costly, larger
scale alternative than an alternative to meet water quality
standards.

The differences between the alternatives to meet the U.S.
District Court Order and applicable water quality standards
are independent of I/I removal levels.  EPA and DNR have
decided not to quantify the costs or storage volume required
for U.S. District Court decision due to uncertain reliability
of some of the more crucial estimating assumptions.

Because of the large quantities of rock and overburden that
would result from the construction of the alternative for
CSO abatement and peak flow attenuation, the EPA recommends
that the MMSD continue facilities planning to develop an
environmentally sound, cost-effective method for spoil dis-
posal.  This planning output must be submitted  to the EPA
and DNR for approval prior to the start of construction.

                              1-26

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1.4.2  Wastewater Treatment

The EPA concurs with MMSD Recommended Plan for wastewater
treatment because the total present worth of the Local
Alternative is $50 million more than the MMSD Recommended
Plan.  In addition, the MMSD Recommended Plan would use
slightly less energy and resources and its annual operation
and maintenance costs would be lower than other alternatives
under consideration.

The Jones Island and South Shore WWTPs would serve the
entire planning area except for South Milwaukee which would
operate its own facility.  All other public WWTPs would be
abandoned.  The two private wastewater treatment plants,
School Sisters of Notre Dame and Wisconsin Electric Power
Company should also continue operations, and the Muskego
Rendering Company should operate its private facility for
pretreatment of effluent before discharge to the local sewer
system.

The EPA also concurs with the MMSD Recommended Plan with
respect to liquids and solids treatment processes at the
Jones Island and South Shore WWTPs.  However, the MMSD
recommendation for a 9.5 acre lakefill at the Jones Island
WWTP and enclosing 30 acres and filling 12 acres at the
South Shore WWTP are considered excessive by the EPA.  EPA
recommends limiting the Jones Island WWTP lakefill to 5.7
acres and the South Shore WWTP lakefill to 12 acres.  The
smaller lakefills would allow WWTP expansion to proceed
without any major construction difficulties.

The EPA agrees with the MMSD recommendation to disinfect the
final effluent from the Jones Island and South Shore WWTPs
with chlorine gas.  The MMSD's discharge permits require a
chlorine residual of 0.5 mg/1 in the final effluent.  The
MMSD recommends dechlorination with sulfur dioxide to achieve
this effluent limit.  However, the EPA recommends that de-
chlorination be used to reduce residual chlorine to at least
0.05 mg/1 without causing excessive sulfur dioxide overdosing,
Adequate system controls such as feed control should be used
to minimize sulfur dioxide overdose and avoid the resultant
unnecessary oxygen demand in the final effluent.  This level
of residual chlorine would also minimize the toxic effect of
combined and free chlorine, while continuing to provide
adequate pathogen removal.
                              1-27

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EPA also recommends that the MMSD evaluate alternatives for
ammonia-nitrogen control at the Jones Island WWTP and im-
plement the most cost-effective alternative.  Ammonia-
nitrogen control is necessary due to the EPA's and DNR's
interpretation of the effluent mixing zone and the existing
DNR standard for un-ionized ammonia-nitrogen of 0.04  mg/1
for the Outer Harbor.

1.4.3  Solids Handling

The EPA is basically in agreement with MMSD's recommendations
to landfill Jones Island sludge and to apply sludge from
South Shore to agricultural land.  The concern about toxic
substances and heavy metals and their potential effects on
area farmland is valid, but the controls proposed by MMSD
should be sufficient to avoid any adverse effects.  It is
important that MMSD rigorously implement its pretreatment
program to minimize all toxic discharges to its system.  If
the pretreatment program is successful, reduced levels of
toxic substances and heavy metals may, in the future, allow
land application of Jones Island sludge.

1.4.4  Wastewater Conveyance

EPA is in agreement with MMSD's Recommended Plan for con-
struction of intercepting and relief sewers.  There are
several cases however that are somewhat controversial,
and one case where EPA cannot make a definite recommendation
at this time.

EPA concurs with the MMSD that the Menomonee Falls-Germantown,
Hales Corners and Oak Creek Interceptors should be constructed,
but mitigating measures of institutional controls to limit
development should be implemented through staging or with
planned development in each sewer service areas.  The South-
eastern Wisconsin Regional Planning Commission (SEWRPC) and
the local governments will need to work closely to prevent
scattered development not in conformance with the Regional
Land Use Plan.  EPA also concurs with the MMSD that the
Northeast Side Relief System, Underwood Creek, Root River
and Franklin-Muskego Interceptors should be constructed.

The Franklin Northeast Interceptor was also recommended in
the 208 Plan, but MMSD, at least initially, found it to be
more cost-effective to upgrade several pump stations.  They
later changed their recommendation after strong opposition
at public hearings.  EPA believes that additional information
is necessary concerning the existing on-site systems in
the area and the ability to serve additional development on
such systems.  The 208 Plan conclusion was based primarily
on the fact that the soils in the area are classified by the
Soil Conversation Service as severely limiting.  While this

                               1-28

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factor must be taken into consideration it alone cannot
serve as the basis for supporting an interceptor recommen-
dation.  Until further information is available, the EPA and
DNR will be precluded from approving this portion of the
facilities plan.

1.4.5  Costs

The total system costs for EPA's Preferred Alternative assum-
ing a 13% cost-effective I/I removal rate will range from
$1.47 billion for a 2-year level of protection for CSO to
$1.64 billion for a 5-year level of protection for CSO.  The
total system cost for U.S. District Court alternative would
be higher because more storage is required for a greater
level of protection.

1.5  ENVIRONMENTAL CONSEQUENCES

The environmental impacts of EPA's Preferred Alternative
are very similar to the MMSD's Recommended Alternative.
Section 1.2.2 describes the environmental impacts for all
alternatives considered by the EIS including the MMSD Re-
commended Plan.  Outlined below are the environmental impacts
of EPA's Preferred Alternative which were not addressed in
Section 1.2.2.

1.5.1  CSO Abatement and Peak Flow Attenuation

The Modified Storage Alternative with a 2 to 5 year level of
protection for CSO would have the same environmental impacts
which are outlined in Section 1.2.2.3.  However, EPA's Preferred
Alternative would overflow to the receiving streams on the
average once every two to five years.  These overflows would
disturb the highly polluted sediments, re-introducing these
pollutants into the waterways.  Levels of dissolved oxygen
would be temporarily diminished as this organic matter de-
composed .

1.5.2  Wastewater Treatment

EPA's Preferred Alternative is identical to the MMSD's alter-
native except for the size of the proposed lakefills at both
WWTPs.  The South Shore WWTP lakefill preferred by EPA would
enclose and fill only 12 acres compared to the MMSD alternative
of enclosing 30 acres and filling 12 acres.  EPA's Preferred
Alternative would utilize approximately 400 ft. of Lake
Michigan shoreline rather than 1000 feet.

The loss of 400 ft. is reasonable considering the potential
water quality improvement that would result from the upgraded
South Shore WWTP.  The EPA also recommends limiting the Jones
Island lakefill to 5.7 acre rather than the 9.5 acre as re-
                              1-29

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     commended by the MMSD.  The  limited  lakefill  would reduce the;
     amount of aquatic habitat being permanently removed from the
     Outer Harbor by almost 50%.

     1.5.3  Solids Handling

     The environmental impacts of EPA's preferred  solids handling
     alternative would be identical to those  of  the  MMSD Recommended
     Plan, since EPA has also recommended landfilling of all solids
     from the Jones Island WWTP and agricultural application of
     solids from the South Shore  WWTP.  The environmental impacts
     are discussed in Section 1.2.2.5.

     1.5.4  Wastewater Conveyance

     The construction of interceptors would directly affect the
     natural environment of the MMSD planning.   In addition, these in-
     terceptors  would have a minimal secondary  growth impacts
     in some areas.  These impacts are outlined  in Section 1.2.2.6.

     1.6  SUMMARY

     This Executive Summary only  briefly  outlines  the EPA and MMSD
     Preferred Alternatives for water pollution  abatement and the
     effects of these alternatives on the environment of the
     planning area. The Chapters  2 through 5  of  the  EIS describe
     in more detail the legislation guiding the  MFP, the development
     of alternatives, the environment of  the  MMSD  planning area,
     and the environmental impacts of the alternatives. In addition,
     the appendices to this document provide  technical information
     about the component projects of the  MFP.
U.S. Environmental Protection Agency'
Region V,  Library             "^
230 South Dearborn Street  ^^^ A     1-30
Chicago, Illinois  60604

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