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                                CHAPTER 4
                    ENVIRONMENTAL EFFECTS OF ALTERNATIVES


                                     TASK _9

                         PHYSICAL ENVIRONMENTAL IMPACTS


9.1       IMPACT ON THE ECOLOGY

9.1.1     General

          The ecosystem of the area will be adversely impacted during
          construction and operation of the proposed wastewater treatment plant
          only if the mitigative measures recommended in Task 11 are not
          practiced.  It is recommended that a member of the Bloomington Utility
          Board make frequent inspections during construction operations to
          ensure that the recommended mitigative measures are implemented.

          The caliber of adverse physical environmental impacts which can result
          from poor engineering practices and which should be avoided in the
          proposed project are described in an article appearing on page 3 of
          the July 1969 Bloomington Newspaper, "The Balancer," which reports
          sewer lines, siphon boxes and manholes constructed in the Bean Blossom
          Flood Plain were not buried and covered properly.  As a consequence,
          during heavy rains the pipe lines dammed up water which became
          stagnant and served as a hatching area for mosquitos.  The pipelines
          were uncovered and heavy siltation of the creek occurred below the
          facilities.

          In the following paragraphs, the possible sources of physical damage
          to the aquatic and terrestrial environments due to construction and
          operation activities will be considered.  Table 9-! compares the
          physical impacts by alternative sites for the wastewater treatment
          plant.

9.1.2     Aquatic Ecology

          Rare and Endangered Aquatic Organisms

          No aquatic organisms appearing in the area of the proposed project are
          considered rare or endangered as defined in The Federal Register
          (July 1, 1975) and the U.S. Department of Interior (1974). Table 9-2
          lists the aquatic organisms which have been found in the subject area.

          Impacts of Interceptors and Outfalls on the Aquatic Environment Storm
          water runoff carrying silt from areas excavated for interceptors,
          outfalls and other facilities associated with the project could affect
          the biota of Clear and Salt Creeks.  The smothering influence of silt
          could affect the primary producers as well as all other levels of the
          food chain.  Filter-feeding zooplankton are harmed because their
          feeding apparatus becomes clogged.  Aquatic plants are affected
          because silt suspended in the water blocks out light and inhibits
          photosynthesis.  Dying plants consume oxygen and lower dissolved
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oxygen (DO) of the water.  A decrease in DO could be harmful to fish
when they are smothered as a result of silt particles clogging their
operculum cavity and gill filaments.  Silt settling on fish eggs
decreases oxygenation of the eggs, which die.  This effect on fish
populations is the most severe effect of silt production.

Because the depth of soil over the bedrock is much greater in the
alluvial portion of Clear Creek near its confluence with Salt Creek,
the quantity of silt in runoff is greater there than in the upper
portions of the creek.  This situation contrasts to the waters of
Clear Creek further north where topsoil is not as thick and runoff  is
not as silt-laden.  Observation made of the creek in August of 1975
confirmed that: near the confluence of Salt and Clear Creeks the water
was very muddy.  Between Bloomington and Ketcham road, Clear Creek was
relatively clear.  Heavy siltation of the creek during construction
activities would worsen the already bad siltation problem in the
southern end of Clear Creek and create a new and adverse condition  if
it occurred in the northern reaches of the creek.  Silt production  can
be minimized if the recommended engineering practices mentioned in
Task 11 are followed.

Crossing of the creek with interceptor lines and rerouting the creek
are construction activities which are potential sources for
alterations in the natural aquatic ecology of the area if good
engineering practices are not followed.  Because the creek bed is
solid limestone the dredging and blasting required for these
activities is not expected to produce a great deal of silt.  While  the
trench is being dug, habitats for benthic organisms in the immediate
area will be disrupted; however, after the encased pipeline is
installed the trench will be refilled with riprap consisting of the
caliber of heavy stones which now line the creek bed.  These stones
will be recolonized by organisms seeded from the water passing over
them.

Proof of the ability for Clear Creek to recover from localized
devastation is shown by two historical occurrences:

1.   The installation of the tertiary lagoon in the Winston Thomas
     Sewage Treatment Plant

2.   Rerouting the creek to accomodate expansion of the Winston Thomas
     Sewage Treatment Plant

Prior to 1969, when the tertiary lagoon was built, the poor water
quality of the creek was reflected in the low species diversity for
invertebrates! and absence of fish.  Since the lagoon has been
installed and the quality of sewage effluent flowing into the creek
has improved, species diversity of invertebrates has increased and  the
more tolerant Cyprinidae such as the stoneroller (Campostoma anomalum)
and the creek chub (Semotilus atromaculatus) have been found near the
outfall (D.G. Frey - personal communication).

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When the creek was rerouted, the water channel was simply transferred
from one bedrock channel to a new one with no apparent disruptions of
the creek south of the rerouting.

Impacts of Operation on the Aquatic Ecology - Effluent

The physical effects of the effluent will depend on where the outfall
is located and the degree to which the sewage is treated.  According
to Indiana State .regulations, the following levels of treatment will
be required by 1977 for discharges to Salt Creek and Clear Creek.

                                   Salt Creek          Clear Creek

BOD (Biological                    10 mg/1 or 95%      5 mg/1 or 97.5%
  Oxygen Demand)                   removal             removal

Suspended Solids                   10 mg/1 or 95%      5 mg/1 or 97.5%
                                   removal             removal

Phosphorus                         1 mg/1 or 80%       1 mg/1 or 80%
                                   removal             removal

Ammonia Nitrogen                   6.5 mg/1 in summer  1.5 mg/1 summer
                                   no limitation       3.0 in winter
                                   in winter

The requirements for a greater degree of treatment for effluent
discharged into Clear Creek is due to the lower dilution rate which
occurs there.  When comparing the potential physical effects of the
effluent discharged into Clear Creek and Salt Creek, the two primary
considerations are:

1.   The decreased flow which would occur in Clear Creek if the
     effluent were no longer discharged into it

2.   The chemical characteristics of the effluent when it reaches
     a water intake for the city of Bedford, 13 miles downstream from
     the Lake Monroe dam

Canoeing of Clear Creek is impossible during low flow conditions
which normally occur during the summer.  On four sampling dates
between February 22, 1975 and April 2, 1975 (a high flow period for
the creek) the flow of Clear Creek averaged 200 MGD
(Pullman G. Douglas, 1975).

If the flow from the city's sewage treatment plant was removed from
Clear Creek and discharged into Salt Creek, Clear Creek would be
unnavigable by canoe sooner than it is now.  If the outfall is moved
farther south on Clear Creek, the flow from Bloomington to the new
location will be reduced from its present level.  This reduced flow
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rate which could occur if effluent were removed from Clear Creek  is
significant from another standpoint:  it would no longer dilute the
pollutants which drain into the creek from a variety of sources.
Hartzel et al.  (1971) reported that pollution of Clear Creek above
the Winston Thomas Sewage Treatment Plant outfall came from the
following sources:

1.   Oil from a creosote plant

2.   Indiana University via the Jordan River which is located on
     campus

3.  Faulty septic tank drainage fields

4.  Runoff from Bloomington
On April 2, 197L, water quality parameters which were more severe
above the sewage treatment plant when compared to those below it
included:

1.   Bicarbonate alkalinity

2.   pH

3.   Nitrate

4.   Resistivity

These parameters were improved below the outfall due to the effect of
dilution.  Parameters which were more severe below the plant included
dissolved oxygen, calcium, and total phosphate.  Removing the effluent
from Clear Creek or upgrading the treatment to the projected level
required for 1977 would generally improve the water quality of Clear
Creek.  However, those pollutants which enter from above the point of
discharge of the Winston Thomas plant would no longer be diluted and
their concentrations would become higher than they are now below the
discharge of the Winston Thomas Plant.

Two questions have been raised concerning the effect sewage will have
on the City of Bedford's water intake on Salt Creek.  The first is
whether the effluents could raise the nitrage level in the water to a
level which would be toxic to humans drinking it.  The nitrate
concentrations above and below the present Winston Thomas Treatment
Plant on April 2, 1971, were 5.6 above the discharge and 2.0 ppm below
the discharge, and 3.9 and 6.6 ppm on April 9.  On April 12, 1975 at
7 P.M., the nitrate concentration was 3.2 ppm at Clear Creek, 0.29 ppm
on Salt Creek and 0.3 ppm at their confluence.  These were high flow
conditions.  During low flow conditions, the nitrate levels may be
                              4-9-4

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 considerably higher.  In addition to the effluent, another source of
 nitrate is the sludge injected into the land, which could be washed
 off during floods.  This is a potential problem only at the Salt Creek
 site where the sludge injection system is proposed and where frequent
 flooding occurs.  The amount of nitrate which could be washed off
 during floods can be controlled through manipulation of the
 application rates.  As discussed in Section 11.2.1, it is recommended
 that if the Salt Creek site is selected, a study be carried out to
 determine the application rates.  Pollution of surface or ground water
 with other materials as a result of the sludge injection system would
 not be expected (Ken Dotson EPA, Cincinnati, personal communication).
 After the effluent is discharged into a creek, the nitrate
 concentration will drop as a consequence of denitrification and
 nitrate reduction which occurs naturally as the creek flows southward.
 There is no possibility that the nitrate concentration could reach the
 50 ppm level which has been associated with infant methemaglobinemia
 (Maxey-Rosenau, 1965).

 There has also been some question about toxic chlorinated organics in
 the effluent reaching the intake for the City of Bedford's water
 supply.  The chlorinated organics form as a result of the chemical
 reaction of chlorine, added to the sewage for disinfection purposes,
 and the organics discharged into the sewage by industries and
 university laboratories.  No definite statement can be made at this
 time concerning this potential problem except that natural degradation
 of the compounds is more likely to occur in Clear Creek which is well
 aerated and further from the reservoir than will occur in Salt Creek
 which is less aerated and closer to the intake.  In addition, the
 greater degree of treatment required for sewage discharged into Clear
 Creek may result in the decomposition of the organics which could
 react with chlorine and will decrease the quantity of chlorine
 required for disinfection.  It is recommended that the raw sewage and
 chlorinated effluent from the Winston Thomas Sewage Treatment Plant be
 analyzed by the gas chromatographic mass spectro-photometric method to
 identify toxic chlorinated compounds that may be formed during the
 chlorination process.  If they are detected, alternative disinfection
 systems can be designed into the proposed treatment plant.
 Alternatives which could be considered include:

 1.   Ozonation

 2.   Chlorination - dechlorination

 3.   Bromine chloride

 4.   No disinfection

*"... uncontrolled and excessive use of chlorine for wastewater
 disinfection may result in potential harm to both human and aquatic
 life (A/WPR, April 28, 1975, p. 166) ...Alternative means of
 disinfection control (dechlorination) must be considered where public health
 hazards and potential adverse impact on the aquatic and humand environments
 coexist, but disinfecting should not be required in those instances where
 benefits are not present."  (A/WPR, August 25, 1975, p. 332).

                               4-9-5

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9.1.3     Terrestrial Ecology

          Rare and Endangered Terrestrial Organisms

          A search of the .scientific and other literature was conducted to
          determine if rare or officially designated "endangered." species might
          occur in the area.   Table 8-3 lists terrestrial vertebrates of
          potential occurrence which are listed as "threatened" and/or
          "endangered" by the U.S.  Department of the Interior, Office of
          Endangered Species  and International Activities (1973,  1974).  Because
          critical nesting habitat  for the two birds is abs€-.nt from the area,
          and caves which would attract the bat (Hall 1962)  are unknown in the
          areas potentially affected, it is believed that effects of
          construction would  be neglible at any site proposed.

          Impact of Interceptors and Outfalls on Terrestrial Ecology

          Interceptor and connector sewers necessary for the several
          alternatives under study  would require trenches of depth and width
          appropriate to provide drainage by gravity.  If the Salt Creek site is
          chosen, it will require interceptors.  The interceptors will require
          trenches about 2m (6 feet) wide, no less than 2.7  m (9 feet) deep, and
          extending for varying lengths, but in no instance  less than several
          kilometers.

          One hundred foot construction right-of-ways and 50 foot permanent
          right-of-ways are required for interceptors.   After the trench was
          closed, vegetation could  become reestablished along the right-of-way,
          and in fact would be essential to prevent damage from erosion and to
          limit penetration of frost.

          It would be necessary to  maintain a road for  vehicles along the entire
          length of the right-of-way to permit inspection and repair to the
          facility.  Manholes would protrude at intervals.  Consequently,
          construction of any sewer so large as the several  proposed in
          alternative plans in the  present project must be assumed to have
          significant effect, much  of which will not diminish for the useful
          life of the sewer,  and much lasting long after the sewer line has lost
          its utility.  The following paragraphs discuss in  some detail uhe
          effects probable from constructing such sewers.

          The effects of clearing a wide swath through  fields and woodlands, or
          along the riparian vegetation bordering such  a stream as Clear Creek,
          are manifestly significant, whether or not they can be quantified in a
          particular instance.  Vegetation would be destroyed.  Consequently,
                                        4-9-6

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the area would become untenable, at least during construction, for
many kinds of animals dependent on that vegetation.  Any such project
as those considered here clearly has unavoidable influence on vast
areas.  For example, a right-of-way only 100 feet wide would occupy
about 12 acres per mile (i.e., a right-of-way 30 m wide and 1.6 km
long would occupy 4.9 ha).

If the interceptor is built to the Salt Creek site, it should clearly
affect riparian communities to the almost total exclusion of uplands,
and the right-of-way would traverse cropland at almost every point
where it was not in woods.

The riparian vegetation which would be removed by construction is
suitable habitat for a variety of game species of recreational
importance, as well as some species which are apparently incompletely
harvested  Ce.g., raccoons, Procyon lotor).  More hunter pressure is
apparently placed on upland game birds (e.e., ring-necked pheasants,
Phasianus  colchicus) in the adjacent croplands, and destruction of
forest growth would probably increase the attractiveness of the area
traversed  by the sewer to hunters during a brief part of the year.

Clear Creek is a moderately severely polluted stream, presently
ill-suited for most aquatic sports for much of its length.  However,
it is presently used during the period of high water in the winter for
canoeing;  it has been characterized as the "only" sizable reach of
water suitable for canoeing in a radius of 30 miles or more from
Bloomintgon.  The riparian growth, while difficult to traverse on
foot, offers a potentially rewarding experience to hikers along the
stream.  The Cedar Cliffs preserve, owned by the Nature Conservancy,
is in fact worthy of protection as a wild area; and it is recommended
strongly that no construction be considered which would degrade the
area.

The presently proposed sewer routing, and any other along Clear Creek
that seems to be economically feasible, would have little adverse
effect on  agriculture.  Digested sludge probably would be a beneficial
soil adjuvant in the area, and consequently its availability would
encourage  agricultural use of bottom lands.

The importance of forest industries in the region appears to be small
at present, though some large and consequently merchantable trees have
been noted in the riparian community.  However, the destruction of
timber associated with construction of the proposed sewer would be
deleterious in proportion to its extensiveness.
                             4-9-7

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          The use  of  Clear Creek  for recreational purposes might  be  fostered if
          adequate sewage treatment were to be  instituted to  ensure  its
          attractiveness throughout the year.   Use of  the creek for  aquatic
          sports,  including  fishing, might well induce the construction  of
          summer homes  or year-round residences along  its course.  Such  use
          would probably depend upon the availability  of convenient  sewer
          connections.

          Information on potential industrial development which might be
          encouranged by constructing the sewer is not known.

          Man can  influence  succession in many  ways.   Some of  these  involve  the
          establishment of almost permanent disclimaxes.  Egler and  Foote  (1975)
          provide  a hook-length summary of techniques  for stabilizing the
          vegetation  of rights-of-way, and review the  scientific  literature.

          One economically advantageous course  of management of the  right-of-way
          would provide for  establishing shrubs  along  the boundaries of  the
          affected area and  limiting growth in  the center to grasses and other
          herbaceous  vegetation too low to interfere with the  passage of off-
          road vehicles.  Experience elsewhere  suggests that such
          self-sustaining plant communities could be established  in  this area by
          making appropraite plantings initially.  However, experiments  have not
          to our knowledge yet been performed which would definitively
          demonstrate the feasibility of such techniques, and  it may be
          necessary to  limit growth in part by  mechanical and/or  chemical means.

          However,  if vegetation on rights-of-way is maintained, we assume here
          that a stable plant community can in  fact be  established, and  that the
          growth-form of the plants will be various, ranging from grasses and
          low shrubs  to tall trees.  The habitats afforded by  such a community
          will be  more productive of game and other animals than  if a sharp
          delimintation of forest from an artifically-maintained grassland type
          existed,  because of the phenomenon of  edge effect (Leopold
          1933:131-132, Ghiselin 1975).

9.2        Impact on the Visual Aesthetics

          While the design of the plant and the  arrangements may differ  slightly
          from site to  site, the visual impact  of the  plant site will depend
          largely  upon its position wihin the landscape with .respect to  both
          terrain  and natural vegetation, as well as upon the  number and
          position of potential viewers, and the duration or frequency of the
          view.  Since each  sense is not entirely independent  of each other, the
          odor associated with a plant might easily influence  the visual
          register of the plant.

          Of all the  potential sites, only one,  the existing Winston Thomas Site
          is located  within  an existing or planned development corridor.  One
          might theorize that this plant has been there for such a long  time
                                        4-9-8'

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          that the average person wouldn't even be visually bothered by a
          different plant site configuration.  Nonetheless, it is here where
          trailers, residences, and apartments are located in relatively close
          proximity on the hills overlooking the site to the west of Clear
          Creek.   A good part of the view from this residential development
          along Rogers Road is visually screened from the site by the natural
          tree line found between the residences and along the railroad and
          Clear Creek.  In addition, views are possible from the Gordon Road
          trailer development as well as from traffic passing along Old State
          Route 37, the main north-south artery.

          Both the Salt Creek and the Dillman Plant Sites would be visible from
          State Route 37 Bypass, the Dillman Site for a shorter duration than
          the Salt Creek Site.  The latter is, however, more distant from the
          viewer, in this case from a vehicle, than would be the Dillman Site.
          The Dillman Site is, however, tucked into a narrow landform depression
          at a point where the highway alignment changes quickly and, therefore,
          probably eliminating any long duration vistas toward the site, which
          might be more prevalent at the Salt Creek Site.

          The Ketcham Site is the most visually removed of all the sites.  Both
          Dillman and Salt Creek are located well outside the limits of planned
          growth corridors, so they shouldn't be surrounded by development which
          might intensify their future visual impact.  The Salt Creek site does,
          however, sit adjacent to the boundary of a potential seasonal
          development which would overlook the site.

9.3       Impact  on the Traffic Pattern

          Traffic impacts are expected to be minimum with peak truck traffic
          expected during sludge removal.  Most of the plant sites are located
          relatively close to major arteries; with Dillman, Ketcham, and Salt
          Creek having access via State Route 37 Bypass; and Winston Thomas and
          Rogers  via Old State Road 37.  In this regard, the impact will be
          relatively more significant in the more urbanized locations, however,
          all of  these major highways have significant traffic capacity to add a
          few more trucks, approximately fifteen round trips per day.

          The Dillman Site cannot be reached without a new bridge over Clear
          Creek since the present bridge is one lane wide and limited to five
          tons.  Construction truck traffic, especially cement trucks, would
          have trouble getting to this site unless a new bridge were to be
          constructed.  The fact that a new bridge would be constructed here as
          part of the creek relocation would result in a positive impact.

          The Ketcham Road Site probably has the most inadequate and hazardous
          highway access of all the sites.  Not only is Ketcham Road narrow, but
          its intersections with State Route 37 and Fluckmill Road are
          hazardous.  In addition, the railroad underpass may be too low to
          allow for construction truck traffic to pass under it.  The only other
          access  way to this site is via Victor Road, a narrow, curving, rural
          residential road.

          The Salt Creek site offers few, if any, potential traffic impacts.

                                        4-9-9

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References
     Egler, F. C.;  and S. R. Foote, 1975.  The Plight of the Right-of-way Domain,
     Victim of Vandalism.  Futura Media Services, Inc., Mount Kisco, N.Y.  2 vols.

     Ghiselin, J. 1975.  The Edge Index:  A Method for Comparing Terrestrial
     Species Diversity.  Bull. Ecol. Soc. Amer. 56(2):14.  (Abstr.)

     Gray, H. H.; Howe, P. A.; Randolph, J. C.; Roberts, M. C.: and White, N. L.
     1975.  A Technical Report on a Selected Portion of the Lake Monroe Watershed.
     Indiana University School of Public and Environmental Affairs, Center for
     Urban and Regional Analysis Bloomington.

     Hall, J. S. 1962.  A Life History and Taxonomic Study of the Indiana Bat,
     Myotis sodalis.  Reading Publ. Mus. Sci. Publ. No. 12.  68 pp.

     Hartzel, M. H.; Hobbs, H. H.; Paterson, K.:  and Seechausen, S.; 1971.  The
     Headwaters of Clear Creek Drainage - A Comparative Study - A Class Report
     for Dr. D. G.  Frey, Unpublished.  U. of Indiana, Bloomington.

     Hawn, G.; and J. A. Huber.  1975.  A Study of the Diversity of the
     Macroinvertebrates of Clear Creek After Sewage Outfall.  A class Report for
     Dr. D. G. Frey, Unpublished.  U. of Indiana, Bloomington.

     Leopold, Aldo.  1933.  Game Management.  New York (Charles Scribner's Sons):
     xxi + 481 p. ill.

     Maxcy, K. F.;  and M. J. Rosenau.  In Preventive Medicine and Public Health,
     P. E. Sartwell, Ed.  (New York, Appleton - Century - Crofts, 1956).

     Pullman, Douglas G., 1975.  A Survey of Clear Creek and Salt Creek Near
     Their Confluence South of Bloomington, Indiana - A Class Report for
     Dr. D. G. Frey, Unpublished.  U. of Indiana, Bloomington.

     Restle, Barbara, 1969.  State To Investigate Bloomington's Sewer Installation,
     The Balancer,  July P. 3 Bloomington, Indiana.

     Shelford, Victor E. 1963.  The Ecology of North America.  Urbana (Univ.
     111. Press):  xxii + 1-610 pp., 195 ill.

     U.S. Department of the Interior, Bureau of Sport Fisheries and Wildlife,
     Office of Endangered Species and International Activities.  1973.  Threatened
     wildlife of the United States.  Resource Publ. 114.  289 pp.

     U.S. Department of the Interior, Fish and Wildlife Service, Office of
     Endangered Species and International Activities.  1974.  United States
     list of endangered fauna.  22 pp.

     U.S. Department of the Interior, Fish and Wildlife Service.  1975.  Threatened
     or Endangered Fauna or Flora Tuesday, July;  1975.  Federal Register.
                                        4-9-10

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     Fish
                                    TABLE  9-2

                    AQUATIC ORGANISMS FOUND IN LAKE MONROE AND
                             EXPECTED IN SALT CREEK1
Largemouth bass
Bluegill
White crappie
Black crappie
Yellow perch
Yellow bass
Carp
Black bullhead
Yellow bullhead
Channel catfish
White sucker
Spotted sucker
Redear sunfish
Pumpkinseed
Longear sunfish
Green sunfish
Warmouth
Orange-spotted sunfish
Redhorse
Rockbass
Smallmouth bass
Flathead catfish
Northern pike
Micropterus salmoides
Lepomis macrochirus
Pomoxis annularis
Pomoxis nigromaculatus
Perca flavescens
Morone mississippiensis
Cyprinus carpio
Ictalurus melas
Ictalurus natalis
Ictalurus punctatus
Catostomus commersoni
Minytrema melanops
Lepomis microlophus
Lepomis gibbosus
Lepomis megalotis
Lepomis syanellus
Lepomis gulosus
Lepomis humilis
Moxostoma sp.
Ambloplites rup_estr_is
Micropterus dplomieui
Pylodictis oliyari^
Esox lucius
 From Gray et al 1975
                                         4-9-12

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                             TABLE 9-2   (Continued)

                        Nannoplankton Algae and Protozoa
Melosira italica
Meloslra sp.

Dinobryon divergens
Dinobryon bavaricum

Stephanodiscus sp.

Merismopedia tenuisslma
Merismopedia minor

Ankistrodesmus sp.

Cryptomonas sp.

Fragilaria crotonensis

Chroococcus limenticus
Chroococcus minor

Mallomonas akrokomas
Mallomonas sp.

Coelastrum sp.

Asterionella formosa

Anabaena lemmermanni

Coelosphaerium kutzingianum

Strombidium viride
                                       4-9-13

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                             TABLE 9-2  (Continued)

                                   Zooplankton
Protozoa
     Codonella
     Ceratium
     Difflugia cristata
     peritrich

Rotifera
     Ascomorpha
     Asplanchna
     Branchionus
     Colurella
     Conochilus
     Filinla
     Gastropus
     Kellicottia
     Keratella cochlearis
     Polyarthra euryptera
     Polyarthra vulgaris
     Rotatoria
     Trichocerca
Cladocera
     Alona sp.
     Alonella sp.
     Bosmina coregoni
     Ceriodaphnia lacustris
     Chydorus spaericus
     Daphnia laevis
     Daphnia retrocurva
     Diaphanosoma leuchtenbirgeanum
     Holopedium gibberum
     Leptodora kindtii
     Pleuroxus denticulatus
     Pseudosida bidentata
     Sida crystallina

Copepoda
     Cyclops (2 sp.)
     Limnocalanus
     Diaptomus

Ostracoda
                                        4-9-14

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                             TABLE 9-2  (Continued)

                                  Phytoplankton
1.    Cyanophyceae
          Chroococcales
               Chroococcus
               Coelospaerium
               Dactylococcopsis
               Gloeocapsa
               Gomphosphaeria
               Marssoniella
               Merismopedia
               Microcystis
          Chaemae s iphonales
               Pleurocapsa
          Oscillatoriales
               Anabaena
               Lyngbya
               Oscillatoria

2.    Chlorophyceae
          Chloroccoccales
               Ankistrodesmus
               Crucigenia
               Lauterborniella
               Oocystis
               Pediastrum
               Scenedesmus
               Tetraedron
          Tetrasporales
               Gloeocystis
          Volvocales
               Volvox
          Zygnematales
               Closterium
               Cosmarium
               Gonatozygon
               Micrasterias
               Spirogyra
               Staurastrum
3.    Chrysophyccae
          Dinobryon
          Mallomonas
          Ochromonas

4.    Xanthophyceae
          Asterogloea
          Ophiccytium

5.    Bacillariophyceae
          Centrales
               Cyclotella
               Meloslra
               Stephanodiscus
               Terpisnoe
          Pennales
               Amphiprora
               Amphora
               Asterionella
               Cymbella
               Fragilaria
               Gyrosigma
               Navicula
               Neidium
               Nitzschia
               Surirella
               Synedra
               Tabellaria
                                        4-9-15

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                             TABLE 9-2  (Continued)

                     Aquatic Organisms Found in Clear Creek
Monera
     Sphaerotilus

Algae
     Chlorophyta (green algae)
          Volvocales
               Chlamydomonas
          Tetrasporales
               Tetraspora
          Ulotrichales
               Ulothrix
               Stigeoclonium
               Chaetophora
               Coleochaete
          Cladophorales
               Cladophora
          Oedogonlales
               Oedogonium
          Zygnematales
               Zygnema
               Spirogyra
          Chlorococcales
               Ankistrodesmus
          Desmidiales
               Closterium
               Cosmarium
     Euglenophyta (euglenoids)
          Euglenales
               Euglena
               Peranema
     Chrysophyta (yellow-green algae & diatoms)
          Chrysomonadales
               Synura
          Pennales
               Tabellaria
               Diatomella
               Meridion
               Diatoma
               Fragilaria
               Synedra
               Asterionella
               Ceratoneis
                                         4-9-16

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                             TABLE 9-2  (Continued)
               Cocconeis
               Brebissonia
               Gyrosigmia
               Anomoeneis
               Amphipleura
               Navicula
               Cymbella
               Amphora
               Gomphonema
               Gomphoeneis
               Aphanotheca
               Nitzschia
               Bacillaria
               Denticula
               Centronella
          Cyanophyta (blue-green algae)
               Anacystis
               Oscillatoria
               Lyngbya
               Spirulina
Vascular Plants
     Najadaceae (pondweed)
          Potomogeton
Protozoa
     Sarcodina
          Amoeba
     Ciliata
          Vorticella
Coelenterata
     Hydrozoa
          Hydra
Platyhelminthes (flatworms)
     Turbellaria
          Dugesia
Aschelminthes
     Nematoda
     Rotifera
                                        4-9-17

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                             TABLE 9-2  (Continued!


Tardigrada
Annelida
     Oligochaeta
          Aeolosoma
          Tubifex
          Lumbricus terrestris
     Hirudinea
     Glossophonidae
     Piscicolidae
          Pisicola
Mollusca
     Gastropoda (snails)
          Lymnaea
          Goniobasis
          Campeloma
          Physa
          Helisoma
     Pelecypoda (bi-valves)
          Sphaerium
          Musculium
Arthropoda
     Chelicerata
          Arachnida
Arthropoda
     Crustacea
          Malacostraca
               Isopoda
                    Asellus
                    Lirceus
               Amphipoda
                    Ganmarus
                    Haustoriidae
               Decapoda
                    Cambaru8 laevis
                    C_. d_^ diogenes
                    Orconectes p. propinquus
          Insecta
               Apterygota
                    Collembola (springtails)
                                        4-9-18

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              TABLE 9-2  (Continued)
Pterygota
     Ephemeroptera (mayflies)
     Ephemeridae
          Hexagenia
     Heptageniidae
          Stenonema
     Baetidae
          Neocloeon
     Odonata (dragonflies)
          Anisoptera
          Aeschnidae
          Gomphidae
     Zygoptera
          Agrionidae
               Nehallenia
     Plecoptera (stoneflies)
          Perlidae
               Atoperla
          Isoperlidae
               Isoperla
     Hemiptera (true bugs)
          Corixidae
          Notonectidae
          Gerridae
     Neuroptera
          Corydalidae
               Corydalus
     Coleoptera (beetles)
          Elmidae
               Stenelmis
          Haliplidae
               Peltodytes
          Hydrophilidae
          Psephenidae
               Psephenus
     Trichoptera (caddisflies)
          Rhyacophilidae
               Hesperophyla
          Hydropsychidae
               Drydropsyche
          Hydrophilidae
          Limnephilidae
                          4-9-19

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                             TABLE 9-2   (Continued)
                    Diptera  (flies)
                         Tipulidae
                         Chironomidae
                              Chironomus
                         Tipulidae
                              Hexatoma
                         Simulidae
                         Culicidae
                              Culex
Chordata
Osteichthyes
     Cyprinidae (carps & minnows)
          Campostoma anomalum
          Pimephales notatus
          Semotilus atromaculatus
          Ericymba buccata
     Centrarchidae (sunfish)
          Lepomis cyanellus
     Percidae (perch)
          Etheostoma spectabile
          _£._ flabellare
          E. nigrum
Amphibia
     Urodela (salamanders)
          Plethodontidae
     Anura (frogs & toads)
          Rana catesbeiana

     Reptilia
          Squamata (lizards & snakes)
               Natrix s. sipedon
                                       4-9-20

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                                    TABLE  9-3

                           TREES OF THE RIVER BOTTOMS


Common Name                             Scientific Name


Black walnut                            Juglans nigra

American hornbeam                       Carpinus caroliniana

Oak                                     Quercus sp.

Chestnut oak                            Quercus prinus

Elm                                     Ulmus sp.

Hackberry                               Celtis sp.

Sassafras                               Sassafras albidum

Sycamore                                Platanus occidentalis

Wild black cherry                       Prunus serotina

Water locust                            Gleditsia aquatica

Silver maple                            Acer saccharinum

Basswood                                Tilia americana

Ash                                     Fraxinus sp.


             RARE AND ENDANGERED TERRESTRIAL VERTEBRATES POTENTIALLY
                           OCCURRING IN THE STUDY AREA


Common Name                   Scientific Name                    Remarks


Peregrine falcon              Falco peregrinus sspp.             Possibly transient

Kirtland's warbler            Dendroica kirtlandii               Possibly transient

Indiana bat                   Myotis sodalis                     Possibly summer
                                                                 resident
                                         4-9-21

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Common Name






True Solomon's seal




Hydrangea




Wood-sorrel




Poison ivy




Jewel weed




Black-eyed Susan




Ironweed
       TABLE 9-3  (Continued)




HERBS AND SHRUBS OF THE RIVER BOTTOMS






                  Scientific Name






                  Polygonatum commutatum




                  Hydrangea sp,,




                  Oxalis sp.




                  Rhus radleans




                  Impatiens sp.




                  Rudbeckia hirta




                  Vernonia sp.
                                        4-9-22

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                                      TASK 10

                         INDUCED DEVELOPMENT - LAKE MONROE


10.1       INTRODUCTION

10.1.1     Regionalization Issue

           The issue of induced development and its secondary impacts on Lake
           Monroe assumes the eventual development of sewerage service.  The
           issue of how this service will emerge or develop and what form it will
           take is also the issue within the regionalization issue.  Without a
           regional interceptor around the lake and a near term demand of 3.0 MGD,
           there would really be little need to locate a plant sized to serve the
           Bloomington Region at the lake.

           Both the Bloomington and the Lake Monroe Regional Waste District 201
           Plans assumed that the Lake Regional System and single regional
           treatment at Salt Creek was the best alternative.  The reaction
           following this conclusion was that widespread environmental damage
           would result from the increased development at the lake.

 10.1.2     Other Questions and Considerations

           The Consultant, based upon independent analysis and many unanswered
           questions about the market potential, timing, and other factors, has
           found it extremely difficult to theorize induced impacts at Lake
           Monroe.  There are no real assurances that many of these proposed or
           potential developments around the lake are actually viable
           undertakings.  On this basis, the economic feasibility of the regional
           sewer system for the lake is questionable, as is the matter of how
           such a system could somehow be constructed so as to logically and
           sequentially serve development proposals as they fall due.  It is also
           difficult to corroborate the Lake Monroe Regional Waste District
           rationale for near term sewerage service in light of the lack of firm
           commitments.

           Also worthy of consideration is the possibility that sewer development
           itself may well not be the overriding consideration on whether the
           Lake Monroe area grows or not.  In fact, considerations of the market
           for second homes, the money market, and potential income tax reform
           might override the sewer question.

           One thing that is obvious is that the nature of the regional system as
           proposed benefits the large scale developer who can afford the interim
           treatment facilities needed, costs of pumping and injecting into the
           force main, and what is anticipated to be a rather expensive system to
           operate.
                                        4-10-1

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            There are enough other uncertainties attached to expectations for
            development around the lake to further cloud the issue, the main one
            being the fact that the State of Indiana is the biggest and most
            successful developer around the lake.

            Further complicating this analysis is  the lack of readily available
            data, the multiplicity of public and private interests which are often
            times strongly Intertwined, and the lack of any overall coordinated
            water and land use goals and policies.

            The potential growth of the lake area  will for the most part depend on
            future expectations in seasonal and recreational housing.  Trends
            within the latter market are probably  far more significant with
            respect to inducing development than the construction of a regional
            sewer system around Lake Monroe.  Conversely, without the market,
            there will in aLI probability be no demand for such a sewer system.

            Present knowledge of the potential market for seasonal and
            recreational development at Lake Monroe is indeed limited, even as
            limited as current information regarding the multitude of lake side
            private projects talked about,  but never evidently entering the
            planning and scheduling stages.   Balanced against the total market
            considerations must certainly be the physical,  chemical, and
            recreational carrying capacity of the  lake itself,  and the watershed
            draining into it.   Hopefully,  the ongoing land capability plan will
            better address some of these issues.

            There are a multitude of federal and state agencies in a position to
            influence the development in and around the lake either directly or
            indirectly.   These include the U.S.  Forest Service, the U.S.  Army
            Corps of Engineers, the Farmers Home Administration,  and EFA at the
            federal level.  At the state level,  the Department  of Natural
            Resources and Department of Health are in a position to influence land
            development potential.   At the local level,  the Lake Monroe Regional
            Waste District and the Monroe County Planning Commission are in a
            position to directly influence the rate and direction of growth.

10 .2       THE UNIQUE ROLE OF THE STATE OF INDIANA

            The State of Indiana,  through its Natural Resources Department,
            occupies a very special and privileged  role in the  real estate aspects
            of Lake Monroe development.  The State indirectly influences lake
            recreational usage by controlling public access points to the lake and
            lakeside facilities, since they are the only lakeside developer having
            direct access to the lake from the shoreline other  than the U.S.  Army
            Corps of Engineers.

            This consideration means that the State may be in a position to
            influence development and change within the Lake Monroe watershed to
            an even greater degree than some of the proposed seasonal
            developments, particularly when one investigates the  complete lack of
            a definitive timetable for the latter.


                                         4-10-2

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How did the State get into this unique pisition?  The Corps of
Engineers and the State shared in the cost of developing the lake with
the Corps retaining ownership of abutting lands.  For the most part,
this ownership corresponds to a specified lineal height above the
flood pool elevation.  In some cases this lake buffer strip is rather
narrow.  In other cases, additional lands were purchased to protect
and control waterside views, etc.  While many argue that the buffer is
too narrow and possibly not totally enforced, in fact, there are no
properties abutting the lake that have direct access to the lake
because of this buffer, except those leased by the State.

The State leases its recreational areas, boat ramps and campgrounds
from the Corps of Engineers on a long term basis.  In turn, the State
subleases this prime waterfront property to private developers.  A
good example at Lake Monroe is the Four Winds Marina initially built
by Ramada Inns and recently sold to Aircoa.  The Four Winds Marina is
a resort hotel with recreational facilities and water facilities
including direct lake access.  At present, there are only two ways of
enjoying the lake, either going to a public access point or to the
Four Winds.

If there are no major restrictions on subleasing of leased recreation
areas, the major portion of which consists of open land, then it would
be inconceivable for another commercial-resort type of development
locating at the lake and competing with Four Winds without similar
lakeside access unless the development were non-water oriented.  If
the lake access is taken away, there should be little, if any,
incentive to locate a resort near Lake Monroe.

The State was asked if it had a master plan for development of its
property around the lake.  The reply indicated that the Department of
Natural Resources felt the Lake Monroe Regional Waste District 201
Plan was the Lake Master Plan.

The State's influence in a real estate sense is not just confined to
its properties, but has application and impact upon seasonal and
second home development expectations around the lake.  An example in
this regard is The Pointe.  The Pointe is a planned condominium
development being constructed along the northwestern shoreline of Lake
Monroe.  The shoreline is fairly wooded and The Pointe does not have
lake access.  In fact, the tree line along the shore all but hides the
view of the lake from intermediate and lower slope positions below the
tree line.  The developers of The Pointe have spent considerable
monies and taken great pains to develop key front end recreational
draws such as a tournament golf course, club house and pro-shop.  Each
phase or village within the development will have tennis courts and
swimming pools as the major attractions.  Even with these attractions,
the developers made arrangements with the Four Winds Marina (which
sits on land subleased from the State) for access to the lake for
boating and swimming.
 Telecon, with Carl North, Department of Natural Resources, State
 of Indiana.
                             4-10-3

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          Assuming there will be a limit to the number of private agreements
          that the Four Winds Marina can make, the combined draw of The Pointe
          recreation and water access will make it extremely difficult for other
          developers to compete with it, since later developments will probably
          not be able to emulate The Pointe's fortuitous position, i.e., not
          able to overcome this competitive advantage, unless the State
          subleases additional lands.

          If there are to be no more subleases and arrangements for private lake
          access, then all subsequent developers will have to appeal to a market
          of persons prepared to drive a considerable distance to a lake that
          they cannot see or directly use, except at public facilities, the use
          of which will probably be self-governing due to congestion that will
          discourage use somewhat.

10.3       SEWER SYSTEM DEVELOPMENT

          Basic to the question of servicing Lake Monroe is the question of how
          such a system might develop.  Sewer systems are not developed in a
          vacuum years in advance of actual need.  Nor are systems conceived,
          designed, funded and constructed overnight.  The regional system
          proposed around Lake Monroe in the 201 Plan consists of a force main
          with each individual proposed development served by a lift station,
          lifting the sewag;e up the hill.  A force main is pressurized, and
          access is limited to points where sewage may be injected into the
          system.  This would tend to effectively limit the size of developments
          around the lake t:o large ones.  It is not likely that small
          developments would be able to pass through pump station and other
          associated costs onto the cost of housing as effectively as large
          scale developers.

          Except for public recreation areas and facilities and The Pointe
          seasonal development, there is no current or near term demand for a
          regional collection system around the entire lake.  Of the
          developments proposed around the Lake, few if any are located near
          enough to one another to easily support a regional collection system.
          The collection system would have to pass through large sections of
          open land with little prospect of picking up additional flows along
          the way.  Few, if any of these seasonal projects, can at this time
          produce even a tentative time table or development schedule.  In fact,
          no one can say with certainty, if or even when, these projects will
          ever be constructed, although it seems safe to conclude that The
          Pointe will be completed.

          This means that the lakewide system as proposed in the LMRWD 201 Plan
          would have to develop internally with each development culminating in
          either a package treatment plant or connection to the regional
          collection system, if accessible at that time in that area.  This will
          increase the total economic cost of the system since the temporary
          sewage treatment costs will have to be quickly written off.  The
          financing of such a system has to be tenuous when one considers that
          potential customers along the way may not be ready to participate at
                                        4- 10-4

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           the time the collector system is being financed,  or that if one or two
           developments along the system have financial difficulties or fold, the
           costs  would then be picked up by few users.

           The U.S. Forest Service is in a position to  influence the routing and
           timing of interceptor development, and it has gone on record as
           intending to withhold permission for sewer line easements across its
           property.  In some cases,  this will merely mean rerouting, in others
           it might mean that no service can be provided.

           The west side of the lake  has been shown to  be more suitable for
           development because it is  more accessible; the general terrain is more
           amenable for development;  and temporary sewerage service is now
           available there.  Three of the five seasonal developments proposed on
           the south side of the lake could pump their  sewage up and discharge
           effluent out of the lake basin without having to construct an
           expensive collection system.   Such an opportunity is not possible on
           the north and west side of the lake.  The proposed development around
           the causeway near Paynetown recreation area  is physically located
           closer to the existing Winston Thomas treatment plant than to the
           proposed Salt Creek site,  but drains toward  the lake.

           Even if the sewers were to be constructed, there is no guarantee that
           every  seasonal development proposed for the  lake will in fact be
           constructed.  Rather, this will depend more  upon the market demand and
           the money market for seasonal housing.

10.4       PROJECTED LAND USE PATTERNS/ZONING

           No real pattern has developed to date around Lake Monroe.  The lack of
           an overall coordinated land use plan for Lake Monroe is detrimental to
           orderly development in light  of the intricate web of governmental,
           quasi-governmental, and private interests in and around the lake.
           There  is not a single level of government that is not intricately
           involved in Lake Monroe's  development; and yet there is not one single
           agency or mechanism that can  guarantee or ensure such coordination at
           this time.

           The actual responsibility  for land use planning and the legislative
           controls rests with the Monroe County Planning Commission.  The Lake
           Monroe Regional Waste District, a single purpose agency responsible
           for utility planning and development, has taken the role of the lead
           agency in fostering coordinative land use planning.  This agency
           contracted with the Indiana University of Public Affairs to prepare an
           environmentally oriented land capability plan for eventual use by
           local  officials.  This plan reportedly will  show how to best plan for
           the long term use and enjoyment of the land  compatible with continued
           beneficial use of the lake.  Unfortunately,  this material is only
           approaching the stage where it can be utilized in land policy planning
           efforts; and this report must precede those  efforts.
                                         4-10-5

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The Monroe County Zoning Ordinance is the land use control document  in
effect around the lake.  This document was prepared after the Lake
Monroe 201 plan, but the zoning pattern does not particularly
correspond to or reflect the sewer plan, except in some isolated
spots.

The land surrounding Lake Monroe is zoned for a wide variety of
activity patterns.  Most of Salt Creek and Polk Townships are located
within a Forest Reserve Zone.2  The intent of this zone is to include
rough terrain and also publicly owned forest land.  While these
townships are almost exclusively zoned for reserve usage, which is
quite restrictive in its standards, huge tracts of land within this
reserve are set aside for business, presumably to allow for planned
developments and commercial recreational activities within these two
townships.  The largest business districts correspond roughly with the
Graves-Monroe-Inland Steel tracts near the north end of the causeway,
and Tan-Tara on the south side of the causeway.  Neither of these
projects now have a definitive time schedule.  It would appear that
the force main needed to serve these units will require an easement
across Federal Forest Land, unless the Moore Creek inlet on Lake
Monroe is to be crossed nearer the Paynetown recreation  area.  The
county zoning plan requires a minimum lot size of 4.5 acres in this
forest reserve, and the county health department requires a permit for
lots under ten acres in size.  Within the business district,
residences may be built at a density of 6 units per acre with public
sewers.

Most of the remainder of the lakefront within Clear Creek and Perry
Townships is zoned for residential usage with .4 acre lots allowed
with community water systems and on-lot sewerage;, and .8 acre lots
with on-lot water and sewer systems.   The only substantial sized
business district here adjoins the Fairfax recreation area .and
Harrodsburg.  What fostered this delineation of these two districts in
this location is not known.  The Consultant has no knowledge of
specific developments proposed here.   It is interesting that the only
planned unit development under construction in the county was not
zoned similar to the many other potential seasonal developments
located around the lake which were zoned for business.

Another curious zoning district configuration is the noticeable lack
of an agricultural district within the Lake Monroe area except for the
property immediately surrounding The Pointe.   Considering the
potential for sewering this area, it would appear that this would be a
prime area for additional development.  The intent of the agricultural
district is, according to the County Zoning Ordinance,  to provide
areas in which little or no urbanization has occurred or is likely to
occur in the near future.  Lots used for residences in the
agricultural district would have to be the same size as in the Forest
Reserve District, 4.5 acres.
 Monroe County Zoning Ordinance

                               4-10-6

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          The remainder of  the land is residential!;?  zoned.  The  intent  of  the
          residential zoning is either to include, areas that can  be  served  by
          water and sewage  utility systems, principally near state highways and
          present urban centers, or to include areas  that have been  subject to
          urbanization on a scattered pattern, principally along  county
          highways.

          Under the terms of the county zoning ordinance, approximately  16.5
          square miles of land around the lake is zoned for residential  use; 3.5
          for agricultural; 25 square miles for forest reserve; and  about 3
          square miles for  business.  Under the present zoning umbrella, some
          13,200 lots could be spread out on these 16.5 square miles supporting
          some 32,000 to 40,000 people, with on-lot sewers and septic tanks
          flowing into rather unsuitable receiving soils.

1Q5       PHYSICAL CONSTRAINTS

          The lake is assumed to have an absolute limit in terms  of  recreation
          carrying capacity although this limit has not yet been  ascertained.
          Some sources have indicated that based upon certain standards  of  boats
          per acre of water, the lake is now overutilized.  The Department  of
          Health has evidently held off issuing permits to discharge effluent
          into the lake.  Statements have been made that the lake is
          environmentally phosphate sensitive.  Land activities such as  clear
          cutting for development and exposing unstable and easily erodable
          steep soils, if uncontrolled, will only increase the potential for
          soil erosion and  sedimentation.  Once areas are developed, additional
          nutrients will be derived from fertilizer runoffs, etc., even  if  the
          sewage problem is solved.  Development not sewer connected will only
          increase the potential for groundwater seepage and lake pollution.  As
          more development  occurs, it is probable the usage of the lake will
          increase.  With increased boating, the chance for wave  and bank
          erosion and oil spill finding its way into the reservoir becomes  more
          likely.

          With few exceptions, the general landform, geology, topography soils
          and rather poor road structures would not be considered conducive to
          normal construction and development.  The road pattern  is  almost
          exclusively restricted to the ridges, since the impoundment covers the
          former valley floor.

          Lake Monroe's soils are severely restricted in terms of development of
          new highways, basements, and on-lot septic systems.  The major
          limiting factor is the steep slope, and the next is shallow bedrock
          conditions.  The  Lake Monroe terrain is quite rough and steep, and
          highly credible.  The area's present land use is predominantly
          woodland.  Any changes in land use are bound to have more  of a
          physical Impact here than elsewhere on less sloping lands.
                                        4-10-7

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          It is anticipated that ongoing land capability studies and future
          models will better pinpoint the specific limiting parameters of the
          environment at Lake Monroe,  The environmental capability plan is a
          forerunner in this regard, and is expected to culminate in the
          adoption of additional environmental constraints and controls on
          development designed to protect the quality of the lake and its
          environs.

1Q.6       DISCUSSION OF SECONDARY IMPACTS

          The secondary impacts from the proposal generally fall into one of two
          categories, physical or fiscal impact.  The physical impacts relate to
          changes as they result from cutting of vegetation, clearing and
          improvement of land, paving over of pervious soils, reworking the
          landscape, changes in density of population and their effects on
          traffic, sewage flow, water usage, increased demands upon lake usage,
          fertilizer runoffs, etc.  The fiscal impacts include all the increased
          demands upon municipal services and facilities resulting from the
          development.

          Fiscal impacts are normally evaluated in a cost-benefit analysis
          wherein the incremental changes in revenue of a development are
          evaluated against the incremental Increases in the cost of government.
          Normally, in a community development cost-benefit analysis, the number
          and type of housing units planned are of paramount importance, since
          this has a direct bearing upon the family size, the number of children
          and their impact upon the school system.  The latter usually comprises
          the major share of total municipal expenditure, sometimes reaching 75Z
          of the total expenditure.  Data shows that, for example, apartments
          will generate less school children for each similar size unit than a
          single family house.  In addition, the larger the housing unit the
          greater the expectation for more school age children.   The remaining
          municipal costs often are considered on a per capita basis.

          Rut second and seasonal home developments do not fit well into a
          normative cost-benefit analysis.  Each such analysis must be tailored
          to each specific plan, and a picture of local services and financial
          structure.  In seasonal developments, school age children become less
          of an issue since so few of these units will become occupied year
          round by families with small children that will enter the local school
          system.  Without entering Into a detailed set of calculations, resort
          and seasonal developments accrue taxes to the school system without
          the concomitant Influx of students, and therefore usually overshadow
          other municipal cost considerations, such, as road and bridge
          maintenance, other public works, hospitals, fire protection, police
          protection.

          The shortcoming of most cost-benefit analyses is their preoccupation
          with the operational stage of development while often ignoring the
          initial capital expenditures that such developments may foster, suck
          as new road, storm sewers where not previously present, etc.
          3
           Cost Revenue Impact Analysis, Urban Land Institute, June 1975.

                                        4-10-  8

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           Without a fairly definite plan to peruse, it is difficult to forecast
           the magnitude of demand for services and facilities that might be
           generated by these proposed lakeside developments.  In fact these
           developments could be augmented or diminished overnight to change the
           picture rapidly.  With seasonal housing, the length of occupancy and
           type of covenants and restrictions on subleasing are also critical in
           determining equivalent demands upon municipal services.  The Lake
           Monroe area does not appear as an area having much in the way of a
           four season attraction, having little to offer in the winter.
           Therefore, less than full year-round occupancy probably could be
           anticipated.

10.7       IMPACT OF NOT SEWERING LAKE MONROE

           The impact of not developing the force main interceptor and providing
           regional sewer service will fall mainly upon the expectations of the
           larger developments proposed around the lake.  It is the large scale
           developers who stand to benefit by such a system, and conversely, get
           hurt if it is not built.

           The physical nature of this regional system encircling the lake would
           essentially limit individual lot by lot hook-up, since a pump station
           would be needed.  This means that certain population levels would need
           to be reached before pumping can become economical to the lot owner or
           small developer.  The lack of service would probably be no more
           limiting than a regional force main.

           The Pointe development did not wait for the regional system and
           thecefore gained permission to build package treatment plant and
           discharge into Clear Creek.  Design plans are now underway to add
           the Fairfax Recreation Area to the Caslon package plant, thereby
           eliminating the most significant sewage discharge to Lake Monroe.
           This plant might relieve the development pressure from other lake
           locations for the interim period, since it could serve this area
           that has the more amenable landform and better potential for
           development.
                                         4-10-9

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                                     TASK 11

               MITIGATIVE MEASURES FOR MINIMIZED PHYSICAL EFFECTS


11.1      CONSTRUCTION ACTIVITIES

11.1.1    Revegetation

          For right-of-ways, it is desirable to maintain low growing vegetation
          that will allow for easy access to the area and at the saae time
          prevent undesirable native vegetation from overgrowing the area.
          Dr. Marion T. Jackson, Professor of Life Sciences at Indiana State
          University, offered the following information on plant species which
          could be used to revegetate the area.

          "1.  If it would survive that far south, Sweetfern, Myrica
               asplenifolia, would be a strong choice.  It is characteristic of
               the Indiana Dunes area where it covers extensive areas,
               particularly in combination with bracken fern, Pterldium
               aquilinum.  Myrica is presumed to be a nitrogen fixer, which
               would enhance its value as a site-recovery shrub species.

          "^*  Corylus americana (American hazelnut) and Ribes cynosbati
               (pasture gooseberry) are shrubs with wildlife value, and possible
               cover species.  Both occur in extensive stands when well
               established.  Corylus grows quite tall on better sites, but
               usually reaches less than a meter on poor soils.  Both species
               are found throughout Indiana.

          "3.  Ceonothus americanus (Jersey tea) does well on dry sites where it
               grows less than a meter tall.  It has possibilities as a cover
               species, but I doubt that it would exclude tree seedlings or
               other later successional species.

          "4.  Two species of shrubby dogwoods offer promise.  Roughleafed
               (Cornus asperifolia) is a wet site species for the most part
               where it grows quite tall.  Gray dogwood (C. racemosa) is found
               in both wet and dry sites, but is more common in N. Indiana than
               in the south.  It is generally of a shorter stature (1-2 m) than
               roughleaf dogwood.  Either would be an interesting species for
               trial plantings.

          "5.  Coralberry (Symphpricarpos orbiculatus) occurs in extensive
               stands in both full sun and under thin forest canopies.  The
               limber shrub is usually less than a meter tall.  This species
               seems to be one of the strongest candidates for utility corridor
               plantings.
                                      4-11-1

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          "Other possibilities  include Lonicera japonica (Japanese honeysuckle)
          although I personally prefer native to exotic species.   Also, the
          honeysuckle often gets out of hand and spreads flagrantly.   Some of
          the greenbriers (Smilax)  could be used, but they often grow in nearly
          impenetrable tangles.  Perhaps such species could be used to impede
          the corridor construction crews!"  Reference:  Jackson, M., 1975,
          personal communication.

          Before the construction begins, the Consultant recommends that an
          Indiana botanist such as Dr. Jackson be consulted.

          In the case of revegetation to prevent erosion of areas disturbed by
          major excavation and  grading activities, the objective is to select a
          grass or group of grasses which germinate quickly.  Pasture grasses
          which are known to grow well in the area include alfalfa, red clover,
          broome grass, tall fescue and orchard grass.

11.1.2    Pipe Crossings in Stream Beds

          Type of Site:;

          1.   Rock strata, gradually sloping banks, rocky stream bed.
               Generally found  in upper drainage area.

          2.   Alluvial stream, high banks, significant depth to rock strata
               under stream bed.  Generally found in lower drainage area.

          Comments:

          Type 1 is a young stream, with high velocities during floods, steep
          slopes.  Large rocks  are transported by flow, and bars may form at
          various locations and move along the stream.

          Type 2, in alluvial material, is probably meandering.  Difficult to
          predict future stream channel alignment.  Bed is made of fine
          material.  Significant scour during runoff events.

          Suggestions for Minimizing Environmental Impact

          1.   Conduct construction operations during dry weather when stream
               flows are low, on the average.

          2.   Store excavated  material on stream banks, outside of stream bed
               and above anticipated flood level for mean annual flood.

          3.   If stream is flowing, consider a downstream rock dam, possibly
               with a filter layer on the upstream face, to prevent downstream
               movement of material.
                                      4-11-2

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          4.    In Type 1 stream, excavate pipe into rock strata, blasting if
               necessary.  Use selected fill, topped with native stream bed
               stone.   Keep top of pipe 1 ft. below normal stream bed, as a
               minimum.

          5.    For Type 2 stream, especially if banks are high, consider the use
               of a pipe bridge, rather than burying pipe.  These streams are
               generally unstable and scour or meandering may expose buried
               pipe.  Keep pipe bridge foundations away from stream bank as far
               as possible.

          6.    If pipe is buried in a Type 2 stream, bury deep enough that
               general scour during floods will not disrupt pipe.

          7.    During trenching, consider dikes to divert one-half of the stream
               around construction, fill, and perform construction on other
               side,  A better method would be to divert entire stream around
               construction area until backfill is completed.  If dikes are
               used, hydrology of area should be re-evaluated to determine
               optimum duration of construction.  Stability of materials should
               be evaluated with respect to erosion and slippages.

          8.    Replace stream bed in as near its original condition as possible.

          9.    Protect disrupted banks with mulch or temporary lining (jute
               mesh, etc.).  Seed with native vegetation.  Re-establish vegetation
               as soon as possible.

          10.  In severely disrupted areas of the stream bank, consider the use
               of rock riprap to prevent erosion.

11.1.3    Pipes Laid Parallel to Stream Banks

          In general, follow good construction erosion control practices.

          1.    Keep excavation as far from stream bank as possible.

          2.    Use ditch checks in sloping areas to prevent erosion along pipe
               trench.  Checks may be of any less credible materials such as
               clay.

          3.    Seed, mulch, and re-establish native vegetation as soon as
               possible.

          4.    Use temporary linings such as jute mesh in steep areas.

          5.    Use temporary sediment basins to collect sediment in areas where
               runoff is concentrated.  Hay bales could be used in some
               instances to form temporary dikes.
                                      4-11-3

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          6.   Avoid disrupting or intercepting natural drainage areas.  Bury
               pipe deep enough to return bed to original elevations.

          7.   Keep excavated material away from stream channel, and revegetate
               d isrup t ed areas.

          8.   Leave existing vegetation on all areas where possible until
               necessary to remove to grade for construction.

          9.   Stockpile topsoil to be spread on surface when preparing final
               grade.

          10.  Use temporary seeding on areas that must be scalped but will not
               be finished for a period of time.

11.1.4    Channel Relocations

          This is a difficult problem, because when a stream channel in alluvial
          material is disrupted, it will usually cause a reaction at some other
          location, such as headcutting, general channel erosion, deposition, or
          new meandering.   There is no particular problem in nonerodable stream
          channels except  for the disruption of the aquatic habitat and sediment
          production.

          In an alluvial channel, the relocated channel should have the same
          characteristics, as far as possible, as the channel which has been
          replaced.  For example, if the new channel is shorter than the old
          channel, the friction slope will increase and erosion will occur.
          Thus, a solution would be to add riprap to increase friction losses in
          the new channel  and protect the bottom.  Generally, riprap channels
          are quickly rehabitated by aquatic organisms and haive a somewhat
          natural appearance.  The use of smooth concrete channel linings for
          relocated channels should be avoided.  Ideally, the relocated channel
          should have as near as possible the same length, bank width, and bed
          features as the  old channel.  Since this is not possible, one should
          isolate the main considerations and study each separately and as a
          combination.  The principal considerations for diversion locations
          are:

          1.   Outlet conditions

          2.   Topography

          3.   Land use

          4.   Agricultural operations

          5.   Soil type

          6.   Length of slope

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          The design of a diversion involves:

          1.   The above generalities

          2.   Velocities as high as possible but not eroding

          3.   Grades dependent on site

          4.   Peak runoff capacity dependent on site

          5.   Appropriate friction coefficients

          6.   Available construction equipment

          Finally, they should be inspected annually and after heavy floods.

          Suggestions for Minimizing Environmental Impact

          1.   Conduct operations during dry period when stream flows are low.

          2.   Replace old channel in kind, and design based on river mechanics
               to transport sane sediment load.

          3.   Store excavated materials outside flood levels (mean annual
               flood).

          4.   Consider use of open graded rock dam with filter material on
               upstream face to prevent downstream movement of sediment.

          5.   After construction, seed, mulch, and revegetate disrupted areas.
               Use temporary linings or riprap as necessary to prevent erosion
               in channel.

          6.   Use standard erosion control measures as necessary:

               Ref:  "Guidelines for Erosion and Sediment Control Planning and
                    Implementation"  EPA-R2-72-015, U.S. Environmental
                    Protection Agency, Washington, D.C.  August 1972.

                    "Erosion Control on Highway Construction Projects"  Project
                    20-5, Topic 4-01, Natural Cooperative Highway Research
                    Program, Highway Research Board, Washington, B.C., Draft
                    January 1973.

11.1.5    Tunneling Operations

          Environmental impact should not be serious.

          Generally:

          1.   Dispose of excess material in an acceptable manner to prevent
               erosion and downstream sediment problems.  Example, outside
               stream flood plains, revegetate, no steep slopes.

                                      4_ 11-5

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          2.    Revegetate disrupted areas,  or protect with artificial materials
               to prevent erosion.

11.2      PLANT OPERATION ACTIVITIES

11.2.1    Sludge Disposal by Land Application

          Minimizing the adverse environmental impact which could result if
          excessive amounts of sludge were applied on land is contingent on
          proper application rates.  It is recommended that a research project
          be conducted to determine the best application rates for sludge
          produced at the plant when it is constructed for the different soil
          types on which it will be applied.

11.2.2    Odor Control

          Control of odors at wastewater treatment plants is of utmost
          importance particularly when communities are located near the
          treatment plant.,  This has been an occasional objection to the Winston
          Thomas treatment: plant.  Sources of odors include the following:

          1.    Grip and grit chambers both in and out of service.

          2.    Septic wastewater screenings and grease at wetwells.

          3.    Pre-aeration tanks in which odorous gases are stripped from
               wastewater.

          4.    Primary settling tanks where gasification of sludge may be caused
               by infrequent sludge withdrawal and floating solids.

          5.    Biological facilities in which aerobic conditions may not always
               be maintained.  Causes such as clogged diffusers in aerators or
               surcharged air-intake channels should be identified.

          6.    Tank walls, open channels, boxes and pits which are cleaned
               infrequently.

          7.    Secondary settling tanks with accumulations of floating solids.

          8.    Over chlorination.

          9.   Oxidation ponds with odorous sludge accumulations.

          10.  Digesters of the anaerobic or aerobic type in which optimum
               conditions have not been maintained.

          11.  Sludge holding and thickening facilities in which the contents
               are not aerobic.
                                      4-11-6

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12.  Sludge dewatering facilities processing odorous sludges.

13.  Incinerators that have exit gas temperatures below 1400°F.

The existing plant is overloaded.  The new plant will not be
overloaded; and, furthermore, it will use the activated sludge process
with denitrification which will lend itself to better controls and
efficiency of operation.  If odors should develop at the new plant,
the following mitigative measures will be used:

1.   The first control strategy will evaluate physical and chemical
     control measures that are permanent and effective in reducing
     odors below the detectable level at the plant property line.
     These may consist of:

     a.   Oxidation by chlorine, ozone, or hydrogen peroxide.

     b.   Chemical precipitation of sulfides.

     c.   Treatment of liquors such as supernant, centrate, filtrate,
          and thickener overflow with lime powdered carbon, or
          chemical oxidants.

     d.   Adjustment of loadings upon all biological facilities to a
          level not in excess of design capacity.  This may include
          requiring pre-treatment of strong industrial wastes to an
          acceptable strength.

     e.   Maintaining optimum operating conditions in all treatment
          facilities.

     f.   Installation of environmental enclosures as required.
          Filter and scrub air prior to discharge to atmosphere.

2.   The second control strategy will evaluate corrective measures to
     be implemented should an odor episode occur such as killing of
     biological processes by toxic substances.  These corrective
     measures may include:

     a.   Staffing and equipment to identify sources and causes of
          odors either at the plant or at the discharge source
          responsible for the odor

     b.   Masking of odors

     c.   Emergency chemical treatment

     d.   Interim modification of plant operation
                            4-11-7

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11.2.3    Disinfection of Treated Sewage Effluent

          Because of the possibility that chlorinated effluent could contain
          toxic compounds which would reach the water supply of Bedford, 13
          miles south of the Lake Monroe dam, it may be desirable to choose an
          alternative disinfection system.  It is recommended that chlorinated
          sewage from the Winston Thomas plant be analyzed by gas
          chromatographic mass spectropholometric (GC-MS)  techniques to
          determine if potentially toxic compounds are present.  The results
          should be compared to unchlorinated sewage at Winsiton Thomas to
          determine which compounds result from the addition of chlorine.  The
          Environmental Protection Agency's laboratory in Athens, Georgia may be
          commissioned to do the GC-MS work.   If toxic compounds are detected
          alternative disinfection agents which should be considered include:

          1.    Ozone

          2.    Bromine chloride

          3.    Chlorine - sulfur dioxide (i.e., chlorinatiori - dechlorination)

          4.    No disinfection

11.2.4    Visual Impact

          The visual impact: of the plant sites can be mitigated by redesigning
          the landscape features,  creating berms from site excavated materials
          and by strategically locating these berms where  they will minimize the
          more unsightly visual elements of the plant site.   Much of this can be
          done in conjunction with rechanneling, floodproofing and soil erosion
          and sedimentation control activities.  In addition, trees and natural
          vegetations make ideal foils to hide unsightly views.  The added
          benefit resulting from carefully designed mitigative efforts will be
          better noise control, since noise travels on a lirie-of-sight.

11.2.5    Clear Creek Recreation

          Reference has been made to the fact that Clear Creek is sometimes used
          for non-white water leisure type canoeing, and as  such, is one of the
          few creeks in the area with enough  flow for canoeing.  While the
          Consultant was unable to substantiate this claim,  it is quite certain
          that with the Salt Creek site configuration in low flow periods such
          as  the summer, there will not be enough water in Clear Creek to
          support canoeing since most of the  flow now in the summer consists of
          effluent.  The only way to remedy this would be  to augment Clear Creek
          flow upstream with dams, etc., which is not likely to happen.
                                     4- 11-8

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11.2.6    Zoning
          The non-structural mitigative measure with the greatest potential for
          easing land use frictions which are more apparent during the
          operational stage is the standard zoning ordinance and the floodplain
          ordinance.   Most sewage treatment plants are located in or near the
          flood plains, since a low-lying location is necessary to facilitate
          gravity flow and to provide for ready discharge to a waterway.  This
          location is less than ideal for residential locations since they
          normally can less afford expensive flood protection devices.  A
          floodplain ordinance can restrict and control floodway and floodway
          fringe development.  Such a provision is incorporated into the City of
          Bloomington's zoning ordinance which would affect the Winston and
          South Rogers sites.  The county zoning ordinance, applicable to all
          other sites, does not have a similar provision.

          Rarely is a sewage treatment plant located in the middle of an
          existing residential development.  Usually the plant is located prior
          to residential development.  One aspect of zoning that can be used to
          ensure that this situation is controlled to require that sewage
          treatment plants, because of their unique operating conditions, come
          in for a special exception or a conditional use permit.  Usually this
          requires that special preconditions be met in the course of plant
          location such as extra wide setbacks and yards, and the special
          exceptions procedure usually requires a public hearing and public
          notification of adjoining property owners as a prerequisite to any
          hearing.  The Bloomington Zoning Ordinance is silent with respect to
          sewage treatment plant locations and does not precondition or make
          special exception to plant location, while the county zoning considers
          the sewage treatment plant as a special exception and requires open
          and unutilized yards having 300 feet depth as its sole condition.

          Probably the most pertinent aspect of zoning in relation to mitigating
          the effects of sewage treatment plants would be to zone the site and
          immediate area for other than residential uses to ensure that people
          do not build at the edge of sewage treatment plants.  This would
          protect people from making poor locational decisions that they may
          later regret, and then use pressure to work for the removal of sewage
          treatment plants, pump stations, or other utility facilities.

          The Dillman and Ketcham Road sites are protected from residential
          encroachment.  Both are located within a rather large industrial
          district that does not allow location of residences therein.  At Salt
          Creek, the land is zoned for residential usage, which under the
          provisions of the Monroe County Zoning Ordinance allows for a variety
          of residential housing types ranging from single family to apartment
          units depending upon the availability of public sewerage.  While it
          seems unlikely that residences would be constructed in this poorly
          drained bottom land, the current zoning ordinance would, on the face,
          allow such a condition to develop.
                                      4-11-9

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The Rogers Site is apparently not zoned.  The County Zoning Map shows
it within the city's jurisdiction, and the City Zoning District
boundaries terminate at Gordon Road.  This should be rectified.

The development pattern around the Winston Thomas site is fairly well
established and would probably not be affected by any change in zoning
designations, although redesignation of the low density residential
strip bordering the northern boundary of the site might better be
classified as light manufacturing, the present site designation.
                            4-11-10

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12.1     Irreversible and irretrievable commitments of resources to the proposed
         action should it be implemented.

         Two classes of irreversibillty and Irretrievability need to be identified
         in evaluating the commitment of resources.  Class I is the irreversible
         and irretrievable decisions that cannot be reversed such as the expenditure
         of energy.  And Class II commitments are the decisions to commit resources
         which are not likely to be retrieved or reversed during the useful life
         of the project.

         Class I commitments resulting from the construction of the proposed
         sewage treatment plant include the capital costs, energy, and labor
         necessary to construct and make operational the proposed facility.

         Class II commitments for the proposed STP include: the operational
         requirements of chemicals, energy, mechanical equipment, labor, the
         use of 60 acres of land zoned as industrial and the tax loss associated
         with alternate uses of the site.  Clear Creek will be relocated and
         channelized to provide maximum utilization of the Dillman Road site.
         The habitat for typical wildlife such as birds, rabbits, field mice,
         etc. will be diminished.
                                    4-12-1

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13.1     The relationship  between  local  short  term uses  of  man's  environment and
         the maintenance and  enhancement of  long  term productivity.

         The construction  and operation  of the proposed  South Bloomington Sewage
         Treatment  Plant will result  in  efficient treatment  of  sewage  generated
         in the South Bloomington  Service Area and a general improvement  in the
         water  quality of  Celar Creek and Salt Creek.  To accomplish this im-
         provement  in surface water quality  a  commitment of  energy and  resources
         necessary  to operate the  proposed facility  (flow through the  STP is
         projected  to be 15 MGD by the year  2000) and the removal from  the tax
         roles  of approximately 60 acres of  land  zoned industrial will be
         required.
                                    4-13-1

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                              CHAPTER 5
                  CONCLUSIONS AND RECOMMENDATIONS


1.  A 15 MGD two-stage activated sludge  sewage treatment  plant with
    rapid sand filters and sludge treatment  via aerobic digestion
    and centrifugation should be constructed at the  Dillman Road
    site to serve the South Bloomington  Service Area.

2.  The present 1.9 MGD diversion from the  south service  area via
    a force main to the Blucher  Poole STP should continue.

3.  The processed sludge from the proposed  STP should  not be applied
    to farmland until:  1) the extent of the PCB problem  in Bloomington
    has been determined 2) corrective actions are  taken that reduces
    the PCB levels to those determined to be safe  for  agricultural
    application.  When the PCB problem is resolved,  land  spreading
    of the sludge on farmland at agronomic  rates consistent with
    Federal and State of Indiana regulations for land  application
    is one recommended alternative.   The composting  operation that
    presently utilizes some of the Winston  Thomas  (W.T.)  sludge
    should be sampled to determine if heavy  metals or  PCB's due to
    the W.T. sludge are at concentrations such that  application of
    the composted material should be  restricted to certain uses
    until the heavy metal and/or PCB  problem is resolved.  If PCB's
    or heavy metals are present  at an unacceptable level  in both
    processed sludge and the compost  product, then landfilling of
    the south service area sludge should be  practiced  until the
    nature of the sludge changes (due to pretreatment  requirements
    or changes occur in the composition  of  the sludge) so that the
    alternatives of composting and land  spreading  can  meet the
    standards promulgated by Federal  and State agencies.

4.  Regionalization of the South Bloomington Service Area and the
    Lake Monroe Regional Waste District  as  proposed  in the Bloomington
    201 plan is not cost-effective.   The Dillman Road  STP could provide
    service to the communities of Smithville and Sanders  via an 80,000
    GPD interceptor if it is determined  that this  is the  most cost-
    effective alternative.  (An  approval facilities  plan  would have
    to be completed for the LMRWD prior  to  any grant award for design
    and construction of these facilities.   Furthermore, it must be
    demonstrated that properly operated  and  maintained septic systems
    cannot function as designed  due to existing soil and  bedrock con-
    ditions.)

5.  Other areas in the Lake Monroe District  can be adequately served
    with existing and proposed facilities,  e.g. Paynetown, served by
    an existing package plant and the Caslon plant serving the Pointe
    and Fairfax.  The Caslon plant could also be expanded (if cost-
    effective) to handle a flow  from  Harrodsburg and from development
    along Old State Route 37. Another possibility,  if Harrodsburg
    would be served by the plant, would  be  to move the Caslon package
    plant to an alternate location at the confluence of Clear Creek
    and Little Clear Creek.


                                5-1

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                     CHAPTER 6

FEDERAL/STATE/LOCAL AGENCY COMMENTS AND PUBLIC PARTICIPATION
The written comments in this chapter were received or trans-
mitted during the preparation of the draft EIS.  The order
of the comments is as follows:

A) Federal, B) State, C) Local Agencies and Interest Groups,
and D) letters from individuals.
                         6-1

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A)  FEDERAL  COMMENTS
         6-2

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           Uniteb &tate* Senate
               MEMORANDUM


     Please note the attached letter from
a constituent which I am forwarding for
your consideration.  It would be greatly
appreciated if you would check into this
matter.  Upon completion of your inves-
tigation, please advise me of the status
of this case in duplicate and return the
original letter in an envelope addressed
to the attention of Parry. Sragow.

     Thank you for your assistance.

                   Sincerely,
                   Birch
                   United States '•Senator
    6-3

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                     INDIANA  UNIVERSITY

                             Department of I'liysics
                             SWAIN ItAI.L—WEST I I I
                        BLOOM I.N'CTON, INDIANA 4740
                                                              «L. NO. «i2— 337-265C
                                             November 13, 1975
Senator Birch Bayh
363 Old Senate Office Bldg.
Washington, D.C.  20510

Dear Senator Bayh:
             enclosed a copy of a letter sent to Mr. Hirt of the EPA, Region
V, in Chicago.  It is important that the full interests of the community be
considered in this matter.

     As mentioned in the letter to Mr. Hirt, some members of the Bloomington
Utilities Service Board have placed a high priority upon the economic
consequences of the delays in initiating our wastewater treatment project.
The delays reflect a long public discussion and a broad concern with the
ecological impact of the location of the treatment plant.  A priority that
is governed solely by economic concerns and not responsive to the environ-
mental considerations is, in our opinion, misplaced.

     It is important that you understand that the costs for this project
have not increased solely because of inflation.  More detailed engineering
studies and changes in the treatment ^oe± have also affected the cost esti-
mates.
     The Envi?:onmental Impact Statement being prepared >by EPA will resolve
our particular problem and bring the public debate to a conclusion.  The
citizens of the United States must have an agency that works in a responsible
manner to preserve the best interests of our land.  The economic and ecolog-
ical factors must be viewed together and properly balanced.  The Congress
has given this responsibility to the EPA and defined the Environmental Impact
Statement as one of the instruments to be used to meet this obligation.  The
EIS must be prepared carefully and completely if it is to serve its purpose.

                                        Sincerely yours,
       David L. Dilcher                 Hugh j  Martin
       Member, Utilities Service Board  Member, Utilities Service Board
       Dept. of Plant Sciences          Dept. of Physics
       Indiana University               Indiana University
       Bloomington, IN  47401           Bloomington, IN  47401. -
DLD/HJM:mlc
enclosure
                                       6-4

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                  E'"'IRONMENTAL PROTECTION
                                        DEC 10 1975
Honorable Birch Bayh
United States Senate
Washington, D.C. 20510

Dear Senator Bayh:

The Environmental Protection Agency is fully aware of the need to
address all pertinent issues in the siting of new sewage treat-
ment facilities for the South Bloomington Sewage Service Area as
indicated in the Nov. 13, 1975 letter from David L. Dilcher and
Hugh J. Martin.  To aid us in our environmental evaluation the
consulting firm, Gilbert Associates of Reading Pennsylvania, was
hired and is completing an analytical report on key issues related
to the proposed projects.  When the draft environmental impact
statement is issued, the final report of Gilbert Associates will
also be available, and a public hearing will be held to consider
all comments on these documents.

I aa also enclosing a copy of the Nov, 3, 1975 letter from other
members of the Utilities Service Board and our response of Nov* 20,
1975.  Based on the concerns of the citizens of Bloomington, it is
clear to us that the EIS process provides a viable mechanism for
resolution of these important concerns.

Your interest in this matter is appreciated and copies of the draft
and final EIS will be mailed to you when they are available.
                                  Sincerely yours,
                                       A/.
cc:  Office of Legislation
    Planning & Standards Branch
    OCIR
Valdas V. Adamkus
Acting Regional Administrator
                             6-5

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Respectfully referred to:
          E.P.A.
          Waterside  Mall
          401 M. Street, S.W.
          Washington,  D.C.  20460
Because  of the desire  of this office to be
responsive to all inquiries and communications,
your consideration of  the attached is
requested.  Your findings and views, in
duplicate form, along  with return of the
                       i
enclosure, will be appreciated by
                Senator Vance Hartke
               	ii.s.s.
                Attns Janis McClintock
                      447  Federal Building
                      Indianapolis,  Indiana
                                        46204
        6-7

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TOOK
v^Vx vyjLv.

  November 3, 1975
  The Honorable Vance Hartke
  313 Old Senate Office Building
  Washington, DC  20510

  Dear Senator Hartke:

  The Utilities Service Board of the City of Bloomington recently requested  the
  Environme*^*1-! Protection Agency to provide .information .concerning, -the, direct
  and indirect costs lpf.,,the,..Envirojimental. Impact Statement that EPA jLs.  currently
  preparing 'on Bloomington' s proposed wastewater treatment "facility.  (See the"1* ''
  attached" letter of August 21, 1975, from Utilities Project Coordinator Richard
  S. Peoples.)  As you can see from Mr. Harlan Hirt's response of September  19, 1975
  which is also attached, EPA does not seem disposed to divulge this information,
  which we feel should be a matter of public record.

  As citizens of Bloomington who are very interested in this project and as  federal
  taxpayers who are concerned with the total environmental and economic costs of
  the new wastewater treatment facility, we sincerely believe we have the right
  to know what the direct and indirect costs of the Environmental Impact Statement
  will be.  As one of our elected federal representatives, we would appreciate it
  if you would look into this matter to help us secure, this information.
  Sincerely,
  mjh

  Enclosures

  cc:  Mr. Harlan Hirt
                                          6-8

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                  ENVIRONMENTAL PROTECTION AGENCY
                                         DEC 11 1975
Honorable Vance Hartke
447 Federal Building
Indianapolis, Indiana 46204

Dear Senator Hartkez

This is in response to your request for information  concerning
a letter you received from several members of th«  Utilities
Service Board (USB) of the City of Bloonington,  Indiana.  The
Environmental Protection Agency has responded to the Cook In-
corporated letter of Mov. 3, 1975 signed by several  members of
the US3. Our response is detailed in the attached  Nov.  20, 1975
EPA letter.

During November a second letter from two other members  of the
DS3 was received by EPA.  I am attaching this letter and  the local
newspaper article which accompanied it. These letters illustrate
the differing viewpoints which exist on the USB  regarding the
preparation time for the draft EIS. EPA is concerned about project
delays but also recognizes the need to fully evaluate all alter-
natives in the proposed project and the associated environmental
impacts.

When the draft EIS is issued, the final report of  Gilbert Associ-
ates will also be available, and a public hearing  will  be held to
consider all comments on these documents.  Based on  the concerns
of the community it is clear to us that the. EIS  process provides
a viable mechanism for resolution of these important concerns.

Your interest in this matter is aopreciated and  copies  of the
draft and final EIS will be mailed to you when they  are available.
                                  Sincerely yours.
                                  R.  J.  Schneider
                                  Acting Regional  Administrator

                                       7G
         LEE  HftHH-TO*J  /fA/i>.. T&ttV Mf^KS   t*

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                    ENVIRONMENTAL PROTECTION AGE* CY
                                                        0£C   41975
Mr. Gary R. Kent
Director of Utilities
City of Bloomington Utilities
P.O. Box 1216
Bloooington, Indiana  47401

Dear Mr. Kent:

This letter is a response to your November 20,  1975  letter concerning
preliminary findings with respect to the Environmental Impact Statement
for the South Bloonington-Lake Monroe Service Area.   As you know EPA
has received a draft report from the consulting firm of Gilbert Associates
on the proposed wastewater treatment facilities.  While some revision
of this report is necessary and ongoing, a clear position with respect
to comparing the Salt Creek Site and the Clear  Creek Sites can be stated.

We will not support construction of the new sewage plant for the South
Blooaington Service Area at the Salt Creek Site in the Draft EIS.  We
have determined that three Clear Creek Sites (Winston Thomas,, Dillman
Road and Ketchun Road) are preferable to the Salt Creek Site on an
environmental, economic and geographic basis.  Preliminary present worth
analyses indicate that the Salt Creek Site is more costly than the three
Clear Creek Sites by several million dollars.
                                                        i
Furthermore, selection of the Salt Creek Site would  result In less
centralization of sewer interceptor facilities, extensive disruption of
the Clear Creek stream banks, a poorer quality  effluent, a less reliable
sewage treatment facility, and might cause an acceleration of the
development of the Lake Monroe Area prior to a  full  opportunity by the
local planning commission, with appropriate citizen  input, to discuss and
evaluate land use options for the Lake Monroe Area.

I wish to point out that the above position la  not a final determination
by EPA which can only be taken in the Final EIS after reviewing and
responding to agency and public comment.  Our present analyses indicates
that the Salt Creek Site is not cost-effective  and is not the optimum
environmental alternative.  We cannot advise you on  the manner In which to
respond to your purchase option on the Salt Greek Site.  This letter can
only identify the position that will be presented in the Draft EIS.
                                         6-10

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                                                    DEC  41975
Mr. Gary R.  Kent
Page Two
When the Draft  EIS Is Issued, the final report of Gilbert Associates Will
also be available and a public hearing will be held to consider all
comments on these documents.

                                  Sincerely yours,
                                  Valdas V. Adankus
                                  Acting Regional Administrator
                                     6-11

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                             November 20, 1975
Cook Incorporated
925 South Curry Pike
P. 0. Box 439
Blooraington, Indiana 47401

Gentlecten:

Ue have received your latter of November 3, 1975 regarding
costs of preparing the SIS for the Bloowdngton project and
are responding within tha procedures of the Freedom of In-
forraation Act.

Ky staff advises that tha Utilities Service "oard and others
involved in the Bloomin^ton EIS have provided excellent co-
operation.  We dafinitaly want to continraa in that spirit of
cooperation.  Unfortunately, r-ost of tha information. yon ara
requesting is not available without consujaing a sraat deal
of effort in additional study and would require a mmber of
8tiV]octi79 fi3suRption3 which would lo.ive a ^ood bit of douht
as to th* ras'.ilt*  £a ainply do not have tha r-aapover to con-
duct such n study.

The only readily available feet in response to your requast
is that our contract on the EIS io for $32,690.  VJe estioate
we cay Jarvota approximately one tr.an-year of in-house effort
at an estimated cost of about $16,000.

Although we recognize that compliance with the National En-
vironmental Policy Act does involve delays when Inpact State-
ment preparation is initiated late in the planning process,
it was our judgment that the Sloosdngton proposal required
an EIS to satisfy the statute.  Wa also feel thnt the poten-
tial savings in environmental irepact and dollar costs out-
weigh the potential costs of lost tine.

I trust f:hat through continuing cooperation we can bring tha
process to a rapid conclusion and nove forward to design and
construction at an early date.

                                 Sincerely yours,
HDTIirf.p™ 11/20/75
                                 Ilenry L. Longest II
                                 Director,, Water Division
                          6-12

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.                           UN1TED STATES         •
Ti                ENVIRONMENTAL PROTECTION AGENCY

                        23° SOUTH DEARBORN ST.
                        CHICAGO. ILLINOIS 60G04
                                September 19, 1975
        Mr. Richard S. Peoples, Project Coordinator
        City of Bloomington Utilities
        P. 0. Box 1216
        Bloomington, Indiana 47401

        Dear Mr. Peoples:             •        •             .

        In your letter of August 21, 1975, you requested direct and
        indirect cost data to all parties related to the prepara-
        tion of the Bloomington-Lake Monroe Indiana Draft and Final
        BIS.  First, let me identify that the decision to do an
        EIS on a proposed project is not based on direct or indirect
        costs, but on whether or not the proposed Federal action
        (in this case a grant award for construction of wastewater
        treatment facilities) is a major Federal action signifi-
        cantly affecting the quality of the human environment (NEPA
        Section 102(2)(c)).  Furthermore, the final regulations
        for Preparation of Environmental Impact Statements of EPA,
        40 CFR Part 6, April 14, 1975, Sections 6.200 and 6.510,
        identify criteria for determining when to prepare an envi-
        ronmental impact statement.
                                                    i
        With respect to the Bloomington-Lake Monroe, Indiana pro-
        ject, it was apparent to EPA, based on the NEPA Act and our
        regulations, that unresolved environmental concerns, such as
        the optimum location for a new wastewater treatment facil-
        ity existed and could most efficiently be resolved through
        the environmental impact statement process.  As you know,
        both the Bloomington Utilities Board on April 4, 1975 and
        the Mayor of Bloomington on April 10, 1975 officially re-
        quested an EIS for the proposed project, being aware that
        the EIS process generally takes 8-12 months until a grant
        award can be made.

        Once a Federal agency or a Federal court has declared that
        an EIS is required, the time period necessary to complete
        the EIS process is considered an essential step for the
        project to proceed.  (The courts have, in fact, stopped
        construction of nuclear power plants, etc., until satisfac-
        tory EIS was prepared.)
                                  6-13

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                      .  -2-

The EIS process also provides the public a greater oppor-
tunity to identify their concerns and have their concerns
addressed in a written document subject to review by the
public, local, state and Federal agencies.

In the environmental impact statement EPA will address
costs through the cost effective analysis required under
P,L. 92-500.  The cost effectiveness analysis with proper
concern for environmental impacts will be the basis upon
which a specific recommendation for wastewater treatment
facilities will be made.  Direct and indirect: costs assoc-
iated with the project will not be identified unless they
relate specifically to the cost effective analysis re-
quired under P.L. 92-500.

                          Sincerely yours,
                          BarIan D.  Hirt
                          Chief, Planning Branch
                          6--14

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B)  STATE COMMENTS
        6-l5

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STATEr
                                                           INDIANAPOLIS, 46204
   DEPARTMENT OF NATURAL RESOURCES

            JOSEPH D. CLOUD
               DIRECTOR
    September  12,  1975
    Mr.  Dale  Luecht
    Project Officer
    Environmental Protection Agency
    230  South Dearborn Street
    Chicago,  Illinois   60604
    Dear  Mr.  Luecht:

    We have reviewed  the proposed wastewater  treatment  facilities  to  serve  the
    South Bloomington-Lake Monroe area and find that  no known historic  sites
    will  be effected.

    This  area has not been surveyed and if you find that your project has a
    direct effect or  is in close proximity to any older structures, please
    contact us at the earliest possible time.
I understand that you have already been in contact with the Glenn A.
Archaeology Laboratory about archaeological sites in the area.  Any
recommendations they forward should be included in your assessment.

Very truly yours,
                                                                         Black
    J/bs-ephlD.  Cloud,
          !»r
       irtment of Natural Resources

    JDT;:EG:jm
                                                       rr F i v
                                              rLAJ.ViVl.JVjr
                                              f'l. •
                                      6-16

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C)  LOCAL AGENCIES' AND  INTEREST GROUPS' COMMENTS
                   6-17

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            CITY OF BLDDMINbrDN  UTILITIES

                            P. D. BOX 1216

                      BLDDMINGTON, INDIANA 47401
                          TELEPHONE AC 812 339-2261

                         November 20, 1975
Dale Luecht
Planning
U.S.. E. P.A.  Region  V
230 South  Dearborn
Chicago, Illinois   60604

Dear Mr. Luecht:

     During  the  past  few months, we have stressed the
importance of the completion of the draft EIS prior to
December 12,  1975 as  the City has  invested and stands
to lose  some  $20,000  on land options at the proposed
Salt Creek site.  I realize that it is impossible for
you to issue  the draft EIS by December 12th.

     It  is imperative that we receive as much advise
and assistance as possible from your agency prior to
the expiration of these options.  Therefore, we are
hereby requesting that you consider our situation and
its urgency.   We do need guidance from (E.P.A. so that
the City can  decide whether it should exercise, renew,
or drop  the  options on the Salt Creek site.

     Any assistance you can give will be most appreciated

                     Sincerely,
                     Gary R. Kent
                     Director of Utilities
GRK/sew
cc: Utilities  Service  Board
    Richard Peoples, Project Coordinator
                      6-18

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                 T'TY  DF BLDDMINGinN  UTILITIES

                                 P. 0. BOX 1216      j

                           BLODMINGTON, INDIANA 47401
                               TELEPHONE AC t\i 339-Z261

                               August 21,  1975
Dale Luecht
Planning                          .
U.S. E.P.A.  Region V            .. .-   .
230 South  Dearborn
Chicago,  Illinois  60604 .     •

Dear Mr.  Luecht:

It would  seem  appropriate that the citizens have an opportunity
to know the  cost for an Environmental Impact Statement.   There
appears to be  three vital areas which need to be explored in a
study of  this  type:
       Cost  to  the  Federal government for the study.   This
       should  include employee time for an Environmental
       Impact  Statement and cost of any outside consultants.
       Cost  to  the  state and local bodies who have instigated
       the project.  This section should include items such
       as principle and interest on funds expended on the
       project.   Parts of prior engineering or design, which
       may have  been discarded by the Environmental Impact
       Statement, should be included.
       Increased  cost of construction
       during  the  period required for
       Environmental Impact Statement.
resulting from
preparation of
inflation
the
                              6-19

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Dale Luecht
August 21,  1975
Page 2
For the sake of good order, we, the Utilities Service Board  of
Bloomington, Indiana respectfully request that the Environmental
Protection Agency include a section in its Environmental  Impact
Statement entitled Summary erf Direct and Indirect Costs for  the
Envi ronmental  Impact Statement.
                          Sincerely,
                          Richard S.  Peoples
                          Project Coordinator
RSP/ses
cc: Utilities  Service' Board
    Environmental  Impact  Statement  (file)
                                   6-20

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                      INDIANA  UNIVERSITY

                             Department of Ph\tics
                             SWAIN HALL	WEST ! 1 '
                         BLOOMINGTON, INDIANA 47401
                                                              TEL. NO. . ! 2— 337-2650
                                        November  13,  1975
Mr. Harlan Hirt
Chief, Planning Branch
EPA Region V
230 South Dearborn
Chicago, IL  60604

Dear Mr. Hirt:

     You recently received a letter from several members of the Bloomington,
Indiana, Utilities Service Board expressing their concern with the delays and
costs associated with the preparation of the Environmental Impact Statement
for our wastewater treatment plant.  We want to make it clear that this
position is not supported by all members of the board.  The initial request
for an EIS was made by the Utilities Service Board knowing full well that
costs and delays would be incurred.  To now make an issue of the dollar costs
can only serve to thwart the reasons for the initial request.

     The location of the wastewater treatment plant has been a controversial
issue in our community for several years and has remained so despite extended
public discussions.  Both economic and ecological concerns were expressed.
In our nation's past, decisions of major importance were often based on
economic considerations alone.  The Environmental Impact Statement insures
that both economic and ecological factors are considered in decisions involving
public funds.  A proper balance between these factors is necessary if, in
the future, we are to sustain the quality of life we enjoy and preserve the
land we occupy.

     We appreciate the work that EPA is doing on this project and the respon-
sibility that is assumed when preparing an EIS.  A hastily-prepared statement
would not be adequate.  To dismiss the concerns of any segment of the community
would not be proper.  The time required for careful preparation of the EIS
will be only a small fraction of the time that we must live with the actions
that are to be taken.

                                        Sincerely yours,


                                             j
             David L. Dilcher           Hugh J. Martin
             Member, Utilities Service  Member, Utilities Service Board
                Board                   Department of Physics
             Dept. of Plant Sciences    Indiana University
             Indiana University         Bloomington, Indiana
             Bloomington, IN A7401      47401

DLD/HJM:mlc                            6~21
Copies to:  Senators Bayh, Hartke; Representatives Meyer, Hamilton

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   fctalenvirbnmei   t
                     By DON JORDAN
                      H-T Outdoor Editor
   Environmental protection is coming under fire from all quarters
 of business and industry these days with critics beating the same
 dam with the same tune that protecting the environment costs too
 much.
   F'art of the difficulty environmentalists have in countering these
 charges is that the large majority of business-oriented individuals
 put price I ags on everything But how do you put a price tag on the
 environment?
   Many enviornmental thinkers point to  the what they call "ex-
 ternalities" of continued growth without environmental concerns
 figured
   LYNTON K. CALDWELL. lU's environmental  and political
 science  leader, is fond of pointing out these externalities of ex-
 pansion when the total environment is not considered.
   When William Cook  of the Bloomington Utilities Service Board
 recently  blasted  an  environmental  impact  statement being
 prepared by the U S  Environmental Protection Agency, lie in-
 sisted that economics is part of the the environment.
   Environmentalists accept that argument, but Cook went one step
: farther, claiming that economic considerations must always come
 first, then environmental protection is fine.
   But what about those externalities9
   Dollar figures  can  be  placed on providing schools,  streets,
 sewers, water lines, sidewalks, transportation. These factors must
 also be considered as part of the environment, and all have large
 price tags afixed And, when all of these environmental factors are
. included, costs incurred by government in drawing up impact
 statements fade in comparison.
   COOK CLAIMED THE IMPACT statement for the new south
- sewage  plant will end up costing  millions. But what will be the
 ultimate cost to the citizens of Bloomington and Monroe County if
 an environmental mistake is made in selecting the site for the
 plant?
   Utilities Director Gary Kent has pointed out that when new
 service areas are picked up by the city, funds used to purchase the
 utility lines from developers come from utility revenues.
   'in other words, all customers served by the utility end up paying
 for new service. Such practices result in millions of dollars over
 long periods of time.                                      >
   Likewise, when new utility services like the new sewage plant are
 built,  it is the customers who always end up paying the bills. Utility
 rate increases result and tax increases are eventually needed to
 provide those myriad other services demanded by new residents.
 Tcix base increases seldom provide increased income over the long
 run when new services must be maintained into infinity.
   BY  NARROWLY DEFINING the environment,  business and
 industry leaders detail economic considerations and seldom talk
 at out the environment as a whole.
   Who asks  about the environment of Bloomington and  Monroe
 County as a whole — not just that narrow economic spectrum ?
   Unfortunately, the asking of that question is in this area lefl in the
 hands of private citizens or environmental groups like Sassafras
 Andubon Society, Sierra Club, Izaak Walton League and others.
 This is unfortunate, but necessary, since government officials are
 many times not  sensitive to preserving the  environment that
 makes this area attractive.
   Claude Ferguson recently pointed out that he likes this area and
 wouldn't move to a metropolitan area like New York or Washington
 for double his salary.  Likewise, said Ferguson, his wife wouldn't
 leave her favorite turkey wood for any salary.
   PEOPLE HAVE MOVED to the Bloomington area because they
 like the total environment oi the area. The sprawling forests and
 riijgelines provide a relief from the tensions of modern society.
   When considering economics as a part of the environment of this
 area,  it would be good to wonder how far we can go in changing it
 before people in other areas say: "I wouldn't take double my salary
 to move from here to someplace like southern Indiana."
   When those words are uttered is when the real economic crisis
 w II hit southern Indiana.
6-22

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"COOiV
   November 3,  1975
   Mr. Harlan D. Hirt
   Chief, Planning Branch
   U.S. E.P.A. Region V
   230 South Dearborn Street
   Chicago, Illinois  60604

   Dear Mr. Hirt:

   At the di^^tion of the Utilities Service Board of the City of Bloomington,
   Mr. Richard S. .Peoples, Utilities Project Coordinator, in a letter of August
   21, 1975, requested a summary of direct and indirect costs for the Environmental
   Impact Statement that the Environmental Protection Agency is currently preparing
   on our proposed wastewater  treatment facility.  In your response to Mr. Peoples
   of September  19, 1975, you  state:  "Direct and indirect costs associated with
   the project will not be identified unless they relate specifically to the cost
   effective analysis required under P.L. 92-5QQ."

   As you are well aware, the  Environmental Protection Agency has requested a
   great quantity of information from the Bloomington Utilities Department, the
   consulting engineers Black  & Veatch, and other interested parties.  To our
   knowledge all of this information has been provided with willingness; nothing has
   been withheld or refused.   Since the direct and indirect costs of the Environmental
   Impact Statement are a genuine concern of local residents, we feel that the
   Utilities Service Board's request for this information from the Environmental
   Protection Agency is both legitimate and reasonable.  Your response to Mr.
   Peoples' letter, however, seems to indicate that the Environmental Protection
   Agency does not believe that the people of Bloomington have the right to know
   this information.  As citizens of Bloomington who are very interested in this
   project and as federal taxpayers t;ho are concerned with the total environment
   and economic  costs of the new wastewater treatment facility, we respectfully
   disagree.

   When a study  such as an Environmental Impact Statement is undertaken, the cost
   of the study  is just as important as the other data that is collected.  We feel
   that the value and merits of an Environmental Impact Statement should be measured—
   at least in part—by the cost of collecting the information.  An Environmental
   Impact Statement takes time; in this day, time, unfortunately, can be measured
   by the rate of inflation.   Without knowing the cost due to lost time, might not
   the economic  environment of an entire community be jeopardized?  Here in Bloomington,
   for example,  the possibility of a moratorium on growth in the southern drainage
   area exists because the present wastewater treatment plant is overloaded and
   antiquated.   Inflation since 1972 has increased the cost of Bloomington's proposed
                                             6-23

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Mr. Harlan D. Hirt
November 3, 1975
Page 2


wastewater facility from $27 million to  $40 million.  This  inflationary cost
increase suggests that each month used to  study  the environment  costs $360,000.
We realize that it is impossible to place  a price  tag on the environment;  however,
we believe that it would be in the best  interests  of all people  if the Environmental
Protection Agency would thoroughly review  its  Environmental Impact Statement
process, keeping in mind the economic ramifications of  such studies.
                                        >
In our particular case here in Bloomington,  we sincerely feel that withholding
this information about the direct and indirect costs of the Environmental  Impact
Statement seriously hampers the spirit of  cooperation that  the people of this
community have attempted to foster between themselves and the Environmental
Protection Agency.  With this in mind, we  once again request that  the Environmental
Protection Agency provide us with a statement  that details  the costs  related to
the Environmental Impact Statement currently being conducted on  Bloomington"s
proposed wastewater treatment facility.

Sincerely,
njh

cc:  Senator Birch Bayh
     Senator Vance Hartke
     Congressman John Myers
     Congressman Lee Hamilton
                                         6-24

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               INCOKFUKAii^iJ
                                                          WOV13I975
November 3,  1975
The Honorable  John Myers
103 Cannon House Office Building
Washington,  DC 20510

Dear Mr.  Myers:

The Utilities  Service Board of the  City of Bloomington recently requested the
Environmental  Protection Agency to  provide information concerning the direct and
indirect^yists of the Environmental Impact Statement  that  EPA is currently
preparing on Bloomington 'o proposed uastewater treatment facility.  (See the
attached  letter of August 21,  1975, from Utilities Project Coordinator Richard
S. Peoples.)  As you can see from Mr. Harlan Hirt's response of September 19,
1975, which is also attached,  EPA does not seem disposed to divulge this infor-
mation, which  we feel should be a matter of public record.

As citizens of Bloomington who are  very interested in this project and as federal
taxpayers who  are concerned with the total environmental and economic costs of
the new wastewater treatment facility, we sincerely believe we have the right
to know what the direct and indirect costs of the Environmental Impact Statement
will be.   As one of our elected federal representatives, we would appreciate
it if you would look into this matter to help us secure this information.
Sincerely,
Enclosures  fy  /

cc:  Mr.  Harlan Hirt
                                    6-25

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                  CITY OF  BLDDMINGTDN  UTILITIES

                                   P. D. BOX 1216

                             BLDOMINGTQN, INDIANA 474D1
                                TELEPHONE AC 812 339-2261

                                 August 12, 1975
Dale Luecht
PI anning
U.S.  E.P.A.   Region  V
230 South  Dearborn
Chicago,  Illinois   60604

Dear Mr.  Luecht:

Attached  are  the  position papers for the individual  Utilities
Service Board members concerning the improvement program as
outlined  in the  Bloomington South Facilities Program.

I must apologize  for  the delay in getting this document to you
as  the positions  were presented by the Board at the  June 3,  1975
Utilities  Service  Board meeting.

If you have further questions for the Board or need  clarification,
please direct your  questions to me and I will see that they  are
transmitted to the  Board.

                         Sincerely,
                         Gary R. Kent
                         Director of Utilities
GRK/ses
cc:  James R.  Quin,  Gilbert Associates, Inc.
    Utilities Service  Board members
                                         PUNNING BRANCH

                                         FflENO~-
                           6-26

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                        UTILITIES SERVICE BOARD

                             JUNE 3, 1975
The Utilities Service Board members gave the following recommendations
as to site alternatives for the proposed treatment plant site:
DAVID DILCHER:  Dilcher affirmed his belief that Dillman Road is the best
site for the location of the proposed sewage treatment plant.  He stated
that this site best satisfies the needs of the City and the Region for
the following reasons:

     1.  It accomodates a gravity flow for the main lines and interceptors
         adaptable for picking up both City and Regional waste.

     2.  It is removed from residential areas and can be properly screened
         With proper county zoning, residential development can  be
         restricted.

     3.  It would provide a higher level of treatment for the effluent.

     4.  It would provide a more constant and easily controlled  treatment
         because the two-stage plant planned for this site is less
         susceptible to upsets.

     5.  It would be less distruptive to the Clear Creek Valley.

     6.  The Lake Monroe Region could tie in,in total or in part.

     7.  The cost would be equivalent to or less than the Salt Creek site
         in the long run considering the lower operations and maintenance
         expense.

     8.  It would not encourage stringer type development along  a long
         outfall sewer and will allow the development of city-centered
         f a c i 1 i t i e s .

     9.  Space would be provided for expansion to 40 MGD.

    10.  It would best serve the Region by providing easy pick-up from the
         Smithville and Paynetown areas and it would not require such long
         interceptor sewers as the Salt Creek site.

    11.  There is the distinct possibility of a force main from  the south-
         west section of the Lake being extended up Clear Creek  Valley to
         Dillman Road.


                                     6-27

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                         UTILITIES SERVICE BOARD

                              JUNE 3,  1975
WILLIAM COOK:  Cook indicated that he accepts  the Black & Veatch summary
that the Salt Creek site is the most desirable.   The selected plan in-
cludes a gravity sewer from the existing South Plant along Clear Creek
to a 20 MGD plant at the Salt Creek site.

The selected proposal  is as described under Section Ten of the Facilities
Plan except that the initial  design flow is 20 MGD. This site is the most
desirable based on environmental  concerns  and  cost effectiveness.   In
addition, the plan is  well  adapted to providing  service to the Lake
Monroe Region.   If service  were to be extended to the Lake Monroe Region
the selected plan would be  modified by the construction of a 5 MGD plant
addition approximately fifteen years after the initial  start-up.

Availability of land is a great difference between the  Salt Creek and
Dillman Road sites.  Unlimited land is available at the Salt Creek site
for disposal of wastes, composting, and future plant expansion.

The Salt Creek  site could service Lake Monroe  and also  the southern
Monroe County area.  Since  we supply their water Cook feels we should
consider providing sewage treatment.  He feels that we  must provide for
the future so that growth will take place  in southern Monroe County.  Cook
mentioned that  in the  Land  Suitability Study the southwest section is the
greatest portion of land available for any kind  of development at Lake
Monroe.  Cook indicates disagreement with  Dilcher as far as cost of
operation is concerned.  He stated there would be a $200,000 operations
savings on a year-to-year basis of operation at  the Salt Creek site which
would result in lower  sewer bills for residents.


JACK MARTIN:  Martin listed his reasons in support of the Dillman Road
site.  He feels that a higher degree of sewage treatment is offered by
the two-stage plant proposed  for the location.  Because the effluent
discharged from Dillman Road  eventually passes Salt Creek a higher degree
of treatment is indicated and with less impact for Salt Creek.

The main difference Martin  sees between the Dillman Road and Salt Creek
sites is that the Dillman Road site is the most  cost effective for the
near future.  The arguments for Salt Creek are based upon predictions for
the distant future and projections about what  will happen in different
areas of the City and  the Lake Region.  Because  construction costs for
Salt Creek are  three million  dollars more  than for Dillman Road, Martin
feels it would  take a  great number of years for  Salt Creek to become more
                                        6"28

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                         UTILITIES SERVICE BOARD

                              JUNE 3, 1975
cost effective than Dillman Road.  The areas of clear cost differential
according to Martin are:  (1) the difference between the one-stage Salt
Creek plant and the two-stage Dillman Road plant, and (2) the difference
between the outfall sewer required by Salt Creek and a snorter sewer
required by Dillman Road.  If drying beds were constructed at Dillman
Road the sludge disposal costs would be about the same.   The degree of
treatment offered at Dillman Road would result in 97.5% removal  of BOD
and suspended solids as opposed to 95.7% removal offered at Salt Creek.
The two-stage plant would employ additional people in the daily plant
operation.   Martin stated that the costs are based on a 20 MGD plant
flow which is a higher flow than has been projected for the first
twenty years.

Martin went on to state that he finds the question of a Regional plant
a rather difficult concept.   In looking at the argument that a central
plant is the most effective way to treat sewage, it seems unrealistic
that sewage must be moved so far to implement that concept.  In applying
this to our present situation, Martin stated that with the exception of
the southwest part of the Lake the Salt Creek site is relatively
inaccessible to the rest of the Region and Bloomington.   Martin indicated
that his belief was that perhaps a separate plant should be considered
for the southwest part of the Region.

Martin then outlined his uncertainties concerning the projections for the
Region.  He feels that looking at a 40 MGD plant to service a Bloomington
population of 200,000 is looking too far into the future.  He finds the
Region predictions troublesome for the fact that if the plant is built at
Salt Creek to service the Region and the projected growth fails to occur
then the plant will be serving a very small base of people. Martin stated
that Region growth predictions are based on:  (1) growth in a basically
rural area projected to increase by 1007, (2) growth in the Lake Monroe
recreational areas is predicted to double, and (3) large growth of those
building developments around the Lake.  Martin disagrees with the rural
area growth stating that it would be difficult to determine the high
density areas.  He concluded his remarks by restating his feelings that
the arguments for the Salt Creek site seem to be much more uncertain
and difficult to assess than arguments for Dillman Road.


RICHARD FEE:  Fee stated that as a result of ten years experience he feels
that the most suitable site is the one located as far downstream as possibl
the Salt Creek site.  He indicated that the former sewage treatment plant
was located just two miles north of the present Winston Thomas site so if
we are not to make the same mistake again we should move as far downstream
                                -3-    6-29

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                         UTILITIES SERVICE BOARD

                              JUNE 3,  1975
as possible.   Fee feels that the Salt Creek site would be better suited
to meeting changing dilution requirements, sludge disposal  requirements,
and degree of treatment in future years.
   response to the argument that string-type development will  be
   :ouraged, Fee gave two reasons stating why he feels this will  not
     1.  The pipe is neither in the flood plain nor inaccessible to
         normal  development.

     2.  The land around it is not suitable for development.   There
         are too many quarries on the west and it is economically not
         feasible to build there.
ROBERT SCHMUHL:  Schmuhl  stated that he favors the Salt Creek site.
According to Schmuhl  initial  costs would be higher at Salt Creek but long
term operating and maintenance costs and the cost for equipment replace-
ment would be lower.

Schmuhl feels that there would be a greater expanse of available and
suitable land at Salt Creek.   This would be beneficial because more
efficient sludge disposal and sufficient space for additional facilities
would be provided.  At Dillman Road there would be no room for construction
of additional facilities if further advanced treatment processes were
mandated in the future.
AILEEN SCHALLER:  Schaller stated that because the total costs between
the Salt Creek and Dillman Road sites are not much different that cost
cannot be a basis for decision.

Although no permanent environmental damage will result from either site,
Schaller feels there are two areas of possible concern:  (1) the outfall
sewer, and (2) the Lake Monroe Region.  With careful  attention to
revegetation, long range damage will be prevented in the area of the out-
fall sewer.  As for damage to the Lake Monroe Region, the plant will not
be crucial to development but will instead be of use to the Region.

Regarding other environmental concerns, Schaller stated we must not over-
look the aesthetic and odoriferous considerations.  She stated that the
plant should only be located along a major entry corridor to the City as
                                       6-30
                                -4-

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                        UTILITIES SERVICE BOARD

                             JUNE 3, 1975
a last resort.  The Dillman Road site would be on constant display, while
the Salt Creek site will use less of our dwindling energy year in and
year out.

Physical characteristics should also be considered in choosing a plant
site.   The plant should be located on level ground relatively free of
rock.   There should be adequate room for expansion and on-site sludge
disposal.  Undeveloped land should be available for a buffer zone. There
should be natural screening of the plant.

In closing Schaller stated that the Salt Creek site meets all of the
preceding criteria while the Dillman Road site meets none.


Further discussion of the plant sites followed the Board members pre-
sentations.  Fee recognized additional pluses for the Salt Creek site as
being the lessened effects of an accident due to greater dilution possibl<
He also mentioned that the plant would probably be resized down to 15 MGD
by the Environmental Protection Agency.

Utilities personnel were then asked to give their opinions as to the plan'
site choice.  Director of Utilities Gary Kent stated that major consider-
ations should be the cost of operation as far as local dollars are concen
the balance of commodities in operation, the ability to serve the potenti.
growth and the plant layout.  He indicated that some costs are questionab
for both sites but he favors the Salt Creek site.  Utilities Treatment
Engineer Mike Phillips added that he felt the Salt Creek site was best fr
the operating standpoint and Project Coordinator Rick Peoples concurred.

Fee moved, Schmuhl seconded a motion that the Salt Creek site be
recommended to the Environmental Protection Agency as the site chosen by
members of the Utilities Service Board and by Black & Veatch engineers to
be the most suitable for the proposed treatment plant.  The vote was four
to two in favor of the Salt Creek site.
                                     6-31
                                -5-

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                                               RECEIVED
                                                ''^ 2: 1076
                EVALUATION OF GILBERT
     A direct comparison between the Gilbert Report
and the Facilities Plan prepared by Black & Veatch is
extremely difficult.  However, our preliminary review
reveals a number of areas where serious questions exist.
Among these are:
          1.  On page 5-1, a misunderstanding of the
     nitrogen discharge requirements of the State of
     Indiana is apparent.  On Clear Creek the winter
     requirement should be 3.0 and not 6.5.  On Salt
     Creek the summer discharge should be 7.9 rather
     than 3.0.
          2.  The additional cost of facilities to
     provide second stage nitrification at Clear Creek
     sites is estimated on page 6-14 of the report at
     $1,722,000.  It would seem that this second set
     of aeration, sedimentation and sludge handling
     facilities should cost about 20% of the liquid
     treatment cost (page 6-14) or about $3,400,000.
          3.  The cost of operating and maintaining a
     two stage nitrification plant on Clear Creek is
     estimated at only 8% more than operating a single
     stage nitrification plant at Salt Creek, despite
     the fact that the Salt Creek plant must nitrify
     only during the summer months while a Clear Creek
     plant must nitrify twelve months a year.
          4.  Either no rock excavation is included
     or the quantity of rock is seriously underestimated
     for the necessary channel relocations for Clear
     Creek sites.
                           6-32

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           EVALUATION OF GILBERT REPORT
                     PAGE TWO

     5.  The cost of the gravity sewer to the Salt
Creek site shown on page 36-A is over-estimated.
The price for all sewers larger than 42" in diameter
is based on an over-sized pipe that is not needed to
carry the anticipated flow.  Current quotations on
sewer pipe are from 20 to 35% less than those used
for each pipe size.
     6.  In our experience, we have never found it
necessary to construct and maintain a permanent road
for vehicles along an outfall sewer.  (page 8-6)
     7.  On page 10-1, the report states that the
Salt Creek site is not adequate to sustain land
application of sludge produced there.  A call to
Joseph B. Farrell, Chief of the Ultimate Disposal
Section, of the Municipal Environmental Research
Laboratory, of the U.S. EPA in Cincinnati, revealed
that the formula used in the Gilbert Report was not
current.  Using the correct figures would allow about
2 1/2 times the sludge loading proposed in the report.
     8.  The report states on page 10-20 that the
costs for the recommended haul and application of
sludge from Dillman Road and Salt Creek sites are
within 8% of each other, even though the sludge
application site is immediately across the creek from
the Salt Creek site, according to Plate 3.  In addition,
the report assumes that the owners of this property
will accept the sludge.
                         6-33

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                EVALUATION  OF  GILBERT  REPORT
                         PAGE  THREE
          9.   It is  extremely  doubtful that  a  new 15 mgd
     two  stage nitrification  treatment plant  can be built
     on  the  Winston  Thomas  site west  of the  existing
     facilities as  stated on  page 3-1.  In addition, the
     report  reveals  a lack  of  understanding  of the exist-
     ing  Winston Thomas  facility when  it refers to the
     obsolete, fixed-nozzle,  sprinkling filters as
     "Bio-filters."
          10.  The assumption  that pumping 1.9  mgd north
     to  the  Blucher  Poole plant will  provide  a less cost-
     ly  treatment scheme than handling it in  its natural
     watershed.  (page 1-4)  It does  not consider the fact
     that the  Blucher Poole plant will have  to be upgraded
     to  meet substantially  the same  standards  as discharges
     to  Clear  Creek.
          11.  Page  31-A of  the report  discusses the need
     for one pump station to  serve Smithville  while Plate
     3,  illustrating this facility,  shows two.
          12.  The statements  in Section 5 to the effect
     that two  stage nitrification by  a plant  on Clear Creek
     is,  per se, superior to  single  stage nitrification on
     Salt Creek, suggests that it is  considered that the
     State of  Indiana has not properly allocated waste
     loading to the streams of the State.
     If  a detailed  comparison between this Report and the
Facilities Plan would be of value, we at Black & Veatch
respectfully request that this Report be presented on a
basis comparable to the Facilities Plan.
                           6-34

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                                          Blooming-ton, Indiana
                                          May 3, 1975
Steve Riggins, President
Monroe County Plan Commission
County Courthouse Annex
Bloomington, Indiana

Dear Mr. Riggins s

A number of organizations concerned with implementation of the
Land Suitability Study of the Lake Monroe area, in process of
completion by the Indiana University School for Public and
Environmental Affairs, would like a place on the agenda of the
May 20th meeting of the Monroe County Plan Commission in order
to present two requests:

     l)  for formulation and adoption of a policy and plan for
         the use of the Lake Monroe Land Suitability Study, and

     2)  for consideration of applying for a Planning Grant for
         a similar study for the remainder of the County.

Enclosed is a statement which we are sending to the members of
the Monroe County Plan Commission, the Monroe County Council,
and the Monroe County Commissioners.

                          Yours sincerely,
                          Anne Rippy     /
                          809 S. Stull, representing the
                                        organizations
 cc:  Bob Snoddy
                           6-35

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TO:  TIDE MONROE COUNTY PLAN COU.ilSSION

FROM:  CONTACT, 13LOOMINGTON LEAGUE Oi-1 V/Ol.IEj! VOTERS, iiLOOi.Ij.,IGTO;J  rL.
       MENTAL DUALITY AND CONSERVATION COLLiIS^IOiI, SADoAl^fAS  AUDUBON SOCIETY
The Land Suitability Study being conducted by the Indiana University  School
of Public and Environmental Affairs covers approximately a 100  square mile
area around Lake Monroe and v/ill provide a valuable data base and  Land Capa-
bility Model for use in planning for that area.  It is an important first
step in terms of the study and planning needed for the entire Lake Llonroe
Watershed.

The value of such a study, however, v/ill not be realized until  the results
of the study are incorporated into planning and decision-making for that
region.  We ask that the Monroe County Plan Commission formulate and  adopt
a policy and plan for the implementation of the study.  Those involved in
making the study will demonstrate how to retrieve and interpret the data,
but we need a firm committment to its use to gain the benefits  inherent in
the study.

We believe that the time is appropriate, also, for undertaking  a compre-
hensive land use study for the remainder of Monroe County with  the joal of
incorporating the two studies with the zoning ordinance recently adopted
into a Comprehensive Master Plan for the County.

The need for such a study is apparent.  For example, the Indiana University
School of Business recently predicted a 25,000 population increase in the
south drainage basin of the. County within the next two decades.  Y/e need
to identify critical areas such as fragile lands, renewable resource  lands,
natural hazard lands, mineral resources, etc and protect them through
planning --- as well as seek an over-view of our land-use problems and  potential.

Funding for such a study is available through a Federal 701 Planning  Grant
which would pay 2/3 of the cost with the local governing body providing 1/5-
701 Planning Grant funds are allocated by the Indiana State Planning  Services
Agency which could conceivably give high priority to a project  which  would
include land-use planning for Lake Monroe as one of its components.

Many kinds of data are available which would minimize the cost  of  the study.
The Soil Survey of Monroe County is well advanced and expected  to  be  com-
pleted within two years.  The Indiana Geological Survey will provide  geo-
logical and hydrological data and both the Soil Conservation Service  and
the Geological Survey will provide expert services in interpretation  of
this data.  A recently completed study of the karst region of the  west side
of the County should prove valuable.  The services of the Region 10 planner
and cooperation with the planning services of the City of Blooniington could
also expedite planning and minimize costs.

We would appreciate early consideration by the Monroe County Plan  Commission
of an application for a Planning Grant.
                               6-36

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              RECOMMENDATIONS OF THE


ENVIRONMENTAL QUALITY AND CONSERVATION  COMMISSION


           ON THE SITING OF THE PROPOSED


    BLOOMINGTON SEWAGE TREATMENT FACILITIES
               R F n
          i-ilJ. NO-,-
             1
                  6-37

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        RECOMMENDATIONS OF THE ENVIRONMENTAL QUALITY
    AND CONSERVATION COMMISSION ON TliC SITING OF THE PROPOSED
         BLOOMINGTON SEWAGE TREATMENT FACILITIES

1.  General  Background
     Almost  since its inception during the spring of 1972 the Environ-
mental  Quality and Conservation Commission (EQCC) has been studying
the environmental aspects of the placement of a new waste-water treat-
ment facility in southern Bloomington.  This is demonstrated by the
record of the EQCC meetings, whichis summarized in the Appendix.  The
EQCC has discussed the siting of the facilities during many civic
meetings, has supported several pertinent studies, and has participated
in studies carried out by others.  We have presented recommendations
and relevant information to the citizens of Bloomington, to the Common
Council, to various members of the City Administration, and to State and
Federal officials.  Relying on these experiences and the understanding
we have gained from them, we present this report as our analysis of
the environmental factors -associated with the siting of the proposed
facilities.
     From an environmental perspective, there are two major siting
options:  the proposed Salt Creek site and the alternative sites on
upper Clear Creek.  Possible alternative sites mentioned to date include
the present Winston Thomas site and sites on South Rogers Street, on
Dill man Road, and on Ketcham Road.
                              6-38

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                                 -2-
II.  Recommendations
     Based on their community involvement referred to above and on
their professional  expertise in such areas as physics, chemistry,  eco-
logy, and soil science, the members of the EQCC have unanimously con-
cluded that all of the Clear Creek sites are environmentally preferable
to the Salt Creek site.  Of the Clear Creek sites, the EQCC believes
that the total environmental impact of construction and operation  at
the Dillman Road site will be the least.  Therefore, the EQCC recommends
that the treatment facility be placed at the Dillman Road site.  This
report will present our reasons for this recommendation;  first, the
environmental issues differentiating all of the Clear Creek sites  from
Salt Creek; second, the environmental and social  issues which differ-
entiate Dillman Road from Winston-Thomas and South Rogers St.  There
are four main reasons for selection of a Clear Creek Site:
     a.  The terrestrial and aquatic destruction involved in running
         the outfall sewer to Salt Creek will be avoided.
     b.  The level of effluent quality from the Clear Creek sites  will
         be greater.
                          <
     c.  The Salt Creek site is within the floodplain of Salt Creek,
         directly below the spillway at the reservoir and located on
         a soil type known to be subject to waterlogging. (Soe Soil  Survey)
     d.  The possibility of adverse secondary effects of facilitated
         development at Lake Monroe because of placement at Salt Creek
         will be less severe.
The primary considerations differentiating Dillman Road from Winston
Thomas/St. Rogers St. are the adverse aesthetic impact of a wastewater
treatment facility placed in the more densely populated areas and the
                               6-39

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                                  -3-
social  impact of relocation  of several  families  living in a trailer
park on the proposed site.

III.  Comparison of the Environmental  Effects  of Clear Creek and
      Salt Creek Siting

A.  Outfall Sewer Effects
     Locating the waste-water treatment plant  at the distant Salt
Creek site requires a long  outfall  sewer.   There are five alternative
sewer routes from Bloomington to that  site:
     (1)  under Clear Creek;
     (2)  along Clear Creek, but higher upon the banks and slicing
          across the creek's bends;
     (3)  as in (2), but using a force main to cut across the broad
          westerly bend of  the creek;
     (4)  along Clear Creek to the  Ketcham Road  area, then across the
          hills via a force main to lower Little Clear Creek, then
          south along Little Clear Creek and Clear Creek;
     (5)  as in (4), but to upper Little Clear Creek.
The proposed outfall sewers to the Ketcham Road  and Dill man Road sites
follow route (2) above, but for much shorter distances.  Both the South
Rogers Street and Winston Thomas sites would require 9000 ft. force
mains running up the Clear Creek bed from the proposed southeast inter-
ceptor sev.^r.  It should also be noted that, should the Lake Monroe
Regional Waste District decide to have its wastewater treated at a
Bloomington Clear Creek facility, a force main running overland from
                                6-40

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                                 -4-
from Smithville to the Clear Creek bed will  have to be built.
     Outfall sewer construction and maintenance will  have detrimental
environmental effects; the longer the sewer  is, the worse these  effects
will be.  These effects can result from earth-moving  during  construction
and may also include permanent environmental  damage caused by  right-
of-way clearance and maintenance.  All of these effects are  magnified
by the proximity of a natural  area, Cedar Bluffs.   Following is  a
more detailed consideration of these factors.
     The right-of-way for construction of sewer alternative  (2), which
is the one recommended by Black & Veatch, is  100 feet wide and about
60,000 feet long.  An area of six million square feet will thus  be
subjected to physical abuse.  A trench averaging twelve feet deep will
be dug down the length of this right-of-way.   Much of the 4.3  million
cubic feet of earth that will  have to be removed is limestone, which
will have to be blasted out.  Some of this spoil will be bulldozed  and
graded to level the right-of-way for maintenance access.  It is  rather
difficult to believe that bulldozing and blasting on this scale  could
be done with an eye to "limiting environmental  disruption" (Black &
                          •!
Veatch, p. X-16).  It is more reasonable to  believe that construction
activity will result in the destruction of much terrestrial  and  aquatic
wildlife habitat, in addition to impairing the stream's aesthetic value.
     Despite the promise to grade and reseed  "as soon as practicable,"
it may work out that, considering the frequency of rain and  flash-
flooding in the area, erosion may set in before vegetative cover does.
In the case of alternative  (3), erosion may also result from unrevege-
tated sewer line easements in the hills above the creek.  In any case,
the resultant siltation of the stream could have an effect on  the  aquatic

                               6-41

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                                   -5-
biota more permanent that that caused  by  sewer construction  itself.
     The EQCC also has  reservations  about the effects  of  the twenty-odd
creek crossings proposed under alternatives  (1)  and  (2).   The provisions
for keeping the line from being dug  up by the action of the  stream are
not described in the Black & Veatch  report.  This  makes it impossible
to comment on them specifically except to hypothesize  that there  may
be permanent changes in the substrate  of  the creek which  could affect
stream biota, flow characteristics,  and aesthetics adversely.
     Though specific techniques for  right-of-way maintenance have not
been described by Black & Veatch, usual procedures involve defoliation
with herbicides.  This would constitute a chronic  perturbation to the
immediate and neighboring wildlife habitat as well as  a possible  source
of pollution from runoff.
     Another problem is the proximity  of  the Cedar Bluffs area to the
Clear Creek sewer route.  Sewer construction arid maintenance could affect
the integrity of this area through the resultant noise, dust, and impair-
ment.  While the sewer does not pass through the area, alternatives
place the line just across the creek from it.   On  the  basis  of the above
                          5
considerations, the EQCC recommends  that  the important potential  negative
environmental effects of the outfall sewer be  minimized  by minimizing
the length of the sewer, subject to  constraints  described below.

B.  Effluent Quality Effects
     The Salt Creek facility is to be  a one-stage  plant,  while current
state water quality standards require  that a Clear Creek  plant, because
of the low dilution capacity of the receiving  stream,  be  a two-stage
                              6-42

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                                 -6-
plant.  A one-stage plant is somewhat more susceptible to  rapid
changes in plant variables such as water volume than a two-stage  plant.
Rapid changes in water volume do occur in the Bloomington  area during  the
summer.  It is conceivable that at that time a one-stage plant could
discharge improperly treated effluent.
     More importantly, however, a one-stage plant will be  unable  to
discharge effluent of a quality high ehough to meet the standards
currently required for 1983 by Public Law 92-500.  Yet the Black  &
Veatch study which judges the cost effectiveness of the Salt Creek
and Dillman Road sites to be similar assumes a one-stage plant at the
Salt Creek site.  The EQCC questions the rationale behind  a twenty-
year cost effectiveness study predicated on water quality standards that
will be superseded by more stringent ones after only five years.   Clearly,
with respect to present water quality standards, a Dillman Road  plant
would be more cost effective thafi a Salt Creek plant, because the former
would discharge a higher quality effluent for the same cost; with respect
to future standards, a cost effectiveness study would have to consider
fines the City might have to pay due to the emission of an illegal
effluent by a Salt Creek plant.  The EQCC concludes that, environmentally,
and legally, a two-stage plant is better than a one-stage plant  and
that, economically, a two-stage plant at Dillman Road is better than a
two-stage plant at Salt Creek.
     An added benefit of a Clear Creek site with the relatively clean
effluent it is required to discharge is the potential recreational use
of Clear Creek as a canoe stream.  Such areas are not abundant around
Bloomington.  If the Salt Creek site is chosen, the flow in Clear Creek

                                 6-43

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                                     -7-
will be too low to permit its  use  for this  purpose.

C.  Hydrological  Effects
     The proposed method  of  sludge disposal at  the Salt Creek  site  is
subsurface soil injection over an  area comprising most of  the  site.
During the spring rains of 1975, this area  was  heavily waterlogged.  The
EQCC cautions that sludge injection into  land which  is subject to
periodic leaching by rain water, and which  abuts major receiving streams,
may result in periodic large influxes of  nutrients,  untreated  heavy
metals, and other matter  into  the  streams.   It  should be noted that this
creek water is a  water source  for  Bedford,  only thirteen miles down-
stream.  These problems are  not addressed in the facilities  plan.
     These possible detrimental hydrological effects may be  exacerbated
by the location of the Salt  Creek  site within a 100-year flood plain.
Until flood-plain alterations  potentially caused by  the Lake Monroe
dam are known, it would be wise to require  that the  facility's constr-
uction plans include safeguards to prevent  discharge, leakage, or
leaching of untreated wastes from  the plant area into the  creeks during
periods of high water.    '

D.  Secondary Effects of  Unplanned Development  in the Lake Monroe Area.
     Another major concern of the  EQCC is the possible adverse effect
on the Lake Monroe area  resulting  from development  in the  lake's
watershed stimulated by the  placement of  the treatment facility at
Salt Creek.  We anticipate this facilitation because, according to
         92-500
Public Law /   development cannot  occur without suitable wastewater
treatment.  While the dollar costs to Bloomington at. Dillman Road or
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                               -8.
Salt Creek are similar, the cost to LMRWD*1s  much  less  if  the  Bloom-
ington Plant is at Salt Creek.   The advantage of this Salt Creek  hookup
is that several existing sources of effluent  will  be  removed from the
lake.  This is the main environmental  benefit of this arrangement.
This is balanced by the possibility that cheaper sewage treatment will
permit more rapid development than  would otherwise occur.   In  principle
the development of private living structures  and even commercial  ones,
need not lead to the deterioration  of  the lake region,  providing  that
sufficient planning controls and enforcement  procedures are established
and maintained.  No such planning structures  and controls  exist in the
region at this time.  The Lake  Monroe  Land Suitability  Study recently
carried out is not intended to  guarantee the  planning needed in the
area although it can serve as background for  the development of such
a plan.  In view of this situation  EQCC is evaluating potential environ-
mental effects based on recent  and  current planning and construction
methods.
     The EQCC considers the primary functions of Lake Monroe to be
1)  flood control water impoundment, 2)  a recreational  resource,
3)  a major source of domestic  water for the  City  of  Bloomington  and its
environs.  It is the potential  deterioration  of these functions of the
lake with which we are concerned.  In  addition, much  of the land  around
the lake presently has an undisturbed, natural quality  which is important
in and of itself and also as it enhances the  recreational  value of the
whole region.
     Development without a regional land use  plan  and construction
 practice regulations  potentially could  detract  from the functions listed
 *Lakc Monroe Renional Waste District
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above in the f61 lowing ways:
     1)  Conversion of privately owned  natural  areas  into  develop-
ments which will  decrease the amount of natural  landscape  for aesthetic,
wildlife and recreational use.  This effect will  be concentrated  in.
certain areas.
     2)  Improperly controlled construction destroys  foliage and  ground
cover, resulting in erosion,  increased  sedimentation  and potentially
decreased water quality.
     3)  Increased use of motor-driven  boats and motor vehicle traffic
on land will probably result  in increased amounts of oil-based products
and heavy metals entering the lake.
     4)  Motor boat traffic may result  in incre?sed shoreline erosion.
     5)  Unaesthetic construction on and around the lake's shoreline
will detract from the natural quality and recreational value of the
lake area.
     One very important variable which  must be considered in evaluating
possible development around Lake Monroe is the opinion of those people
who use the Lake.  Wise  (1975) has surveyed opinions of users and found
                          1
significant expressions in favor of preserving the semi-natural quality
of the area.  Most users prefer swimming, camping, and boat fishing as
recreational activities.  A substantial plurality favored fewer condo-
miniums and houses around Lake Monroe than presently exist.  Facilities
which those interviewed did not desire included motels, sporting goods
stores, condominiums, houses, and boat ramps.  ATI but 3% found the
forest around the lake attractive.  The attribute which people like best
is the beauty of the lake.  The attributes ]_iked  least are the crowding
and facilities.  EQCC's conclusion about public opinion is that the type
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                                -10-
of development likely to be facilitated by placement of Bloomington's
sewage treatment plant at Lake Monroe (houses, condominiums,  commercial)
is precisely the type of development which Lake users do not  want.
Further, such development might destroy those aspects of the  Lake envir-
onment which the users appreciate the most (attractiveness, forests,
fishing) and exacerbate problems which they already perceive  (crowding
and facilities).
     EQCC is concerned that the necessary regional  planning does not
exist to control such effects on the lake's primary functions as those
listed above.  We therefore believe that development should not be
facilitated by placement of the plant at Salt Creek.  He recognize the
environmental value of removing present sources of effluent from the  lake,
but are not certain that this value overweighs the other negative effects
which potentially might result.

E.  Summary
     The Salt Creek site will require a longer and thus more  environ-
mentally disruptive outfall sewer than any of the Clear Creek sites.
A Clear Creek plant will produce effluent of higher quality than the
proposed Salt Creek plant, whose effluent will be outside legal limits
shortly after commencement of operation.  Hydrological considerations
indicate that a Salt Creek plant may periodically cause stream pollution.
Finally, the Salt Creek site is more likely than a Clear Creek site to
lead to unplanned development in the Lake Monroe area, with all the
environmental deterioration this, implies.  Because the environmental
costs of the Salt Creek site are obviously much higher than those of
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                                   -li-
the Dillman Road site, and because the economic  costs  are similar, the
Salt Creek site can be eliminated from further consideration.

IV.  Comparative Evaluation of jthe jjeiar J>§ek jj>i_tes
     Differences among the impacts of the  various ciearCreek sites on
the physical  environment are minor compared  with the difference in
impacts between any of the Clear Creek sites and the Salt Creek site.
The outfall sewer to the Dillman Road site would be a  little longer
than the force main from the southeast interceptor to  the Winston Thomas
or South Rogers Street sites, and the outfall  sewer to the Ketcham
Road site will be a little longer still.  On the other hand, if the
new plant is  not built at the Winston Thomas site, that site can be
converted to  a park, though the  South Rogers site  would use part of the
present site  and decrease the value  of a park  there.   Selection of the
Winston Thomas site may lead to  better re-use  of existing materials.
Thus, in terms of physical environmental impact, the only clear advan-
tage at this  point is that of Dillman Road over  Ketcham Road.   Given
its higher economic costs, also  the  Ketcham  Road site  can be eliminated
from further  consideration'.
     The major drawback to the present location  seems  to be the con-
struction disturbances and the possibility of  increased odors  in the
vicinity which is heavily populated, and the possible  need to  relocate
several households.  The Dillman Road site is  not  presently densely
populated and for topographic reasons dees not seem threatened by nearby
settlement.  EQCC finds that, while  all  the  Clear  Creek sites  seem
preferable to Salt Creek, we would rank Dill man  Road ahead of  Winston
Thomas/S. Rogers St. primarily for social  reasons.
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                                -12-
 V.  The Need for an Environmental  Impact Statement
     EQCC recommends that if the Salt  Creek Site is  selected,  EPA
should definitely prepare an EIS to investigate not  only the points
made above but also many other specific  points  concerning possible
routes for the outfall  sewer, the advisability  of sub-surface  injection
as a means of sludge disposal, and specific treatment  plans.  The issue
most difficult for us,  as citizens, to predict  and understand  about
the problem of site selection is the question of secondary impact of
development in the Lake Monroe Area.  EQCC recommends  that,  because of
the complexity of this  problem, major  efforts should be made by EPA
to predict, evaluate and Suggest solutions to these  secondary  impacts.
A list of points needing investigation in an EIS follows this  section.
Some members of EQCC believe that an EIS might  be desireable irrespective
of which site is chosen and so points  related to both  sites  are included
on the list.
1.  Environmental desirability of returning Clear Creek to its  pre-
                          i
Winston Thomas flow level  in order to restore the original  biota;
comparative study of Little Clear Creek biota might be made to  determine
if change has occurred.

2.  Extent of direct destruction of wildlife habitat by outfall  sewer
construction.

3.  Quantitative assessment of Clear Creek siltation which might be
caused by sewer construction; effect on Bedford drinking water.

4.  Extent of indirect environmental  degradation caused by outfall
                             6-49

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                               -13-
sewer construction due to  activities  by  the  work  crew  such  as
driving equipment into and out of right-of-way, parking  automobiles,
etc.

5.  Identification of those areas where  blasting  must  be done  and
assessment of the impact of the resulting fallout and  noise on
nearby wildlife habitat and cultural  areas,  e.g., Cedar  Bluffs,
Ketcham Road cemetery.

6.  Differentiation of sewage treatment  alternatives with respect
to effluent quality, especially between  alternatives 2A  and 3A in
Facilities Plan; analysis of economic-environmental  tradeoffs.

7.  Extent to which revegetation is necessary following  sewer con-
struction, how soon it must be done, and how likely it is to be
successful, given the area's hydrology;  differentiation  between degrees
of  erosion expected with and without revegetation.

8.  Environmental impact of overland sewer routing, including conside-
rations similar to those given above for creek bed routing.  Judgment
on  the advisability of building alternatives 3, 4, 5,  and LMRWD
Smithville-Clear  Creek force main.
9.  Reevaluation  of economic-environmental costs of outfall sewer alter-
natives for Salt  Creek site, expecially with respect to alternatives
2 vs.  5A; analysis of environmental tradeoffs of greater overland as
opposed to less creek bed  routing for alternative 5A; amount of eco-
nomic  difference  LMRWD might fund as their share of Little Clear Creek
sewer  to  have  a  plant on  Salt  Creek instead of Clear Creek.
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                               -14-
10.  Description of biota of wildlife habitat to be destroyed  at
Ketcham Road and Salt Creek sites and determination of its  rarity.

11.  Measures to be taken to ensure that holding ponds,  etc.,  will
not be flooded.

12.  Environmental  assessment of possible landfill  and soil  injection
sites to determine potential for water pollution due to flooding  or
leaching after rainfall.

13.  Comparisons of degrees of buffering needed and possible for  various
sites and various treatment and disposal methods to shield  local  residents
and visitors to natural and cultural areas from noise, odor, and  ugli-
ness of sewage treatment.

14.  Assessment of tradeoffs between biotic-geologic costs  and social
costs, the latter accruing from #13 above and from forced relocations
at some of the sites.   (See also #23)

15.  Current aesthetic values of undeveloped sites.
                          i
16.  Comparative analyses of economies of land use for various sewage
treatment and sludge disposal alternatives.
17.  Size of the work crew required for construction, where they  will
commute from and what social costs they might impose on the community.

18.  Social benefits with respect to reducing unemployment  of con-
struction of plant.
                                  *
19.  Comparative analysis of energy and resources required  for various
site, treatment, and disposal alternatives.
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                                 - i o-
20.  Environmental  effects of travel  over,  entry to,  and exit from
right-of-way by maintenance crews.

21.  Precautions that must be taken  to  prevent  the creek from digging
through to the sewer at crossing  points;  effects of these precautions
on biota and flow characteristics;  impact of altered  flow character-
istics on downstream creek ecosystem.

22.  Impact of possible herbicide use during right-of-way maintenance
on environment, both directly on  biota  and  indirectly due to possible
water pollution this might cause.

23.  Surveys of local residents as  to what  impact they feel  the Winston
Thomas plant and its proposed expansion or  removal  to South  Rogers
Street has or will  have on their  lives; income  distribution  of resi-
dents so affected and assessment  of  their political  power.

24.  Environmental  benefits accruing  to Clear Creek sites due to
potential recreational  uses of Clear  Creek  resulting  from maintaining
its present flow level.
                          i
25.  Possibility that a regional  plan should be a prerequisite for
selection of the Salt Creek site.

26.  Total environmental  analysis of  the  effects of unplanned development
around Lake Monroe facilitated by the Salt  Creek site, including poten-
tial biotic, geologic, and social costs accruing from any destruction
of forest, degradation of the water supply, and increase in  population
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density and potential  social  gains accruing fro'm economic growth;
tradeoff analysis  of these  costs and gains.-
27.  Environmental  and economic costs and gains accruing from
sludge disposal  by means  of treating it and selling it as fertilizer.

28.  Determination of any upper "ceiling which geologic restrictions
may place on south-planning-area population and deduction of largest
sewage treatment design capacity that will ever be needed.

JCR/nan
                         Acknowledgements
     James Chiesa,  S.P.E.A.  graduate student, has permitted use of
portions of an unpublished manuscript as well as volunteering editorial
help.  The following  report  was  cited in the text:
     Wise, Charles.   1975.   User preserences of policy alternatives:
        the case of recreational  user attitudes toward development
        and regulation  at Lake Monroe,  Indiana.  School of Public and
        Environmental Affairs Occasional Papers, No. 4.
   Soil' Survey, 1973.   Interim Soil  Survey, Vol. 2,  Information
and  Interpretation, Blooinington, Indiana.  U. S. Department of
Agriculture, Soil Conservation Service,  Purdue Uni-versity.
                                 6-53

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                         APPENDIX






     Brief synopsis of items discussed during  Environmental




Quality and Conservation Commission meetings which pertain to




Lake Monroe, water quality,  and the sewage treatment plant.
                           6-54

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HISTORY OF ENVIRONMENTAL COMMISSION'S INVOLVEMENT WITH LAKE MONROE
                       Based on 1972 minutes

May 10 -- reported that Rod Crafts and Barbara Restlc would travel to
Indianapolis to speak with John Cregor, an attorney who is the foremost
leading authority in the country on riparian rights, about the City's
power to control development in Lake Monroe,  The Water'Quality Commit-
tee wished to issue a warning about the possibility of Inland Steel
encroaching upon Lake Monroe and requested the Commission's support and
approval for enlisting the aid of other groups in the effort.  A motion
was made and approved that The Water Quality Committee should accumulate
as much factual information as they can before the next Commission
meeting with their suggestions as to what action the Commission can
take respecting Lake Monroe,

July 12 -- The resolution on Lake Monroe development was read and David
Docauer presented a background report on the resolution.  He said that
the resolution was^beginning step in seeking protection for Lake Monroe,
The vote was unanimous,  John Patton directed that the absent members be
polled to ensure a majority giving approval,

August 9 -- A notion made that: The Commission reques'' the City of Bloom-
ington to name a representative to sit in on the final hearing of the
Department of Natural Resources; to request from Inland Steel's attorney
a copy of the plans to be made available as soon as possible; and a
representative be named to appear at the hearing of the Stream Pollution
Control Board on Tuesday, August 15, 1972,  Whitehead offered an amendment
asking that Inland Steel give the plans of their development  within the
drainage basin of Lake Monroe and that they also name a representative
to come before the Commission to discuss the development.  The motion and
amendment were approved unanimously,

October 11 -«• Dick Hilliker, Representative of Inland Siael Development
Corp,, presented maps, gave a report on a proposed development around
Lake Monroe and discussed the development proposal with the Commission
and the audience,  A Water Quality Committee report submitted by Docauer
was accepted,  Donald ^Hiitehead and David Docauer agreed to write a
letter to the Stream Pollution Control Board and the University on
behalf of the Commission  stating their views on the ISDC's plans,

November 8 — Ted Najam, Administrative Assistant to the Mayor, read
a statement from the Office of the Mayor concerning the proposed Position
Paper prepared by David Docauer and Donald Whitehead on land development
around Lake Monroe; the present state of Lake Monroe and a projection
of its future in relation to presently proposed developments and future
developments.  The statement basically said that the Commission should
not make such statements without making it clear that it is not necessarily the
position of the City and "A statement of this kind with such broad
ramifications should be made only after there has been broad partici-
pation by all those City departments and commissions which have something
to contribute,"  Discussion followed, and some changes were made on
the position paper.  The paper was approved.  It was decided that Don
Whitehead would represent the Commission before the Common Council,

December 13 -- Donald Whitehead reported that the Common Council passed
a resolution accepting and concurring in the Commission's Position Paper,
Bron added that at the end of the discussion a suggestion was made by         '
Council President ChaMotte Zietlow for the formation of a body to look

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into the ecological  factors that concern the lake and the long range
view.  Chairman Patton would contact  Zietlow to  request that the
Commission be included in such a body if it was  not already  constituted.
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   SUMMARY OP ENVIRONMENTAL COMMISSION'S INVOLVEMENT WITH LAKE MONROE
                           Based on 1973 minutes

January 10 — The Commission's draft statement.on the Black and Veatch report
was presented.  In the discussion that followed, it was brought out that there
would be federal funding but the City does not require an impact statement,
Dave Rogers(President of the Board of Works)  said he worked with the Black and
Veatch Report and thought the comments of the statement appropriate.  Cn finding
Number two (Monroe Reservoir) he felt the comments were well taken, but said
that Black and Veatch were only asked to do a bare bones study so the report
does not take into account the impact of increased development.   The construc-
tion of waste water facilities would of necessity require federal grants,  which
would in turn require an impact study, though that study would be directed
primarily toward alerting the public rather than binding any specific agen cy
to a set course of action.  Mr. Rogers said also that Lake Monroe Reservoir  would
not provide all of Bloomingtcn's future water need.  The city plans to continue
to develop dependencies on Griffey Creek-Bean Blossom, though  dependence  on
Lake Monroe would continue to be very important.  He added that the state  makes
a good profit from the city of Bloomington bv providing the water from the
Lake Monroe Reservoir and that the state owed the city considerable consideration
in protecting the security of that  water supply.
Barbara Heise asked if Mr. Rogers thought the tertiary xreatment facilities
should be funded immediately.  He acknowledged the need and said the city  would
file for both federal and local funds, but he warned that the costs would  be
astronomical.  Mr. Spencer asked whether effluent from the .treatment plant was
delivered to Salt Creek below the dan, and whether any study had been made on
plans to deliver processed water in the same  area where the sewage system  is
proposed.  Mr. Rogers said that the sewage plant was in one of the areas which
the Public Service Commission had currently given to one of the rural water
corporations and that the outflow main that goes down through Clear Creek  actually
goes through a no man's land where there is currently no allocation of responsi-
bility.  Mr. Bron asked about future additional  water sources besides Lake Monroe
Rogers said that Griffey Creek-Bean Blossom was  not delivering the high quality
water it could if the treatment system were improved.  He expected that once
improved, the city could receive good water from it at a price below that  the
city is paying to the state for water from Lake  Monroe,  Mr. Cron asked what
population was projected by fiat plan and Mr. Rogers answered that it ought  to
be done just on the basis of present population  because of the high price  the
city is paying for Lake Monroe water.  To meet projected need both systems would
have to be improved, and the plant on Lake Monroe doubled.  Mr Bron said it  was
his personal feeling that, in view of the high taxes to be paid by city
residents:, it was not unreasonable to ask that whatever development occurs be
controlled so that it doesn't damage the lake.  My Rogers answered that he
didn't think there was any conflict with that, but he was not sure whether the
government had the current ability to control development.  Barbara Heise  asked
if it wasn't true that the city has virtually no control over development.  Mr.
Rogers responded affirmatively saying the city really could only make hopeful
statements.
Mr. Docauer spoke about the Griffey Creek Reservoir saying that it has good
quality water because it is well forested, but the quantity is insufficient.
He had little personal knowledge of Bean Blossom, but had heard it was very
turbid and hard to process.  He doubted if it would serve if the population
increased.  He said some of tho mistakes in the Black and Veatch Report had
not been corrected.  His comments were: I, That all growth projected in the
report until 19^0 occurring within Bloomington was unlikcly--much should occur
outside the city.  2. That more growth would occur in the city than in the
county was also unlikely.  3, The overloaded south plant was designed for
7,000,000 gallons whereas before the Commission was told 10,000,000.

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4. The tertiary treatment facilities  need  to  be placed now.   Sometimes tertiary
lagoons cause problenis--high algae  growth  causes secondary pollution.   No  sure
method exists to remove the algae by  sedimentation  a.id the city  ought  to con-
sider this.  In response to Barbara Heise's question  as to whether tertiary
lagoons were the method of tertiary treatment now in  use, Mr.  Docauer  said
there were other methods (electrolysis,  chemicals)  depending  on  the purpose of
the tertiary treatment.
Chairman Patton suggested an amendment to  the wording of the  statement of  the
effect that "all future additional  water needs must cone from Monroe Reservoir"
be changed to "and much of the foreseeable future additional  water need of
Bloomington must come from the Monroe Reservoir."  The motion was accepted and
the amendment adopted.

February 14 -- George Walkenshaw, of  the City's Utilities Department,  spoke
about the problems facing the City's  other sources  of water,  Lake Lemon and
Lake Griffey.  He pointed out that  the City was never able to utilize  fully
Lake Lemon water because tt has_to  flow down  a creek  ten miles before  it  is
collected and rcpunped to the Griffey Water Treatment Plant,  a facility which
was never designed to treat a water with a high turbidity content.  Thus,  in
the past year the city has only been  able  to  use Yfater taken  directly  out  of the
Griffey Reservoir,  He mentioned that water from Lake Monroe  was costing the
city about three million dollars a  day.  It would be  Black and Veatch's
recommendation to expand and remodel  the Griffey Water Treatment Plant so  that
the water from Lake Lemon could be  fully utilized.  This would involve extensive
settling and floculation facilities because of the  sludge problem.  He knew of
no perfect solution to the dewatering of alum plant sludge, but  said,  the  City
is presently constructing some pave drying beds frori  which the sludge  could
be scraped after it has been dried  by mechanical equipment, then hauled off
and buried in land fills.  Other methods arc  under  investigation.  Other
problems included storm water entering the South Sanitary Treatment Plant, and
the plant is a dry ditch situation  allowing little  oxidation  of  the organic
material in the stream thereby causing odor.   He then spoke on solutions ancl a
discussion followed.
     The Water Quality Committee introduced a resolution to support the Lake
Shore Protection Bill now in the state legislature.  The Bill would give  the
Natural Resources Commission the right to  review, all  development within two
miles of state owned or managed reservoirs.   Docauer  remarked that the purpose
of the Bill was to make the NRC into  a kind of Plan Commission for the lake
which would examine all aspects of  planning.   The Stream Pollution Control
Board presently hasn't the power to do this and neither does  the NRC.   Cor-
poration-owned land within the Monroe watershed is about 33OO acres, all but
about 600 acres inside the two mile area.   The Bill gives the NRC
power to make decisions which it previously was not able to make.

March 21 —Barbara Restle of the Water Quality Committee, presented a  prelimi-
nary report on a sedimentation survey of Lake Monroe.  Since  the area  is under-
going rapid change, it is necessary to start  now to obtain accurate records of
the sedimentation rate, which is thought by the Army  Corp of  Engineers to  have
a worse effect on a reservoir than  sewage  or  industrial pollution.  The Corp may
not survey Lake Monroe for 4 to 5 years and the only  soil surveys of the area
now are based on a 1922 study.  A recconnaissance stxidy of the Lake is in  order.
now to determine roughly what the rate might  be, especially since the  original
surveys were made with no projected Change in the land use around the  reservoir.
A motion was made for the Commission  "to encourage the City to take cooperative
action with the county as soon as possible to get the Corps of Engineers to
make a recconnaissance sedimentation  study of Lake Monroe at  its earliest  pos-
sible opportunity in view of the probable  effects of  the proposed developments
around the lake,"


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May 9 -- Barbara Hci.se reminded the Commission of the position it had taken
last year, that in the absence of good regional planning, massive development
around Lake Monroe was unwarranted.  Since that time, Inland Steel has been
given its nearly final approval to build.  Heise noted that the county zoning
ordinance would be having public hearings during the summer and urged Commis-
sioners to attend these meetings to' defend tighter controls for the two mile
fringe.  Jan Biar.chi indicated that a representative of the Army Corps of
Engineers had indicated that the Corps may not be favorably disposed to issuing
a permit to Inland.

June 13 —A letter from the Army Corps of Engineers said that the Corps planned
to resurvey the Lake, completing the other range installations, in 1977.  In
the meantime a preliminary survey would be conducted and the results would be
communicated to the City.  The letter added that the Corps did not fear a
potential reduction of the lifespan of the lake due to sedimentation even
though studies of otl.cr reservoirs indicate that initial projections of that rate
are incorrect,  Bianchi suggested, in light of Senator Dayh's recent disapproval
of the Indianapolis Heservoir project, that the Commission could exercise a lit-
tle more force in pursuit of a survey.  More pressure could be brought to bear
upon the Corps at least to get a study on track for 1977*  Bron argued that
1V77 may well be too late because the dcvelopnent around the Lake appears to be
irninent.  Heise asked what results could be expected from a preliminary survey.
In response Barbara nestle, new chairwoman of the Water Quality Committee,
indicated that such a survey would probably be quite trivial.  A comprehensive
survejr is quite complex and must give an indication of where the sedimentation
is coning fror:, not just iiow nuch deposition there is.  Such information would
be necessary in order to design sedimentation basins to protect the reservoir
from further sedimentation.  Responding to a question of the cost of such a
study, Fix estimated around 020,000.  He thought the Commission  should
ascertain the estimate cost and then go directly to Washington for the appro-
priation.  Bron agreed that the City has much to lose should it not pursue this
course.  Patton proposed that the Commission take initial steps to carry out
Fix's proposal by seeking a cost estimate.
     The Environmental Commission has been asked by the Plan Staff, to appoint
a member to attend meetings at Purdue on the ramifications and possible uses of
the information gathered by the Skylab experiments over Lake Monroe,
     Bianchi reported that Inland Steel had still not accepted the restric-
tions placed upon then by the Stream Pollution Control Board and were not on
the agenda for the June meeting.  In another development, the proposed county
zoning ordinance has been amended to provide that no development visible from
the shores of Lake Monroe would be permitted, and to require drainage and
erosion controls around the lake.  This amendment will be discussed June 14,
and could use the support of all Commissioners.  Bron added that the Forest
Service had also decided to deny permits to cross Forest Service land with
utility pipelines until a regional plan is devised.  Heise pointed out that this
would have particular significance for Granves-Monroe and Inland Steel.

July 11 -- Assistant City Planner, Stu Heller, and Dr. David Frey reported on
the Lake Monroe-Skylab project and its possible ramifications  for environ-
mental concerns.
     Bianchi reported that the estimated cost of a sedimentation survey of
Lake Monroe is $24,000 for a resurvey of the existing ranges,  and 320,000
to complete the range installations.  The Corps said its preliminary study
scheduled for July should give a reasonable indication of the  scdirient in the
project now.  In light of Barbara Restle's opinion that  it is  more important to
know where the sediment is cor.iing  from, such a preliminary study would pro-     >
bably not help rr.uch, added Hianchi.  She pointed out that Sen. Bayh sits on
tli c iiiDremriftfcioas.CoBinitteo and coyld be contacted  for help in this matter.

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The initial response from the Mayor's office,  she reported,  was a willingness
to pursue the request in Washington,  asking that the appropriations be nade now,
rather than in 1977.

September 12 — Ted Najam discussed the letter,  sent to Birch Dayh, concerning
a sedimentation study of Lake Monroe.  He explained that an  earlier letter
had been sent to the Louisville District Army  Corp of Engineers in reference
to the study.  Their reply was that they could give only a quick visual esti-
mate at this time,  but that funds for an in-depth study would not be available
until 1977,  Sen. Bayh explained that the 1974 appropriations bill for the Corps
has already been passed by Congress arid therefore it is impossible to amend
it for such a large amount.  He expressed his  desire to work with the City in
getting appropriations for this study during the next funding session.  This
would make the study possible 2 to 3  years earlier than predicted and in
this sense he was encouraging.
     In reference to the Department of Utilities'  proposal to close Lake Lemon
as a water supply,  Marcia Gelpe replied that the Water Quality Committee has
begun to look into  the proposal and tactics that could be used to clean up
Lake Lemon,  They expressed their feeling to the City's Utilities "oaru.  The
reasons for closing have to do with estimates  of renovating  the facility
compared to the cost of Lake Monroe,  volume of \/ater and the plant.  Patton
cc .im en ted that several inversti gations are taking place,  one  of which is a
sedimentation report and he assumed the decision won't be made until the
information is in,
October 1O — The Water Quality Corr.ni tteo has bpen studying the ^rob] en of
spills of raw sewage into Salt Creek from the Nashville Sewage Plant and sent
a letter to the County Commissioners of Crown County asking that a joint
meeting be set up to discuss the source of the problem as well as possible
solutions.  The Commission agreed to send a letter to the Crown County Com-
missioners endorsing the idea of a joint meeting and asking to be kept informed
on the progress on solving the problem.

November 14 -- Dennis King presented a report concerning the meeting of the
Lake Monroe Regional Waste District Board and City Utilities Service Board
and a request of the Water Quality Committee submitted for an additional
hearing on an environmental assessment hearing to determine the environmental
effects of the regional sewer treatment plant that is goir-g to be constructed
by the City Utilities Service Board and of the diversion system that will be
put in by the LMRVD3.  The Water Quality Committee said that the LMRWDB had
not filed any information prior to the meeting in conjucction with regulations
that the EPA has stated and therefore did not give the public a 30-day notice
to study the information.  The outcome of a request that they hold another
meeting was a letter which indicated that another meeting would not be held,
but they would put some information on file and answer questions, if there
are any.  A motion was made by the Environmental Commission and approved  that
a hearing be held at the regular December Environmental Commission meeting with
the Utilities Service Board and their engineers answering questions from the
Commission and the public.  In addition, the LMRWBD and the Monroe County Plan
Commission were requested to attend.  Barbara Rcstle stresi;ed the interrela-
tedness of these two projects in the Water Quality Committee report.

December 12 — see attached minutes.
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      HISTORY OF ENVIRONMENTAL COMMISSION'S INVOLVEMENT WITH LAKE MONROE
                              Based on 197^ minutes

February 13 — Barbara Restle read . the minutes of the last Water Quality
monthly meeting.  In short, it said there waa concern on the part of many members
that an environmental impact statement should be requested by the committee
that would deal with the effects of the new sewage plant in greater detail.  A
working subcommittee was formed to study the assessment hearings held by the
USB.  It was hoped that this subcommittee would reach a conclusion on the course
of action the Water Quality Committee should pursue.   No questions or comments
were added.
Restle presented to the Commission a summary of the considerations from the sub-
committee.   She said the summary was by no means complete.   The  two considera-
tions presented were in the areas of population data projections for Monroe
County and problems with the treatment p-lant site and outfall sewer.  Patton
recommended that these comments, if approved by the Commission,  should become
part of the December 12^ meeting,  Restle agreed but added that  more considera-
tions than these two are being questioned.  Restle stated that,  although
the population data appears complete in the assessment it is not.  Dennis King
explained that one of the first considerations to be included in an assessment
is a description of the effect of population distribution concentration on any
growth that might occur if the project is undertaken.  He said that, with that
in mind, the subcommittee went through the Infiltration and Inflow Study and
the hearing record for the October 25- environmental  assessment  hearing and
the December 12^ information meeting to determine what RSH Associates had done
in regard to population projections.  King said his impression was that the
statistics used in the assessment had projections to 1980-1990 based on the
census of 1950-1960,  If it is based on these years there would  be no influence
from the lake on the extraurban area because the lake was not constructed
until 19^3?  King said that the alternatives to the temporary plant site were
not mentioned with regards to growth in different volumes and directions.  He
said the Water Quality Committee is recommending further study.   Heise asked
if the Water Quality Committee was asking for an environmental impact statement.
King replied that at this time they are n6t asking fcr an environmental impact
statement but only trying to point out subjects that are not adequately investi-
gated.  Patton summed up King's comments by saying that the population projection
studies are not adequate and the effect of the waste water disposal plant on
changes in population have not been assessed at all.   King's final comment pointed
out that if the population projections have not been adequately  looked into
one can not design capacity of a plant properly,  A copy of these questions will
be sent to the USB and EPA administrators.  The Commission voted unanimously to
forward them.
Jim Ferro reported that at the last monthly meeting of the Water Quality commit-
tee another working group was formed composed of Jim Pres,  David Docauer, and
himself.  This working group will investigate the effects of construction
activities around Lake Monroe with regards to water run-off.  The second major
project the working group is considering is one concerning Lake  Lemon.  This
would involve sampling the shoreling during a rainy period to measure runoff,

April 10 -- Jim Ferro said the water sampling project which is being planned to
test the quality of the run-off in the Lake Monroe watershed is  being organized
and should be underway soon.

September 11 -- An ad hoc committee consisting of Rick Peoples,  Dave Parkhurst,
Rick Darby, and Barbara Heise agreed to study the USB report on  the Long Range
Plan Water Supply and Distribution Facilities for Bloonington, IN.
Rick Darby gave his report on Lako Vonroe.  This report concerned the legal
standing; how can a reservoir outside of the city boundaries be  controlled and
what is the relationship of the Commission to that lake, and whether there is

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anything the Commission can look into  other than water  quality itself.

September 25 — Barbara Restle said that  interests  in the  Water Quality Committee
are too broad.   There are Legal problems,  bacteriological  problems,  limnological
problems, sedimentary problems, and more.   The committee needs to  form  subcommit-
tees and she asked for suggestions  on  restructuring.

November 13 —  Rick Darby gave a report on Lake Monroe.  Ho  said that Lake
Monroe is a large interest requiring tremendous work.   There is no way  one
person can provide the Commission with enough information  for the  Commission
to feel it is in control with the situation.  He has therefore arranged with
Professor Vhite in the Law School for  students to receive  credit for participa-
ting in a project designed to prepare  a paper or pamphlet  which would ade-
quately describe the jurisdiction of various governmental  bodies over Lake
Monroe, interaction and jurisdiction between this commission and the City,
of Bloonington  in those various bodies and the rights
                              generally given to individuals in Indiana in the
Environmental field.  Rick feels with  this help, by the first of the year, a
comprehensive and fairly clear statement  of exactly where  the Commission stands
can be provided.  He then went on to state the legal proceedure the  Commission
wouid have to go through if it was  to  take action and suggestions  the Commission
should consider.  Walter Bron asked if Rick had a specific group in  mind other
than Water Quality,  Rick said no.   Rick  Peoples gave a report on  the status
of the Water Quality Committee.  The first meeting  was  held.  Only four people
showed up but only one was interested  in  participation.
                                       6-62

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CITY
                       OF
BLOOMINGT
                                                          N
          PO BOX 100, MUNICIPAL BLDG., BLOOMINGTON, INDIANA  47401
                                                           'Environmental Commissic
June 5, 1975
Mr. Harlan D. Hirt
Chief, Planning Branch
United States Environmental
   Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois  60604
Dear Mr. Hirt:

The Environnental Quality and Conservation Commission of
Bloomington would like to amntend  its  "Recommendations of the
Environmental Quality and Conservation Commission  on the Siting
of the Proposed Bloomington Sewage Treatment Facilities."   The
report has been sent to you within the past week.

The amendment takes the form of clarification  of some of the
points made in the original "Recommendations"  and  additional
points which we raise in the hope that they will be addressed
in the forthcoming Environnental  Impact Statement.  These  addi-
tional items stem primarily from  the  discussions which  occurred
during the Environmental Assessment Hearing held in Bloomington
on May 29.

The amendment is enclosed.

Sincerely yours,
./I
W. E. 3ron, Chairman
Bloonington Environmental Quality
and Conservation Coninission

VED/1!-
                                6-63

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               Amendment  to  the  "Recommendations  of  the




       Environmental  Quality and Conservation  Commission  (EQCC)




                     on the  Siting  of  the  Proposed




               Bloomington Sewage Treatment Facilities"









1.  Comparison of the Effluent Quality Effects between the  Salt.  Creek




     Site and Any of  the  Clear Creek Sites.







     Discussion during the May 29,  1975 Environmental Assessment Hearing




     brought out the  point that  current requirements on effluent,  based




     on the dilution  capacity of the receiving stream, may  not  (or may)




     be changed in the future to meet  the  19?'3 goals stated in Public




     Law 92-500.  If  the  requirements  are  not  increased,  then clearly the




     one-stage Salt Creek plant  could  continue to be in compliance with




     the legal requirements. In any event, however, as regards  full  cost




     effectiveness, a Clear  Creek plant is more cost effective than the




     Salt Creek plant, because the  former  would discharge a higher quality




     effluent for the same cost. Moreover, with  regard to  future stan-




     dards, a Clear Creek plant  would  discharge an effluent more clearly




     in the spirit of Public Law 92-5OO than would the Salt Creek plant.







2.  The EQCC recommends that every  effort  be made to consider construction




     of a plant at the Dillman Road site without  relocating Clear Creek.




     An amount of about $1.3 million has been  estimated by  Black and




     Veatch for the cost  of  relocating the creek. An additional Si million




     appears to have  been included  for aligning the  plant to fit the site




     after relocation of  the creek. It appears to the EQCC that for
                                 6-64

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     $2.3 million (and probably for considerably less),  a«w«r  link*  can




     be built between components of the facility which would need to be




     located on either side of the creek.   We  request that  the EIS con-




     sider the environmental consequences  of relocating  the creek com-




     pared with the construction of sewer  links, and also the  relative




     cost effectiveness of these alternatives.






3.  At the Environmental Assessment Hearing, Black and Veatch  claimed




     that the need for vacuum drying of sludge  at the Dillman  Road site




     results from the lack of two to three level acres of land needed to




     build drying beds.  The relative additional cost for vacuum  drying




     over drying beds is projected to be 51 million (projected worth).




     This additional expenditure is assessed only on the Dillman  Road




     site.  A study of a geodetic map of the site suggests  that the




     required two to three acres of land are available,  even if the




     Black and Veatch layout is adhered to. In any event,  it  appears to




     the EQCC that the required acreage can be  constructed  for consider-




     ably less than the incremental Si million.  The EQCC requests that




     this cost differential be investigated.






4.  The EQCC questions the need for an additional amount of 3lOO,OOO




     yearly attached by Black and Veatch to the labor costs  at  any of the




     Clear Creek sites compared to the Salt Creek site.  The only explana-




     tion of this amount given by Black and Veatcli to date  is  that the




     Clear Creek sites do not require nore personnel but, rather, higher




     quality personnel.  Since Black and Veatch has stated  that the  com-




     plexity of operation is the sane at all sites, the  EQCC fails to
                                   6-65

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understand the basis for this incremental assessment against the




Clear Creek sites.  The EQCC requests that this cost differential




also be investigated.
                           6-66

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                    MVmONNENTAI. PROTBCTIOI1 A8EMCY
                          RECEIVED
                           .;--.!i02lS75
                     PLANNING BRANCH
              RECOMMENDATIONS OF THE


ENVIRONMENTAL QUALITY AND CONSERVATION COMMISSION


           ON THE SITING OF THE PROPOSED


    BLOOMINGTON SEWAGE TREATMENT FACILITIES
                 6-67

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        RECOMMENDATIONS OF THE ENVIRONMENTAL QUALITY
    AND CONSERVATION COMMISSION ON THE SITING OF THE PROPOSED
         BLOOMINGTON SEWAGE TREATMENT FACILITIES

1.  General Background
     Almost since its inception during the spring of 1972 the Environ-
mental Quality and Conservation Commission (EQCC) has been studying
the environmental aspects of the placement of a new waste-water treat-
ment facility in southern Bloomington.  This is demonstrated by the
record of the EQCC meetings, whichis summarized in the Appendix.   The
EQCC has discussed the siting of the facilities during many civic
meetings, has supported several pertinent studies, and has participated
in studies carried out by others.   We have presented recommendations
and relevant information to the citizens of Bloomington, to the Common
Council, to various members of the City Administration, and to State and
Federal officials.,  Relying on these experiences and the understanding
we have gained from them, we present this report as our analyses  of
the environmental factors associated with the siting of the proposed
facilities.
     From an environmental perspective, there are two major siting
options:  the proposed Salt Creek site and the alternative sites  on
upper Clear Creek.  Possible alternative sites mentioned to date  include
the present Winston Thomas site and sites on South Rogers Street, on
Dill man Road, and on Ketcham Road.
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                                 -c-
II.  Recommendations
     Based e»f» their community involvement referred to above and on
their professional expertise in such areas as physics, chemistry, eco-
logy, and soil science, the members of the EQCC have unanimously con-
cluded that all of the Clear Creek sites are environmentally preferable
to the Salt Creek site.  Of the Clear Creek sites, the EQCC believes
that the total environmental impact of construction and operation at
the Dillman Road site will  be the least.  Therefore, the EQCC recommends
that the treatment facility be placed at the Dillman Road site.  This
report will present our reasons for this recommendation;  first, the
environmental issues differentiating all of the Clear Creek sites from
Salt Creek; second, the environmental and social  issues which differ-
entiate Dillman Road from Winston-Thomas and South Rogers St.  There
are four main reasons for selection of a Clear Creek Site:
     a.  The terrestrial and aquatic destruction involved in running
         the outfall sewer to Salt Creek will be avoided.
     b.  The level of effluent quality from the Clear Creek sites will
         be greater.
                          i
     c.  The Salt Creek site is within the floodplain of Salt Creek,
         directly below the spillway at the reservoir and located on
         a soil type known to be subject to waterlogging. (see Soil Survey)
     d.  The possibility of adverse secondary effects of facilitated
         development at Lake Monroe because of placement at Salt Creek
         will be less severe.
The primary considerations differentiating Dillman Road from Winston
Thomas/St. Rogers St. are the adverse aesthetic impact of a wastewater
treatment facility placed in the more densely populated areas and the
                               6-6.9

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                                  -3-
social impact of relocation of several  families living in a trailer
park on the proposed site.

III.  Comparison of the Environmental Effects of Clear Creek_a_n_d
      Salt Creek Siting

A.  Outfall Sewer Effects
      Locating the waste-water treatment plant at the distant Salt
Creek site requires a long outfall sewer.  There are five alternative
sewer routes from Blo:mington to that site:
      (1)  under Clear Creek;
      (2)  along Clear Creek, but higher upon the banks and slicing
          across the creek's bends;
      (3)  as in  (2), but  using a force main to cut across the broad
          westerly  bend of the creek;
      (4)  along Clear Creek to the Ketcham Road area, then across the
          hills via a force main to  lower Little Clear Creek, then
          south along Little Clear Creek and Clear Creek;
      (5)  as in  (4), but  to upper Little Clear Creek.,
The proposed outfall sewers to the Ketcham Road and Dillman Road-sites
follow  route  (?) above, but for much shorter distances.  Both the South
Rogers  Street and Winston Thomas sites would require 9000 ft. force
mains running up the Clear Creek bed from the proposed southeast inter-
ceptor  sewer.   It should  also be noted that, should the Lake Monroe
Regional  Waste  District decide to have its wastewater treated at a
Bloomington  Clear Creek facility, a  force main running overland from
                               6-70

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                                 -4-
from Smithville to the Clear Creek bed will  have to be built.
     Outfall sewer construction and maintenance will have detrimental
environmental effects; the longer the sewer is, the worse these effects
will be.  These effects can result from earth-moving during construction
and may also include permanent environmental damage caused by right-
of-way clearance and maintenance.  All of these effects are magnified
by the proximity of a natural area, Cedar Bluffs.  Following is a
more detailed consideration of these factors.
                                                 p  ^
     The right-of-way for construction of sewer alternative (2), which
is the one  recommended by Black & Veatch, is 100 feet wide and about
60,000 feet  long.  An area of six million square feet will thus be
subjected to physical abuse.  A trench averaging twelve feet deep will
be dug down  the length of this right-of-way.  Much of the 4.3 million
cubic feet  of earth that will have to be removed is limestone, which
will have to be blasted out.  Some of this spoil will be bulldozed and
graded to level the right-of-way for maintenance access.  It is rather
difficult to believe that bulldozing and blasting on this scale could
be done with an eye to "limiting environmental disruption" (Black &
                          <
Veatch, p.  X-16).  It is more reasonable to believe that construction
activity will result in the destruction of much terrestrial and aquatic
wildlife habitat, in addition to impairing the stream's aesthetic value.
     Despite the promise to grade and reseed "as soon as practicable,"
it may work out that, considering the frequency of rain and flash-
flooding in the area, erosion may set in before vegetative cover does.
In the case of alternative  (3), erosion may also result from unrevege-
tated sewer line easements  in the hills above the creek.  In any case,
the resultant siltation of  the stream could have an effect on the aquatic

                                6-71

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                                   -5-
biota more permanent that  that  caused  by  sewer construction  itself.
     The EQCC also has  reservations  about the effects of  the twenty-odd
creek crossings proposed under  alternatives  (1)  and  (2).  The provisions
for keeping the line from  being dug  up by the action of the  stream are
not described in the Black &  Veatch  report.  This makes it impossible
to comment on them specifically except to hypothesize that there may
be permanent changes in the substrate  of  the creek which  could affect
stream biota, flow characteristics,  and aesthetics adversely.
     Though specific techniques for  right-of-way maintenance have not
been described by Black &  Veatch,  usual procedures involve defoliation
with herbicides.  This  would  constitute a chronic perturbation to the
immediate and neighboring  wildlife habitat as well as a possible source
of pollution from runoff.
     Another problem is the proximity  of  the Cedar Bluffs area to the
Clear Creek sewer route.   Sewer construction and maintenance could affect
the integrity of this area through the resultant noise, dust, and impair-
ment.  While the sewer  does not pass through the area, alternatives
place the line just across the  creek from it.  On the basis  of the above
                          5
considerations, the EQCC recommends  that  the important potential negative
environmental effects of the  outfall sewer be minimized by minimizing
the length of the sewer, subject to  constraints  described below.

B.  Effluent Quality Effects
     The Salt Creek facility  is to be  a one-stage plant,  while current
state water quality standards require  that a Clear Creek  plant, because
of the low dilution capacity  of the  receiving stream, be  a two-stage
                               6-72

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                                 -6-
plant.  A one-stage plant is somewhat more susceptible to rapid
changes in plant variables such as water volume than  a two-stage  plant.
Rapid changes in water volume do occur in the  Bloomington area  during  the
summer.  It is conceivable that at that time a one-stage  plant  could
discharge improperly treated effluent.
     More importantly, however, a one-stage plant  will  be unable  to
discharge effluent of a quality high ehough to meet the standards
currently required for 1983 by Public Law 92-500.   Yet the Black  &
Veatch study which judges the cost effectiveness of the Salt  Creek
and Dillman Road sites to be similar assumes a one-stage  plant  at the
Salt Creek site.  The EQCC questions the rationale behind a twenty-
year cost effectiveness study predicated on water quality standards that
will be superseded by more stringent ones after only  five years.   Clearly,
with respect to present water quality standards, a Dillman Road plant
would be more cost effective than a Salt Creek plant, because the former
would discharge a higher quality effluent for  the same cost;  with respect
to future standards, a cost effectiveness study would have to consider
fines the City might have to pay due to the emi.ssion  of an illegal
effluent by a Salt Creek plant.  The EQCC concludes that, environmentally,
and legally, a two-stage plant is better than  a one-stage plant and
that, economically, a two-stage plant at Dillman Road is  better than  a
two-stage plant at Salt Creek.
     An added benefit of a Clear Creek site with the  relatively clean
effluent it is required to discharge is the potential recreational use
of Clear Creek as a canoe stream.  Such areas  are not abundant around
Bloomington.  If the Salt Creek site is chosen, the flow in Clear Creek
                                6-73

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                                     -7-
will be too low to permit its use for this  purpose.

C.  Hydrological Effects
     The proposed method of sludge disposal  at the Salt  Creek  site is
subsurface soil injection over an area comprising most of the  site.
During the spring rains of 1975, this area  was heavily waterlogged.  The
EQCC cautions that sludge injection into land which is subject to
periodic leaching by rain water, and which  abuts major receiving streams,
may result in periodic large influxes of nutrients, untreated  heavy
metals, and other matter into the streams.   It should be noted that this
creek water is a water source for Bedford,  only thirteen miles down-
stream.  These problems are not addressed in the facilities plan.
     These possible detrimental hydrological effects may be exacerbated
by the location of the Salt Creek site within a 100-year flood plain.
Until flood-plain alterations potentially caused by the  Lake Monroe
dam are known, it would be wise to require  that the facility's constr-
uction plans include safeguards to prevent  discharge, leakage, or
leaching of untreated wastes from the plant area into the creeks during
periods of high water.    »

D.  Secondary Effects of Unplanned Development in the Lake Monroe Area.
     Another major concern of the EQCC is the possible adverse effect
on  the Lake Monroe area resulting from development in the lake's
watershed stimulated by the placement of the treatment facility at
Salt Creek.  We anticipate this facilitation because, according to
         92-500
Public Law /  development cannot occur without suitable wastewater
treatment.  While the dollar costs to Bloomington at Dillman Road or
                                6-74

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Salt Creek are similar, the cost to LMRWD*IS much less  if the Bloom-
ington Plant is at Salt Creek.  The advantage of this  Salt Creek  hookup
is that several existing sources of effluent will be removed  from the
lake.  This is the main environmental  benefit of this  arrangement.
This is balanced by the possibility that cheaper sewage treatment will
permit more rapid development than would otherwise occur.  In principle
the development of private living structures and even  commercial  ones,
need not lead to the deterioration of the lake region,  providing  that
sufficient planning controls and enforcement procedures are established
and maintained.  No such planning structures and controls exist in the
region at this time.  The Lake Monroe Land Suitability Study recently
carried out is not intended to guarantee the planning needed in the
area although it can serve as background for the development of such
a plan.  In view of this situation EQCC is evaluating potential environ-
mental effects based on recent and current planning and construction
methods.
     The EQCC considers the primary functions of Lake Monroe to be
1)  flood control water impoundment, 2)  a recreational resource,
3)  a major source of domestic water for the City of Bloomington  and its
environs.  It is the potential deterioration of these functions of the
lake with which we are concerned.  In addition, much of the land  around
the lake presently has an undisturbed, natural quality which is important
in and of itself and also as  it enhances the recreational value of the
whole region.
     Development without a regional land use plan and construction
 practice regulations  potentially could  detract from the  functions  listed

 "Lake  Monroe Ueflional  Waste District
                                    6-75

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                                   -y-
above in the f61 lowing ways:
     1)  Conversion of privately owned  natural  areas  into  develop-
ments which will  decrease the amount of natural  landscape  for aesthetic,
wildlife and recreational use.   This effect  will  be concentrated  in
certain areas.
     2)  Improperly controlled  construction  destroys  foliage and  ground
cover, resulting  in erosion,  increased  sedimentation  and potentially
decreased water quality.
     3)  Increased use of motor-driven  boats and motor vehicle traffic
on land will probably result  in increased  amounts of  oil-based products
and heavy metals  entering the lake.
     4)  Motor bo?t traffic may result  in  increased shoreline erosion.
     5)  Unaesthetic construction on and around the lake's shoreline
will detract from the natural quality and  recreational  value of the
lake area.
     One very important variable which  must  be  considered  in evaluating
possible development around Lake Monroe is the  opinion of  those people
who use the Lake.  Wise  (1975)  has surveyed  opinions  of users and found
                          1
significant expressions in favor of preserving  the semi-natural  quality
of the area.  Most users prefer swimming,  camping, and boat fishing as
recreational activities.  A substantial plurality favored  fewer_ condo-
miniums and houses around Lake Monroe than presently  exist.  Facilities
which those interviewed did not desire  included motels, sporting  goods
stores, condominiums, houses, and boat  ramps.  All but 3%  found the
forest around the lake attractive.  The attribute which people like best
is the beauty of the lake.  The attributes 1iked least are the crowding
and facilities.  EQCC's conclusion about public opinion is that the type
                                6-76

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                                -10-
of development likely to be facilitated by placement of Bloomington's
sewage treatment plant at Lake Monroe (houses, condominiums, commercial)
is precisely the type of development which Lake users do not want.
Further, such development might destroy those aspects of the Lake envir-
onment which the users appreciate the most (attractiveness, forests,
fishing) and exacerbate problems which they already perceive (crowding
and facilities).
     EQCC is concerned that the necessary regional  planning does not
exist to control such effects on the lake's primary functions as those
listed above.  We therefore believe that development should not be
facilitated by placement of the plant at Salt Creek.  We recognize  the
environmental value of removing present sources of effluent from the  lake,
but are not certain that this value overweighs the other negative effects
which potentially might result.

E.  Summary
     The Salt Creek site will require a longer and thus more environ-
mentally disruptive outfall sewer than any of the Clear Creek sites.
A Clear Creek plant will produce effluent of higher quality than the
proposed Salt Creek plant, whose effluent will be outside legal limits
shortly after commencement of operation.  Hydro!ogical considerations
indicate that a Salt Creek plant may periodically cause stream pollution.
Finally, the Salt Creek site is more likely than a Clear Creek site to
lead to unplanned development in the Lake Monroe area, with all the
environmental deterioration this, implies.  Because the environmental
costs of the Salt Creek site are obviously much higher than those of
                               6-77

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                                   -li-
the Dillman Road site, and because the economic  costs  are  similar,  the
Salt Creek site can be eliminated from further consideration.

IV.  Comparative Evaluation _of the Clear Creek _SHes
     Differences among the impacts of the variousCiearCreek sites  on
the physical environment are minor compared with the  difference in
impacts between any of the Clear Creek sites and the  Salt  Creek site.
The outfall sewer to the Dillman Road site would be a  little longer
than the force main from the southeast interceptor to  the  Winston Thomas
or South Rogers Street sites, and the outfall sewer to the Ketcham
Road site will be a little longer still.  On the other hand, if the
new plant is not built at the Winston Thomas site, that site can be
converted to a park, though the South Rogers site would use part of the
present site and decrease the value of a park there.   Selection of the
Winston Thomas site may lead to better re-use of existing  materials.
Thus, in terms of physical environmental impact, the only clear advan-
tage at this point is that of Dillman Road over Ketcham Road.  Given
its higher economic costs, also the Ketcham Road site can  be eliminated
from further consideration'.
     The major drawback to the present location  seems to be the con-
struction disturbances and the possibility of increased odors in the
vicinity which is heavily populated, and the possible need to relocate
several households.  The Dillman Road site is not presently densely
populated and for topographic reasons does not seem threatened by nearby
settlement.  EQCC finds that, while all the Clear Creek sites seem
preferable to Salt Creek, we would rank Dill man Road ahead of Winston
Thomas/S. Rogers St. primarily for social reasons.
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                                -12-
 V.  The Need for an Environmental  Impact Statement
     EQCC recommends that if the Salt Creek Site is selected,  EPA
should definitely prepare an EIS to investigate not only the points
made above but also many other specific points concerning possible
routes for the outfall sewer, the advisability of sub-surface  injection
as a means of sludge disposal, and specific treatment plans.  The issue
most difficult for us, as citizens, to predict and understand  about
the problem of site selection is the question of secondary impact of
development in the Lake Monroe Area.  EQCC recommends that, because  of
the complexity of this problem, major efforts should be made by EPA
to predict, evaluate and Suggest solutions to these secondary impacts.
A list of points needing investigation in an EIS follows this  section.
Some members of EQCC believe that an EIS might be desireable irrespective
of which site is chosen and so points related to both sites are included
on the list.
1.  Environmental desirability of returning Clear Creek to its pre-
                          ?
Winston Thomas flow level in order to restore the original biota;
comparative study of Little Clear Creek biota might be made to determine
if change has occurred.

2.  Extent of direct destruction of wildlife habitat by outfall sewer
construction.

3.  Quantitative assessment of Clear Creek siltation which might be
caused by sewer construction; effect on Bedford drinking water.

4.  Extent of indirect environmental degradation caused by outfall
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                               -13-
sewer construction due to activities  by the  work  crew  such  as
driving equipment into and out  of  right-of-way, parking  automobiles,
etc.
5.  Identification of those areas  where blasting  must  be done  and
assessment of the impact of the resulting  fallout and  noise on
nearby wildlife habitat and cultural  areas,  e.g., Cedar  Bluffs,
Ketcham Road cemetery.

6.  Differentiation of sewage treatment alternatives with respect
to effluent quality, especially between alternatives 2A  and 3A in
Facilities Plan; analysis of economic-environmental tradeoffs.

7.  Extent to which revegetation is necessary  following  sewer  con-
struction, how soon it must be  done,  and how likely it is to be
successful, given the area's hydrology; differentiation  between  degrees
of erosion expected with and without  revegetation.

8.  Environmental impact of overland  sewer routing, including  conside-
rations similar to those given  above  for creek bed routing.  Judgment
on the advisability of building alternatives 3, 4, 5,  and LMRWD
Smithvilie-Clear Creek force main.

9.  Reevaluation of economic-environmental costs  of outfall  sewer alter-
natives for Salt Creek site, expecially with respect to  alternatives
2 vs. 5A; analysis of environmental tradeoffs  of  greater overland as
opposed to less creek bed routing  for alternative 5A;  amount of  eco-
nomic difference LMRWD might fund  as  their share  of Little  Clear Creek
sewer to have a plant on Salt Creek instead  of Clear Creek.
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                               -14-
10.  Description of biota of wildlife habitat to  be destroyed  at
Ketcham Road and Salt Creek sites and determination of its  rarity.
11.  Measures to be taken to ensure that holding  ponds,  etc.,  will
not be flooded.
12.  Environmental  assessment of possible landfill  and soil  injection
sites to determine  potential for water pollution  due to flooding  or
leaching after rainfall.

13.  Comparisons of degrees of buffering needed and possible for  various
sites and various treatment and disposal  methods  to shield  local  residents
and visitors to  natural  and cultural  areas from noise, odor, and  ugli-
ness of sewage treatment.

14.  Assessment  of  tradeoffs between biotic-geologic costs  and social
costs, the latter accruing from #13 above and from forced relocations
at some of the sites.  (See also #23)

15.  Current aesthetic values of undeveloped sites.
                          i
16.  Comparative analyses of economies of land use for various sewage
treatment and sludge disposal alternatives.
17.  Size of the work crew required for construction, where they  will
commute from and what social costs they might impose on the community.

18.  Social benefits with respect to reducing unemployment of  con-
struction of plant.
                                  «
19.  Comparative analysis of energy and resources required for various
site, treatment, and disposal alternatives.
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                                 -15-
20.  Environmental  effects of travel  over,  entry to,  and  exit from
right-of-way by maintenance crews.

21.  Precautions that must be taken to prevent the creek  from digging
through to the sewer at crossing points; effects of these precautions
on biota and flow characteristics;  impact of altered  flow character-
istics on downstream creek ecosystem.

22.  Impact of possible herbicide use during right-of-way maintenance
on environment, both directly on biota and indirectly due to possible
water pollution this might cause.

23.  Surveys of local residents as to what impact they feel the Winston
Thomas plant and its proposed expansion or removal to South Rogers
Street has or will have on their lives; income distribution of resi-
dents so affected and assessment of their political power.

24.  Environmental benefits accruing to Clear Creek sites due to
potential recreational uses of Clear Creek resulting from maintaining
its present flow level.
                          1
25.  Possibility that a regional plan should be a prerequisite for
selection of the Salt Creek site.

26.  Total environmental  analysis of the effects of unplanned development
around Lake Monroe facilitated by the Salt Creek site, including poten-
tial biotic, geologic, and social costs accruing from any destruction
of forest, degradation of the water supply, and increase in population
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density and potential  social  gains accruing from economic growth;
tradeoff analysis of these costs  and gains.

27.  Environmental  and economic costs and gains accruing from
sludge disposal  by means of treating it and selling it as fertilizer.

28.  Determination of any upper'ceiling which geologic restrictions
may place on south-planning-area  population and deduction of largest
sewage treatment design capacity  that will ever be needed.

OCR/nan
                         Acknowledgements
     James Chiesa, S.P.E.A.  graduate student,  has permitted use of
portions of an unpublished manuscript as well  as volunteering editorial
help.  The following report was cited in the text:
     Wise, Charles.  1975.  User preserences of policy alternatives:
        the case of recreational  user attitudes toward development
        and regulation at Lake Monroe, Indiana.  School of Public and
        Environmental  Affairs Occasional Papers, No. 4.
    Soil Survey,  1973.   Interim  Soil Survey, Vol. 2,  Information
and Interpretation,  Bloonington,  Indiana.  U. S, Department of
Agriculture, Soil  Conservation  Service, Purdue  University.
                             6-83

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                         APPENDIX






     Brief synopsis of items discussed during  Environmental




Quality and Conservation Commission meetings which pertain to




Lake Monroe,  water quality,  and the sewage treatment plant.
                           6-84

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HISTORY OF ENVIRONMENTAL COMMISSION»S INVOLVEMENT WITH LAKE MONROE
                       Based on 1972 minutes

May 10 — reported that Rod Crafts and Barbara Resile would travel to
Indianapolis to speak with John Cregor, an attorney who is the foremost
leading authority in the country on riparian rights, about the City's
power to control development in Lake Monroe.  The Water Quality Commit-
tee wished to icsue a warning about the possibility of Inland Steel
encroaching upon Lake Monroe and requested the Commission's support and
approval for enlisting the aid of other groups in the effort.  A motion
was made and approved that The Water Quality Committee should accumulate
as much factual information as they can before the next Commission
meeting with their suggestions as to what action the Commission can
take respecting Lake Monroe.

July 12 -- The resolution on Lake Monroe development was read and David
Docauer presented a background report on the resolution.  He said that
the resolution was^beginning step in~ seeking protection for Lake Monroe.
The vote was unanimous.  John Patton directed that the absent members be
polled to ensure a majority giving approval.

August 9 — A motion made chat: The Commission request the City of Bloom-
ington to name a representative to sit in on the final hearing of the
Department of Natural Resources; to request from Inland Steel's attorney
a copy of the plans to be made available as soon as possible; and a
representative be named to appear at the hearing of the Stream Pollution
Control Board on Tuesday, August 15, 1972.  Whitehead offered an amendment
asking that Inland Steel give the plans of their development  within the
drainage basin of Lake Monroe and that they also name a representative
to come before the Commission to discuss the development.   The motion and
amendment were approved unanimously.

October 11 -• Dick Hilliker, Representative of Inland Steel Development
Corp., presented maps, gave a report on a proposed development around
Lake Monroe and discussed the development proposal with the Commission
and the audience.  A Water Quality Committee report submitted by Docauer
was accepted. Donald Whitehead and David Docauer agreed to write a
letter to the Stream Pollution Control Board and the University on
behalf of the Commission  stating their views on the ISDC's plans.

November 8 -- Ted Najam, Administrative Assistant to the Mayor, read
a statement from the Office of the Mayor concerning the proposed Position
Paper prepared by David Docauer and Donald Whitehead on land development
around Lake Monroe; the present state of Lake Monroe and a projection
of its future in relation to presently proposed developments and future
developments.  The statement basically said that the Commission should
not make such statements without making it clear that it is not necessarily the
position of the City and "A statement of this kind with such broad
ramifications should be made only after there has been broad partici-
pation by all those City departments and commissions which have something
to contribute,"  Discussion followed, and some changes were made on
the position paper.  The paper was approved.  It was decided that Don
Whitehead would represent the Commission before the Common Council.

December 13 — Donald Whitehead reported that the Common Council passed
a resolution accepting and concurring in the Commission's Position Paper.
Bron added that at the enrl of the discussion a suggestion was made by         '
Council President ChaMotte Zietlow for the formation of a body to look


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into the ecological factors that concern the lake and the long range
view.  Chairman Patton would contact Zietlow to request that the
Commission be included in such a body if it was not already constituted.
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   SUMMARY OF ENVIRONMENTAL COMMISSION'S INVOLVEMENT WITH LAKE MONROE
                           Based on 1973 minutes

January 10 — The Commission's draft statement on the Black and Veatch  report
was presented.  In the discussion that followed, it was brought out that  there
would be federal funding but the City does not require an impact statement.
Dave Rogers(President of the Board of Works) said he worked with the Black and
Veatch Report and thought the comments of the statement appropriate. Cu  finding
Number two (Monroe Reservoir) he felt the comments were well taken, but said
that Black and Veatch were only asked to do a bare hones study so the report
does not take into account the impact of increased development.  The construc-
tion of waste water facilities would of necessity require federal grants, which
would in turn require an impact study, though that study would be directed
primarily toward alerting the public rather than binding any specific agen cy
to a set course of action.  Mr. Rogers said also that Lake Monroe Reservoir  would
not provide all of Bloomington's future water need.  The city plans to  continue
to develop dependencies on Griffey Creek-Bean Blossom, though  dependence on
Lake Monroe would continue to be very important.  He added that the state makes
a good profit from the city of Bloomington by providing the water from  the
Lake Monroe Reservoir and that the state owed the city considerable consideration
in protecting the security of that  water supply.
Barbara Heise asked if Mr. Rogers thought the tertiary treatment facilities
should be funded immediately.  He acknowledged the need and said the city would
file for both federal and local funds, but he warned that the costs would be
astronomical.  Mr. Spencer asked whether effluent from the .treatment plant was
delivered to Salt Creek below the dam, and whether pny study had been made on
plans to deliver processed water in the same area where the sewage system is
proposed.  Mr. Rogers said that the sewage plant was in one of the areas  which
the Public Service Commission had currently given to one of the rural water
corporations and that the outflow main that goes down through Clear Creek actually
goes through a no man's land where there is currently no allocation of  responsi-
bility.  Mr. Bron asked about ^uture additional water sources besides Lake Monroe
Rogers said that Griffey Creek-Bean Blossom was not delivering the high quality
water it could if the treatment system were improved.  He expected that once
improved, the city could receive good water from it at a price below that the
city i. s paying to the state for water from Lake Monroe.  Mr. Bron asked what
population was projected by that plan and Mr. Rogers answered that it ought  to
be done just on the basis of present population because of the high price the
city is paying for Lake Monroe water.  To meet projected need both systems would
have to be improved, and the plant on Lake Monroe doubled.  Mr Bron said it  was
his personal feeling that, in view of the high taxes to be paid by city
residentsi it was not unreasonable to ask that whatever development occurs be
controlled so that it doesn't damage the lake.  My Rogers answered that he
didn't think there was any conflict with that, but he was not sure whether the
government had the current ability to control development.  Barbara Heise asked
if it wasn't true that the city has virtually no control over development.   Mr.
Rogers responded affirmatively saying the city really could only make hopeful
statements.
Mr. Docauer spoke about the Griffey Creek Reservoir saying that it has  good
quality water because it is wall forested, but the quantity is insufficient.
He had little personal knowledge of Bean Blossom, but had heard it was  very
turbid and hard to process.  He doubted if it would serve if the population
increased.  He said some of the mistakes in the Black and Veatch Report had
not been corrected.  His comments were: 1. That all growth projected in the
report until 1980 occurring within Bloomington was unlikely--much should occur
outside the city.  2. That more growth would occur in the city than in  the
county was also unlikely.  3« The overloaded south plant was designed for
7,000,000 gallons whereas before the Commission was told 1O,000,000.


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4. The tertiary treatment facilities need to be placed now.   Sometimes tertiary
lagoons cause problems--high algae growth causes secondary pollution.   No sure
method exists to remove tne algae by sedimentation and the city ought  to con-
sider this.  In response to Barbara Heise's question as to whether tertiary
lagoons were the method of tertiary treatment now in use,,  Mr.  Docauer  said
there were other methods (electrolysis,  chemicals) depending on the purpose of
the tertiary treatment.
Chairman Patton suggested an amendment to the wording of the statement of the
effect that "all future additional water needs must come from Monroe Reservoir"
be changed to "and much of the foreseeable future additional water need of
Bloomington must come from the Monroe Reservoir."  The motion was accepted and
the amendment adopted.

February 14 — George V/alkenshaw,  of the City's Utilities  Department,  spoke
about the problems facing the City's other sources of water, Lake Lemon and
Lake Griffey.  He pointed out that the City was never able to  utilize  fully
Lake Lemon water because it haSjto flow  down a creek ten miles before  it is
collected and rcpunped to the Griffey Water Treatment Plant, a facility which
was never designed to treat a water with a high turbidity  content.   Thus, in
the past year the city has only been able to use w,ater taken directly  out of the
Griffey Reservoir.  He mentioned that water from Lake Monroe was costing the
city about three million dollars a day.   It would be Black and Veatch's
recommendation to expand and remodel the Griffey Water Treatment Plant so that
the water from Lake Lemon could be fully utilized.  This would involve extensive
settling and floculation facilities because of the sludge  problem.   He knew of
no perfect solution to the dewatering of alum plant sludge,  but said,  tlie City
is presently constructing some pave drying beds from which the sludge  could
be scraped after it has been dried by mechanical equipment,  then hauled off
and buried in land fills,,  Other methods are under investigation.   Other
problems included storn water entering the South Sanitary  Treatment Plant,  and
the plant is a dry ditch situation allowing little oxidation of the organic
material in the stream thereby causing odor.   He then spoke  on solutions and a
discussion followed.
     The Water Quality Committee introduced a resolution to  support the Lake
Shore Protection Bill now in the state legislature.   The Bill  would give the
Natural Resources Commission the right to review all development within two
miles of state owned or managed reservoirs.   Docauer remarked  that  the purpose
of the Bill was to make the NRC into a kind of Plan Commission for  the lake
which would examine all aspects of planning.   The Stream Pollution  Control
Board presently hasn't t'he power to do this and neither does the NRC.   Cor-
poration-owned land within the Monroe watershed is about 33OO  acres, all but
about 600 acres inside the two mile area.  The Bill  gives  the  NRC
power to make decisions which it previously was not able to  make.

March 21 —Barbara Restle of the Water Quality Committee,  presented a  prelimi-
nary report on a sedimentation survey of Lake Monroe.   Since the area  is under-
going rapid change, it is necessary to start now to obtain accurate records of
the sedimentation rate, which is thought by the Army Corp  of Engineers to have
a worse effect on a reservoir than sewage or industrial pollution.   The Corp nay
not survey Lake Monroe for 4 to 5  years  and the only soil  surveys of the area
now are based on a 1922 study,   A recconnaissance study of the Lake is in order.
now to determine roughly what the rate might be, especially  since the  original
surveys were made with no projected change in the land use around the  reservoir.
A motion was made for the Commission "to encourage the City  to take cooperative
action with the county as soon as  possible to get the Corps  of Engineers to
make a recconnaissance sedimentation study of Lake Monroe  at its earliest pos-
sible opportunity in view of the probable effects of the proposed developments
around the lake."
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.May 9 —  Barbara Heise  reminded  the Commission of the position it had  taken
 last year,  that  in  the  absence of good regional planning, massive development
 around Lake Monroe  was  unwarranted.   Since  that time, Inland Steel has been
 given its nearly final  approval  to build,   Heise noted that the county zoning
 ordinance would  be  having  public hearings during the summer and urged  Commis-
 sioners to attend these meetings to defend  tighter controls for the two mile
 fringe,   Jan Bicr.chi  indicated that a representative of the Army Corps of
 Engineers had indicated that  the Corps may  not be favorably disposed to issuing
 a permit  to Inland,

 June 13 —A letter  from the Army Corps of Engineers said that the Corps planned
 to resurvey the  Lake, completing the  other  range installations, in 1977.  In
 the meantime a preliminary survey would be  conducted and the results would be
 communicated to  the City,  The letter added that the Corps did not fear a
 potential reduction of  the lifespan of the  lake due to sedimentation even
 though studies of other reservoirs indicate that initial projections of that rate
 are incorrect,  Bianchi suggested, in light of Senator Bayh's recent disapproval
 of the Indianapolis Reservoir project, that the Commission could exorcise a lit-
 tle more  force in pursuit  of  a survey.  More pressure could be brought to bear
 upon the  Corps at least to get a study on track for 1977.  Bron argued that
 1977 may  well be too  late  because the development around the Lake appears to be
 iminent,   Heise  asked what results could be expected from a preliminary survey.
 In response Barbara Restle, new  chairwoman  of the Water Quality Committee,
 indicated that such a survey  would probably be quite trivial.  A comprehensive
 survey is quite  complex and must give an indication of where the sedimentation
 is coning from,  not just how  much deposition there is.  Such information would
 be necessary in  order to design  sedimentation basins to protect the reservoir
 from further sedimentation.   Responding to  a question of the cost of such a
 study, Fix estimated  around S20,OOO,  He thought the Commission . should
 ascertain the estimate  cost and  then  go directly to Washington for the appro-
 priation,  Bron  agreed  that the  City  has much to lose should it not pursue this
 course,  Patton  proposed that the Commission take initial steps to carry out
 Fix's proposal by seeking  a cost estimate.
      The  Environmental  Commission has been  asked by the Plan Staff, to appoint
 a member  to attend  meetings at Purdue on the ramifications and possible uses of
 the information  gathered by the  Skylab experiments over Lake Monroe,
      Bianchi reported that Inland Steel had still not accepted the restric-
 tions placed upon them  by  the Stream  Pollution Control Board and were  not on
 the agenda for the  June meeting. In  another development, the proposed county
 zoning ordinance has  been  amended to  provide that no development visible from
 the shores of Lake  Monroe  would  be permitted, and to require drainage  and
 erosion controls around the lake.  This amendment will be discussed June 14,
 and could use the support  of  all Commissioners,  Bron added that the Forest
 Service had also decided to deny permits to cross Forest Service land  with
 utility pipelines until a  regional plan is  devised,  Ileise pointed out that this
 would have particular significance for Granves-Monroe and Inland Steel,

 July 11 -- Assistant  City  Planner, Stu Reller, and Dr, David Frey reported on
 the Lake  Monree-Skylnb  project and its possible ramifications for environ-
 mental concerns,
      Bianchi reported that the estimated cost of a sedimentation survey "of
 Lake Monroe is $24,000  for a  resurvey of the existing ranges, and 520,000
 to complete the  range installations.  The Corps said its preliminary study
 scheduled for July  should  give a reasonable indication of the sedinent in the
 project now.  In light  of  Barbara Restle's  opinion that it is more important to
 know where the sediment is coming from, such a preliminary study would pro-     <
 bably not help much,  added Bianchi,   She pointed out that Sen, Bayh sits on
 tli c anBremriations.Coiainitteo  and coyld be contacted for help in this matter.

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The initial response from the Mayor's office, she reported, was a willingness
to pursue the request in Washington, asking that the appropriations be made now,
'rather than in 1977.

September 12 — Ted Najam discussed the letter, sent to Birch Bayh, concerning
a sedimentation study of Lake Monroe.  He explained that an earlier letter
had been sent to the Louisville District Army Corp of Engineers in reference
to the study.  Their reply was that they could give only a quick visual esti-
mate at this time, but that funds for an in-depth study would not be available
until 1977.  Sen. Bayh explained that the 197^ appropriations 'bill for the Corps
has already been passed by Congress and therefore it is impossible to amend
it for such a large amount.  He expressed his desire to work with the City in
getting appropriations for this study during the next funding session.  This
would make the study possible 2 to 3 years earlier than predicted and in
this sense he was encouraging.
     In reference to the Department of Utilities' proposal to close Lake Lenon
as a water supply, Marcia Gelpe replied that the Water Quality Committee ha?
begun to look into the proposal and tactics that could be used to clean up
Lake Lemon.  They expressed their feeling to the City's Utilities Board.  The
reasons for closing have to do with estimates of renovating the facility
compared to the cost of Lake Monroe, volume of water and the plant.  Patton
commented that several investigations are taking place, ine of which is a
sedimentation report and he assumed the decision won't be made until the
information is in.

 October  1O — The Water Quality Comnittee has been studying the problem of
 spills of raw sewage into Salt Creek from tho Nashville Sewage Plant and sent
 a letter to the County Commissioners of Brown County asking that a joint
 meeting be set up to discuss the source of the problem as well as possible
 solutions.  The Commission agreed to send a letter to the Brown County Com-
missioners endorsing the idea of a  joint meeting and asking to be kept informed
 on the progress on  solving the problem.

November 14 -- Dennis King presented a report concerning the meeting of the
 Lake Monroe Regional-Waste District Board and City Utilities Service Board
 and a request of the Water Quality  Committee submitted for an additional
hearing on an environmental assessment hearing to determine the environmental
 effects of the regional sewer  treatment plant that is going to be constructed
 by the City Utilities Service Board and of the diversion system that will be
 put in by the LMRVDS.  The Water Quality Committee said that the LMRWDB had
 not filed any information prior to  the meeting in conjucction with regulations
 that the EPA has stated and therefore did not give the public a 30-day notice
 to study the information.  The outcome of a request that they hold another
 meeting was a letter which indicated that another meeting would not be held,
 but they would put  some information on file and answer questions, if there
 are any.  A motion  was made by the  Environmental Commission and approved  that
 a hearing be held at the regular December Environmental Commission meeting with
 the Utilities Service Board and their engineers answering questions from the
 Commission and the  public.  In addition, the LMRWBD and the Monroe County Plan
 Commission were requested to attend.  Barbara Restl* stressed the interrela-
 tedness of these two projects in the Water Quality Committee report.

 December 12 -- see  attached minutes.
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      HISTORY OF ENVIRONMENTAL COMMISSION«S INVOLVEMENT WITH LAKE MONROE
                              Based on 1974 minutes

February 13 — Barbara Restle read  the minutes of tht last Water Quality
monthly meeting.  In short, it said there was concern on the part of many members
that an environmental impact statement should be requested by the committee
that would deal with the effects of the new sewage plant in greater detail.  A
working subcommittee was formed to study the assessment hearings held by the
USB.  It was hoped that this subcommittee would reach a conclusion on the course
of action the Water Quality Committee should pursue.  No questions or comments
were added.
Restle presented to the Commission a summary of the considerations from the sub-
committee.  She said the summary was by no means complete.  The two considera-
tions presented were in the areas of population data projections for Monroe
County and problems with the treatment plant site'and outfall sewer,  Patton
recommended that these comments, if approved by the Commission, should become
part of the December 12^ meeting,  Restle agreed but added that more considera-
tions than these two are being questioned,  Restle stated that, although
the population data appears complete in the assessment it is rot.  Dennis King
explained that one of the first considerations to be included in an assessment
is a description of the effect of population distribution concentration on any
growth that might occur if the project is undertaken.  He said that, with that
in mind, the subcommittee went through the Infiltration and Inflow Study and
the hearing record for the October 25^ environmental assessment hearing and
the December 12^ information meeting to determine what RSH Associates had done
in regard to population projections.  King said his impression was that the
statistics used in the assessment had projections to 1980-199O based on the
census of 195O-1960.  If it is based on these years there would be no influence
from the lake on the extraurban area because the lake was not constructed
until 1963;  King said that the alternatives to the temporary plant site were
not mentioned with regards to growth in different volumes and directions.  He
said the Water Quality Committee is recommending further study.  Heise asked
if the Water Quality Committee was asking for an environmental impact statement.
King replied that at this time they are not asking fdr an environmental impact
statement but only trying to point out subjects that are not adequately investi-
gated.  Patton summed up King's comments by saying that the population projection
studies are not adequate and the effect of the waste water disposal plant on
changes in population have not been assessed at all.  King's final comment pointed
out that if the population projections have not been adequately looked into
one can not design capacity of a plant properly.  A copy of these questions will
be sent to the USB and EPA administrators.  The Commission voted unanimously to
forward them.
Jim Ferro reported that at the last monthly meeting of the Water Quality commit-
tee another working group was formed composed of Jim Pres, David Docauer, and
himself.  This working group will investigate the effects of construction
activities around Lake Monroe with regards to water run-off.  The second major
project the working group is considering is one concerning Lake Lemon,  This
would involve sampling the shoreling during a rainy period to measure runoff,

April 10 -- Jim Ferro said the water sampling project which is being planned to
test the quality of the run-off in the Lake Monroe watershed is being orgaaized
and should be underway soon,

September 11 -- An ad hoc committee consisting of Rick Peoples, Dave Parkhurst,
Rick Darby, and Barbara Heise agreed to study the USB report on the Long Range
Plan Water Supply and Distribution Facilities for Bloomington, IN,
Rick Darby gave his report on Lake Monroe,  This report concerned the legal
standing; how can a reservoir outside of the city boundaries be controlled and
what is the relationship of the Commission to that lake, and whether there is


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anything the Commission can look into other than water quality itself.

September 25 -- Barbara nestle said that  interests in the Water Quality Committee
are too broad.  There are legal problems,  bacteriological problems,  limnological
problems, sedimentary problems, and more.   The committee  needs to  form  subcommit-
tees and she asked for suggestions  on restructuring,

November 13 — Rick Darby gave a report on Lake Monroe.   He  said that Lake
Monroe is a large interest requiring tremendous work.   There is no way  one
person can provide the Commission with enough  information for the  Commission
to feel it is in control with the situation.   He has  therefore arranged with
Professor White in the Law School for students to receive credit for participa-
ting in a project designed to prepare a paper  or pamphlet which would ade-
quately describe the jurisdiction of various governmental bodies* over Lake
Monroe, interaction and jurisdiction between this commission and the City,
of "Bloomington in those various bodies and the rights
                             , generally given  to individuals in Indiana in the
Environmental field.  Rick feels with this help,  by the first of the year, a
comprehensive and fairly clear statement of exactly where the Commission stands
can be provided.  He then went on to state the legal proceedure the  Commission
would have to go through if it was  to take action and  suggestions  the Commission
should consider.  Walter Bron asked if Rick had a specific group in  mind other
than Water Quality.  Rick said no.   Rick Peoples gave  a report on  the status
of the Water Quality Committee.   The first meeting was held.   Only four people
showed up but only one was interested in participation.
                                      6-92

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 LEAGUE OF WOMEN  VOTERS
                                                      BLOOMINGTON. INDIANA

                                                              1975
To:   City of Bloomington Utilities Service
      Indiana Stream Pollution Control Board
      Region V Environmental Protection Agency
      Lake Monroe Regional Sewage Board

From: League of Women Voters of Bloomington-Monroe County

Subject:  Addition to our statement of May 29, 1975 for the
          record of the assessment hearing for the proposed
          sewage treatment facility at the confluence of
          Salt and Clear Creeks in southern Monroe County

     Our initial statement consisted of an outline of the
positions of the League on the issues of water resources and
land use, followed by questions regarding the six major issues
of EPA concern as stated in the announcement of requirement
for an environmental impact statement.

     The purpose of this addition to the first statement is
twofold.  We would like to express our disappointment in the
reception given our questions.  For most of them there seemed
to be little serious attempt to answer tnem at the assessment
hearing.  Second, we would like to outline, this time in
statement form, our reservations and doubts about the
Facilities Plan and First Amendment prepared by Black and Veatch:

I. Regionalization

     The concept of regionalization, as it has been used in
this long conflict over expansion of treatment facilities
for Bloomington's south service area, is fuzzy.  The most
widely understood meaning of a regional facility is that of
a facility planned by two or more local governmental bodies
with existing needs which can be more efficiently and
economically met by a common facility.  That Blocmington's
situation fits tnis description is extremely doubtful.

     An additional complication is a semantic problem which
has arisen with the use of the words "region" and "regional".
These words have been used to describe both the domain of the
Lake Monroe Waste District and the larger service area including
the Bloomington South Area.  The confusion is most obvious when
someone uses the phrase "regional plant" which might be for the
lake only (3 mgd) or for the larger proposed region (15 or 20 mgd).
            AFFILIATED WITH TH« 1.IAOUI OF WOMCN VOTIKI OF THI UNITID «TAT» AND OF INDIANA


                                6-93

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Page 2   Addition to LWV statement of May 29, 1975
     The needs of the Lake Monroe area are quite small at the
present time and are projected to reach 3 million gallons per
day only in 199&.  The Lake Monroe area has individual treat-
ment facilities for each of its few developments, since no
construction is permitted without approval of treatment
facilities.  Those which discnarge an effluent must have
NPDES permits and meet schedules for upgrading their treatment
as required by Public Law ^2-500.

     The replacement of these small treatment facilities with a
collector sewer almost completely circling the lake basin
west of the causeway and a single treatment plant is a plan
which may not, by itself, be economically feasible.  There
may never be enough users to pay for it.  The facilities
plan for the Lake Monroe Regional /n'aste District lists costs
of more than $8 million for the collector and interceptor
sewers.  Presumably these costs are at prices as of October 23,
197^, the date of publication of the report.  The construetiion
cost listed for a 3 mgd plant is approximately 83.& million.
These costs are to be borne by a present user population of
about 1900 home equivalents (370 gpd per home).  To finance
the total of $11.8 million in construction costs amounts to
about $6000 per home equivalent.  It seems clear and has been
so stated publicly that large developers will be needed to bring
the costs per dwelling within reasonable limits.

     At the 1998 projected population of about bOOO home
equivalents (3 million gpd, 100 gpd per person, 3.7 persons
per home equivalent), the cost still amounts to about $1500
per home equivalent for construction alone; and this does not
include lateral sewers from collector to dwelling.

     In addition single family dwellings not able to be served
by planned collector sewers nave been included in present and
projected user populations for the Lake Monroe Regional Waste
District.  They will have tne additional cost of building a
sewer from their lot line to the region interceptor sewer.,
The cost to serve scattered single family dwellings v/culd be
extremely high.

     There is no existing legal mechanism for forcing homes
now using eeptic tanks to hook onto the planned sewers.
There is a state law requiring homes within 300 feet of a
sewer to hook on; but this nas not been uniformly enforced
even within the Blooraington city limits.  Moreover there does
not seem to be a mechanism for taking existing small treatment
plants out of service and forcing tneir users to hook onto the
region's interceptor.  It seems probable that many users
would reject this expensive alternative unless there are
legal means to compel them to accept it.
                                   6-94

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Page 3   Addition to LWV statement of May 29, 1975
     If the concept of providing sewer service for these areaa
of low population density proves unworkable, we are ]eft with
a rather small probable service area for a Lakt Monroe regional
plant at the site proposed.  This area might reasonably include
The Pointe, the Fairfax area, Seven Flags Corporation, possibly
Harrodsburg.  The total projected flow from tnese communities
by 1998 is 843,663 gpd compared to 3,000,000 gpd for tne whole
lake area, (page 15, Lake Monroe region facilities plan)

     There is already in existence a treatment plant built for
The Pointe with a capacity of 116,000 gpd.  The effluent of
this plant discharges into Little Clear Creek, out of the
Lake Monroe watershed.  This "interim plant" represents a
large investment and might not be willingly abandoned even
if Bloomington chooses the proposed Salt Creek site for its
South Area plant.

      In summary of  our thinking on the regional concept, we
would like to see more cost  factors discussed.  At what
population density  does  it become cost effective to go  to  one
big regional plant?  Do  any  cost projections consider a
planning  span long  enough  to include replacement of sewers?
What  is the state of the art for small  (less than 1 mgd) treat-
ment plants?  For individual hone treatment?   Is there  an
increased cost for  "old" users when their sewer service area
is broadened?  Should a  densely populated,  efficient service area
share treatment plant construction costs with  a sparsely
populated, inefficient service area?  Do the growth projections
accurately predict  wnat  will  happen when a  service area is
greatly expanded?   Might not  a slowly growing  Bloomington Soutn
area find itself paying  the  costs for a rapidly growing area
southwest of LaKe Monroe?

II. The Capacity (ies) and  Location(s) of a_ Kegional STP or
    Separate STPs

    A. Capacity

     There are a number  of important unanswered questions
relating  to the amount of  new plant capacity which is needed.
In the original facilities plan (December 4, 1974) a figure of
14.9 mgd  was given  for the Bloomington South area for 1^96.
In the First Amendment to  tnt facilities plan  (March HO, 1975),
after a recalibration of flowmeters at tne Winston Thomas plant,
this figure was cnanged  to 17.6 cigd.  (In both cases the flow
contribution estimated for tne Lake Monroe area is 3 mgd.)

     Included in these figures is 1.9 mgd now  treated at
Bloomington*s north treatment plant, tne Blucher Poole  plant.
This compares to a  total of  2.7 mgd treated at tnat plant.
                                 6-95

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Page k   Addition to LrtV statement of May ^9, 197b


tVnen this 1.9 mgd is taken away from the flow at  tne ncrtn  plant,
only O.b mgd remains,, a figure well below tne design capacity
of the plant (6 mgd).,  Are we justified in building new  plant
capacity for this 1.9 mgd?  Witnout it the South  area  flow
would be 15.7 mgd for 1996.

     Another uncertain factor is the final outcome of
infiltration/inflow studies now underway.  The Facilities Flan
lists figures cf 1.6 mgd for present dry weather  infiltration
and 0.5 mgd additional wet weatner infiltration.  Another 0.9
mgd from infiltration/inflow is projected for 1998.  This
amounts to 3 mgd out of a total of 1?,6 mgd for 1996.  (Tnese
infiltration/inflow figures were not repeated in  the First  Amendment,  so  the
figures given are from tne original Facilities Plan.)
                                   ~  ."     .,   The Facilities
Plan analysis of t..is situation is: "inflow and infiltration into
the existing sewers will tend tc increase with age of  the system.
Maintenance of the system will be continued but the recent
inflow/infiltration studies nave indicated that extensive repairs
will not be cost-effective."  Tne studies are stilJ in progress,
however, and the final conclusions may be different.   Neitner of
the firms involved ir. the first phase of tne study will be  involved
in the second pnase.  Tne Utilities Board nas recently accepted
the bid of American Consulting Services, Inc.  of Minneapolis, Minn.
for tne second phase.  It is to be hoped tnat  tneir calculations
of the cost-effectiveness of renovation  will  include the costs
of new plant treatment capacity construction.

     The two factors discussed above are applicable to eitner
the Bloomington Soutn area alone or combined  with the Lake
Monroe area.  A third factor applies only to  tne larger service
area.  This lactor,  discucsed above under regionalization,  is
that cf the probability of success for  completion of trie
collector and interceptor se'.vers around  Lake  Monroe.   Tne 1996
flow figure for the lake area (3 ragcU  is based on the  complete
network as shewn in the Beam, Longest  and Neff Facilities Plan.
If the complete network cannot be financed,  then a plant at
tne Salt Creek site mignt serve only tnose developments within
two or three miles of tne plant.  The  flow from tnis restricted
area might not exceed 1 rr.gd and could  be amen  less if  the
new "interim plant" is not abandoned.

     A final factor not even mentioned  in tne  Facilities Plan
is the conservation of water use which  mignt  be acnieved within
the plan period.   This mignt be brougnt  about  by consumer
education,  a reform in the rate structure to  reward conservation
rather tnan high volume use, tr.e depressed economy,  or the higher
rates resulting from tne planned construction.  The Facilities
Plan projects an increasing per capita  consumption in a tine
when there  is rapid development of the  technology for water reuse
                                   6-96

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Page 5  Addition to LWV statement of May 29, 1975
and even individual home treatment.  These trends in the technology
have obvious cost benefits to the buyer of water and sewer services.

     To summarize our thoughts on plant capacity, there would
appear to be a number of reasons to question an initial design
capacity of ^0 mgd (as recommended in the First Amendment).
For the Bloomington South area 15 mgd is a preferable design
capacity, with provision for staged enlargement of capacity.
If the decision is made to serve tne Soutn area and tne Lake
Monroe area with a single plant, the 15 mgd would still be adequate
with staged enlargement depending on the speed of development in
the area.

    B. Location

     Obviously the location problem is tied up with the choice
between one large and two or more smaller plants to serve the
region.  If the choice is one large plant and it is expected
that the entire Lake Monroe interceptor sewer system can be
built, the Salt Creek site might be the best location (only location
is considered here), but it would certainly seem foolish to build
a gravity outfall sewer all the way down Clear Creek and a
parallel interceptor sewer down Little Clear Creek valley when
the two might be combined in Little Clear Creek valley.  If,
however, it is decided that tne southwest corner of the lake
might be served by its own plant (the "interim plant",  already
constructed/ Siscnarges out of the lake watershed), then tne
remainder of the lake service area mignt be just as well served
by a plant at Dillman Read or Ketcham Road.  This would remove tne
necessity for the interceptor sewer from Smithville down  the
Little Clear Creek valley to Salt Creek and the necessity for
11 miles of outfall sewer down Clear Creek.

     No cost comparisons nave been made for the alternative
just described, with a small plant serving the south part of
the lake and a Bloomington plant at Dillman Road or Ketcnam Road
serving the north part of the lake area.  (The Facilities Plans
calculated costs for a separate lake plant serving the  entire
lake area.)  It might turn out to be/cost-effective  solution
for the planning region.  It would eliminate most of the Clear
Creek gravity outfall sewer wnich has caused so much environmental
concern.

Ill.  The Treatment Process Best Suited tj> Specific Sites

     We wilJ not attempt to evaluate the relative merits of
available sewage treatment processes.  Tnis does, however,
seem to be an engineering specialty in whicn tnert. is much
current research and a great many developing new methods.
In addition, the requirements of Public Law 9^-500 are  for
increasingly high effluent quality to tne point where tne
eize of the receiving body of water wiJl not be considered
as important as it is at present.

     The implication of the above situation for Bloomington's
choice are as follows:

                                 6-97

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Page 6  Addition to LWV statement of May 29, 1975
     a) The treatment chosen should be capable of being changed
        or treatment steps adaed, to the extent possible with
        present knowledge.
     b) It seems likely that treatment level required in the
        future will be higher than that required at present.
     c) The level of treatment required for the Clear Creek sites
        probably is closer to future requirements tnan that
        required for tne Salt Creek site.
     d) The larger acreage at tne Salt Creek site probably gives
        more improvement flexibility, depending on the space
        requirements for improvements.
     e) The cost balance between Salt Creek and Clear Creek sites
        might well change before tne end of the planning period
        if a higher level of treatment becomes mandatory at tne
        Salt Creek site, since the cost effectiveness of the
        latter depends on its lower level of treatment.
     f) Alternatives involving small treatment pla.nts depend
        on the ability of sucn plants to produce effluent of
        high quality.

IV. The Environmental Impacts of Construction and Cperation
    of ST^s, Interceptors and Outfall Sewers
     The most important environmental impact of the construction
and operation cf the STPs would seem to be tne quality of the
effluent produced, and possibly tne odor in the immediate
vicinity of the plant.  Anotner impact, of course, would be
the amount of site preparation necessary.  The Audubon Society
has questioned tne stream recnannelizat ion whicn is proposed
in the Facilities Plan.  We leave this point to them and the
engineers .

     With regard to tne quality of the effluent produced, any
of the Clear Creek sites is superior to the Salt Cretk site
in this respect.

     As far as secondary A/ater quality impacts are concerned,
we feel unable to predict tnese.  The number of septic tanks
abandoned, small treatment plants snut down, facilitation of
development in the Lake Monroe area, water quality impact of
that development, are all unknown quantities.  There are water
quality arguments on botn sides of the controversy.  Statements
have been made that, a large regional plant is essential to
Lake Monroe water quality, *nd that a large regional plant is
fatal to Lake Monroe water quality.  he are unable to reach
either of these conclusions.  Botn sides of the argument seem
to nave been overstated.  A small Lake Monroe region treatment
plant can easily be built and would seem to have the same
advantages and disadvantages for Lake Monroe water quality as a
larger plant bui^t by Bloomin^ton.  We would like to see tne
primary emphasis placed upon other factors.
                                  6-98

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Page 7  Addition to LWV statement of May 29,


     The direct environmental impact of the interceptor and outfall
sewers construction and operation is considerable.  Discussion of
this issue is omitted here because others have addressed this
problem.  Alternatives should be evaluated with a goal of minimizing
sewage construction impact.  It is not clear that the present plan
does this.

     The secondary effects of sewer construction are another
matter entirely.  In the absence of otner more powerful forms of
planning for development, the construction of sewers is equivalent
to planning for development.  One may therefore expect that a loose,
sprawled network of sewers will lead to tne same sort of development.
These in turn require loose, sprawled networks of roads, schools,
school buses, refuse collection.  All of tnese services cost more
than their clustered counterparts, and this probably means that
they have more environmental impact as well.

     Considering the effects of sewer placement, a plant for
Bloomington should be placed close to the planned development
area for Bloomington, and a plant for Lake Monroe should be placed
close to the area of planned or expected development for Lake
Monroe.  If long connecting sewers passing tnrough undeveloped
areas are planned, then some means of controlling development
along them should be found in advance of construction.

     It is not clear how development along the interceptor sewer
ringing Lake Monroe could be controlled, except in the inaccessible
force-main portions.  In tnis respect, several carefully planned
and well regulated small treatment plants might be preferable, if
they are capable of achieving effluent of the required quality.

V, Tne Induced Growth Implications for tne Lake Monroe Area
   of Building a_ Regional Sewage Treatment Plant

     On this issue like the Lake Monroe water quality issue,
extreme statements have been made.  On one side it nas been
said that construction of a regional plant at the Salt Creek
site will result in rapid, unplanned development of tne lake
area.  On the other side it has been f=aid that development
will take place even witnout a regional plant.  Both sides
cite lake water quality as an important concern.  Both sides
(despite the threat of development without a plant) seem to
feel that development of tne Lake Monroe area is closely
linked to obtaining a regional treatment plant at the Salt
Creek site.  It is this link wnicn is holding up a long
overdue expansion of treatment facilities for Blooming-ton's
south area.

     A great improvement in everyone's logical though
processes mignt be achieved at this point if Bloomington's
future and Lake Monroe's future were considered separately,
as regards sewage treatment needs.  Tnis probably means
separate sewage treatment plants.  It is riot necessarily
                                  6-99

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Page fe  Addition to LWV statement of May 29, 1975
true that Lake Monroe development would ride along on the
coattails of Bloomington's treatment plant expansion.  But the
best way to be sure of fair consideration of both interests is
to find a cost equivalent plan for two or more plants to serve
separate density areas.

VI.  The Best Method of_ Sludge Treatment and Disposal

     This issue, like the one involving treatment processes, is
for experts in the technology.  The situation does seem to be
under intensive study as indicated by published articles.
Changes are likely in recommended methods.  It would therefore
not seem wise to base arguments for choice of plant site on a
disposal method which might change even before the plant :.s
built.  From the same line of tninking, several disposal
alternatives should be possible for each site.

VII. Conclusions

     There is an alternative to a large regional plant which
should be considered.  This alternative would involve first
selecting a plant site which would best serve tne Bloomington
South area present and future needs.  After site selection
it would then be determined whicn portions of tne Lake Monroe
area could be served at the chosen site.  Other treatment
facilities for the lake area might then be planned at one or
two sites near expected dense development.

     The Land Suitability Study prepared by the Indiana
University School of Public and Environmental Affairs has
indicated the southwest corner of the lake as the area most
suitable for development.  Planning for sewage treatment
for the lake area might focus on this corner until the
economics of the lake interceptor sewer plans are worked out.

     Either the Dillmaii or Ketcham Road site could serve the
north lake area,- while a small plant near the dam cculd
serve the south lake area.

     This alternative would avoid the considerable difficulty
of planning a sewer network to connect two planning areas which
are separated by a large stretch of undeveloped land.  It would
avoid both the environmental and unplanned development impacts
of building long sewers through open countryside.

     The Salt Creek site has tne advantage of larger size
and smoother terrain.  The use of Salt Creek for dilution and
of site acreage for sludge injection may be undesirable in the
near future and should not count as reasons in favor of the
site.  Use of the site involves the problem of vtry long
                                  6-100

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Page 9  Addition to LWV statement of May 29,
sewer to connect it to the present plant.  The long controversy
which has been centered on this site is a reason in itself for
not choosing it if acceptable alternatives are available.

     The question of initial capacity contains several issues
which should be examined further; the infiltration/inflow
problem, the future use of the north treatment plant,  conservation
by users, and the portion of tne lake area to be served.  An
adequate solution would seem to be a 15 mgd plant to which
5 mgd capacity could be added when needed, depending on the
issues listed above.

                               Sincerely,
                               Shirley Cordes, Chairman
                               Environmental Duality Committee
                               League of Women Voters of
                               Bloomington-Monroe County
                               (2728 Pine Lane, R.R. 3)
                               339-9364
                                  6-101

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Hay 29, 1975

US Environmental P
Region V
230 South Dearborn Street
Chicago, Illinois 60604                       „«____»   .....
                                                           SASSAFRAS

             of IAWRENCE • qREENE • MONKOE     *W ]/ \ AtdUDON
        BROWN • MORqAN ANd OWEN COUNIJES       y      , SOCIETY

Dear I.ir. Hirt:

In regard to your letter of l.Iay 14,  1975,  the  Sassafras  Audubon Society
is interested in contributing to the preparation of the  Draft Environmental
Impact Statement on the location of the new wastewater treatment system  in
the South drainage basin of Bloomington, Monroe  County,  Indiana.   The
principal question, as stated in your letter,  is whether to build one
sewage treatment plant (STP)  for south Bloomington and the Lake Monroe
area or separate STPs.

Y/e believe that a site near Bloomington would  be advantageous in terms of
curbing urban sprawl and strip development, in minimising environmental
disruption, and in overall economy of operation  and maintenance.   We rec-
ommend serious  consideration of the Dillman Road Site without rerouting
of Clear Creek.

We further recommend that sewage treatment facility expansion at Lake
Monroe be curbed until comprehensive land-use  planning  is in effect  for
at least the area encompassed in the Lake  Monroe Land Suitability Study.
We see serious  consequences if a Regional  Sewerage System is instituted
at Lake Monroe  prior to land-use planning for  the Lake Monroe ₯atershedo

The Sassafras Audubon Society in March, 1974,  sent Region V, EPA (under
cover  letter to Francis Mayo), a file of bibliographical material, corres-
pondence, news  articles, etc on issues and problems surrounding Lake Monroe.
Region T also has a copy of the lengthy statement we presented  at the
Hearing on the  Black & Yeatch Facilities Plan  held in March of  this  year,.

We enclose with this letter the brief statement  we prepared for the  May
29, 1975 Environmental Assessment Hearing on the siting of the  STP,  as
well as a statement sent to the Monroe County  Plan (3ommission  (MCPC) by
a number of organizations seeking implementation of the  Lake Monroe  Land
Suitability Study.

As you know, the MCPC has jurisdiction for land-use planning of a large
and vital area  of the Lake Monroe Watershed.  The MCPC made no  comments  on
the Draft Eake  Monroe Land Suitability Study though asked to do so by the
Director of the study (the MCPC received one of  the four draft  copies).
They have said  that when the study is in final form, they will  read  it
and discuss it.

Please let us know how we can contribute to preparation of the  Draft En-
vironmental Impact Statement.

                             Yours sincerely,
                  6-102       Lake Monroe Committee ior the
                             Board of Directors, Sassafras Audubon Society

-------
               Of UWRENCE .  qREENE •  MONKOE
         BROWN • MORqAN Ar^H OWEN couNiits       Y       SOClETy

                                                      May 1975

Statement presented at Environmental Aseeement Hearing on Facilities Flan
for Wastewater Treatment System, South Drainage Basin, Bloomington,
Th« Sassafras Audubon Society baa studied the various sites Black & Teateh
nave considered for placement of the south basin wastewater treatment
system, and recommend* the Dillman Boad Site.  This site, while rural,  is
oloee to the Bloomington Metropolitan Area and a gravity feed system is
possible without serious environmental disruption.

We would ask, however, that Black & Teatoh prepare an alternative plan for
the Dillman Site without rerouting Clear Creek.  The proposed plan (Figure
7III-5) would sacrifice a substantial pert of the longest continuous pieee
of the site for a new creek channel.  Examination of the site suggests that
the present major piece of land between the railroad and the creek channel
would be adequate for most of the design capacity.  Adjacent acreage could
be utilized if necessary and still maintain a compact unit for operation
and maintenance, even though line(s) across Clear Creek might be involved.
Besides, channelisation has proven repeatedly to be a destructive manage-
ment practice entailing considerable costs in construction and maintenance,
             downstream damages to stream ecology.
Two statements which Black & Teatoh make with regard to the Dillman Site
have little merit*  1) "By tt?8 it is not unlikely that the plant site would
become surrounded by development comparable to that which presently rings
the Winston Thomas Site." (7III-4), and "Acceptance of the Dillman Road
Site is questionable due to the close proximity of State Route 37 Bypass."
(EX-1) .   The Dillman Site, if accepted, could be effectively zoned to pre-
vent build-up in the plant area.  The greater part of the site is adequately
buffered in terms of SR 37 1 and more could be done, if necessary, to lessen
the affront to sensitive motorists I

Mention is also made with regard to the Dillman Site that "There would be
no surplus area available for construction of additional facilities if fur-
thereftdvanoed treatment processes, such as denitrification, were mandated
in the future. " (VIII-4).  This needs clarification, since the possibility
exists that denitrification may be required by the Federal Government within
a few years.  Couldn't the space used for nitrification facilities be con-
verted to denitrifioation?  When denitrification is required, wouldn't this
nullify the advantage of the Salt Creek Site over the Clear Creek Sites,
as emphasized by Black & Voatoh on pages IIZ-1 and 111-27
                               6-103

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The Black & Teatch Reports continue to seem slanted toward maximizing
the advantages of the Salt Creek Site while minimising the advantages of
the aitoe significantly closer to the Bloomineton riotropolitan Area.   Ho
assessment of the environmental damages which could result from  construc-
tion of the lengthy transport system to the Soli Creek Site have been
made by Black & Yeatch.  Environmental damages should be considered a cost
of the project and not disnissed under the euphenisn of "temporary  dis-
ruption." (DC-9).

The fact that there is sufficient acreage at the Salt Creek Site for  use
of the sludge injection process is stressed as an advantage of the  site,
yet no evaluation As given of the soils of the area in tenas of  the
process, nor of difficulties which might be encountered*  Composting  of
sludge should be considered for all sites* (See Sassafras Audubon Society
Statement to Utility Service Board, February 1973* pages 2*3.).

Black & Veatch assort (IX-10) that "Sewerage service for the Lake Monroe
region is necessary to preserve the ecologic value of the area." While
there is grave need for a new wastewater treatment eystea in the south
drainage basin of Uonroe County, ve continue to asocrt that sewerage
is but one of the facto IB that oust be considered in the protection of
Lake Monroe.  LAUD-IKS PLAHNINC PQH TUB LAKT. 1IUKIOE WATERSHED SHOULD  HATE
AS HIGK t'HIORIOT AS Tllil DLTELOPLI3IIT OP A RaC-IOHAL .'Ja/ERAGB SYSTSI.  In-
pleaentation of the Lako Honroe Suitability Study by the Monroe  County
Plan Commission should be of prime importance to the ttloomin^ton-Uonroe
County Poraminity.


                              The Board of Directors
                              Sassafras Audubon Society
                             6-104

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Harlas D. Hirt, Chief
Region T Planning Branch^EPA
2JO South Dearborn Street^AKVl/Vc UM,A
Chicago, Illinois 60604 ****&__  «Afl         	
                                            	THE   f
                                                           SASSAFRAS

             of IAWRENCE • qREENE   MONUOE     ^^ V\ AIJC«!JbON
       BROWN • MORQAN ANd OU/EN couNiits       T     ' SOCIETY

                                                June 16, 1975

Dear Mr. Hirt:

We would like to call the attention of the Planning Branch of Region 7,
EPA, to the Strain Ridge School controversy in Monroe County, as it has
implications with regard to the siting of the new treatment plant.

There was organized opposition to the placement of a school at Strain
Ridge when it was first proposed,  because Smithville citizens wanted
to retain their community school,  and the citizens of Harrodsburg and
Kirksville sought a community school near the center of their popula-
tions (combined)  which would require significantly less bussing than
to Strain Ridge.

We are enclosing several recent news items from the Bloomington Daily
Heraid-Telephone which will give you some idea of the interest and argu-
ments this issue has engendered.  The issue is more complicated than can
be presented here, but we do not feel the issue is whether the children
in these particular areas will be deprived of proper educational facili-
ties, but where those facilities should be placed.   It jshould be noted
that if a Sewage Treatment Plant (STP) were placed at the Dillnan Road
Site, it could service a community school at Siaithville.

          THE SASSAPltAS AUDDBOH SOCIETY WOULD LIKE TO REITERATE ITS
          SUPPORT FOR A STP IFEAR THE BLOOIIHIGT01T METROPOLITAN AREA.
          ?/E BELIEVE THAT A PLANT AT THE DILLIIAH SITS GOULD 3E A
          REGIOUAL STP IN TIE BEST SENSE OF THE WORD, SERVING THE
          1IEEDS OP All EXPANDING, SEWERED, METROPOLITAN POPULATION,
          BUT ALSO STIMULATING THE DEVELOPMENT OF A SEiffiRAGE SYSTELI
          FOR THOSE BUILT-UP AREAS IN THE SOUTH BASIH SERVICED BY
          RURAL Y/ATER SUPPLY SYSTEMS BUT STILL DEPENDENT OH SEPTIC
          TAIUCS.   CCMC.11VAr5LY, ALSQ PARTS OF THE ITORTII \7ATERS1I3D O-1
          LAKE HOimC,^ VnilCII 'JOULD T.!ICLUDE THE PAYIIETOWH RECRfiATIOU
          i\REA, etc WOULD BE \7IT11IN A HI3ASONABLE RAHGE.

V/e v^ere disturbed at the Final Assessment Hearing in Hay to hear the
stress placed on the advantage which the Salt Creek Site had over Clear
Creek Sites in terms of dilution water, (by Black & Veatch and a pepre-
sentative of the 17ater Pollution Control Division of the Indiana State
Board of Health.)  We must deal with realities in terns of lack of imple-
mentation of provisions for the high degree of treatment (or zero dis-
charge) sought by the recent Federal \7ater Pollution Control Act Amdnd-
ments, and insufficient appropriations for constructing STP's capable
of such treatment.  Nevertheless,  we do have goals, we are working on
                             6-105

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the technology arid planning for achieving those  goals.   It  is  not good
policy to use a lesser standard as a selling point 102? a site  on  the
grounds that it is cheaper.

I'urt'icm ;re, it is possible that in the future Lake I-Ionroo's function
as the principal water supply resource of the entire Region will  assume
top priority in the management of the lake.  The Sassafras  Sudubon Society
is working for that top priority recognition.  It is conceivable  then
that low-flow downstream would become a lesser /unction  of  the lake during
periods of prolonged drought.  If so, the site advantage could become a
disadvantage«,

We advocate sludge recycling but object to the approach  of  recommending
a process of sludge disposal (soil injection) as an advantage  of  the
Salt Creek Site prior to an evaluation of the soils and  the process
through on-site research.  Me quote front the Abstract of the paper
of Paul Blalceslee "Monitoring Considerations for Ilunicipal  \7astewater
Effluent and Sludge Application to the Land" presented at the  Joint
Conference on Recycling Ilunicipal Sludges and Effluents  on  Land in 1973:

     "Monitoring the performance of the many interrelated systems which
      are involved in any  project employing wastewater or wastewater
      sludge application to the land can not be  looked upon as a  sub-
      stitute for a full understanding of system response prior to
      project coTrunittment."

We would appreciate having the Dilliaan Road Site re-evaluated  from the
standpoint of "environmental" engineering, to see if  the site  could be
utilized to better advantage thai projected in the First Amendment to
Facilities Plan of Black L Veatch.

Will there be an opportunity to meet with representatives of Region V
SPA on this matter when they are in the area?

                            Sincerely yours, ^   _.
                             y-n^s  &*S»-L^L &. *=*z:/*4-<*r^"
                            R3, Snith Road, Blooningftn, HI 47401
                            Tor the Board of Directors
                            Sassafras Audubon Society
                           6-106

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Dale Leucht
Planning Division
Region V EPA
230 South Dearborn Street
Chicago, Illinois 60604                            !!••••• mm,,*    • >.«-
                                                                SASSAFRAS
                Of UWRENCE • qREENE • MONKOE     ^W V \  AUQUDON
          DROWN • MORqAN ANfi OU/EN COUNllfeS       Y     ,  SOCIETy

                                                     July  2, 1975

Dear Mr. Leucht:

Enclosed are copies of three recent news items from the Bloomington Herald-
Telephone which relate to the siting of the south side  sewage treatment plant.

On June 17 the Utility Service Board heard a presentation from Scarab  Compost-
ing Company of Bloomington for accepting all  the city's sludge.  The proposal
is being considered by the Board.   The implications of  this proposal are  ob-
vious, if implemented, since a leading argument for the Salt Creek  Site is
the space available for the sludge injection process.   We have advocated  con-
sideration of composting as an alternative to the injection process, and  would
like to see serious consideration given to this proposal.

The Statement of the Monroe Engineering Society (signed by  Ray Graham, County
Surveyor and member of the Monroe County Plan Commission, and Ray Long, City
Engineer) backing the Salt Creek Site is essentially an endorsement of the
Black cc Veatch recommendations, using similar arguments for their decision.

Emphasis is placed both in the engineers statement arid  the  H-T editorial  on
the argument th&t the operation and maintenance expenses would be higher  at
the Clear Creek sites.  This is based on the higher degree  of treatment which
would be required at the Clear Creek sites and high costs of sludge disposal
at same sites.  We have discussed these matters previously  and can  only reit-
erate that they have not considered all the factors involved, e.g.  what the
situation might be if effluent standards are adopted and enforced,  implement-
ing recent amendments to the Federal Water Pollution Control Act, if denitri-
fication facilities are required at both sites, if water supply  is  recognized
as a top priority function of Lake Monroe (as we believe it should  be) etc.

The Engineering Society also fails to consider any alternative to landfill
for the Clear Creek sites and blindly accepts the sludge injection  process
for the Salt Creek Site as if it had neither problems nor expenses  associated
with it.   There are unknowns associated with the sludge injection  process
which can only be resolved by research and continuing studies in the field.
Particularly important is thorough analysis of the capabilities  of  the site
which in this instance is lacking although the survey of soil types of t!-e
area has been made.  Perhaps better drainage might be needed, and this would
be a cost of the proiect.  In addition, also, to the costs  of storage, trans-
poT't, and injection of sludge, wou!1 rt be the need for continuing  research  on
what happens to the sludge components in the soil and in the crons  etc.
                                6-107

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GUP- Society would like to see the sludge recycled whatever process is used.  We
realize that it could be expensive,  perhaps,  especially in initial stages when
an adenuate and acceptable Method is being developed.   However,  a community
should feel an obligation toward recycling such a resource.

The assertion by the engineers that  permanent damage in Clear Greek Valley can't
be substantiated reflectsvthe viewpoint that  9 **e en^ justifies the mean, arid
9) ignorance of the word "damage" from an ecological standpoint,   actually, one
type of damage which could result from interference with the stream channel,
and its watershed, has been widely demonstrated in our country in terms o'f changes
in natural systems,,  drainage patterns etc. It is difficult to see how long-lasting
damage could b<= avoided if there are numerous crossings of Clear Creek involved
in th<= lading of the iery large interceptor sewer.   Recent experiences with rock-
slides at road cuts on South 37 indicates the complexity of problems associated
with construction in this area.

Both at the last environmental assessment hearing and  in the engineers statement
it was noted that nature ranidly heals scars  of construction and the Korth Sewage
Plant outfall sewer was given as an  example of how soon a sewer construction pro-
ject can be hidden by nature.  What  is not recognized is that out of sight (dis-
guised by vegetation or hidden under the creek) is not necessarily out of mind
in terras of continuing effects if serious alteration of channel and watershed
has been effected.

We also take exception to the comparison of the North sewer line with the oro-
nosed line to Salt Creek because of  the greater length involved to Salt Creek
and the magnitude of the topographical problems.   The  North line had one short
passage through rugged terrain and then followed the f]ood p]ain to the Bottom
Road plant.  Even so, the laying of  the north line was a travesty of environ-
mental planning!  Enclosed is a copy of page  3 of The  Balancer [newspaper of
Soil Conservation District)  which depicts and describes the situation.  As we
understand it, the City had to absorb costly  changes in the laying of the line.

The news article on the Engineering  Society's statement ends on the note that
one plant is more economic than two, and that the Lake Monroe Regional Waste
District will probably construct a plant somewhere south of Har^odsburg if the
Clear Creek site is selected.  While we would agree that one regional plant
would be more economic than two, there are alternatives which haven't been fully
considered for dealing with effluent now entering the  lake and questions of
policy concerning the management of  Lake Monroe are still  to be answered which
could affect what is needed in the way of a plant at that site (or if there is
any need at all beyond the plant raw in process of construction at Little Clear
Creek).

We reiterate our concern for any action which would promote growth and develop-
ment around Lake Monroe	An AREA OF CRITICAL Ei^lOiriE.^ J/C .M3ERN BECAUSE
IT IS THE CHIPS' (AlID LAST) WATER SUPPLY RESOURCE OP TVE I3LOOHIKGTON ; IUHCHOLI L\i,N
AREA l-wmnnrjj-! the absence of any combined effort on the part of governmental
agencies concerned with its management to evaluate and determine what levels of
development and use can be absorbed  without seriously affecting water quality.

The issue is what is best for the public interest in this instance as the Lake
was created with public funds and the life of a community is involved.
                                  6-108

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A land-use policy for the perimeter and the entire watershed ofl Lake Monroe
needs to be adopted but has not *MK been considered as yet.  St&ndards must
necessarily be more stringent for protection of a communal water supply.

Our Society  would also like to go on record as favoring a 20 mgd plant in
order to provide for built-up areas in need of sewer service and for future
expansion around the metropolitan southern area.

In conclusion, we would like to stress a point already covered but which needs
to be emphasized since the argument used for the Salt Creek Site tends to
center around degree of dilution water:

     "The emphasis of national water pollution control policy is now on
      the amount of wastes that can be kept out of surface waters, rather
      than on the amount of wastes that can be assimilated by the waters.
      This emphasis will guide future acceptable water resource policies."
                (Prom Characteristics and comparative magnitude of non-
                 point sources by Raymond C. Loehr,  Journal of1 Water Pollii'f";'NTi
                 Control Federation, 1974, ^6-(S) :' 1?49-1872.  Mr. Loehr is
                 professor of civil and agricultural engineering,  Cornell
                 University, Ithaca, N.Y.

                                     Yours sincerely,
                                     for the Board of Directors,
                                     Sassafras Audubon Society
                                     R3.  Smith Road
                                     Bloomingtan,  Indiana 4*740-
                                   6-109

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D)  LETTERS FROM INDIVIDUALS
                 6-110

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                                            7i;l Eigenmann Center
                                            Indiana University
                                            Bloomington, IN
                                            June 3, 1975
Region V Office
Environmental Protection Agency
1 North Wacker Drive
Chicago, IL 60606

Gentlemen:

With regard to the environmental impact statement you have decided to
write concerning the siting of the proposed Bloomington sewage treatment
plant, I believe that the following points, in addition to those made
in the report of the Bloomington Environmental Quality and Conservation
Commission, should be considered:

(l)  The amount of rock to be removed by blasting during the construction
of the outfall sewer.  The assumption made by Black & Veatch in their
Facilities Plan that the soil depth along Clear Creek is equal to the
average Monroe County soil depth is tenuous.  More blasting would quite
probably result in higher economic and ecological costs.

(2) Identification of sludge injection sites in the Dillman Road site
vicinity.  If soil injection could be used as a sludge disposal method
at that site, it would substantially reduce the present worth of that
alternative from the Black & Veatch estimate.

(3) Identification of the soil types at the various sites and their impli-
cations for plant construction and ionic leacjning from sewage.

While I realize that resource constraints may prohibit a full investiga-
tion of these points, I think that, to the extent that they can be con-
sidered, the EIS will benefit from them.

                                            Sincerely,
                                    6-111

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                   Indiana University Alumni Association
                   AKEA CODE S12 / SS7-17I1

                   Office of the Executive Secretary
                                                                       1975
             June 17, 197;
o

w
S

fc
Mr. Dale Luecht
United States Environmental Protection
      Agency, Planning Branch
12th Floor
230 South Dearborn Street
Chicago, Illinois  6o6oU

Dear Mr. Luecht:

I would like to endorse the Salt  Creek site  as the best location
for the Waste Treatment Plant  to  serve Bloomington and that part
of Monroe County which is  in the  natural drainage area.

I believe the Salt Creek site  will  not only  serve a much larger
area for a collection system,  but it will also result in less
environmental damage than  any  other site to  which serious attention
has been given.

I am interested in environmental  considerations for our community
and believe that the Salt  Creek site will provide the greatest
protection.
                   B. Jone
             Alumni Secret

             FBJ:jh
   Winner of three national Alumni Administration awards for comprehensive excellence in alumni programming
                                          6-112

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               BUILDING AND CONSTRUCTION TRADKS COUNCIL
                             IN AFFILIATION WITH
          BUILDING AND CONSTRUCTION TRADES  DEPARTMENT
        AMERICAN FEDERATION OF LABOR	CONGRESS OF INDUSTRIAL OKGAM/ATIONS
                                            '-MV'WENTAL
of •HJriter 2555 Vernal  Pike.  BloomingtonT Ind.
! V K
                                                          o
                                        June 18,
Mr. Dale Luecht
United States -Environmental  Protection
Agency, Planning  Branch
12tt Floor
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Luecht;

     The Bloomington Building & Construction Trades
Council is  a  Council of representatives from all the
fifteen Construction Unions in this area.  As it was
impossible  for us  to attend the public meeting this
letter is to  advise  you that the Council has went on
record to support  the Salt  Creek site for Construction
of the new  Waste Treatment  Plant for the Bloomington
Indiana area.
     This site would serve  a much larger area that
badly needs a sewage system.
                           6-113

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                  of
                LOCAL UNION No. 1664
                     2335 VERNAL PIKE
                 ELODMINGTQN, INDIANA 474OT
                    PHDNC: a7Z/336-43SQ
                                    June 18,
Mr. Dale Luecht
United States Environmental Protection
Agency, Planning Branch
12m Floor
230 South Dearborn Street
Chicago, Illinois 60604-
Dear Mr. Luecht:
     The Carpenters in the Bloomington, Indiana are
very much interested in the proposed Waste Treatment
Plant for this area.
     When building a house, apartment, store, office,
school, factory or what ever, it is only good business
to design and locate the structure so that it will be
utilized to its .fullest extent.  For these reasons
and others we want to urge your approval of the Salt
Creek site for this plant.
     As you may know Monroe County Indiana does not
have maney areas that are suitable for Septic Systems.
The Engineering report given in the local paper
recomended this site to service a large area and
thereby eleminating maney other possible environmental
problems in the future.
     We further think this plant should serve the
greatest number of people at the lowest possible cost.
The Salt Creek site is the best suited to do this
pluss protecting the environment of the largest
possible area.
                                            pkins
                        6-114

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JAMES R. REGESTER
COWARD W.NAJAM.JR.
                        REGEBTEH S NAJAM
                         ATTORNEYS AT LAW
                          I OO Vt WEST SIXTH STREET
                        BLO D MIM BTDN, INDIANA
 TELEPHONE

AREA CODE 812

 332-3334
                                   June 4, 197^
Mr. Dale Luecht
United States Environmental Protection Agency
Region V, Planning Branch
230 South Dearborn Street
Chicago, Illinois  60604
                                                        j i 1575
                              RE:  City of Bloomington,  Indiana
                                   Wastewater Treatment
                                   Disposal of Sludge
Dear Mr. Luecht:
          It is our understanding that you are presently evaluating
various proposals for construction by the City of Bloomington of  a
new wastewater treatment facility.  You have been referred to us  by
Mr. Gary Kent, Director of Utilities, and Mr. Rick Peoples, Utilities
Chemist.

          The Scarab Compost Company has developed a process for
the accelerated decomposition of organic matter.  The Company can
process virtually any organic substance, e.g., leaves, grass, saw-
dust, wood chips, cardboard, paper, etc., and can convert such
organic material into a mineral rich dirt in a period of thirty
(30) days.

          The Company has worked with the Indiana State Board of
Health in cleaning up the Bloomington Packing Company by disposing
of its organic refuse through composting.  The Company has also,  by
way of experimentation, disposed of sludge left over from the City
of Bloomington wastewater treatment process.

          The Company now has a tentative agreement for a contract
with the City of Bloomington to dispose of the sludge material
produced by both the Winston Thomas and Blucher Poole waste treat-
ment plants.  The end product from this process will be a harmless,
odorless and mineral rich black dirt.
                               6-115

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Mr. Dale Luecht
June 4, 1975
Page Two
          We believe that the process which Scarab has developed
holds great promise as an alternative to conventional land applied
means of disposing of sewage sludge.  We would like to discuss this
process with you or other representatives of the Environmental
Protection Agency, with emphasis on the high cost effectiveness of
the Scarab method and the environmental benefits.

          Please let us hear from you at your earliest convenience.

                                   Very truly yours,

                                   SCARAB COMPOST COMPANY, INC.
EWN:ap
                              6-116

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                          REQEBTEH S NAJAM
                            ATTORNEYS AT LAW                      TELEPHONE
                            IOO14 WEST SIXTH STREET                     AREA CODE 812
JAMES R. REOESTER

EDWARD W.NAJAM,JR.                 Hl^Q OMIN QTPN, IMDIANA
                                  August 8, 1975
  Mr. Dale Luecht
  United States Environmental
  Protection Agency
  Region V, Planning Branch       RE:  City of Bloomington, Indiana,
  230 South Dearborn Street            Contract for Sludge Disposal
  Chicago, Illinois  60604             Through Composting

  Dear Mr. Luecht:

            Since I met with you and Cathy Grissom in Bloomington
  on July 17th, the Scarab Compost Company has signed a sludge
  disposal contract with the City of Bloomington to compost the
  sludge produced by the City's present wastewater treatment plants.
  A copy of the Contract is enclosed herewith.

            The purpose of this letter is to request that the
  Environmental Protection Agency and its consulting engineers fully
  consider and evaluate composting as a sludge treatment alternative
  in preparing the Environmental Impact Statement for Bloomington's
  proposed wastewater treatment facility.

            In our Contract with the City, our objective is to
  demonstrate, in practical use, the desirability and feasibility
  of composting sewage sludge.  We believe that composting is the
  most effective method of sludge treatment and disposal both in
  terms of environmental protection and solid waste resource re-
  covery and utilization.

            Our Contract with the City provides for testing and
  evaluation of digested sludge both before and after composting.
  We anticipate that, given the constituent character of Blooming-
  ton's digested sludge, the concentration of heavy metals and other
  contaminants before composting will be acceptable and will improve
  in the future with pre-treatment.  After the sludge is composted
  with other organic materials, e.g. leaves, sawdust, corn cobs, etc.,
  there is a significant dilution factor in the finished product.
                                  6-117

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Page Two
Dale Luecht
August 8, 1975

          The Scarab compost process also achieves significant
pathogen reduction.  Accelerated bio-degradation generates tem-
peratures which disinfect the digested sludge in a natural pro-
cess of stabilization through bacterial action.

          In addition, the Scarab aerobic or "open stomach"
method requires a limited energy investment, a factor of in-
creasing significance which should be considered in evaluating
various sludge disposal alternatives.

          The Federal Water Pollution Control Act Amendments of
1972 call for the development of alternative means of sludge
disposal and utilization.  As you know, traditional land appli-
cation of digested sludge presents significant problems of soil
and water contamination.  These problems can be controlled and
significantly reduced or eliminated by adequate composting under
controlled conditions.

          To insure safe operation and control while the sludge
is being processed, our Contract provides for inspection by the
City and other appropriate public agencies, including the Envi-
ronmental Protection Agency.  We invite you and your consulting
engineers to participate in the evaluation which will be conducted
by the City's Environmental Quality and Conservation Commission.

          There are not many people qualified and capable of
producing large amounts of compost on a commercial scale through
an accelerated process of bio-degradation.  The President of our
Company, William Addison, was among the original group of persons
involved in the 1930's in compost research at George Washington
University at College Park and Beltsville, Maryland.  Mr. Addison's
early work involved field research in agriculture and animal hus-
bandry and the creation of organic substitutes to commercial ferti-
lizers.  In his early research Mr. Addison worked with Dr. E. E.
Pfeiffer who was responsible for the fundamental research in
composting during that period.  Mr. Addison's composting experience
spans forty years.  Three years ago he sold his sole proprietorship
and began the commercial production of compost within the present
corporation, the Scarab Compost Company.

          As I indicated to you in my letter of June 4, 1975,
Mr. Addison and the Company have worked with Indiana State
Board of Health in cleaning up the Bloomington Packing Company
                              6-118

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Page Three
Dale Luecht
August 8, 1975

which was under an order to close unless it disposed of its
organic refuse.  The Packing Company now has a clean bill of
health and Scarab composts all of the offal remaining after the
meat packing process.

          Mr. Addison has worked with numerous officials from
the State Board of Health.  Among those who may be contacted
are Mr. Frank Kuhns, Field Supervisor in the Division of Meat
and Poultry.  Mr. Lee Parsons of the Agricultural Waste Disposal
Section is also familiar with Mr. Addison*s work.,

          Composting deserves serious and systematic consideration
in preparation of the Environmental Impact Statement wherever the
proposed treatment plant is to be located.  One reason we have
obtained the present Contract with the City is that our proposal to
compost the City's sludge is the most reliable and cost-effective
means of disposal.  The Scarab process also offers an environmental
control factor not available with other methods.   Further, composting
could result in a substantial savings to the City in eliminating the
need to purchase land for a sludge farm operation.

          We look forward to hearing from you or your consulting
engineers in the very near future.

                                Very truly yours,

                                SCARAB COMPOST COMPANY, INC.
EWN:rn
                                   Edward W.  Najam, Jr.
                                                    VJ
                               6-119

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                                             .  i
                                        V ''I'^A
                                              ALTERNATIVE  REGIONAL SEWAGE

                                                TREATMENT PLANT SITES

-------
                              APPENDIX A

                         •PHYSICAL. PARAMETERS

•A.  MUNICIPAL WASTE LOADS.

    Data  for each of  the Bloomington wastewater treatment plants are shown

 in Tables IV-1, V-l,  V-2.  This data indicates the chemical and biological.

 characteristics of untreated and treated wastes.

    There is a substantial change between the recently recorded data and

 similar data for 1971.   A comparison of the 1971 and 1973-74 data is shown

 in the following tabulation:

                                 Average Concentrations

                              North Plant      South Plant
                            (Blucher Poole)  (Winston Thomas)

                   Year     BOD5      J3S_     BOD5      j>S_

                   1971     125       89     196      261
                 1973-74   164      187     137      146

    The change in waste  characteristics at the Blucher Poole plant may be

 attributed to the fact that since September 1973 waste has been pumped

 from the  south drainage  area to the north drainage area.

    Reasons for the change in strength of waste at the Winston Thomas

 plant are not clear.  There is no known significant change in industrial

 waste contributions.  The quantity of flow during the 1973-74 period

 was slightly lower than  in 1971, which would suggest less infiltration/

 inflow.

    Bloomington has historically experienced problems with the operation of

 the anaerobic digesters at the existing Winston Thomas plant.  High concen-

 trations  of heavy metals in the raw waste have been partially responsible

 for the operational problems.  An industrial waste ordinance has been

 passed in recent years to allow control of industrial waste discharges.
                                    A-l

-------
                           Table IV-1

                  RAW WASTE CHARACTERISTICS
                     BLUCHER POOLE PLANT

                                       Total
Date    BOD    ^      DO      pH      Phosphate    Chlorides  Alkalinity
1973
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sep.
Oct.
Nov.
Dec.
1974
Jan.
Feb.
Mar.
Apr.
May

105
172
200
160
140
110
150
158
171
147
205
139

158
199
201
201
165

103
185
106
140
70
73
75
136
200
165
431
234

227
217
261
314
243

3.3
3.2
4.3
3.5
2.1
1.6
1.0
0.8
0.9
0.6
1.2
2.4

2.8
2.1
2.4
1.9
1.9

7.2
7.3
7.3
7.2
7.2
7.2
7.1
7.1
6.9
6.9
6.9
7.0

7.0
7.0
7.1
7.1
7.0


5.2
3.5
4.3
7.5
4.6
7.4
8.5
10.8
6.8
4.5
2.9

3.2
3.6
2.9
2.7
9.2


53
43
37
42
45
37
40
36
40
43
47

72
59
59
50
46




120
250
200
206
199
113
186
180
160

180
167
171
153
152
                               A-2

-------
Date
BOD
SS
       Table IV-2

RAW WASTE CHARACTERISTICS
  WINSTON THOMAS PLANT

                       Total
        DO     _gH    Phosphate  Chlorides  Alkalinity
1973
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sep.
Oct.
Nov.
Dec.
1974
Jan.
Feb.
Mar.
Apr.
May
185
366
150
96
95
70
105
106
127
129
153
118

108
114
136
133
128
166
174
130
81
110
98
88
165
180
174
223
155

113
137
157
164
159
5.2
5.4
6.8
5.7
3.8
3.7
3.0
2:5
2.6
2.8
5.1
4.8

6.4
3.9
8.0
5.2
4.7
^ .
7.3
7.3
7.4
7.0
7.0
7.1
7.0
7.0
6.8
7.0
7.0
7.0

7.2
7.2
7.0
6.7
7.0


3.3
2.4
5.3
3.3
6.3
4.9
5.5
7.5
4.9
3.5

2.7
3.2
2.9
4.0
10.8


55
49
45
45
41
46
44
34
44
57

95
67
56
51
46



86
185
170
160
107
174
212
164
176

168
151
164
152
159
                                 A-3

-------
An industrial waste monitoring program is scheduled to start in the fall  of




1974.  Heavy metals concentrations will be monitored as part of this program.




Heavy metals concentrations in the raw waste during recent months are shown




in Table IV-3.




 B.  RECEIVING WATER QUALITY




    The receiving stream for the Blucher Poole plant is Bean Blossom Creek




and for the Winston Thomas plant it is Clear Creek.  The receiving stream




for the new regional plant will be either Clear Creek or Salt Creek,depending




on the site selected.




    Data for dissolved oxygen levels in the streams above and below the




existing treatment plants have been obtained by the City and are recorded




in Table IV-4.
                                   A-4

-------
                                Table  IV-3



           CHEMICAL ANALYSES -  RAW WASTE  (WINSTON THOMAS PLANT)
                             4 1 •*     "
Date _
1 07-3
i.7 / J
Sep. 19
Sep. 25
Oct. 3
Oct. 16
Oct. 24
Oct. 31
Nov. 7
Nov. 14
Nov. 21
Nov. 28
Dec. 12
Dec. 19
1974
Jan. 9
Jan. 16
Jan. 24
Jan . 30
Feb. 6
Feb. 14
Feb. 20
Feb. 27
Mar. 6
Mar. 13
Mar. 20
Mar. 27
Apr. 3
Average
Cu
— -
0.06
0.09
0.15
0.11
N/T*
0.14
N/T*
0.08
0.11
0.11
N/T*
0.12

0.12
0.07
0.07
0.05
0.09
0.07
0.06
0.11
0.06
0.02
0.04
0.12
0.11
0.09
Cr
- • •
0.03
0.07
0.18
0.11

0.09

0.04
0.16
0.06

0.17

0.15
0
0.01
0.04
0.05
0.04
0.02
0.03
0
0
0.01
0.09
0.08
0.06
	 Nl 	
0.02
0.14
0.21
0.12

0.09

0.18
0.26
0.21

0.07

0.10
0.06
0.05
0.05
0.06
0.08
0.05
0.09
0.09
0.05
0.04
0.06
0.09
0.10
— •-" •"* "'£
Fe
— 1. 1, — . , ,
0.45
0.82
3.10
0.77

1.51

0.49
0.71
1.95

1.02

0.73
0.54
0.68
1.10
1.7
1.08
0.63
0.44
0.26
0.11
0.32
1.45
1.65
0.98
-,1 -i-
Zn Mg
0.16 7.6
0.47 7.1
1.99 7.6
0.34 6.6

0.59 8.37

0.60 8.1
0.86 8.1
0.42 8.7

0.47 8.8

0.33 8.4
0.21 11.2
0.17 10.26
0.24 9.44
0.40 9.44
0.35 9.4
0.25 8.6
0.18 10.7
0.11 9.2
0.11 9.1
0.13 9.2
0.55 8.9
0.50 9.7
0.43 8.84
Ca
54.9
26.0
47.1
42.7

32.3

23.3
29.8
30.2

40.8

—
63.1
70.6
75.6
56.4
47.3
32.2
71.9
66.9
63.4
78.0
59.3
61.1
51.1
*N/T = No Test.

                                  A-5

-------
                             Table  IV-4




                 DISSOLVED OXYGEN LEVELS IN STREAMS




            BLUCHER POOLE PLANT           WINSTON THOMAS PLANT
Date Above Outfall
1973
Jan.
Feb.
Mar.
Apr.
May
June
July
Aug.
Sep.
Oct.
Nov.
Dec.*
1974
Jan.
Feb.
Mar.
Apr.
May
13.6
14.0
11.9
11.0
9.5
7.0
6.4
6.2
6.5
6.4
8.3
9.1
12.5
12.4
10.4
9.4
8.2
Below Outfall
13.2
12.0
12.0
10.0
8.7
6.6
6.1
5.4
4.6
4.2
6.1
8.3
12.7
12.1
10.2
9.2
8.2
Above Outfall
13.1
14.4
13.0
11.0
8.9
7.7
7.1
6.9
7.2
7.6
8.7
9.3
10.9
11.4
10.1
10.8
8.7
Below Outfall
9.2
10.0
11.0
8.8
8.9
7.6
7.1
6.3
4.8
5.8
8.1
7.8
10.1
9.7
9.2
8.3
8.7
*Estimated
                                 A-6

-------
                           Table V-l

                 ANALYSES OF NORTH PLANT WASTE
                        (BLUCHER POOLE)
                     Suspended Solids
BOD
Date

1973
Jan.
Feb.
Mar.
Apr.
May
June
July
Aug.
Sep.*
Oct.
Nov.
Dec.
1974
Jan.
Feb.
Flow
(mgd)
0.41
0.40
0.84
1.03
0.41
0.48
0.38
0.45
1.44
2.21
2.34
1.76

2.59
3.36
Raw
(mg/1)
103
185
106
140
70
73
75
136
200
165
431
234

227
217
Final
(mg/1)
18
18
38
7
7
27
32
23
27
38
32
29

21
20
Raw
(mg/1)
105
172
200
160
140
110
150
158
171
147
205
139

158
199
Final
(mg/1)
10.4
13.4
8.8
6.7
4.4
9.5
10.2
9.7
5.6
11.0
14.4
7.0

6.2
13.1
*  Since September 1973, flow has been pumped from the south basin

   to the north plant through the central lift station.
                             A-7

-------
                             Table V-2

                   ANALYSES OF SOUTH PLANT WASTE
                          (WINSTON THOMAS)
                       Suspended Solids
Date

1973
Jan.
Feb.
Mar.
Apr.
May
June
July
Aug.
Sep.*
Oct.
Nov.
Dec.**
1974
Jan.
Feb.
Flow
(mgd)
9.1
8.9
10.6
11.2
7.9
8.4
8.2
7.2
5.6
5.3
5.8
6.4
7.8
7.2
Raw
(mg/D
166
174
130
81
110
98
88
165
180
174
223
239
113
137
Final
(mg/1)
29
38
40
45
39
36
32
46
34
24
44
58
18
19
Raw
(mg/1)
185
366
150
96
95
70 '
105
106
127
129
153
121
108
114
Final
(mg/D
40
59
47
41
30
27
35
41
35
20
31
19
18
17
 *  Since September 1973 flow has been diverted to the north plant

    through the central lift station.

 ** Estimated.

*** See pages A-9 to A-ll of this appendix for correction of flows due to
    inaccurate metering devices.
                                  A-8

-------
                  L.fY  DF BLOOMINGTU UTILITIES
                                  P.O. BOX 1216
                            BLDDMINGTDN, INDIANA 47401
                                TELEPHONE AC «12 339- 2261
                                March 18, 1975
Robert Denman
Field Engineer
Municipal Wastewater Section
Indiana State Board of Health
1330 West Michigan Street
Indianapolis,  Indiana  46206                        •

Dear Mr.  Denman:

Attached is  a copy of work we have done checking the accuracy
of our raw sewage meter.
               o                            •          • • • -  .   -r

Our work seems to indicate that the actual flow is only about
84% of the metered flow.  We are contacting the meter  manufac-
turer and hope to have them re-calibrate it in the near future.

If you have  any questions on what we have done or need additional
information, please contact me.

                                Very truly yours,
                                Michael M. Phillips
                                Treatment Engineer
MMP:jf

Attachment

cc:F. Beatty^Black & Veatch
   G. Kenti
.   File
                           A-9

-------
          •,  Ct   WINSTON THOMAS WASTEWATER PLANT

                       FLOW MEASUREMENTS


As part of our routine maintenance policy, the factory represen-
tative was contacted -to inspect and calibrate our magnetic raw
sewage meter.

On August 28 the meter was worked on for the first time.  Because
of the large increase indicated by the meter, he was called back
on September 30 and October 21 to inspect and re-adjust it.  Table
I gives information on flows for the Blucher Poole and Winston
Thomas Plants from 1973 to the present, along with the monthly
measured precipitation.  Graph I shows this pictorially.

To check the accuracy of the meter, three methods were used:
displacement of the dosing tank, chemical gauging, and a". weir.

The volume of the four dosing tanks was calculated from the blue
prints and checked by addition of a known amount of LiCl.  The
number of times the tanks filled times their volume, was then
compared to the gallons indicated by the meter totalizer for the
same period of time.  These values were then converted to MGD.

Chemical gauging was the second method used to check the flow.
A known concentration of tracer, LiCl, was metered into the waste-
water flow and samples were then collected down stream of the
meter.  The samples were analyzed for lithium by a model 403
Perkin Elmer Atomic Absorption Spectrophotometer, and the flow
was calculated by the formula:
                      (0^)    1440 min/day
         o   **             x
          u
                    CD        3785 ml/gal

Where:   CD  *=  downstream concentration  Li mg/1

                flow of injected stream  ml/min

                concentration of injected stream  mg/1

         Qu  =  flow MGD

Figure I shows the arrangement of equipment and sample point.

As a final test we constructed a 3 foot weir and placed it in
one channel leading to the aerated grit chambers.  The other side
was then shut- off and all flow passed over the weir.
                                 A-10

-------
                       r
•The comparison of the results of these three methods is as  follows
          Dosing tank          84.4% of indicated flow
          Chemical gauging     83.5% of indicated flow
          Weir   •             84.6% of  indicated flow.
 MMP:jf
 3-75
                                   A-ll

-------
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-------
                      D. Sludge Composition

                   CITY DF  BLDDMINGTDN UTILITIES

                                   P. 0. BOX 1216
                             BLDDMINGTDN, INDIANA 474D1
                                 TELEPHONE AC 812 339-2261
                                September 17, 1975
Dale Leucht
Planning
US  EPA  Region V
230 South Dearborn
Chicago, Illinois  60604

Dear Dale:

The following is  the  information you requested:

     1.  Winston  Thomas sludge composition in mg/kg
         dry weight:

                      Cu    980
                      Cr    585
                      Fe   5940
                      Ni    282
                      Cd     29
                      Zn    430

         Winston  Thomas sludge which is now picked
         up by the  public for use in gardens and
         composting is about 65% solids.
     2.   Blucher Poole sludge composition in mg/kg
         dry weight:

                      Cu    690
                      Cr     82
                      Fe   2900
                      Cd     23
                      Ni     55
                      Zn    380

         Blucher Poole sludge used for injection is
         about  8%  solids.  That used for land appli-
         cation is about 2070 solids.
                           A-13

-------
Dale Leucht
September 17, 1975
Page 2
     3.  Enclosed is a copy of a Winston Thomas sludge
         test run by Purdue's Soil Testing Laboratory.
     4.  Tentative plans for sludge disposal at the
         Salt Creek Site include injection on approx-
         imately 240 acres.  The Site will be divided
         into thirds.   In a particular year one third
         will be injected, one third fallow, and one
         third farmed.  We now plan to grow corn, beans,
         and grass.
I hope this response answers all of your questions.  If not,
please contact me.

                                 Sincerely,
                                 Richard S. Peoples
                                 Project Coordinator
RSP:jf

Enclosure

cc:  J. Quin, Gilbert Associates
     G. Kent, Blgtn. Utilities Director
     F. Beatty, Black & Veatch
     File
                          A-14