-------
The Black & Teatoh Reports continue to seem slanted toward naxiniaing
the advantages of the Salt Creek Site while minimizing the advantage* of
the sites significantly oloaer to the Bloomineton Iletropolitan Area. No
assessment of the environmental damages which could result from construc-
tion of the lengthy transport system to the Salt Creel; Site hare been
made by Black & Veatoh. Environmental damages should be considered a cost
of the project and not dismissed under the euphenisa of "temporary dis-
ruption,1' (EC-9).
The foot that there is sufficient acreage at the 3alt Crook Site for use
of the sludge injection process is stressed as an advantage of the site,
yet no evaluation to given of the soils of the area in tenaa of the
process, nor of difficulties which night 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•)•
Blade & Veatoh assert (I&-10) that "Sewerage service for the Lake Monroe
region is necessary to preserve the ecologic value of the area*" While
these is grave need for a new irastevater treatment system in the south
drainage basin of Monroe County, we continue to assert that sewerage)
is but one of the factors that most be considered in the protection of
Lake Monroe. LAHB-USE PLAITJINC POK TUB UoQ'. UUBROB V/ATSRSIIED SHOULD HATS
AS HIOK PRIORITY AS THE DETELOPlEin? Of A REGIONAL 1JA/ERAGB STOP1&. Im-
plementation of the Lake Monroe Suitability Study by the Monroe County
Plan Comoission should be of prime importance to the 21oomington~Uonroe
County CoBssunity.
The Board of Directors
Sassafras Audubon Society
6-80
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TJp?-lnii D. 'iivt, Chief
Re •',"'. on V Planning Branch
2JO Sovth Dearborn £
Chicago, Illinois 6060/
of IAWRENCE . qREENE • MONKOE
DROWN • IMORQAN ANfl OWEN COUNTItS
lliE
SASSAfRAS
AudUDON
SOCJETy
June 16, 1975
Dear Hr. llirt:
Ve would like to call the attention of the Planning Brancii of Region V,
EPA, to the Strain Ridge School controversy in llonroe County, as it has
inplications with regard to the siting of the new treatment plant.
There was organized opposition to the placement of a school at Strain
nidge when it was first proposed, because Snithville 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.
Me are enclosing several recent news items from the Bloomington Daily
Herald-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 should be noted
that if a Sewage Treatment Plant (STP) were placed at the Dillnan Road
Site, it could service a comr.Tanity school at Snithville.
stress
Crook
THE SASo/LttiAS AUi>U30If SOCTETY ",'ODLD LIKE TO REITERATE ITS
SUPPORT POR A STP, .TEAR THE BLOOh'EIGTOH IHiTROPOLITAII AREA.
"/E BE:IEVE THAT .. PLAJTT AT T:IE DIL^IA.: SITE COULD BE A
PuEGIO.iAL ST? Ii.f TIffi BEST oEifSE OF THE '/OIID, SERVIliG TIIE
ilEEDS OP Ail EXPAITDIIIG, SIvTERED, i^TTtOPOLTTAil POPULATION,
BUT ALSO STIMULATING TaE DEV-JLOE^ifT OP A SE.fERAGE SYSTEM
^0?L T.IOSE BUILT-UP AREAS Ilf T!.^1 SOUTH BASIII SERVICED BY
RURAL ',/ATER SUPPLY SYSTBI.IS BUT STILL DEPEirDTJT dll SEPTIC
TViJnS. CC.iCCYj'LoLY, ALSO, PARTS 07 TPE ]IORTH 'JATEZISIIED O"1
LAizf] i!o:mc.-i :,/]ric:i -.'OITLD :a.rCLU3E TIS ^AYinrran; RECNATION
.'JMA, etc TOULD BE l/IT'IIN A REASONABLE RAIfGE.
re disturbed at the Final Assessment ifearing in l.Iay to hear the
-olr.ced on the advantage which the Salt Creek S;to had over Clear
Sites in terms of dilution water. (b,;.r Blacl: c°: Veatch and a pepre-
se.-itative of the '.later Pollution Control Division of the Indiojia State
of JlealthJ V/e must deal with realities in terns of lack of imple-
:i on of provifr;.ons for the high degree of treatment (or sero dis-
Borrd
neritat
chr--,r--e
nentr:,
of nuc
) sought b.y the recent federal \/ater Pollution Control Act Amdnd-
,?,nd insufficient appropriations for constructing STP's capable
;rcatnent. ilevortheless, we do have goals, we are working on
6-81
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the technology and planning for achieving those goals. It is not good
policy to use a lessor standard an a selling point for a site, on the
grounds that it is cheaper.
Airt'icr:.! ,rc, it is possible that in the i'uture _,a/;e "'onroc's function
P,G the -rinciTial -vatcr r;u M)ly ^csourcc of the entire ilegion vri.ll ascune
top priority in the :.iruuig->,.:cnt or the lal'-e. ivac Sassafras Sudubon Societ./
is vorlcj.ng for that too priority recognition. It is conceivable then
that lov.'-flov.' oo'.vnstrean v,rould becor.ie a lesser 'unction o" the lake during
periods oT prolon;;ed drought, ir so, the site advanta ,e could become n,
disadvantage.
We advocate sludge recycling but object to tne approach o± reco:mending
a process of sludge disposal (soil injection) as an advantage of the
Salt Creeir Site nrior to on evaluation of the soils mid the 'rocess
through on-site research. Me quote "ro:.i the Abstract of the pa^er
of Paul Blalceslec "Monitoring Goiisiuerationo Cor Lluivicipal ..'astev;ater
Effluent and Slii.dge Application to the Land" presented at the Joint
Conflorence on Recycling TTtmicipal Sludges and Affluents on Land in 1973:
'Tonitoring the -lerfornance of the Many interrelated systens v/hicn
are involved in any ^roject enraloying v.ras i.ev/ater or v;nste\vater
sludge application to the land GOJ-I not be looked \ipon as a sub-
stitute for a full understanding of systen res loiisc orior to
project co-^ritt, sent."
We \/ould appreciate having the Di.LLr vrhon tne/' ;o_'e in tlio area':'
Sincerely yours, ,, _^
'?fi--^> xSx. >-£ ^. £? . • -x^VW-c *-~
i{3j ti '-th Load, nloo: i" n, ;tT>:i, lj[ /Y/'Ol
fo ' the r>oarcl o" Dl'^ctors
Uas:-,pJL"r:-s Av.iiubon Sociotv
6-82
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Dtle Leucht
Planning Division
Region V EPh.
230 South Dearborn Street
Chicago, Illinois 6060,4
of IAWRENCE • qREENE • MONROE
DROWN • MORCjAN ANfi OWEN COUNT if. S
SASSAfRAS
AUaUDOIN
sociEiy
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 al] 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 & Veatch recommendations, using similar arguments for their decision.
Emphasis is placed both in the engineers statement and the H-T editorial on
the argument thbt 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 Greek 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 or the capabilities of the site
which in this instance is lacking although the survey of soil types of tve
area has been made. Perhaps better drainage might be needed, and this would
be a cost of the pr^iect. In addition, also, to the costs of storage, trans-
noint, and injection of sludge, would be the need for continuing research on
what happens to the sludge components in the soil and in the crons etc.
6-83
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Oil"1- Society would like to see the sludge recycled whatever process is used. We
realize that it coiild be expensive, perhaps, especially in initial stages when
an adequate and acceptable Method is being developed. However, a community
should feel an obligation toward recycling such a resource.
The assertion bv the engineers that permanent damage in Clear Creek Valley can't
be substantiated refleetsvthe viewpoint tl at ^f the end justifies the mean, and
?^ ignorance of the word "damage" fro1^ an ecological standpoint. Actually, one
type of damage which could result fTvn interference with the st^p^n channel,
and its watershed,has been widely ^emonRtrt-ted in ou^ country in terns o^ changes
in natural systems, drainage "»a+terns ^+c. Tt is difficult to see how long-lasting
damage could bf5 avoided if -I-hern fire numerous crossings of Cl par Creek involved
in th*5 laying 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 are;;.
Both at the last environmental assessment hearing and in the engineers statement
it was noted that nature rabidly 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 bv nature. What is not recognized is that out of sight (dis-
guised by vegetation or hidden under the creek"1 is not necessarily out of mind
in terms of continuing effects if serious alteration of channel and watershed
has been effected.
We also take exception to the convnarison of the North sewer line with the oro-
posed 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 •flood plain to the Bottom
Road plant. Even so, the laying of the north line was a travesty of environ-
mental planning! Enclosed is a copir of r>age 3 of The Balancer (newspaner 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 th<= not<= that
one plant is more economic than two, and that the Lake ''onroe Regional 'Jaste
District will probably construct a plant somewhere south of Farrodsburg if the
Clear Creek site is selected. While we would a^ree that one regional plant
would be more economic than t./ra, there are alternatives which haven't been fully
considered for dealing with effluent now entering the lake and questions of
po'jicy concerning the management of Lake iionroe are still to be answered which
could affect what is needed in the way of a QJant tt that site (or if there is
any need at all beyond the plant . ow in process of construction at Little Clecr
Creek).
We reiterate our concern for any action which would nromote growth and dev>ion-
"lerrb around I,ake "!onroe ,ui ,.R^. OF Cill^C. I, KT/IIOIT:; T, L^G >! CIlli: .-EC, 1 ,;1
YT is ^HT? ci'T'F (V'ri liuST1} WJiX'l X:3 'IY .•I^T^CE o^ ?! •; ~S O'"i ,; ,^/n r; "T ,-n'Oi [._ "
j- Viv '•»«*"l»^in the absence of any combiner? «rfort. on t.hn ogrt of -ovprrir.er.tal
a^«:;cies concerned with its m^nagenent to evaluate and determine -f< -r^ 1 pvola of
development and USP can b^ absorbed without seHously affecting wal.er HU.J ity.
^he isfue is what is bes+ To^ the public interest in this instance as the r>< V^
TOS crested with oub] ic funds L.nd th^e li fp of a comiiuriitv i.c" involved.
6-84
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l?:nd-usp policy for- the perimeter i>nd the entire watershed ofi Lake Monroe
to be adopted but has not «nma been considered as yet. Standards must
necessarily be more stringent for protection of a communal water supply.
Our Society wou1 H a.l so lil<^ to fro on record as favoring a ?0 rn^d nlarit in
order to provide for built-up areas in need of newer service and for future
oxoansion around the metronoli+an southern aT>a.
Tn conclusion, WP would "liVe to strer.s a point already covered but which n^eds
to be emp^osi zed since the sT^jimpnt used for the Salt Creek Site t^-nds to
center around d»,rpp /-.f dilution water:
"The emnVifl.qi R of national water pollution control policy is now on
the amount of wastes that can bp kept out of surfacp waters, rathp
than on the amount of wastes that can be assimilated by the waters.
This emphasis will ^uide future acceptable water resource policies.
(?vOTn Characteristicf? and comparative magnitude of non-
point sources by RayiorH C. Loehr, Journal of Water P
Control ^Pderati^n, I??.',, 'fi-W :' l?/,9-l *72. M^. Loehr is
prof PS SOT* of civil and agricultural engineering, Cornell
University, Tthaca, ^.v.
Yours sincerely.
for the Board of Dirpctors,
Sassafras Audubon Society
R3. Smith Road
Bloomi nf^ton, Indiana /;-7/f01
6-85
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D) LETTERS FROM INDIVIDUALS
6-86
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7h1 Eigenmann Center
Indiana University
Bloomington, IN klhOI
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:
(1) 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 Dill man 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 leaching 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,
0
6-87
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•*
fc
I
i
m
—
I
Indiana University Alumni Association
AREA CODE 812 / 337-1711
Office of the Executive Secretary
June 17, 197;.
N A6ENCr
y
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 Secreta,
FBJ:jh
Winner of three national Alumni Administration awards for comprehensive excellence in alumni programming
6-88
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BUILDING AND COXSTRK'TIOX TKADKS COUXt'IL
IN AFFILIATION WITH
BUILDING AND CONSTRUCTION TRADES DEPARTMENT
AMERICAN* FEDERATION OF LABOR CONGRESS OF INDUSTRIAL ORGANIZATIONS
of -Pritcr 2535 Vernal Pike, BloomingtonT Ind
PKO;CC ^
1 V E o "'
June 18,
Mr. Dale Luecht
United States Environmental Protection
Agency, Planning Branch
12» 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.
6-89
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^Brotlg*rlgiro& of tysxxytntec* mtfc ^Ixxm*** of
LOCAL UNION No. 1664
2335 VERNAL PIKE
BLaDMINClTQN, INDIANA 474D1
PHONE: 81 2/336-43 SO
June 18,
Mr. Dale Luecht
United States Environmental Protection
Agency, Planning Branch
12ft 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.
John irampkins
B. A.
6-90
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JAMES R.REGESTER
EDWARD W. NAJAM,JR.
REQEBTEH 5 NA.JAM
ATTDHNEYB AT LAW
IOO14 WliST SIXTH STREET
, INDIAKA
June
Mr. Dale Luecht
United States Environmental Protection Agency
Region V, Planning Branch
230 South Dearborn Street
Chicago, Illinois 60604
TELEPHONE
AREA CODE 812
1 i 1975
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.
6-91
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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
6-92
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REQEBTEH S NAJAM
ATTOHNEYB AT LAW TELEPHONE
JAMES R.REGESTER IOO»t WEST SIXTH STREET AHEA CODE 812
EDWARD W.NAJAM.JR. BLODMiKQTDK, INDIANA 332-333*
474OI
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.
6-93
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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
6-94
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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.
Edward W. Najam, (Tr,
EWN:rn
6-95
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Part II Comments on the Draft EIS
1. Public Hearing Comments
Comment; MAYOR FRANK McCLOSKEY:
I'd like to thank the EPA and Gilbert Associates for coming down
and the interest they've shown. As would be the gist of this state-
ment, I'd like to stress that in no way should anything I say be
construed as being in opposition or counter to the Dillman Road
site. I think almost everyone in Bloomington would enthusias-
tically endorse the Dillman Road site and I think, for the Record,
I would like some questions stressed, and I am also helpful that
the EIS would be finalized come June or so, that wherever we go,
it does move along. But now I'll read the statement.
For about four years now the City of Bloomington has been actively
working on a sewage expansion program for the south treatment area.
There is total concensus by all parties that the City direly needs
a new wastewater treatment facility to service the southern drainage
area. Recent weeks have seen the imposition by the Stream Pollution
Control Board of an additional hook-on limitation. Neither our
concern for the environment nor for improved economic conditions
in Bloomington can allow further delay on this vital project.
Every month of delay results in better than $300,000 in infla-
tionary costs.
The Environmental Protection Agency with the aid of their con-
sultants have definitely decided that Dillman Road is the best
site for the new facility. The city's technical consultants,
Black and Veatch, endorse the concept that a completely functional
and satisfactory plant can be constructed at the Dillman Road
site. I believe the entire Utilities Service Board will agree
to the Dillman Road site, as I will.
However, as the final EIS is still being processed, for the
Record I would like to see several concerns addressed. These
concerns include the technical questions raised by Black and
Veatch during the hearing on January 29th. I believe that two
gentlemen from Black and Veatch would like to speak later, briefly.
I believe that only one — the nitrogen discharge requirements
of the State of Indiana -- has been addressed thus far.
Perhaps of more importance to me than location would be the
question of plant size, as additional growth is expected and
almost certain in the Bloomington metropolitan area. It would
be unfortunate if after years and years of effort that a 15 MGD
plant at the Dillman Road site would be in any way inadequate
and have to undergo an additional expansion program soon after
construction.
I have no desire to freeze-in or artificially justify a less than
optimum decision on a plant site. However, consultation with the
engineers indicates it would almost be an additional year's delay
for the new planning sheets for modification to the Dillman Road
6-96
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site to be completed. Total additional costs for all consumers
and governmental agencies could amount to several million dollars
given the current inflationary spiral. I would hope that in the
ensuing weeks that these additional costs — due to inflation,
time and consultants' work on modifications — would be considered
in cost-benefit decisions as to the two sites.
I would stress, however, that these concerns are in no way raised
in opposition to the Dillman Road site. The Utilities Service
Board, the consulting engineers, and I will support the Dillman
Road site. These questions are raised only to develop pertinent
information to facilitate the best decision about a project that
has been underway for a number of years.
If the final version of the EIS recommends Dillman Road and that
is the decision of the EPA, the City of Bloomington and the entire
Bloomington and Monroe County area will enthusiastically work
toward the accomplishment of this project.
Comment; MRS. DAVID FREY, commenting for the Sassafras Audubon
Society:
1. Supported construction of the proposed STP at the Dillman
Road site.
2. Stated that the Audubon Society, had aksed EPA to address
the capacity issue in an earlier "communication.
3. Expressed deep concern about the PCB problem and suggested
that the Audubon Society would like to see a closed system for the
use of PCB's by Westinghouse in the very shortest time possible.
Response: To MAYOR FRANK McCLOSKEY and MRS. DAVID FREY
1. The questions that Black & Veatch raised and the responses
to them are found on pages 6-35to6-36of this EIS.
2. The capacity of the proposed STP for the South Bloomington
Service Area recommended in the draft EIS was 15 MGD. As a
result of Mayor McCloskey's concern that the proposed STP
might be undersized, USEPA requested the City of Bloomington
Utilities to recheck the existing flow data for the Winston
Thomas STP. The revised flows and a discussion of them is
found in Appendix A pp 9 to 15 , The conclusion is that
a 15 MGD capacity (with 1.9 MGD diverted to the North STP)
should be sufficient to meet the needs of the south service
area through the year 2000.
3. The PCB issues are addressed in Appendix G.
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COMMENT; MR. L.W. BREMSER - Black and Veatch, Inc.
At the January 29th meeting we commented concerning twelve points
in evaluation of the Gilbert Report. These comments are repro-
duced on pages 6-32 through 6-34 of the draft (and final) Environ-
mental Impact Statement. One point (Point #1) regarding nitrogen
discharge has been resolved (in the draft EIS). However, we still
have reservations as- to six other points, five of them concerned
with cost. They are:
Point two - The estimated additional cost for second-stage nitri-
fication required on Clear Creek has been increased from $1,722,000
back in January to $2,253,000. We are still concerned that this
may not be adequate.
And if I understood the statement by the Gilbert representative
awhile ago today, the two stage plant was estimated at one and a
half times the single stage aeration plant. This statement is
not borne out in the summary of estimates, Table 6-8, page 3-6-17.
Point four - We still question the adequacy of estimates for
channel relocation at the Dillman Road site.
Point five - We wish to point out again that overestimation of
the cost of the gravity outfall sewer tends to make the upper
Clear Creek sites more attractive than would otherwise be the
case.
Point three - Differentials in operation and maintenance costs
pointed out in January have been increased to the nine to ten per-
cent range as opposed to the eight percent which they were. We
still question the adequacy of this differential.
Point eight - The additional 8 percent for sludge handling and
disposal still does not seem adequate but the backup for these
figures is not included in the draft.
Point ten - This is concerned with pumping the 1.9 million
gallons per day to the Blucher Poole Plant as a routine practice.
This plan was only intended to serve on an interim basis and with
the current energy shortage, we believe this recommendation should
be reconsidered. If this recommendation stands and the statement
as to the lesser cost treatment at Blucher Poole is correct, we
assume that no additional stage of treatment at the Blucher Poole
Plant would be required within the design period.
Finally, the interpretation of trends and the pumping of 1.9 MGD
to the north has been used to justify the construction capacity
of only 15 MGD. We are concerned along with others that limita-
tions of only 15 MGD capacity design could prove to be a short-
sighted approach. Thank you.
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Response: MR, JAMES QUIN of GILBERT ASSOCIATES (Consultant to EPA)
We did reply to EPA after that January 29th meeting but our reply
was not published in the draft EIS. (These comments have been
included in the final EIS and are found on pages 6-35 and 6-36.)
On the costs that Mr. Bremser mentioned on point two of the
additional cost for the two-stage nitrification, the figures
were revised after that January 29th meeting. The one and a
half times figure that I spoke of earlier is incorrect, and we
will stand behind the figures that are published in the cost
summary tables, in the draft EIS. (Same tables in Final EIS.)
Mention was made in the January 29th meeting of misunderstanding
that we had of the nitrogen discharge requirements (Point one).
This has been cleared up and the nitrogen discharge requirements
are shown correctly in the final report of Gilbert Associates
(and in the draft and final EIS's).
On the question of the rock excavation (Point four) at the Clear
Creek sites, our estimates are based on a minimum rock excavation
at the Clear Creek site, at the Dillman Road site, and that
assumption is based on an on-site investigation that we did •
while we were here during our field visit in August. We didn't
do any extensive borings at the site, but we did do some borings
down to a depth of about ten feet at several places on that
Dillman Road site.
And we feel, based on that, that the rock excavation for a
stream relocation at that site will be minimal. That is the
reason behind that assumption.
Another item (Point five) that was mentioned was the sizing
of the pipes that we used for the interceptor sewer going from
Winston Thomas down to the Salt Creek site. Apparently, there
is a difference in two places in the facilities plan. We took
the pipe sizes that were shown on a plate in the Black and Veatch
report and took the pipe sizes directly off that. I noticed
in the table within the facilities plan (after our final report
to EPA was completed) that different pipe sizes are ased. I
think the pipe sizes that we took from the Bloomington 201 plan
are consistently six inches larger than the sizes that were
used in costing in the Black and Veatch report.
This was an error, and it definitely involves higher costs,
but even if the smaller pipe sizes were assumed, it would
still not make the Salt Creek alternative more attractive than
Dillman Road.
We did take the pipe sizes directly off the plate in the
facilities plan.
On point ten involving the continued pumping to the Blucher
Poole plant we did recommend that it be continued based on
the low energy requirement for pumping. The figure we were
given by the Utilities Service Board was on the order of
$4,000 a year in pumping costs to that north plant. In
looking at the north plant, it's our feeling that the plant
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is presently being underutilized based on its design capacity,
and that the additional flow that's coming from the south
service area now should continue, and even if additional treat-
ment is required at the north plant, that it's still going to
be more cost effective to treat that sewage at the north plant
and continue the pumping, than it would be to increase the
capacity at the new plant to handle this.
We feel that there is certainly plenty of capacity at the north
plant to handle that 1.9 MGD flow. I think that covers our
reply to those comments. I think the other comments that
were made on January 29th have been covered in the EIS itself
and in our letter to EPA of February 17, 1976 (see pages 6-35
and 6-36).
Comment; MR. ORAL HERT, Technical Secretary of the Stream
Pollution Control Board, State of Indiana.
I might say that I do feel right at home in Bloomington. I
attended the joint school out on White Hall Pike, just a few
blocks from where Westinghouse is now located. I graduated
from the high school that burned down a few years ago, and
attended one year at I.U. before World War II. My gray hair
might indicate the age.
I would say that we have been concerned over the delay in
construction of additional treatment facilities for the City
of Bloomington. We admit that we are somewhat taken aback
by the long sewer line that was proposed to transport the
sewage all the way to the Salt Creek site.
However, the State of Indiana does not make a cost effective
analysis, and our consideration was that there might be a
tradeoff of first cost of the sewer versus the less operation
and maintenanae costs over the years at the Salt Creek site.
We did rely on the city's engineers to select the proper site.
We do believe — I am looking at the environmental report,
that the plant can be located at the Dillman Road site designed
to produce an effluent that will reach standard water quality
standards. We certainly hope that this Environmental Impact
Statement would be completed at an early date, and it will be
acceptable to the city, so that they can have their consulting
engineers adapt the plans that have been developed for the
treatment plant for the city in time to receive construction
grant funds from grants that are now available and have to be
obligated to municipalities in the State of Indiana prior to
September 1977.
I have discussed this problem with the City officials, and
they have indicated to me that they are ready to go forward
as rapidly as possible once this environmental impact is
finally decided.
We are somewhat concerned that the Lake Monroe area will not ,
be served by a joint treatment plant, because we believe that
sewers in this area where there is development will be delayed
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because there is not a region system to meet that requirement.
But, we will continue as we have in the past to limit develop-
ments on Lake Monroe that propose discharge effluent to the
lake.
We'd just cite a couple of points on page 3-3-1 in the Environ-
mental Statement. It cites the average daily flow treated by
the south plant as 11.2 MGD. Recent information from the City
indicates the average flow at the plant is in the range of 7
to 8 million gallons a day with two to two and a half million
gallons a day pumped to the north sewage treatment plant. I'm
not sure whether that was available to the consultants when
they made their survey or not.
And one other point on the Pointe development sewage plant,
they may be required to extend their outfall to Salt Creek
since, at the time their treatment plant was approved by our
Board, we contemplated that a regional plant would be built,
and the effluent would be discharged to Salt Creek, so we will
have to take another look at the Pointe treatment plant in
the near future once this site is established to determine
whether or not a longer outfall will be required from the
Point treatment facility.
I think that's the only comments I have.
Response; to MR. ORAL HERT
USEPA has reviewed the latest flow meter calculations on the
existing flows at the Winston Thomas STP. This is found in
Appendix A-9 toA-15. USEPA finds that 15 MGD is a cost effective
capacity for the proposed STP. The decision on the outfall
location for the Caslon (Pointe) STP is determined by the ISBOH.
Comment; MR. ROBERT SCHMUHL, President, Bloomington Utilities
Service Board.
Let me say first of all that the Utilities Service Board shares
the concerns expressed by Mayor McCloskey and Black and Veatch
about certain elements of the draft Environmental Impact State-
ment, and we appreciate the opportunity of presenting this
statement this evening.
In May of 1972, the City of Bloomington began to make plans for
a sewage treatment expansion program. It was apparent at that
time, as it is now, that a new facility to replace the old and
nearly overloaded Winston Thomas plant was necessary.
Given the condition of the Winston^ Thomas plant, the recent letter
from the State limiting sewer hook-ons in the southern drainage
area, and other factors, the Utilities Service Board hopes that
the authorities of the Environmental Protection Agency and the
State of Indiana in cooperation with the City of Bloomington
will select a definite site as rapidly as possible. The years
of delay on this project have already almost doubled what it
will eventually cost. We need to get this program moving, and
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we need to move without delay.
To facilitate the selection of s site for the proposed facility,
the Utilities Service Board last Spring requested an Environmental
Impact Statement. Since certain doubts about the site existed,
we felt that an EIS was necessary. We appreciate the work done
by EPA and Gilbert Associates in preparing the EIS.
Although the Utilities Service Board has supported the Salt Creek
site as a cost effective and versatile choice, we nevertheless
recognize the arguments that have led EPA to select the Dillman
Road site. Of utmost importance to the Board is a positive and
concerted movement towards the construction of a new plant.
We believe the Dillman Road site will serve the needs of our
community. It will also provide for immediate and continuing
growth and is compatible with the City's plans for the future.
The level of treatment at the Dillman Road site will be vast
improvement over the capability of the present Winston-Thomas
plant. We feel that a plant at Dillman Road will respond to
the environmental considerations and concerns that have been
raised by many segments of the community. For these reasons
and others, the Utilities Service Board supports the selection
of the Dillman Road site.
In conclusion, let me reiterate on behalf of the Utilities
Service Board the City's genuine need for a new wastewater
treatment facility. We sincer.ely hope that this project,
which has been delayed for so long, can be completed with all
deliberate speed. Environmentally, Bloomington cannot afford .
an old and overloaded sewage treatment facility. Economically,
Bloomington cannot afford a moratorium on the number of sewer
hook-ons. Our need is acute, and we hope by working together
that the community can have a new, environmentally-sound plant
in operation as soon as possible.
Response; EPA has addressed MR. SCHMUHLs' concerns in the
response to MAYOR McCLOSKEY.
Mr. Fuller, Deputy Planning Branch Chief, USEPA.
Do we have a representative here from the Lake Monroe Regional
Waste District? Anyone wishing to speak on their behalf?
(No one spoke on the behalf of the LMRWD.)
Comment: MR. JIM PERRIN
Good evening. It's been about a year since Bloomington Sierra
Club spoke at the May 29th meeting concerning the problem that
we saw with the study that had been done before and some of
the issues that we felt the EPA should address in the draft
Environmental Impact Statement.
At that time, we endorsed the Dillman Road site, and this
evening, we would like to affirm our support for the selection
of the Dillman Road site, and indicate that we are somewhat
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gratified that as a fairly new group at that time, *-ith little
experience, and a lot of help from other environmental groups
in town, that we were able to get involved in this issue and
come to some conclusions that we felt were right, and to have
them for the most part substantiated by' an external agency
that I am sure spent more money and time than we did in coming
to our conclusions.
There are some points, I guess, we still feel somewhat uneasy
about. While the demographic projections made by Gilbert and
adopted by EPA are quite elaborate and seem certainly within
the realm of justification, it is difficult for us to come
to a conclusion about the size of the plant. It is, of course,
crystals-bailing to look 20 years in the future, and it will be
an important decision in the Bloomington community.
The environmental concerns seem to have quite well covered by
Gilbert and the EPA and for that we are very gratified. Our
stance was, of course to see first of all that the environ-
mental considerations were protected and did get a fair con-
sideration, and for that we are much appreciative.
Response; None required.
Comment; MR. W. E. BRAUN
I would like to read a prepared statement from the Environ-
mental Quality and Conservation Commission — I'll refer to
it hereafter as EQCC — of the City of Bloomington has counseled
the people of Bloomington on the siting of the proposed Sewage
Treatment Facility (STF). The Commission's position was
completely summarized in its statement to the May 29, 1975,
Environmental Assessment Hearing on the subject. The major
recommendations were:
1. That the Sewage Treatment Facility be located at the Dillman
Road site. The main reasons for rejecting the Salt Creek were:
a. The terrestrial and aquatic destruction involved in
running a long outfall sewer to the site.
b. The lower quality of effluent from the Sewage Treatment
Facility proposed for the Salt Creek site as compared to any
of the Clear Creek sites.
c. The Salt Creek site is within the flood plain of Salt
Creek, directly below the spillway at the reservoir and located
on a soil type known to be subject to waterlogging.
d. The possibility of severe adverse secondary effects
of facilitated development at Lake Monroe because of placement
at Salt Creek.
In addition, the EQCC requested that the Environmental Impact
Statement consider £g points of secondary impact.
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The draft Environmental Impact Statement contains detailed
treatment of items l.a, b, and d above and the majority of
the points of secondary impact. In addition, item l.c and
most of the remaining points of secondary impact are treated
in a general way.
Our conclusions are as follows.
The Environmental Quality and Conservation Commission of
the City of Bloomington concurs with the conclusions of the
Environmental Impact Statement, specifically, one —
The EQCC concurs that a 15 million gallon per day activated
sludge sewage treatment plant with rapid sand filters and
sludge treatment via aerobic digestion and centrifugation
located at the Dillman Road site will serve the needs of the
South Bloomington Service Area.
2. The EQCC concurs that the processed sludge from the south
treatment plant should not be applied to farmland until
a. The extent of the PCB problem in Bloomington has been
determined and;
b. Corrective actions are taken that reduce PCB levels
to a safe level.
We take this opportunity to recommend further that the pre-
cautions be taken placing contaminated sludge into landfill
so that the eventual leakage from such landfill does not
pose a future problem for the area's watersheds.
3. The EQCC concurs that in view of the economic forecasts
and in view of the absence of a comprehensive development
plan, for the Lake Monroe region, regionalization of the
South Bloomington Service Area and the Lake Monroe Regional
Waste District as proposed in the Bloomington 201 plan is
not warranted. We caution, however, that future development
trends may vary from current forecasts. Since the Lake
Monroe region represents the prime watershed for drinking
water for Bloomington and its neighboring communities, land
use in the area should be closely monitored and indiscriminate
utilization as currently practiced be strongly discouraged.
4. The EQCC concurs with the remaining conclusions in the
draft Environmental Impact Statement.
The EQCC would like to take this opportunity to thank all
those concerned, particularly the U.S. Environmental Pro-
tection Agency, for their efforts to place in proper per-
spective the economic and environmental factors concerned
in this project.
Response: None required.
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Comment; MR. LARRY NEMBA
Good evening. I am representing the Monroe County Home Builders
Associated. We met with Mayor McCloskey and discussed the
possibilities of the sewage treatment plant at both sites.
We are in agreement with Mayor McCloskey's statement that we
need a site and we need it as soon as we can get one, whether
it be the Dillman Road site or the Salt Creek site. As it
appears, it will probably be the Dillman Road site.
Our main desire is to provide housing for anyone in the City
of Bloomington or Monroe County. Without sewage treatment,
we cannot increase the number of residents in Monroe County
or the City of Bloomington. We are now down to a limited
number of hook-ons as you read in the paper recently. Without
more hook-ons, virtually home builders and developers are out
of business.
We do desire that there be a reasonable growth. We're not
just wanting to build anyplace anytime, with no concern for
what it does to the environment. We still feel that the
original site on Salt Creek would have been our preference
due to the fact that there has been development around Lake
Monroe with better treatment of the sewage from that area.
We are also concerned on the additional cost that's going
to be to do all the planning and all the delaying to change
over to the Dillman site.
The time schedule, as it was mentioned these are just kind
of loose figures — at the time we were probably talking six
to eight months, before all the paper work can even be altered,
so we feel that we can live with either facility, but our main
goal is to get one underway.
Response; EPA shares the objective of getting a new facility
constructed for the South Bloomington Area.
Comment; MR. DENNIS FALLS, Chairman of the Bloomington Sierra
Club here in town.
Both Mayor McCloskey this afternoon and the Utilities Service
Board this evening expressed a need for proceeding with all
deliberate haste in proceeding with the beginning the con-
struction of additional sewage treatment facilities in
Bloomington.
I think they will excuse me if this is not their intent, but
I think I should comment on the implication that the prepara-
tion of the EIS itself was a cause for the additional delay
and cost in planning this facility. I think that this has
been an excellent lesson for this community that had environ-
mental considerations and existing alternatives that were
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known at the time but inadequately considered in the initial
planning that the delay in the additional costs might not have
had to have been incurred.
Might I at this time ask Mr. Ross some questions about his
statement? (See Appendix G for Mr. Ross's statement)
I was here this afternoon and asked Mr. Ross for a copy of
EPA's statement, on the PCBs in this area. We were very happy
to see this, it really does indicate some forward momentum on
this problem and indicates that some action certainly has been
initiated to help deal with this PCB contamination in this area,
I would like to ask a couple of questions not in the way of
criticism, but just to clarify a couple of problems with myself,
Could you clarify — I think a lot of people are concerned
about the meaning of the term "minimal discharge". This has
been expressed as a goal, and it might be helpful if people
understood what this meant, since it seems often to be
referred to.
MR. ROSS:
I think you are referring to the statement that Westinghouse
in Bloomington has been placed on a timetable for obtaining
minimal discharging of PCBs by the end of 1976.
That question came up this afternoon from a lady, and I didn't
have the precise answer on it, and I still do not have it now,
because I did not make an attempt to examine the total state-
ment regarding Westinghouse.
Now, the State is the primary one carrying the ball on this.
We did some of the initial work and since then we've done some
joint work, and right now, the State is in the active phase of
the enforcement abatement of it.
But I think what can be said on this is that based upon the
process and the operation at Westinghouse, the schedule that
they are on here now to be completed by 1976 is perhaps based
on technology. It may be the best schedule we can get from
them now, merely because they are going on a schedule now that
permits minimum discharge of PCBs which I might not qualify
now to quantify — it does not mean that the effluent will go
to complete zero either by recycling or by changing due plant
process in search of substitution of PCBs, it's still not the
ultimate goal, and still is being pursued with as much vigor
as it was prior to getting the kind of agreement we now have
with Westinghouse.
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MR. FALLS:
Okay. The reason that I wanted to ask that question was — a
number of years ago when it first became known to State agencies
that PCBs were being discharged at the rate 46 pounds a day,
somebody probably considered that to be a minimal discharge,
and we hope that it will become more minimal as quickly as
possible.
You also stated that testing at Bloomington water plants found
PCBs below detectable levels. Can you tell me what EPA con-
sidered to be a detectable level or minimum detectable level?
MR. ROSS:
I think the laboratory now looks at PCBs routinely at a level
that would generally stand as what you can detect in a labora-
tory. Let's see, is Mr. Peoples here?
MR. PEOPLES: (City of Bloomington Chemist)
Ten per parts per billion.
MR. ROSS:
He's in the laboratory, and I am not, that's why I asked him
that.
MR. FALLS:
Sure, okay. Refer on the last page to paragraph B.3, (Appendix
G) at the top of the page, in that the EPA recommended the
three landfill sites be closed and reworked which were formerly
used for solids waste disposal, by Westinghouse, and where water
and soil PCB contamination were found. Does reworking a landfill
site mean complete excavation?
MR. ROSS:
Right now that's a recommendation that's in the report but at
the time the actual survey was done, the leaching from the
landfills that were looked at were very, minimal. And when
I say minimal, leachate coming of there probably, one into
the stream, would not be detectable. That doesn't mean now
that we are saying we don't have a concern for them, that's
why we have in there a recommendation to the Indiana district
office that it may be reworked in a manner which would pre-
clude the leachate in some ditches, drainage ditches, so
that the capacitors that actually conduct the flow of water
through landfill and perhaps into the stream. We feel that
if in the future we find that this leachate problem is one
that is contributing to the problem in the creeks and
consequently in the fish, then those things ought to be
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reworked in a manner which would not cause the problem.
MR. FALLS:
One last question. You note here that the Bloomington south
treatment plant — Winston-Thomas right next to us — has
stopped distributing sludge to farmers and gardeners because
of the high levels of PCBs — who or what agency would be
responsible in determining the proper ultimate disposal of
the sludge that is accumulating at the plant next door. And
apparently you only have until September before storage .
facilities are completely filled.
What local agency or state or federal agency would be most
helpful in determining what to do with that?
MR. ROSS:
Perhaps a better approach to it — I'm not prepared to pin-
point what local agency, or federal or state agency would
have the ultimate responsibility, but I think the approach
to it is going to have to be one where all pollution control
agencies — local, state, federal — are going to have to
pool efforts to find methods of safely disposing of sludge.
I think we necessarily should share the responsibility rather
than any one agency excluding the others. We are addressing
a problem that we need all of the expertise and all of the
help we can get so I would think that we are going to work
together on that problem.
MR. FALLS:
Excellent, that's a very excellent idea, and I thank you
again for that report. It's very encouraging.
If you will permit, Mr. Fuller, I'd like to read a short
public statement.
There will be a public meeting to form a citizens committee
on the PCB problem in Monroe, Owen and Lawrence Counties this
Thursday, May 6, at 7 p.m. in the County Public Library. The
purpose of the committee will be provide a focus for citizen
concern on PCBs and to encourage research on and resolution
of the PCB contamination of lands and waters in this area.
If you have used sludge from the Winston-Thomas treatment
plant, you are especially urged to attend. If you know of
others who have used this sludge, please urge them also to
attend. The committee will help obtain advice and assistance
for citizens concerned about the PCB contamination in their
lives and of course this will help support any other agencies
that are working on this problem.
The coordinator of the committee will be Sarah Narreg (phonetic
spelling), and I'd like to remind you that will be May 6th,
in the Monroe County Public Library auditorium, at 7 p.m.
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Comment; MR. RAY GRAHAM, Professional engineer, county surveyor
at the present time.
I think the question tonight on Salt Creek condemned route sites
were the same state when the bypass was built around Bloomington,
It was needed so bad that everybody said we wanted the thing, we
needed the thing, we were afraid to say what we should do with
it. But we let the bypass go without anybody except Dave
Thrasher and I asking for overheads on it, so that we got
several people killed in the last few years.
I am in favor of the Salt Creek site because I think we're not
far enough down the road. We've got a regional problem, we've
got a sanitation problem, below Dillman Road, as Mr. Hert, I
am sure, knows about, I think we should consider the whole
area — we've got a western area clear out to Stanford that
is going to be loading into the Bloomington plant at some
time. I think the Salt Creek site is the only effective site
for the area.
Response; To RAY GRAHAM
All Clear Creek sites (Winston Thomas, Dillman and Ketchum)
are preferable to the Salt Creek site on an environmental,
economic and geographic basis. Present Worth Analysis (p 3-
6-15) indicate Salt Creek to be more costly by several millions
of dollars (e.g. Dillman Road Present Worth $31,775,000 vs.
Salt Creek Present Worth $42,489,000.).
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 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.
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STATEMENT FROM COUNCILMEMBER THOMAS 0 MIDDLETON, M.D.
for the EPA Hearing, 3 May 1976
For the past five to six years, the City of
Bloomington, State of Indiana and U.S. government, as
represented by the Environmental Protection Agency
(EPA) and other appropriate agencies, have variously
considered, debated and procrastinated in the efforts
to solve our increasing problem of disposal of sewagae
waste within the community.
We have now reached the point where future hook-
ons are limited to 208. This is not a year's problem,
but will continue until the problem is solved. This
ruling by the State Board of Health, will preclude the
development of any significant apartment complexes,
limit home construction, and seriously threaten any
commercial developments, including those that are pre-
sently planned.
I have no quarrel with the particular sites that
might-be recommended, although I question the compe-
tence of the report upon which the EPA bases it^ recom-
mendations. In any event, it is my belief that this
problem must be approached and solved without further
dawdling. To this end, I will introduce a resolution
to the Common Council of the City of Bloomington request-
ing the Utilities Service Board to establish a site for
the treatment plant and proceed with all deliberate speed
to implement the plans that are now at hand.
I have sufficient confidence in the capabilities
of the persons on this Board that they can consider the
engineering plans available to them and make a logical
decision in this matter. I urge the EPA to be respon-
sive of the needs of the community and of the desires
of the people who live here to solve their problems
•with a minimum of harrassment and obfuscation by outside
agencies. Further, I have enough respect for the integ-
rity of our local boards and governmental officials that
they are going to be cognizant of the impact of their
actions in this matter upon not only the immediate envi-
ronment of the community, but our neighbors as well.
I urge you to consider this matter expeditiously.
Respectfully submitted,
C^\J^ <~sjtt-^f
\^, y'T/lri /-; / ' -/-// /'">///
Thomas 0 Middleton, M.D.
Response: None
6-110
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United States Department of the Interior
OFFICE OF THE SECRETARY-
NORTH CENTRAL REGION
230 S. DEARBORN STREET, 32nd FLOOR
CHICAGO, ILLINOIS 60604
ER 76/334 May 14, 1976
Mr. George R. Alexander, Jr.
Regional Administrator
U. S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Alexander:
This is in response to your request of March 5 for Department of the
Interior comments on the draft environmental statement for the Sewage
Treatment Facilities for the South Bloomington and Lake Monroe Service
Areas, Bloomington, Indiana.
GENERAL COMMENTS
We have noted that the applicant's proposed 20 MGD sewage treatment
plant at the Salt Creek site described in chapter 1 is not the action
proposed by the Environmental Protection Agency. The EPA proposal,
revealed in the Summary and Conclusion chapters of the statement, is
that a 15 MGD plant be constructed at the 60-acre Dillman Road site.
A connecting sewer approximately two miles long, paralleling Clear
Creek, would be constructed from the existing Winston Thomas plant to
the Dillman Road site. Clear Creek at the Dillman Road site would be
relocated and channelized.
While the draft Environmental Impact Statement (EIS) includes much
information on the aquatic ecology of the Monroe Reservoir, it does
not describe adequately the abiotic and biotic factors of the streams
affected by the proposed facility, in particular Clear Creek which
was recommended in the draft EIS for reception of sewage effluent
from the proposed sewage treatment plant (STP).
On April 28, 1976, a representative of the U. S. Fish and Wildlife
Service conducted a field survey of the selected site (Dillman Road
site) for location of the STP. The Service representative found that
that segment of Clear Creek provides suitable habitat for some fish
and wildlife species. Twenty-five species of birds and several
squirrels were observed. Also, raccoon and deer tracks were found
along the stream bank. Sycamore trees predominate the flood plain
0^T'o/v .
^ /2V \
6-
-------
-2-
with a few river birch arid silver maple. Several species of shrubs
provide dense cover for birds and mammals. Poor water quality in the
surveyed reach of Clear Creek was the only adverse factor found in the
field review. Low species diversity of invertebrates and fish indicate
the unhealthy condition of the stream. Oligochaetes, midge and black
fly larvae dominated the benthic community, and creek chub and stone-
roller were the only fish species observed. Growths of Cladophora were
present and the rocky substrate was slippery with diatom growth. Such
algae growth indicates nutrient rich waters. Properly treated sewage
effluent should improve the water quality and subsequent biotic diversity
and abundance in Clear Creek.
SPECIFIC COMMENTS
Page 1-5 - General and Specific Location of the Proposed Action
The fourth and fifth lines indicate that Lake Monroe discharges a
minimum controlled release of 32 million gallons per day (49.5 cfs).
Also, at the bottom of the page, the EIS indicates that Clear Creek,
presumably at the Winston Thomas STP discharge, has a 7-day 10-year
low-flow of 0. However, low-flow characteristics of Indiana Streams
by P. B. Rohne, Jr. (U.S. Geological Survey, 1972) indicates that Salt
Creek at Peerless, Indiana has a 7-day 10-year low-flow of 0.8 MGD
(1.3 cfs). It also had a zero discharge from September to December 1965.
The same publication indicates that Clear Creek at Harrodsburg has a
7-day 10-year low-flow oE 4.3 MGD (6.6 cfs). Sewage treatment effluents
from Bloomington are apparently included in the statistical estimate at
the Harrodsburg location. This apparent conflict of information should
be investigated for resolution of a recalculated 7-day 10-year low-flow
figure in the final EIS.
Page 1-7 - Polychlorinated Biphenyls (PCBs) in the Winston Thomas STP
System
The final EIS should contain more specific information regarding the
occurrence of PCBs in raw sewage of the Winston Thomas STP. We under-
stand that more information already is known and available, as well as
the source of PCBs. The final statement also should discuss the impacts
of project-processed PCBs on fish and wildlife resources.
Page 2-3 - Parks and Historical Sites
A letter from Mr. Joseph D. Cloud, Director, Department of Natural
Resources (and State Historic Preservation Officer) confirms the state-
ment on page 2-3 that no known historic sites would be affected by the
project. In addition, Mr. Cloud recommends that the subject of archeo-
logical sites be addressed in the statement. We concur and also recommend
that the statement discuss the action taken or proposed to professionally
determine the presence or absence of archeological resources in the
project area and the effect of the proposal upon any such resources
present. The statement should further reflect procedures to be followed
6-112
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-3-
should previously unknown archeological resources be encountered during
project development.
Page 2-3 - Environmental Constraints
The frequency and magnitude of flooding on reaches of Clear Creek and
Salt Creek draining the project area should be assessed. This information
is needed to evaluate the planned flood-protection measures for the
treatment facilities. Impacts of infiltration and exfiltration through
the sewer lines, many of which must actually be laid within the limestones
of the area, should be discussed. The drastic, probably worst-case,
situation of a ruptured sewer line in a limestone with fractures and
cavernous openings should also be addressed.
Page 3-2-1 - Evaluation of Pure Oxygen Process, and Page 3-5-1 - Treatment
Requirements
While we consider the effluent standards adequate for parameters such as
BOD's, suspended solids and phosphorus, we are not in agreement with
concentrations proposed for ammonia nitrogen. To ascertain a safe
concentration for toxic un-ionized ammonia, a correct 7-day 10-year low-
flow should be calculated. Based on that calculated low-flow, the
concentration of project-caused un-ionized ammonia should not exceed
0.02 mg/1 in the receiving waters. This determination should be made
for the chosen project site - - either Salt Creek or Clear Creek - - to
avoid ammonia toxicity to aquatic life.
Page 3-6-2 - Alternative 4
Because of the excellent physical characteristics of Clear Creek and
riparian habitat along Clear Creek at the proposed Dillman Road site,
we suggest further consideration be given to locating the treatment
plant to avoid relocation of 2,000 feet of stream. If relocation is
necessary, we recommend mitigation features be implemented to minimize
permanent destruction of fish and wildlife habitat. Mitigation measures
should include plantings of trees and shrubs along the relocated channel
to provide a variety of wildlife habitat. Also, alternative riffles and
pools should be constructed in the new channel to offset that destroyed
by project construction. A specific fish and wildlife mitigation plan
should be included in the final EIS.
Page 3-8-14 and 5-1 - Conclusions and Recommendations
The conclusions suggest only that land disposal of sludge—although
preferable on a cost basis--should not be undertaken until the PCB
problem is resolved (p. 5-1). The statement should also more fully
describe the nature, distribution, and hydrologic properties of the
soils that may be involved, should address the probable character of
the leachate, and should evaluate the potential impacts over the long
6-113
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-4-
term of the land-disposal process on ground water and the closely related
surface water, for any disposal site that might be considered.
Page 4-9-5 - Aquatic Ecology
The draft EIS considered several methods of disinfection of treated
sewage effluents but no final decision is made in the draft. We support
the recommendation in the draft EIS to study further alternatives to the
use of chlorine and to analyze further the toxic effects of chlorinated
organics formed as a result of chlorination. If chlorination is selected
as the method of disinfection, we recommend that the residual chlorine
be limited to such that the concentration will not exceed 0.003 mg/1 in
the receiving waters. This concentration has been determined to be safe
for most aquatic organisms. However, we agree that ultimately final
chlorine limitations should be determined by bioassay study using the
receiving waters and the most sensitive fish species in the locality.
Page 4-9-16 - Aquatic Organisms Found in Clear Creek
More information should be given for this portion of table 9-2, such as
the location of the stream reach of the Clear Creek study and the dates
of investigations. Judging from the U. S. Fish and Wildlife Service
findings on April 28, 1976, the data presented is unlikely to have been
observed between Dillman Road and Winston Thomas STP.
Page 4-11-1 - Mitigative Measures for Minimized Physical Effects
We support the general mitigation guidelines in the draft EIS. However,
mitigation means and measures of construction activities should be more
specific.
Sincerely,
^
/Xa^
'
Madonna F. McGrath
Acting Special Assistant
to the Secretary
6-114
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USEPA Response: (To U.S. Department of Interior)
1. Page 1-5 General and Specific Location of the Proposed Action
Clear Creek is tributary to Salt Creek below the Lake Monroe Dam. Thus,
the flow in Salt Creek does not change the 7-day 10-year low flow for Clear
Creek. The 7-day 10-year low flow of zero at the Winston Thomas STP does
not include the effluent discharge from the STP. Construction of the Lake
Monroe Dam on Salt Creek began in October 1960 and according,to the discharge logs
at Lake Monroe, the minimum 50 cfs discharge began in February 1965 and has
been maintained since that time. The reference Low Flow Characteristics
of Indiana Streams by P.B. Rohne, Jr. indicates low flows based on the
historic periods frctn February 1939 to September 1950 and February 1957 to
September 1963. Since the flow is now regulated by the Lake Monroe Dam,
the niinimum discharge of 50 cfs (32 MSD) is correct for Salt Creek and
consistent with the design parameters and management discharge program
for the reservoir.
2. Page 1-7 PCBs in the Winston Thomas STP System
This is discussed in Appendix G.
3. Page 2-3 Parks and Historical Sites
The Glenn A. Black Laboratory of Archaeology at Indiana University has
completed a reconnaissance survey and test excavation at the Dillman Poad
site. Their reports are in Appendix H. The conclusions of their test
excavation indicate that "project construction at the Dillman Poad location
will not adversely affect prehistoric cultural resources".
4. Page 2-3 Environmental Constraints
a. The proposed sewage treatment plant must be protected from a 100 year
flood event. Flood protection will be achieved by the construction of levees
as follows:
Site
Winston Thomas
South Roger
Dillman Road
Ketchum Road
Salt Creek
Upstream end
of site
680
676
624
603
515
Downstream end
of site
676
672
617
598
515
Average top
of dike
678
675
620
600
515
b. Impacts of infiltration through interceptor sewer line from Winston
Thomas to Dillman Road site.
To insure the integrity of the sewer system, test borings should be made
along proposed interceptor routes to assure adequate bearing capacity for
the line. With proper construction, infiltration or exfiltration along the
proposed sewer lines should be minimal.
As a rule of thumb, infiltration in a new sewer could be as great as
100 gallons per day per inch of pipe diameter per mile of pipe. Assuming a
42-inch diameter pipe, the infiltation would be:
6-115
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USEPA Response: cont. (To U.S. Department of Interior)
42" x 100 gal x 2 mi = 8 ,400 gpd
day-inch-mile
Assuming 15 MSD average flow, this would be less than one-tenth of one percent
of average daily flow.
5. Page 3-2-1 Evaluation of Pure Oxygen Process and
Page 3-5-1 Treatment Requirements
To determine the "worst case" concentration of unionized ammonia for Clear
Creek, the following parameters are important: pH, temperature, dilution ratio
and atmionia effluent discharge limit.
Values for the worst case are:
a. dilution ration = 0 (i.e. 7-day 10-year low flow = 0)
NH3 before - NH_ after
b. ammonia-nitrogen =1.5 mg/1
c. pH of treatment plant effluent
Effluent pH can be adjusted chemically, but in normal operations should
not exceed 7.4.
d. T = 70° F
\
Based on the article "The Percent Un-Ionized Armenia in Aqueous Ammonia
Solutions at Different pH Levels and Temperatures" by R.P. Trussell, Journal
Fisheries Research Board of Canada, Vol. 29, No. 10, 1972 pp 1505-1507, the
percent unionized ammonia for the worst case situation is 1.32% thus the
unionized concentrations is:
1.32% x 1.5 mg/liter = .0132 x 1.5 = .0198 mg/1
which is less than .02 mg/1 in the receiving
waters recommended as the maximum concentration
by DOI.
6. Page 3-6-2 Alternative 4
Reasons for the stream relocation (provided by Black & Veatch, consultant
to the City of Bloomington) are as follows.
If the stream is not relocated, the plant structures would be in two or
perhaps three separate conplexes separated by the creek. The resulting plant
layout would be very awkward. Increased lengths of piping would be required
and perhaps pumping heads for sludge and return waste lines would be higher.
The longer lengths of piping would result in more maintenance and in the case
of sludge lines, increased probability of clogging. The plant would be more
inconvenient to operate due to the separation of facilities. Increased operation
costs would result due to greater pumping heads and greater maintenance.
Increased initial construction costs would result from the greatly increased
pipe lengths.
6-116
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Since stream relocation is desirable, the following mitigative measures
are recommended:
a. Following the general mitigative actions discussed on p 4-11-5 of
the EIS.
b. A fish and wildlife mitigation plan shall be developed and implemented
for the Dillman Road site by the City of Blocmington in consultation with U.S.
Fish and Wildlife Service and the Indiana Department of Natural Resources.
7. Page 3-8-14 and 5-1 Conclusions and Recommendations
Landfilling is the method of sludge disposal recommended. Until the PCB
problem is resolved. Land spreading and/or composting of the sludge may be
practiced only if these alternatives can meet the standards promulgated by
Federal and state agencies. The nature, distribution and hydrologic prop-
erties of the soils that may be involved in land application as well as the
character of the leachate and long term impacts are beyond the scope of this
study. (See Draft EIS on Sludge Disposal and Land Reclamation in Fulton
County, Illinois, USEPA Region V, June 1976.)
8. Page 4-9-5 Aquatic Ecology
Literature indicates that most aquatic organisms should be protected if
the total residual chlorine in the stream does not exceed a level of 0.003 mg/1.
Typical dosage rates for chlorinating secondary effluents range from 2 to 8
mg/1. Total chlorine residual in the effluent (after 15 minutes detention) of
0.5 mg/1 should be sufficient for purposes of disinfection. Since the kill
(disinfection effectiveness) is proportional to the concentration times the
time of contact, the contact time could be increased and the dosage decreased.
If necessary, dechlorination can be practiced following chlorination, using
sulfur, dioxide or sodium bisulfate. (See Recommendation #8 page 5-2.)
9. Aquatic organisms found in Clear Creek
Further documentation concerning time and location of observations may
be obtained by contacting Dr. D.G. Frey at Indiana University in Blocmington.
The investigation upon which the table (9-2) is based was conducted under
the direction of Dr. Frey. Results of the investigations were loaned to
us by Dr. Frey and have since been returned.
6-117
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National Wildlife Federation
1412 16TH ST., N.W., WASHINGTON, D.C. 20036 Phone 202—797-6800
May 28, 1976
Mr. Harlan D. Hirt
Chief, Planning Branch
EPA - Region V
230 S. Dearborn Street
Chicago, IL 60604
Re: DEIS from South Bloomington and Lake Monroe Service
Areas, Bloomington, IN (C-l80560-01)
Dear Mr. Hirt:
We have received and reviewed the DEIS for the captioned
project. The draft appears to be quite thorough, particularly in
its discussion of alternatives.
We would, however, like to offer the following brief comments
for your consideration:
1) Page 2-3 of the DEIS indicate that the treatment facility
must be protected from flooding and that such protective measures
must not "result in excessive restrictions of the floodplain".
We assume that a portion of the service area embraces a
flood hazard area? If so, we would like some assurance that this
project will not serve to stimulate growth in the floodplain (see
Executive Order 11296, which calls upon you as far as practicable
to preclude the uneconomic, hazardous or unnecessary use of the
floodplain). Also, the list of agencies consulted (see page iii)
fails to list the Flood Insurance Administration as an agency
consulted. If the project involves a flood hazard area identified
under the Flood Disaster Protection Act, 40 C.F.R. 6.512(a)(3)(ii)
requires you to consult with the HUD regional office.
2) Page 4-9-6 of the DEIS states that there are rare and en-
dangered species in the area, but that "effects of construction
would be negligible in any site proposed" (our emphasis).What
secondary effects due to induced development, may be anticipated?
While the DEIS thoroughly discusses the possible secondary effects
of a regionalization alternative (not favored), the secondary impact?
of the recommended alternative are not. This concerns us. For
example, what type of areas will be affected by population growth,
how large will the population growth be, and what will be the
effects of this population growth on wildlife habitat in the
area?
6-118
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National Wildlife Federation
Mr. Harlan D. Hi rt
May 28, 197o
Page Two
We would appreciate your advice.
JML/cr
Very^truly yours,
JOHN M. LISHMAN
Wastewater Treatment/
Land Use Project
Resources Defense
6-119
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USEPA Response: (to National Wildlife Federation)
1. The final meeting on the 100 year flood plain map for Bloomington, Indiana
was held on June 1, 1976. A three month comment period is now in effect. (All
comments are to be directed to the City of Bloomington.) Following resolution
of all issues, an official map will be issued that delineates two areas:
a. The floodway area which is inundated by the 100 year flood and defines
an area of continuously moving water.
b. The floodway fringe - inundated by 100 year flood but is primarily
standing (or extremely slow moving water).
To participate in the flood insurance program the City of Blocmington must develop
land use controls restricting development in the floodway. Development in the
floodway fringe is permitted provided that construction and development are pro-
tected fron a 100 year flood. Although HUD was not listed as consulted on page
iii, of the Draft EIS, copies of the Draft EIS for Blocmington were mailed to
HUD offices. HUD also has been contacted by phone regarding the proposed
project. HUD did not submit any comments on the proposed projects.
2. The Dillman Road Site is situated so that it will encourage centralization
of sewer service for the south service area of the City of Blocmington. This
will minimize induced growth. The secondary growth impacts of normal develop-
ment include the change of land use from open fields and farmland to urban -
suburban uses, development of hones, apartments, and businesses which means
more roads, sidewalks, water, sewer and power lines. The net effect of this
development is to decrease the habitat for small animals. However, by central-
ization of sewer service the total area developed is minimized. The areas affected
by this growth will be in the South Service Area of Blocmington where connections
to interceptor sewers are made. The extent of population growth in the service
area is projected in Chapter 3 Task 1, (see p 3-1-25 for discussion of projected
land use around the Dillman Road site).
6-120
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STATE-
INDIANA
DEPARTMENT OF NATURAL RESOURCES
JOSEPH D. CLOUD
DIRECTOR
INDIANAPOLIS, 46204
April 14, 1976
f""- «—-
Mr. George R, Alexander, Jr.
Regional Administrator
Planning Branch - EIS Preparation Section
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
GV
>
tr
t-T
Dear Mr. Alexander:
The Draft Environmental Impact Statement for Sewage Treatment for the South
Bloomington and Lake Monroe Service Areas, Bloomington, Indiana, indicates
no known historic or architectural sites which will be affected.
The Draft Environmental Impact Statement does not include a report by the
Glenn A. Black Archaeological Laboratory. We ask that the recommendations
by the Black Laboratory, as outlined in their letter of September 9, 1975, be
followed and that an archaeological survey be done prior to construction.
Very truly yours,
). Cloud,
rector
jartment of Natural Resources
C:RG:jm
6-121
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STATEr
INDIANA
DEPARTMENT OF NATURAL RESOURCES
JOSEPH D. CLOUD
DIRECTOR
INDIANAPOLIS, 46204
May 17, 1976
Mr. George R. Alexander, Jr.
Regional Administrator
Planning Branch-EIS Preparation Section
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
RE: DNR #745, DEIS for Sewage Treatment Facilities, Lake Monroe and
South Bloomington, Monroe County
Dear Mr. Alexander:
The above referenced project has been reviewed by the Department of
Natural Resources and is satisfactory in regards to its effect on the
environment, including fish and wildlife resources and recreational
sites.
While no known historical or architectural sites will be effected by
this project, we suggest that any recommendations concerning archaeological
resources by the Glenn A. Black Laboratory be followed closely. We refer
you to our letter of April 14, 1976, addressing this matter.
We appreciate this opportunity to be of service. If we can be of further
assistance, please do not hesitate to contact me.
D. Cloud
irector
JDC:JEF:nm
USEPA Response: An archaeological survey and test excavation have been completed
for the Dillman Road site. The results indicated that "project
construction at the Dillman Road location will not adversely
affect prehistoric cultural resources". Reports on the survey
and test excavation are found in Appendix H.
'EQUAL OPPORTUNITY EMPLOYER'
6-122
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STATE-
INDIANA
STATE BOARD OF HEALTH
An Equal Opportunity Employer
INDIANAPOLIS
Address Reply to:
Indiana State Board of Health
1330 West Michigan Street
Indianapolis, IN 46206
April 28, 1976
Planning Branch-EIS Preparation Section
U. S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Sirs:
Re: Bloomington Sewage Treatment Facilities
We have reviewed the Draft Environmental Impact Statement for the
proposed Sewage Treatment Facilities for the South Bloomington and Lake
Monroe Service Areas in Bloomington, Indiana.
This project will be consistent with the Indiana Plan of Implementation
if the following conditions are followed:
1. That a proper program for dust control during
construction be followed using water sprays,
or other approved methods.
2. That no open burning be conducted without the
written permission of the Indiana Air Pollution
Control Board.
Very truly yours,
Harry D. Williams, Director
Air Pollution Control Division
WEM/sdp
USEPA Response: The Environmental Assessment submitted by the City stated that
the construction contract specifications will require construction
procedures and measures during construction which will minimize
adverse environmental effects. It will be the responsibility
of the City to ensure the specifications are so written and
subsequently enforced during the construction period.
6-123
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RAYMOND GRAHAM
3218 N. SMITH PIKE
BL.OOMINOTON, INDIANA 474OJ
R.P.E. 84O9 INDIANA
May 10, 1^76
Mr. Harlan B. Hirt
Chief, Planning Branch
U. S. Environmental Projection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 6060U
Re: Draft Environmental Impact Statement
Facilities for the South 31oomington and
Lake Monroe Service Areas, Bloomington,
Indiana U/U01
Dear Sir:
After reading the report I am sure someone from this area should point
out some of the parts of this report which need to be commented on.
A fifteen (15) mg/day plant will not be large enough to handle the sewage
of the Bloomington area in 1985. At present there are several areas in the
existing jurisidiction of the City that are not on a sewer system. Some of the
worst needed in the South Plant area are the Edgement Park Addition, the
Broadview area and the South Rogers Street area, the Sunset Hill and Allen Street
Garden acres and parts of Grandview , Clear Creek and the areas along Rogers,
Old State Route 37 and Walnut- Street road below Gordon Pike, the Moffat Lane
area and one large addition is also suitable for gravity sewers.
Of course in the North plant area interce )tibrs have not been built in either
Stoutes Creek or Griffy Creek. There is enought unsewered additions and de'iseiy
populated area to supply half of the North plant capacity at oresent with no
further development.
Also, an area for possible sewer to a South plant includes the State Road
U5 area South and West of \irport road to Stanford w;ich should be collected in
Indiab Creek Valley and pumped to a Clear Creek Line. This area is considerably
built up and has several more orcposed.
6-124
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RAYMOND GRAHAM
32IB N. SMITH PIKE
BLOOMINGTON, INDIANA 474O1
R.P.E. 84O9 INDIANA
-2-
South of Dillman Road in the Clear Creek and Little Clear Creek Watershed area
there IE over one thousand (1000) single residences on a count taken in November,
1975 plus the Pointe, The Fairfax and other recreational and carping sites.
The next thing that looks as though it has not been considered enough is
recommending any location in -he Clear Creek bottom. Both the Dillman and
Ketcham Road sites are solid rock within four (u) feet of the surfact, with a
limited width of valley i'or usable acreage, the Plant cost of construction for
rock removal should alone call for another location. It will be impossible
also to f^nd locations for sludge disposal in the immediate area.
Adding another five (5) million gallon per day effluent is going to cause
considerable damage to Clear Creek. At the present time Clear Creek averages about
sixty-five (65) feet wide and from two (2) to five (5) feet in depth, with the
solid rock bottom/ in any rainstorm the banks are going to be subjected to
considerable more erosion.
Any expansion at a later date would also have to expand the width of this
natural flume and cause considerable more damage than a single excavation which
will be covered in a grassy or weedy state and unnoticable within a few years.
I thought the prime purpose of the Environmental Protection Agency was to
clean up pollution. The Blcomington area could be amodel I'or other regions by
including the Lake Monroe Regional District for treatment at a lower cost of
ooeration and considerable less tax dollars than what it will cost to build
two (?) separate systems.
I am firmly convinced that any Engineering Consultant having amole time
to study the Bloomington area would have to favor the Salt Creek site. It is
supposedly, the responsibility of an Engineer tc give his client the most
6-125
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RAYMOND GRAHAM
3215 N. SMITH PIKE
BL.OOMINGTON, INDIANA 474OI
R.P.E. 84O9 INDIANA
-3-
offiecent and least costly recommendations possible. The Dillman site
operation and maintenance alone in the life of the Plant makes it more costly
to the users, even though initial costs are more at the Salt Jree'K site.
Before a disoosal plant is discarded several exoansions are alwys necessary
and with the limited site selected someone will have to either move the olant to
a new s.te or remove small mountains.
I believe the recommendation of the Di'.lman site is both bad on account of
cost and the unnecessary da- age that will be caused by the increased effluent in
Clear Creek and the effects of a later more costly move. I urge you to consider
both present cost and damage as well as future costs and damages before you g.i VP
your final decision.
Sincerely j
Si
<^X
Raymond Jra >am
Professional Engineer 8i;0? Indiana
Monree County Surveyor
6-126
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USEPA Response: (To Ray Graham)
The capacity of the proposed STP is discussed in Chapter 3 Task 1 and in responses
to Mayor McCloskey and Mr. Oral Hert. (See p 6-97 and 6-101.)
A 15 MGD capacity is a cost-effective capacity serve the South Bloomington Service
Area. Areas presently not sewered were included in the flow projections for the
20 year planning period whenever providing service was determined to be cost-
effective.
Table 1-3 (p 3-1-29) of the EIS indicates that the City Planning Ccnmission
projects a population increase of 2,030 people for the north service area
which is the equivelent of 200,000 gal/day or 0.2 MGD. the capacity of the
north treatment plant is 6 MGD with a present flow of 3 MGD including the
2 MGD division from the South Service Area.
With respect to the State Road 45 area, the area was included in population
projections as far west as the airport. The areas South of Dillman Road and
in the Lake Monroe district discussed in the Draft and Final EIS (see Chapter
3, Task 1, and Chapter 4 Task 10) sludge alternatives are evaluated in
Chapter 3 Task 8.
Adding 5 MGD effluent to Clear Creek should not cause considerable damage.
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 (see
p. 4-9-3). Therefore, an additional 5 MGD to the average flow of Clear
Creek should not cause any problems.
Extensive cost data for the alternatives has been developed and is presented
in Chapter 3, Tasks 6, 7, and 8 and Appendix F.
6-127
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THE IZAAK WALTON LEAGUE OF AMERICA
H003IER HILLS CHAPTER
BEDFORD, INDIANA
May 15, 1976
c/o My. Carroll Ritter
R.R.# 1
Mitchell, IN
Mr. Harlan D. Hirt, Chief
Planning Branch
United States Etvriromnental Protection Agency
Region Fire
230 South Dearborn Street
Chicago, IL 6060lj.
Dear Sir,
The Hoosier Hills Chapter of the Izaak Walton League of
America would like to comment on the Draft Environmental Impact
Statement for Sewage Treatment Facilities for the South Bloora-
ington and Lake Monroe Service Areas, Bloomington, Indiana.
The location of one plant at Salt Creek, some eight miles
south of the metropolitan area is proposed to provide service
for the Lake Monroe Regional Waste District. However, the
questions raised about such a site include whether the system
is economically feasible except to large developers, what the
second home market and recreational picture is going to be like
in the future, whether large developments will ever be constr-
ucted, and whether the decisions fit into a long range plan
for the area.
Although the Lake Monroe 201 plan assumed that all develop-
ments and population within the district would be served, the
EIS Consultant believes that it is almost impossible to predict
seasonal influx and resort prospects from available information.
Although the 201 plans assumed full developments, this is pre-
mature. The LMRWD 201 plan estimated 1,UOl|. household units,
but locations and economic feasilility of hooking on to a
regional line were not included, as was not the seasonal nature
of residents. Furthermore such data is needed because seasonal
population economics vary from permanent residential economic
patterns, arid water usage varies. Of the consultant's pop-
ulation estimate of 3»500 persons in the LMRWD or Service Area
or contiguous areas, a majority resided in older settled areas
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2.
not within the district's boundaries. The only concentration
of year round housing in the LMRWD was at Harrodsburg. Such
areas can be treated at the Ketcham or Dillman sites. Gilbert
Associates further believes that less than 2,500 persons reside
in areas of favorable density and location that warrant near
term sewerage service.
The Salt Creek site would have the most serious long range
environmental impact and would encourage leap frogging devel-
opments. Initial cheap land costs could draw said development
consequently driving up local land prices. Investors would be
second home or high rent apartment or condominium developers or
individual vacation home developers. Monroe CJounty planning
must continue to encourage current infrastructure development
to avoid encouraging leap frogging. Current rural residents
faced with influx of s ervice developments and consequent costs
to support new residents will be forced t» pay higher costs.
Concurrently, land speculators will drive up local land prices.
Development within the existing central growth area will be the
most economical in the long run.
A treatment plant at Salt Creek would require a long sewer
outfall of 13.U miles but since the discharge limits are less
stringent at this site than at the Clear Creek discharge points,
the overall effectiveness of treatment would be less expensive
for Monroe Countians. A two stage nitification process at the
Clear Creek sites would afford notification organisms protection
from sludge of toxic natfcre, high organic loads, and overflow.
Phosphorus removal is also enhanced. The Clear Creek sites
require two stage nitrification but the Salt Creek site requires
only single stage nitrification to meet standards. Cheaper, but
less effective. A greater burden for downstream intake purif-
ication. The two stage system would also be more reliable.
Clear Creek STP's would have then a double advantage: (1) more
effective treatment, (2) greater aeration travel distance
before reaching Bedford.
The sum advantages of the STP at Salt Creek appear to be:
(1) Cheaper site cost and energy less to run
(2) More land area available for site
(3) Greater dilution flow
(U) More land for sludge disposal (but less than 20 years)
The sura advantages of the Clear Creeks sites appear to be:
(1) Overall superior water quality of discharge
(2) Greater travel distance to Bedford
(3) Less cost for outfall
(if) Less environmental effects of outfall
(5) Beneficial effect on low flow of Clear Creek
(6) Superior reliability and high flow containment
(7) Meeting 1983 PL 92-500 requirements more clearly
Because of land requirements for disposal of sludge the
consultants recommended not using the Salt Croek site. Land
injection of sludge at the the Salt Creek site may contribute
to greater nitrate levels in Salt Creek after land flooding.
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This would need controlled through, rate of application after
careful studies. A Clear Creek site would be more efficient
in breaking up chlorinated organic compounds. The two stage
process would not only reduce the organic compounds, but per-
mit a longer travel time for natural degradation. A decrease
in chlorination would be possible, thus eliminating some chlor-
ine to the creek. A careful analysis should presently be
made to determine chromatographically the toxic organochlorine
compounds which may already be present in discharges. The
proposed plant should then be constructed with added capability
to render these harmless.
The regional waste treatment system as proposed by the
Lake Monroe Regional Waste District 201 plan may not be the
pivotal stimulus for lake developments but it should be
considered as a necessity for future development, especially 3n
light of PL 92-500. The system would benefit the large scale
developer. Before any further development occurs, a regional
plan should integrate carrying capacity, impacts on the lake
and contiguous areas, and social and economic impacts. Clear
separation must be maintained between public and private
interest*.
A regional sewer line around the lake would for the most
part cross open land. Too few developments are located close
enough to each other to merit one line. The actual determination
of developments is unsure, especially in the current economic
climate. The only existing development at this time which is
being completed is the Pointe. The fewer the users on a region-
al trunk, the higher the individual cost.
The need for a coordinated plan for future use of the lake
area is paramount. Several jurisdictions overlap and few if any
are coordinated. Such planning needs to reflect concern over
environmental and social impacts. Resource committments may be
irretrievable. Current responsibility for land use planning
lies with the Monroe County Planning Commission. The Lake
Monroe Regional Waste District has the utility planning and
development function , while the Monroe County Zoning Ordinance
has determined the zoning plan around the lake. The Inland area
has been zoned business but the sewer line to reach here would
cross Hoosier National Forest land. (However, Inland has withdrawn!),
The Forest Service has gone on record as intending to withhold
permission for the line to cross its property until an adequate
land use plan is in effect. Current zoning incongruities appear
to hare been influenced by considerations other than environ-
mental. The 16.5 square miles of residential zoning would permit
13,200 lots with on-lot sewers and septic tanks draining to un-
suitable soils. The soils around Lake Monroe are easily eroded
and sloping. Shallow soil depth to bedrock increases the chance
of septic reappearance. Since the present natural land condition
is predominantly woodland, any major alterations are bound to
affect it. As areas are developed more runoff will occur.
Increased boating on the lake will further cause bank erosion and
petroleum slicks. It is hoped that further environmental planning
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will curtail all these things.
The initial capital expenses in developing utilites for
lake developments may be very high. The type of residence and
yearly use will further determine operating costs for services
after development. Although apartment sturctures will hare
fewer children to send into the school system, other services
will be needed. The initial costs and operating costs for
services to any proposed developments need careful planning.
Even in cases where taxes paid may exceed service costs, the
total environmental impact must be the determinant factor for
development.
COHCLU3IOHS
Based upon the information and alternatives contained in
the draft EIS, March, 1976, the Hoosier Hills Chapter of the
Izaak Walton League of America endorses the Dillman Road site.
The site on Clear Creek is preferable for the reasons previously
stated. It is to be hoped that solutions could be found to j
eliminate re-routing Clear Creek for environmental reasons*
The Salt Creek site should be rejected for the following reasons;
(1) The overall quality of effluent would not be as good as the
Clear Creek site
(2) The efficiency of the Salt Creek plant is lower
(J>) The holding capacity for overburdened flows is less
(Ij,) The outfall distance and cost is greater and more damaging
(5) The site is prone to waterlogging
(6) The self purification distance before reaching Bedford is
shorter
(7) Future lake developments are questionable
(8) The regional line around the lake benefits large scale
development
(9) Alternatives for sewage processing are available from other
sites for Smithville, Sanders, Fairfax, and the Pointe
(10) A regional plan for the lake and county is not in effect
nor have long range plans considered all environmental,
softial, ecoaomic, and political relationships and goals.
(11) The Charles Wise survey of 1975 indicates user preference
for keeping the natural conditions in and developments out.
Respectfully,
Mr. Carroll Ritter
Chapter President
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USEPA Response: The City of Bloomington shall be required as a grant condition
to analyze by the gas chronatographic mass spectrophotometric
method the raw sewage and chlorinated effluent from the Winston
Thomas STP to identify toxic chlorinated compounds that may be
formed during the chlorination process. If toxic organochlorine
compounds are identified exceeding Federal or State standards,
a mitigation program shall be required to enable the effluent
to conform to State and Federal water quality standards.
The rerouting of Clear Creek is necessary according to Black
and Veatch, the design engineers for the City of Bloomingtonj
for the following reasons: see response to DOI comment #6
in Final EIS page 6-116 .
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CQRIS OF ENGINEERS COMMENTS: (COE)
General Comments
Both Clear Creek and Salt Creek in the vicinity of this project
will, on July 1, 1977, come under the jurisdiction of the Louisville
District, U.S. Army Corps of Engineers. Any of the proposed
project alternatives will require a Department of the Army Permit
pursuant to Section 404, PL 92-500, for the discharge of dredged
or fill material below the ordinary high water elevation of Clear
Creek or Salt Creek.
The Draft Environmental Impact Statement appears to be more of a
design and economic analysis rather than an examination of envi-
ronmental impacts. An insufficiency of information is noted in
various areas and is discussed in both general and specific
comments.
The "proposed action" for this statement is unclear. The summary
sheet indicates the proposed action to be a 15 MGD sewage treat-
ment plant at the Dillman Road site with no mention of a connection
with the Lake Monroe Regional Waste District. Chapter 1 identi-
fies the applicant's action as a 20 MGD sewage treatment plant
at the Salt Creek site, serving both the South Bloomington Service
Area and the Lake Monroe Regional Waste District. This discrep-
ancy between the EPA view of the proposed action and the local
utility view should be resolved. ~
Response; The proposed action that EPA is recommending is the
construction of a 15 MGD facility. It is anticipated that the
City of Bloomington will amend their facilities plan to propose
construction of a 15 MGD STP at the Dillman Road site instead
of a 20 MGD STP at the Salt Creek site.
Comment; (COE)
A diagramatic layout of plant facilities for each site alternative
would be very helpful for reviewers of this document with key
locational features, such as highways, railroads, and streams,
indicated to provide reference points.
Response; This will be provided by the City of Bloomington when
a diagramatic layout for the proposed 15 MGD STP at the Dillman
Road site is available.
Comment; (COE)
The information provided to characterize the existing environment
for the treatment plant alternative sites, for Clear Creek and
for Salt Creek, is considered inadequate since it provides only
a regional characterization and indicates no detail as to the
characteristics of each alternative site and each stream. This
lack of characterization does not allow a review of this document
to understand the present conditions or reasonably review the
impacts anticipated for each alternative.
6-132b
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Response; The comment is noted and is responded to in the more
detailed comments that follow.
Comment: (COE)
There appears to be a major discrepancy in the 1974 average daily
flow at the Winston Thomas Treatment Plant which is mentioned in
numerous locations. The stated value in most of the text is 11.2
MGD while the Technical Appendix (Table V-3) indicates that the
flow meters showed a substantial error and corrected 1974 average
flow at the Winston Thomas Plant was 8.45 MGD. This discrepancy
should be resolved.
Response; This discrepancy is discussed Appendix A pages A-9 to A-15
CORPS OF ENGINEERS COMMENTS: (COE)
Specific Comments
Chapter 1, - This does not provide an accurate characterization
of the proposed project; the proposed action is unclear. The
elements necessary for this wastewater treatment plant are not
listed. A flow diagram for the proposed plant would also be
helpful at this point in the DEIS so that reviewers can under-
stand the proposed action. Since all alternatives appear to
require stream rechannelization and flood protection, this also
should be described in detail at this point of the EIS, to the
extent that they are adequately described, not merely to mention
that they are necessary.
A listing of all Federal and state permits necessary to construct
and operate a new wastewater treatment plant should be included.
Response; The summary sheet page i identifies the proposed action.
Chapter 1 is a background chapter and follows EPA's Manual for
Preparation of Environmental Impact Statements ... Waste Treatment
Management Plans, Office of Federal Activities, USEPA, July 1974.
A flow chart for the proposed Dillman Road STP is presently not
available. A listing of all Federal and state permits necessary
to construct and operate a new wastewater treatment facility is
not considered to be an environmental issue in this EIS and
therefore is not included in the document.
Chapter 2, - The discussion provided in Chapter 2, the environ-
ment without the proposed action, provides only a regional
characterization of the alternate project locations. This
should be supplemented with an in-depth discussion of the exist-
ing environment for each alternate site considered for the
wastewater treatment plant, the sludge disposal sites and the
effluent receiving streams.
This discussion should include, but not be limited to, a site-
specific discussion of the existing soils and geology, including
construction limitations such as shallow bedrock, erosive soils,
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wet soils, and seismicity; a thorough discussion of the existing
flora and fauna for each potential project area should charac-
terize the mammals, amphibians, reptiles and birds typically
occuring as well as a listing of floral species represented at
each site; a discussion to characterize the aquatic floral and
faunal species known to occur in Clear and Salt Creeks, with
sampling locations at various points in the streams to provide
an accurate representation of species distributions and popu-
lations at numerous locations;- a discussion to clearly charac-
terize the streams involved in, this project, to include mean,
minimum and maximum stream flows for both Clear and Salt Creeks,
floods of record, and an accurate representation of the existing
water quality, with adequate sampling to characterize the present
streams including at least BOD, DO, turbidity, hardness,
alkalinity, temperature, pH, conductivity, nitrates, phosphates,
heavy metals, chlorinated hydrocarbons, fecal coliforms and
total coliforms,; and a thorough discussion of socio-economic
elements involved at each alternative project element location
including archeological field and literature surveys, field
reconnaissance to determine if any structures of possible
historical or architectural significance will be involved,
a discussion of paleontological resources that may occur, a
statement regarding whether the National Register of Historic
Places has been consulted for the alternate project areas should
be included, a characterization of the land use at each alter-
nate site, a discussion of population characteristics at each
site location, in particular, those which will require displace-
ment of persons for project purposes, a discussion of local
employment patterns, and a narrative to describe the local
aesthetic characteristics for each site alternative and both
streams.
Response: Chapter 2 is a regional characterization of the
environment without the proposed action. The details requested
above are generally contained in Chapters 3-6 of the EIS and
in the appendices and are addressed concurrently as the issues
on Page 1-10 are evaluated.
Comments; (COE)
Chapter 3, - Task 1 does provide a short description of several
of the project alternate sites in Section 1.4.4 but his dis-
cussion should be expanded to reflect the information that has
been suggested as addition to Chapter 2 or incorporated directly
into Chapter 2 if the proposed action is to be a range of alter-
natives rather than a specific site.
The summary provided in Section 1.4.1 needs several terms defined.
It describes the Winston Thomas site to possibly be the best site
with respect to serving the "near term urban growth". This term
should be defined and compared to the anticipated population
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growth and given a time frame for reference. A similar definition
should be given for the term "long term viewpoint" applied to the
Dillman Road, Ketcham Road and Salt Creek sites.
Response; Near term urban growth is the present up to 10 years
in the future. "Long term viewpoint" is the time frame beginning
in 15-20 years and beyond. Population projections are detailed
in Chapter 3, Task 1.
Comments; (COE)
Section 1.4.1 also indicates that the Ketcham Road and Salt Creek
sites could be disruptive to the existing land use pattern by
encouraging urban sprawl. The Dillman Road site may also con-
tribute to sprawl and "leap-frogging" and should be included
in the discussion.
Response; The Dillman Road site is approximately 2 miles down-
stream from the Winston Thomas STP. The Dillman Road site retains
centralization of sewer service while allowing for normal growth
in the service area to be sewed by gravity interceptors rather
than a force main system (see Chapter 3 sections 6.1.4 and 6.1.5).
We do not feel that construction of a sewage treatment plant at
the Dillman Road site would be a significant factor causing sprawl
and "leap-frogging" in the Bloomington area.
Comments; (COE)
Task 3, Renovation and Expansion of Winston Thomas Sewage Treat-
ment Plant, indicates that phased construction of new facilities
along with demolition and renovation of existing facilities would
require that effluent standards could not be met at all times.
A definition of the 30-30 standards should be provided to indi-
cate whose standard this is. A definition of "could not be met
at all times" should be included to indicate peak ranges of BOD
and SS levels and the anticipated lengths of time that these
levels may be elevated.
Response; The 30-30 standard is the interim requirement established
by the Indiana State Board of Health through the NPDES permit.
If the Winston Thomas site were chosen, renovation and expansion
via phased construction is recommended by Black & Veatch. While
it is difficult to specify exact changes in treatment efficiency
as construction proceeds, as units initially go off-line the
treatment efficiency decreases until new facilities become oper-
ational.
Comment: (COE)
Task 6, present Worth Analysis, discusses alternative with a
heavy emphasis on economic factors. Only few points of environ-
mental concern are raised, most typically stream relocation, and
they are discussed in terms of actions rather than impacts. In
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view of CEQ guidelines, this and following discussions related to
alternatives are considered inadequate.
Section 6.1.5 discusses alternate interceptor design and timing
for both the South Rogers Street and the Winston Thomas site.
No information is provided on the existing force mains and pumping
stations that presently serve the Winston Thomas Plant. If these
mains and pumping stations are inadequate, this should be stated.
If these existing facilities will be adequate for the near future
and can be utilized to handle anticipated future growth, this also
should be discussed. It appears that few alernate interceptor
routings have been examined. Those that have been examined are
"creek-bottom" routings and do not utilize the existing force
mains that presently serve the southwest and southeast portions
of the service area. The reasons for assuming the need to
construct new southeast and southwest interceptors should be
included.
Response; Figure 6-1 shows the existing collection facilities in
the south service area. The two pump stations which would be
abandoned with construction of a southeast and southwest inter-
ceptor are labeled #1 and 3 respectively. It should be noted
that this EIS does not state that these lift stations should
be abandoned but rather identifies that it is a possibility in
10 or 15 years depending on growth of the area. The present
plan for these pump stations was discussed in the 1972 Long
Range Plan for wastewater collection and treatment facilities
for Bloomington, Indiana prepared by Black & Veatch. Exerpts
from that report follow:
1. Southeast Lift Station
The lift station pumps flow from the southeast trunk sewer
to the south plant. The lift station is equipped with two
electric motor driven pumps, each rated at 2.0 mgd. The third
pump is equipped with a gasoline engine drive, and has a rated
capacity of 3.7 mgd. Firm capacity (with the largest unit out
of service) is 4.0 mgd. Maximum flow rates are slightly less
than firm capcity, and overloading is anticipated in the near
future.
2. Southwest Lift Stations
The two lift stations handle wastewater flow from the south-
west trunk sewer. The lower lift station discharges directly to
the south plant, and has two 6.0 mgd pumps for a firm capacity
of 6.0 mgd. The upper lift station has two electric motor driven
pumps, each rated capacity at 2.4 mgd. The third pump has a
gasoline engine drive and a rated capacity of 4.8 mgd. The
station has a firm capcity of 4.8 mgd. Maximum rates of flows
are approaching the firm capacities of the stations.
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3. Southwest Interceptor Sewer
The proposed southwest interceptor sewer could provide service
to 3,650 acres in the southwest drainage area. The proposed sewer
will be 30-inches in size and will have a capacity of 14.1 mgd
(see Plate 2).
At present flow from the upper half of the southwest drainage
area is pumped eastward into the south drainage area. Completion
of the southwest interceptor sewer will permit abandonment of the
upper lift station.
Completion of the interceptor sewer is desirable in the near
future because flow from the tributary area is approaching the
firm capacity of the upper lift station. However, if financial
limitations require postponement of interceptor sewer construction,
service lift on the lift station can be extended by installing
larger pumps.
4. Southeast Interceptor Sewer
The proposed southeast interceptor sewer would serve a total
of 8,760 acres, including 7,095 acres in the Jackson Creek water-
shed by gravity. Flow from 1,665 acres in the Salt Creek valley
could also be pumped into the southeast drainage area. The pro-
posed sewer would be 30 and 36 inches in size with a design
capacity of 28.9 mgd.
At present flow from the upper half of the southeast drainage
area is pumped into the south drainage area. Completion of the
interceptor sewer will permit abandonment of the southeast lift
station. The flow from the tributary area is approaching firm
capacity of the lift station. It appears that the firm capacity
will be exceeded before the proposed sewers can be completed.
Therefore, it is virtually certain that the service lift of the
lift station must be extended by installing larger pumps. Con-
struction of the interceptor sewer could then be postponed until
justified by development downstream from the lift station.
Note: Before EPA will participate in funding the southeast and
southwest interceptors in the future, it must be demonstrated
that it is the most cost effective alternative to providing
needed sewer service for the area.
Comments: (COE)
The analysis of present worth for providing sewage service for
Smithville and Sanders (Section 6.6) includes only treatment at
the Dillman Road site or the Caslon Treatment Plant. Since this
is the only discussion of alternatives for these communites, it
would seem appropriate to discuss the potential for utilizing
the Winston Thomas, Ketcham Road or Salt Creek sites, particu-
larly since the local applicant favors including the Lake Monroe
Regional Waste District into a Salt Creek site treatment plant.
The discussion of present worth for routing Smithville and Sanders
wastewater to Caslon should be combined with the present worth
estimate for Fairfax since it is a likely contributor to the
Caslon plant.
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Response: The Facilities Plan for the LMRWD is not completed and
EPA will require that additional alternatives be evaluated. The
site selected for the new STP for the south service area is not
affected by the sewerage needs of the LMRWD.
The reasons for selecting the Dillman Road site for the South
Bloomington service area is evaluated in this EIS. Intercon-
necting Fairfax and Caslon is an ongoing task that was funded
without EPA participation and represents a sunk cost.
Comments; (COE)
Task 1, the distribution of costs for the treatment of wastewater
from Smithville and Sanders should be altered if the present worth
analysis suggested above for other treatment sites (Task 6) shows a
more economical alternative.
It would appear that this task would be the likely place for a
further discussion of cost distribution. The costs (monthly,
yearly, etc.) to individual users should be spelled out. An
indication as to the economic impact these alternative plans have
on the average homeowner in Bloomington, Smithville, Sanders and
any other area included in these plans would be useful informa-
tion to reviewers of this document.
Response; The comment is noted approximate projects costs are
identified in Chapter 7. User charges are established by the City
during the Step 3 construction phase of the project.
Comments; (COE)
Task 8, the discussion provided in this section on sludge treatment
and disposal is an engineering and economic discussion. There was,
however, no discussion provided of the environmental consequences
of each of the alternative techniques in the narrative. Since
composting, soil injection, agronomic spreading and landfilling
are all possibilities, the impact of each on soils, surface water
quality, ground water quality, aesthetics, and terrestrial and
aquatic flora and fauna should be included.
Several discrepancies in the sludge production calculations have
been found. The influent BOD and SS appears to be low in light of
fluctuations of unknown origin (page A-l) in BOD and SS levels
historically. It is suggested that a higher, more conservative
figure be used. The BOD and SS removal efficiencies should be
97.5% removal for Clear Creek plants. The effluent BOD and SS
for Clear Creek should reflect the 5 mg/1 requirements for both.
These factors may well represent a need for revision in total
sludge production and disposal costs.
The recommended sludge disposal method is indicated on page 3-8-5.
It should be noted if this is an EPA, Region V recommendation or
one made by Gilbert Associates, Inc.
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Response; It shall be a grant condition that any sludge disposal
alternative meets all applicable Federal and state laws. Specific
sites recommended for landfilling or land application of the
sludges are not identified in this EIS. It shall be the respon-
sibility of the City of Bloomington to identify which alternatives
or mix of alternatives they are going to pursue. (Grant conditions
see Chapter 5.)
If land application is chosen, a sludge management program will
have to be developed. This program will have to meet both Indiana
and USEPA criteria. Environmental factors for sludge application
have been published in the June 3, 1976, Federal Register.
Impacts of applying sludge to farmland is extensively discussed in
EPA*s draft EIS, Sludge Disposal and Land Reclamation in Fulton
County, June 1976. Although the 95% removal figure was used to
calculate sludge quantities instead of 97.5%, the difference is
less than a 3% error while the accuracy of population projections
can vary 10-15%. Therefore, no revisions to sludge disposal and
production costs are necessary.
The recommendation on page 3-8-15 is an EPA recommendation
Comments; (COE)
Task 9, the environmental impacts from the construction and oper-
ation of the proposed wastewater treatment plant do not adequately
address the potential adverse effects that are likely to occur.
The suggestion that "the ecosystem of the area will be adversely
impacted during construction and operation of the proposed waste-
water treatment plant only if mitigative measures recommended in
Task 11 are not practiced" is speculation that cannot be entirely
accepted. Since no adequate characterization of the existing envi-
ronment has been provided for any of the potential wastewater
treatment plant sites, sludge disposal sites or effluent receiving
streams, there is no reasonable way for1 reviewers of this state-
ment to know if any of the mitigative measures are necessary or if
a substantially enlarged list of mitigative measures would minimize
all or some of the potential impacts.
No assurances are provided t6at any or all of the mitigative
measures will be carried out. Some indication should be given
as to the probability of these measures being implemented, such
as, including them as conditions of permits or in project con-
tract specifications.
Response; See Chapter 5 Conclusions, Recommendations and Grant
Conditions.
Comments; (COE)
Section 9.1.1, General, indicates that Table 9-1 compares physical
impacts by alternative sites for the wastewater treatment plant.
This tables does not compare impacts, rather it lists a number
of actions which each alternative will require. The impacts of
each of these actions should be discussed to, at least, the same
degree that engineering and economic concerns are discussed. A
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similar analysis of actions and impacts should be included in
this table for the sludge disposal alternatives.
Response; The impacts of the action are addressed in the body
of the EIS.
Comments; (COE)
Section 9.1.2, Aquatic Ecology, should provide a discussion of
potential adverse conditions in Clear and Salt Creeks during
construction phases, followed by a discussion of the floral and
faunal species which will be impacted and the extent of each
impact. The rerouting of Clear Creek will cause stresses to
aquatic populations because of disturbance, siltation and in-
creases in stream temperatures. These impacts due to stream
relocation are more than length-only dependent. The stream
bed material, existing water quality and riparian vegetation
are only several of the features that need to be examined.
No mention has been made of replacing riparian vegetation on
relocated stream channels. The suggestion that Clear Creek will
recover based on several historical devastations provides no
quantitative or qualitative proof that this has occured. Since
no information is provided to characterize Clear Creek, it is
not known if past alterations of Winston Thomas Plant have
changed species composition of Clear Creek.
Response; See Conclusions, Recommendations, and Grant Conditions.
Comments; (COE)
The impacts of operation on the aquatic ecology mentions that
"the physical effects of the effluent will depend on where the
outfall is located and the degree to which the sewage is treated".
Given the expected levels of treatment at each alternate location;
these impacts on the aquatic flora and fauna should be discussed.
This seems to have been omitted in this section. The discussion
of canoeing seems inappropriate in this section on aquatic ecology
and should be included in a section on recreation. The discussion
of concentration of pollutants from other sources in Clear Creek
should be enlarged. It has been indicated that some water quality
problems were more severe above the existing Winston Thomas Outfall
than below, on a specific date, indicating a possible dilution
effect by the effluent. A discussion should now be provided to
describe the relative water quality impacts if the treatment plant
and outfall are moved further downstream. It is recommended that
these conditions be field checked to indicate if they presently
occur since the information is over 5 years old and changes in
the relative quality of the outfall for this time period were
not indicated.
The April 12, 1975, sampling for nitrates should include a refer-
ence as to the location of the sample stations for each sample,
rather than only list the stream name.
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The discussion of chlorinated organics should include a definitive
statement regarding their occurance in Winston Thomas Plant effluent
and at various locations in Clear and Salt Creeks, including
Bedord's water intake. A smapling program of these streams would
provide this information and its inclusion in further refinements
of this document would be helpful for reviewers to determine if
this problem is occuring and to what extent mitigative measures
indicated can resolve the problem.
The environmental impacts of alternative methods for sludge dis-
posal should be addressed in this portion of the DEIS. No mention
has been made of potential effects of each of the alternate
techniques proposed. Since a thorough discussion of economics
of alternate methods has been included in Task 8, an equally
thorough examination of the environmental effects of land spreading,
soil injection, composting and landfilling should be included in
the next edition of this document.
Section 9.1.3, Terrestrial Ecology, discusses rare and endangered
organisms. The effects of construction are subjective since no
indication of their existance has been provided. The description
of the Indiana Bat's habitat requirements does not mention summer
roosting in trees. No indication of consultation of state lists
of rare, endangered or threatened species is listed.
The impact of the proposed development on terrestrial ecology is
not adequate since it only discusses outfalls and interceptors and
not impacts related to wastewater treatment plant construction.
The disruptions caused by the construction of a new plant would
be definite impacts and, without characterization of the existing
sites, ace impossible to disregard. The discussion of impacts
caused by interceptor construction is speculative since no
description of environmental setting is provided in previous
portions of this document. The type of vegetation that will be
destroyed should be listed, with particular attention provided
to rare, endangered, or threatened plants and any relict plant
communities which would be affected. A discussion of potential
revegetation impacts along the right-of-way should be included.
None of the species listed in Task 11 are found in the lists in
Table 9-3 of probably occuring species. The impact on wildlife
habitat of introducing non-native species should be discussed.
The techniques intended to be used for maintaining interceptor
right-of-way should be indicated. If herbicides will be used,
their potential environmental impacts should be discussed. The
terrestrial species listed in this section indicate nothing other
than game species. Further refinements should indicate those
speices existing on project sites and potential impacts.
The aquatic organisms listing provided in Table 9-2 (those found
in Lake Monroe and expected in Salt Creek) should be enlarged
to differentiate between those species known to exist in Lake
Monroe and those expected in Salt Creek. The two different
aquatic ecosystems would obviously not support identical species
6-141
-------
and population densities. A similar table should also be provided
that lists the aquatic organisms known to exist in Clear Creek,
since this is the stream that will likely be receiving primary
impacts from wastewater treatment plant construction, stream
channelization an continual effluent outfall.
Several other major areas have been omitted in the discussion of
environmental impacts. No discussion has been provided regarding
human displacements that would be required by alternative site
development. A narrative should be included that discusses the
numbers of persons that would be directly displaced at each alter-
nate project site and those in the immediate ricinity of each site
that would receive secondary effects from construction and opera-
tion activities. This portion of the D1IS does not discuss impacts
related to cultural resources that would be affected by develop-
ment at each site. Each alternative location should be surveyed
for historic and prehistoric features and anticipated impacts
associated with project development should be discussed. A
survey of existing literature should also reveal any cultural
features that are known'and would be affected. No discussion
has been provided regarding the impacts associated with the
abandonment of the Winston Thomas Plant. A narrative should
be provided to fully describe the impacts of abandonment,
demolition of the existing plant and the ultimate disposition
of the property which Winston Thomas Plant is located on.
A discussion should be included concerning the environmental
desirability of returning Clear Creek to its pre-Winston Thomas
flow levels. A quantitiative assessment of siltation which will
be caused by construction would be helpful to reviewers. Blast-
ing areas should be identified and impacts on critical habitat
areas and secretive species should be listed. A discussion of
the relationship of Cedar Cliffs Preserve to proposed project
alternatives should be included to determine relative impacts
of each alternative. A narrative to describe flood plain
restrictions and resultant flow levels caused by the wastewater
treatment plant should be included.
Response; In general the EIS does address the questions which
are asked above. We do not find it necessary to address all
comments to the level of detail requested by the Corps of
Engineers in order to assess the significant impacts of the
proposed project.
Comments: (COE)
Task 11, Mitigative Measures, provides some good ideas for
lessening some impacts caused by the proposed project. No
indication is given whether any will be required for the project.
If none are required, no assurances can be given that these
measures will be carried out.
Response; See Chapter 5, Conclusions, Recommendations and Grant
Conditions.
6-142
-------
Comments; (COE)
Chapter 5, Conclusions and Recommendations, provides no indi-
cation regarding whether these conclusions and recommendations
are Gilbert Associates' or Region V, EPA. A clear distinction
should be made in this chapter of this point in subsequent issues
of this statement. Those recommendations included in this section
that will be conditions of permits granted should, be noted. Those
recommendations that will not be conditional in any permits should
include a discussion concerning why they will not be conditions.
Response; The text of the EIS including Chapter 5 represents
the views of EPA on the proposed project. Grant conditions are
identified in Chapter 5.
Comments: (COE)
Chapter 6, Comments and Participation, could include a listing of
agencies and parties who received copies of this statement. Pages
6-32 to 6-35 provides an evaluation of the Gilbert Associates
report (which seems to be the body of this document) by Black and
Veatch which appears to indicate deficiencies in the DEIS. Areas
of conflict or inaccuracies reported by Black and Veatch should
be resolved.
Response; The Final EIS identifies in Chapter 6 all comments
received on the DEIS. Issues raised by Black & Veatch have been
responded to by EPA.
6-143
-------
v.vsp1 '"* • . ,., 7,
^•T^O^'^^ •'
-*__ , n-ij.-i p-.-iC.^^ I *.:. ij. '
• •-^^-^^We---5-^--
" . - 'r ^ - - V • g '^?T
- "I X;'- V":l^
-•i"- -^- ---^¥4.,: ^U---" ..
- L ••'- ^r<:j- ^'
™fr-—4 :r'' ^v-X^'
j -••,--. "•-1 '! -^X-'-r^-y
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PLATE 4
DEMAND CENTERS-
LAKE MONROE AREA
2000
H
Lt IN FE
-------
L E SEND
INTERCEPTOR OR TRUNK SEWER
FORCE MAIN
f . '
POTENTIAL SOI.L INJ
~! LANOSPKEAOINO AREA
SdU-O-GE V| r-
-------
-- I *V 'jvy
NOhTH.SEB-VtM r~"\"
,.
'I -AflEA i'^I-"-!
"~
v^?;>f3Sf£-,V{4.--;
s^^m
PROPOSED TRUNK SEWERS OR INTERCEPTORS
EXISTING FORCE MAIN OR TRUNK SEWER
EXISTI NG FAC ILITY
PROPOSED FACILITY
/, TO BE ABANDONED BY 1990
FM FORCE MAI N
PLATE 2
EXISTING a PROPOSED SEWAGE
TRANSMISSION 8 TREATMENT FACILITIES
SOUTH SERVICE AREA
-------
I-'.F^.:
•tV'r ,/-
-r,:^-u^",<—
t t.-!' t-5-- ••• -If -' S t
[,-p*/ ';--'--i<-\^
L: VlS^-^ f-r^^-^rN
7rV. -i >;%- J^>'-
~ .^"-j
^•'i -''- ,i; ,T-V'' ': - >---!• •-?*
ti^*£:«ii-''- -^v'jk'^l.'y,^/;';'-o-'- - -"
ALTERNATIVE REGIONAL SEWAEE
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
1971
1973-74
BOD5
125
164
SS_
89
187
BOD5
196
137
SS.
261
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
Date
1973
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sep.
Oct.
Nov.
Dec.
1974
Jan.
Feb.
Mar.
Apr.
May
BOD
105
172
200
160
140
110
150
158
171
147
205
139
158
199
201
201
165
SS '
103
185
106
140
70
73
75
136
200
165
431
234
227
217
261
314
243
DO
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
Total
Phosphate
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
Chlorides
53
43
37
42
45
37
40
36
40
43
47
72
59
59
50
46
Alkalii
120
250
200
206
199
113
186
180
160
180
167
171
153
152
A-2
-------
Table IV-2 ' ' *
RAW WASTE CHARACTERISTICS
WINSTON.THOMAS PI»ANT
Date
1973
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sep.
Oct.
Nov.
Dec.
1974
Jan.
Feb.
Mar.
Apr.
May
BOD
185
366
150
96
95
70
105
106
127
129
153
118
108
114
136
133
128
SS DO _gH
166 " 5.2 7.3
174 5.4 7.3
130 6.8 7.4
81 .5.7 7.0
110 """ 3.8 7.0
98 3.7 7.1
88 3.0 7.0
165 2;5 7.0
180 2.6 6.8
174 2.8 7.0
223 5.1 7.0
155 4,8 7.0
113 6.4 7.2
137 3.9 7.2
157 8.0 7.0
164 5.2 6.7
159 4.7 7.0
Phosphate Chlorides Alkalinitv
«.*'." ' i
. ?-. ••. c--
3.3 55
2.4 49
5.3 45
3.3 45
6.3 41
4.9 46
5.5 44
7.5 34
4.9 44
3.5 57
2,7 95
3.2 67
2.9 56
4.0 51
10.8 46
+ f >t
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 Tahle 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 bee» obtained by the City and are recorded
in Table IV-4.
A-4
-------
Table IV-3
CHEMICAL ANALYSES - RAW WASTE (WINSTON THOMAS PLANT)
All results in mg/1
Date
1973
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
Ni
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
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
Zn
0.16
0.47
1.99
0.34
0.59
0.60
0.86
0.42
0.47
0.33
0.21
0.17
0.24
0.40
0.35
0.25
0.18
O.'ll
0.11
0.13
0.55
0.50
0.43
Mg
7.6
7.1
7.6
6.6
8.37
8.1
8.1
8.7
8.8
8.4
11.2
10.26
9.44
9.44
9.4
8.6
10.7
9.2
9.1
9.2
8.9
9.7
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 POOLED
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
(fflg/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 BOD
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/1)
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/1)
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-15 of this appendix for correction of flows due to
inaccurate metering devices.
A-8
-------
LIT DF BLDDMINGTL.J UTILITIES
P. D. BOX 1216
BLDDMINGTDN, INDIANA 474D1
TELEPHONE AC 812 339-2241
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.
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
MMPrjf
Attachment
cc:F. Beatty,/Black & Veatch
G. Kenti
File
A-9
-------
, r 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:
(Cj^ (QL) 1440 min/day
u CD 3785 ml/gal
Where: CD •» downstream concentration Li mg/1
Ql «= flow of injected stream ml/min
C^ «* 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
-------
'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
-------
CITY.QF BLQOMiNGTDN UTILITIES
P. D. BDX 1216
BLDDMINGTDN, 'INDIANA 474 D1
TEUPHONE AC 812 339-2261
June 14, 1976
Mr. Dale Luecht
Environmental Protection Agency
Region V
230 South Dearborn
Chicago, Illinois 60607
Dear Mr. Luecht:
According to our telephone conversation of June 9, 1976,
I have enclosed the information on the flows going to the
South Treatment Plant that you requested.
This reflects, as best as we can tell, the actual flows
at the Winston Thomas Plant. This allows for the raw sewage
meter adjustments made first July 31, 1974 and for the final
adjustment made May 6, 1975.
If you have any questions please contact me at 8Y2-339-2261
Extension 201.
Very truly yours,
Michael M. Phillips"
Assistant Director of Utilities
MMP/d
cc: Paul K. Coulter
Black & Veatch
A-12
-------
•;ONTH
JANUARY
FEBRUARY
MARCH
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
JANUARY
FEBRUARY
MARCH
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
,','OVLMBER
DECEMBER
'
PRECIP.
3.83
2.61
•* 4.78
2.56
7.06
3.72
1.47
6.36
8.39
1.22
4.52
2.94
4.12
L
5.16
4.59
6.70
3.65
3.53
5.47
1.51
3.61
3.28
6.12
3.50
4. 5'6
• 4.30
1974
X
tf
*
W.T.
FLOW
7.7
7.2
8.8
8.0
6.9
6.4
4.5
5.5
9.7
8.1
10.3
10T0
7.8
1975
8.7
9.5
10.6
8.7
6.8
7.7
5.6
6.3
8.0
8.7
9.1
9.J?
8.3
A-13
*
B . P .
FLOW
2.6
3.4
3.9
3.7
2.8
2.0
1.6
2.7
3.2
2.4
-1.8
2.3
2.7
3.6
3.3
3.1
3.0
2.2
2.5
2.2
3.1
3.0
2.8
3.0
2 . 3
2.4
*
TOTAL
U . T . & B . P .
10.3
10.6
12.7
11 .7
9.7
8.4
6.1
8.2
12.9
10.5
12.1
12.3
10.5
12.3
13.0
13.7
11.7
9.0
10.2
7.8
9.4
11.0
11.5
12.1
11.8
10.7
-------
19.76
* * *
W.T. B.P. TOTAL
MONTH PRECIP. FLOW FLOW W.T.& B.P
JANUARY 2.06 9.8 2.4 12,2
FEBRUARY -• 1.90 10.1 3.0 13.1
MARCH 4.54 7.9 3.2 11.1
APRIL 1.00 7.2 2.7 9.9
MAY 4.02 6.1 2.6 8.7
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER -
2.23 8.2 2.8 11.0
A-14
-------
Discussion of Existing Flows at Winston Thomas STP
As identified in Chapter 1, the First Amendment to the Facilities
Plan prepared by Black & Veatch, December 1975, indicated that
the existing flow at the Winston Thomas plant in 1974 was 10.9
MGD + 0.3 MGD for unmetered diversions to the tertiary lagoon
making the total flow 11.2 MGD. The indicated average daily flow
was 10.9 MGD for 1974 after analyses and adjustment for the low
meter readings prior to recalibration. (The 1974 recorded average
flows were 8.4 MGD prior to analyses and adjustments.)
Since the preparation of the 1st Amendment by Black & Veatch
and the Draft EIS, additional adjustments have been made to
the flow meter at Winston Thomas and these latest figures
have been reflected on pages A-12 through A-14 of Appendix A.
The uncertainty in these figures is difficult to determine
since the flow meter has been adjusted by the manufacturer
several times between July 31, 1974, and May 6, 1975. Each
time the meter has been shown to be in error. Mike Phillips
who calculated the latest revised flows stated that the con-
fidence of the numbers is difficult to determine. One could
estimate that these latest figures could be in error 5-10%.
(The flow meter was put in service in 1969 and is designed to
record flows in excess of 20 MGD with an accuracy of 2%.)
Using the June 14, 1976, flow estimations^the existing flows
for 1974 and 1975 are 9.1 MGD and 9.4 MGD respectively. This
was determined in the following way. The highest 8 months in
each year were summed and averaged and 0.3 MGD was added to
each average for the unmetered diversion contribution to the
tertiary lagoon.
Given the uncertainty of the adjustment of the metering device
at Winston Thomas STP during the periods of 1973, 1974, and
1975, and the conflicting flow reports provided by the City
of Bloomington to date, it is the opinion of USEPA that exact
historic flows cannot be developed. If the lower figures
recently provided this agency, are substituted for 11.2 MGD
the resulting design flow change would be approximately 1.5
MGD depending on the uncertainties one assigns to population
projections for the year 2000, the design flows, and the land
use changes that may occur in part of the LMRWD service area
which could be tributary to the Dillman Road STP. Since this
discrepency equates to approximately 10% of the projected
design flow, and since the City of Bloomington has indicated
concern that the facility will be smaller than what they will
require, we find no compelling reason the change the recom-
mendation to construct a 15 MGD facility at the Dillman Road
site.
A-15
-------
D. Sludge Composition
CITY DF BLDDMINGTDN UTILITIES
P. D. BOX 1216
BLDQMINGTQN, INDIANA 47401
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:
2.
Cu
Cr
Fe
Ni
Cd
Zn
980
585
5940
282
29
430
Winston Thomas sludge which is now picked
up by the public for use in gardens and
composting is about 65% solids.
Blucher Poole sludge composition in mg/kg
dry weight:
Cu
Cr
Fe
Cd
Ni
Zn
690
82
2900
23
55
380
Blucher Poole sludge used for injection is
about 870 solids. That used for land appli-
cation is about 207<> solids.
A-16
-------
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.
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
RSPijf
Enclosure
cc: J. Quin, Gilbert Associates
G. Kent, Blgtn. Utilities Director
F. Beatty, Black & Veatch
File
A-17
-------
PURDUE UNIVERSITY sou TESTING LABORATORY - - AGRONOMY DEPARTMENT - - LAFAYETTE, INDIANA - - AES FORM 400
KC-2
SOIL TEST REPORT
for
r~
Richard S. Peoples
City of Blooaington Utilities
Box 100
Blooaington, Indiana 47401
L_
1A6/74
A COPY OF irilS REPORT HAS BEEN SENT TO
Monroe COUNTY EXTENSION OFFICE.
AN EXTRA COPY HAS BEEN SENT TO:
IDENTIFICATION
LAB
NUMBER
9549
9550
FIELD
NUMBER
1
1
Mr. Pi
extrac
plant.
lor yt
Chemii
r*l— • -»-
Total
NUTRIENT RECOMMENDATIONS *
N
IBS/A
P7 05
IBS/A
((,0
IBS/A
HO RBOOMMENDATIOH
REQUESTED
• - • *•
oples: —
tions" of soils t
that
ur purposes r you are
ts' office for nitorg
nitrogen- is not -a pax
— —
— —
— —
LIME
Italy
is.
more
anit<
-2-fc
t of
SOIL TEST RESULTS
SOIL-
BUFFER pH
-
-
to be
inter
i. Ta
i obCa
rooti
SOU-
WATERjH
7.4
7.0
It dui
rated
i won!
1% OQi
w sol
IBS. / ACRE
PHOSPHOIK
_.oS^
915
1080
SWpp
licatc
in tot
d reqx
9AWt=¥*1
1 ana]
POUHIIW
. .01^
210
210
H /«
mitrl
al N-E
ire a
tionn
ysis.
CALCIUM
}
ent reno
-K as re
private
<— ^--^-~
Xfl ^2PH& bU
See pri
nl^^^. *•
Soil Te
MAGNISIUM
ral by
torted
.ab fox
rsgitr MJ
2*k & ssi i
:e list
iting I
% ORGANIC
MAHCR
the gi
by the
this
enclc
aborat
IIPOR1ED WHIN REQUESTED
COLOR
4
4
i
Owl!
Sti
wor'
sed
ory
TEX-
TURE
5
5
>g
ite
»•
r%t /T
*NUTRIENT RECOMMENDATIONS HAVE BEEN PREPARED
FOR THE CROP YIELDS REQUESTED ON YOUR CROPPING
HISTORY FORM. IF NO CROP YIELD LEVELS WERE LISTED,
THEN STANDARD RECOMMENDATIONS WERE WRITTEN,
THAT IS, FOR 125 BUSHEL CORN, 40 BUSHEL SOYBEAN,
50 BUSHEL WHEAT, 70 BUSHEL OATS, 6-TON ALFALFA, OR
4-TON RED CLOVER.
INFORMATION ON METHODS OF FERTILIZATION FOR EACH
CROP ARE DISCUSSED IN YOUR SOIL TEST REPORT EX-
>LANATION SHEET.
40TE: SOIL-BUFFER pH, THE BASIS FOR LIME RECOMMEN-
>ATIONS, IS ONLY USED WHEN THE SOIL-WATER pH IS
ELOW 6.6. LIMING RATES INCREASE AS THE SOIL-BUFFER
, H DROPS BELOW 6.8.
MEANING OF SOU TEST RESULTS
SOIL
TIST
LEVEL
rat tow
LOW
MEDIUM
HIGH
VERY HIGH
P. PHOSPHORUS TEST
fOR CORN.
SOYBEANS
IBS. P/A
0-10
11-70
21-30
3H5
ABOVE 4S
FOR WHEAT, OATS,
PASTURE LEGUMES
ETC IBS. P/A
0-10
11-20
21-30
31-70
ABOVE 70
POTASSIUM TEST
ALL
FIELD CROPS
IBS. K/A
MO
81-150
151-210
211-300
ABOVE 300
A-18
F
-------
E. EFFLUENT LIMITS FOR THE PROPOSED SOUTH BLOOMINCTON STP.*
BOD
30 day average
7 day average
per cent removal
Suspended Solids
30 day average
7 day average
per cent removal
Phosphorus
maximum
br
per cent removal
Salt
Creek
Site
10 mg/1
95%
10 mg/1
95%
1.0 mg/1
80%
Fecal Coliform Bacteria
30 day geometric mean 200/100 ml
7 day geometric mean AGO/100 ml
pH Range 6.0-8.5
* NH^ limits are on p. A-17.
Clear
Creek
Site
5 mg/1
97.5%
5 rag/1
97.5%
1.0 mg/1
80%
200/100 ml
400/100 ml
6.0-8.5
A-19
-------
STATEr
INDIANA
3TREAM POLLUTION CONTROL BOARD
INDIANAPOLIS 46206
1330 West Michigan Street
633-5467
XXX 5467
January 31, 1975
Mr. Gary R. Kent
Director of Utilities
City of Bloomlngton Utilities
P. 0. Box 1216
Bloomlngton, Indiana 47401
Dear Mr. Kent:
Re: Nitrification Requirements for Potential
Bloomlngton Wastewater Treatment Plant Site*
In response to your letter of January 9, 1975r concerning the effluent
ammonia nitrogen limitations for Bloomlmjton's potential wastewater treatment
plant sites, the following limits have been established:
BOD
SS
NH3- N
Summer
Winter
Existing Site or
S. Rogers St.
(0;1 Dilution Ratio)
5 mg/1
5mg/l
1.5 mg/1
3.0 mg/1
Ketcham Road
(0:1 Dilution Ratio)
Salt Creek
(1.6:1 D.R.) (2.1:1 D.R.)
mg/1
mg/1
10 mg/1
10 mg/1
10 mg/1
10 mg/1
1.5 mg/1
3.0 mg/1
6.5 mg/1 7.9 mg/1
The 1.5 mg/1 NH3-N limitation 1s based on the best practicable technology and the
other Ntfo-N limitations are based on a maximum allowable toxldty concentration of
2.5 mg/1 with 1.6 X unionized NH3 1n the stream. The 1.6:1 dilution ratio 1s based
on a 20 mgd facility and the 2.1:1 dilution ratio 1s based on a 15 mgd facility.
The more rigid requirements for ammonia nitrogen limitations were outlined 1n
a letter dated October 21, 1974, from Region V, U.S. EPA In connection with Issuance
of NPDES permits. The cities of Connersvllle, Crawfordsvllle, New Castle, Richmond,
and Warsaw have similar restrictions.
A-20
-------
•2-
Mr. Gary R. Kent January 31. 1975
If you have any more questions concerning this matter, please do not
hesitate to contact this office.
Very truly yours.
Oral H. Hert
Technical Secretary
MAScherer/Jam
cc: Black and Veatch
A-21
-------
-------
Appendix B
AQUATIC ECOLOGY-LAKE MONROE
A. GENERAL INFORMATION
The situation and shape of the Monroe Reservoir appears
in Figure 4.1. The area of the lake watershed is approximately
1008 Km2 or 420 square miles, with about 80% of the runoff
entering the lake through the three forks of Salt Creek
(Figure 4.1). Docauer (1972) compares the population, settle-
ments, urban development, etc. of the three major forks of
Salt Creek (Table 4.1). Most available information concerns
the North Fork of Salt Creek drainage system for the following
reasons: (1) Nashville and its associated tourist attractions
coupled with inefficient sewage treatment facilities; (2) relative
size of the drainage system (almost equal to the combined areas
of Middle and South Forks); and (3) relative accessibility
to the University.
The effects of Nashville's sewage plant effluent can be
seen in Table 4.2 from McAhron's (1972) survey of North Fork of
June 19, 1972. A relative decrease in efficiency of BOD removal
can be seen in Table 4.3 for the influent and effluent of the
sewage plant spanning the years of 1968, 1970, and 1972.
More recently, Nelson (1974) sampled from March 19 to
June 26, 1974, from six stations at regular weekly intervals
to determine the actual characteristics of the North Fork water
and its variation with discharge, seasonal effects, and location.
A partial summary of her findings (Table 4.4) tends to show the
following: (1) during high flows, before fertilization, the
B-l
-------
Aquatic Ecology
Figure 4.1; Lake Monroe Basin and Watershed Map showing the
permanent water sampling stations.
MORQAN CO
MONROE CO
r
JOHNSON CO.
MONROE RESERVOIR WATERSHED MAP
BARTHOLOMEW
CO
JACKSON CO
SPRAVTOWN
4-*WMMl.,.
B-2
-------
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Aquatic Ecology
B-3
-------
Aquatic Ecology
stream maintains a high dissolved oxygen concentration and a
dilution of nutrients; (2) after a peak flood on April 9, dis-
charge then decreased; (3) after field fertilization began,
obvious station-to-station variations became evident. Nutrient
load, conductivity, etc. increased and the oxygen concentration
decreased downstream. One might notice that the effects of the
Nashville sewage plant appear masked in the overall dilution
effect. However, when the water gauge reading becomes available
from Nashville's gauge, the weekly discharge information will
be related to nutrient concentration.
Docauer (1972), in Table 4.6, shows the fate of total
phosphate from Nashville to the causeway within the lake. The
spring and summer data show first the effects of dilution (spring)
and also the possible increase of effluent nutrients from the
Nashville plant during the tourist season of June-July.
A survey of the chemical and physical aspects of the three
tributaries of Salt Creek is shown in Table 4.7 for October 2 and
29, 1974. The effects of discharge on concentration is apparent
particularly at station #2 on Green Valley Road, two miles below
the Nashville plant. Notice, however, that less total phosphate
and soluble reactive phosphate is reaching the upper basin (#6)
during this extremely low flow than reported by Docauer's Tables
4.5 and 4.6. Much utilization occurs removing these nutrients.
Interest in the upper reaches of the South Fork at #3 and
#4 stations is due to the extensive farming practices present in
B-4
-------
Aquatic Ecology
this area. Middle Fork is of special interest since it is
forested with less farming. It will serve as a "control"
system in the upper head waters.
Since about 80% of the volume of yearly discharge occurs
during the late winter, spring, and early summer, there is a need
to concentrate most heavily on the interrelationships between
nutrient loading and discharge at this time (Lee, 1969). Like-
wise, the overall pollution of non-point source loading needs to
be investigated, since recent information shows that non-point
sources are considerably greater than formerly thought (Loehr,
1974). Possible methods for controlling or decreasing the non-
point sources may need to be considered.
B. PHYSIOGRAPHY OF LAKE MONROE
Monroe Reservoir is a shallow basin-shaped lake with a
mean depth of 3 to 4 meters. The old Salt Creek channel meanders
across the bottom as a 7 to 11 meter trench. The lake is divided
into three distinct basins (Figure 4.1). The upper basin above
the causeway is a shallow (3-5 meter mean depth) basin with
approximately 1927 hectares area of lake surface. This basin
receives the water from the three tributaries of Salt Creek.
The middle basin lies between the causeway and the down stream
narrows (station #5) and has an approximate mean depth of 5-6
meters. The lower basin extends downstream to the dam and has
B-5
-------
Aquatic Ecology
Table 4.2:
Survey of North Fork Salt Creek near Nashville, Indiana
State Board of Health
All concentrations in parts per million (ppm) except
fecal coliforms.
Station BOD
100 meters 1.5
Above
Sewage
Plant
76 meters 4.6
below
Sewage
Plant
3.2 Kilo- 1.7
meters
below
Plant
4.83 Kilo- 1.6
meters
below
Plant
7.2 Kilo- 1.6
meters
below
Plant
June 19, 1972
From McAhron
Table 4.3:
Nashville Sewage
Surveys
Date and Station
June 6, 1968
influent
effluent
efficiency
August 16, 1970
influent
effluent
efficiency
June 19, 1972
influent
effluent
efficiency
Dissolved PO.-P NCU-N NH^-N
Oxygen
7.3
6.0
5.0
5.1
5.0
•
(1972) .
4 J -3
0.1 0.1 0.2
1.4 0.2 0.4
0.5 0.3 0.4
0.4 0.3 0.3
0.4 0.4 0.3
Plant, Brown County Indiana—State
All
B.O.D.
490
120
75.5%
570
290
49.8%
350
260
25.7%
concentrations in ppm.
Total PO.-P Suspended
29
37
-27%
500
160
68%
48
43
10.4%
Fecal Coli- Total
forms-*/ Solids
100ml.
90 110
20,000 170
11,000 100
386 110
290 110
Board of Health
Solids Total Solids
850
600
29.4%
880
760
13.6%
910
710
21.9%
June 6, 1968, August 16, 1970 (Hall 1971) and June 19, 1972
(McAhron 1972) .
B-6