905R82111
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
WATER DIVISION
230 S. DEARBORN ST.
CHICAGO, ILLINOIS 60604
OCTOBER, 1982
FINAL
vvEPA
RESPONSIVENESS SUMMARY
FOR
PUBLIC MEETING AND WRITTEN COMMENTS
ON THE REPORT ON
COMBINED SEWER OVERFLOW FACILITIES PLANNING
FOR THE
DETROIT WATER AND SEWERAGE DEPARTMENT
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McNichols Combined Sewer Overflow Gates
located in the City of Detroit, on the
Rouge River. Shown during dry weather.
Constructed in two segments of three
barrels each. Barrels measure 9 feet, 3
inches square in the left segment, and 11
feet by 11 feet 9 inches in the right
segment - each.
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905R82111
RESPONSIVENESS SUMMARY
FOR
PUBLIC MEETING & WRITTEN COMMENTS
ON THE REPORT ON COMBINED SEWER
OVERFLOW FACILITIES PLANNING
FOR THE
DETROIT WATER AND SEWERAGE DEPARTMENT
Prepared By
U.S. Environmental Protection Agency
Jim Novak, Project Manager
and
ESEI, inc.
Peter Swinick, Project Manager
October, 1982
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TABLE OF CONTENTS
TOPIC PAGE NO,
Introduction 1
Public Meeting Notification 7
Summary of Issues Raised 13
Comment Letters Received , 19
Public Meeting Transcript 61
List of Public Meeting Attendees 95
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INTRODUCTION
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INTRODUCTION
One of the major elements being covered by the Detroit Waste-
water Final Facilities Plan was combined sewer overflow (CSO).
An environmental impact statement (EIS) was prepared concurrent-
ly with facilities planning. A finding of the July 6, 1981 Fed-
eral District Court Order, was that the parties (DWSD, MDNR, and
U.S. EPA) have agreed to suspend further CSO facilities planning,
but that U.S. EPA and MDNR wish to reserve their rights to peti-
tion the court in the future for further relief on CSO control.
CSO facilities planning was suspended June 25, 1981. This plan-
ning culminated with the preparation of the Alternative Facili-
ties Interim Report (AFIR).
Since the AFIR was not comparable to a Final Facilities Plan and
identified no alternative for implementation, there was techni-
cally no longer a need for the EIS to address CSO. There was,
however, a need for a detailed overview of the planning that was
completed. The Report on Combined Sewer Overflow Facilities
Planning was generated in response to this need and had four
major objectives:
1) To review and summarize the combined sewer overflow
planning that was accomplished up to the time of
suspension,
2) To evaluate water quality improvements estimated for
the alternatives,
3) To independently evaluate the procedures used in
facilities planning, and
4) To provide a basis from which a resumption of the
CSO planning can proceed.
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It should be noted that this document was not intended to
explain or generate any decision or set any policy on the CSO
planning. Its overall objective is to facilitate future CSO
planning.
The CSO Report covered many technical and non-technical sub-
jects which collectively brought planning accomplishments into
focus. These subjects included:
Section 1 - An introduction describing the purpose
and scope of the report,
Section 2 - An historical account of previous planning,
Section 3 - A description of the existing facilities,
Section 4 - A description of the sewer system transport
model and the model generated CSO flows and
loadings,
Section 5 - A description of the receiving water models,
model outputs and model generated "existing"
water quality estimates,
Section 6 - A description of the alternatives development
procedure leading to the 25 CSO Alternatives
plus the Future-No-Action and Existing Condi-
tion Alternatives. Also, the CSO site selec-
tion methodology and results are described.
Section 7 - A summary of water quality improvements esti-
mated from modeling outputs.
Section 8 - A description of the facilities plan evalua-
tion methodology used to rank the 25 CSO
Alternatives and identify the "few best".
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Section 9 - A summary of revisions made to the alterna-
tives between publication of the Preliminary
and Final AFIR's.
Section 10 - A critique of the evaluations and the find-
ings of the AFIR.
Section 11 - Recommendations of the report (when CSO
Facilities Planning resumes):
1. Alternatives for consideration should include, but
not be limited to: maximization of system storage
and best management practices; and transfer of flows
from the Rouge River Basin to the Detroit River
Basin.
2. Consider how to address CSO planning problems caused
by upstream pollution sources. The procedure should
include a detailed review of "208" data and all CSO
planning data developed to date to redetermine if
sewer overflows are a major problem in the Rouge
River Basin. Coordination of present and future CSO
planning from the headwaters to the mouth would also
be desirable.
3. The concept of spending to the point where marginal
benefits equal marginal costs (dB/dC = 1) may be un-
affordable. Future CSO control planning should con-
sider a spending level where the marginal benefits
exceed the marginal costs (dB/dC > 1).
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4. Several improvements at the System Control Center
(SCC) will maximize the usage of in-line storage for
CSO control.
These include:
a) Verification of the in-line storage volumes and sub-
sequent modification of procedures and equipment to
ensure their utilization.
b) Evaluation and refurbishment, where necessary, of the
SCC computer system hardware and software to ensure
proper collection, storage, and processing of sewer
system operational data.
c) Evaluation, cleaning, replacement (if necessary) and
recalibration of all field sensors to ensure that
accurate signals are being transmitted to the SCC com-
puter.
d) Development of a preventive maintenance program to
increase reliability of the critical components of
the SCC and the field sensors.
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PUBLIC MEETING NOTIFICATION
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PUBLIC MEETING NOTIFICATION
1. Notice of the Public Meeting was Published in;
A. Detroit News on 7/11/82
B. Detroit Free Press on 7/11/82
C. Local Newspapers on 7/19/82
2. Notice of the Public Meeting was mailed to 2700 interested
parties on 6/21/82.
3. One photostatic copy of the Document was placed in each
of ten Detroit area libraries on 6/22/82 and 6/23/82.
4. One original copy of the Document was placed in each of
ten Detroit area libraries on 7/8/82.
5. Over 150 copies of the Document were distributed by request
between 7/19/82 and 9/1/82.
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN ST
CHICAGO ILLINOIS 60604
NOTICE OF PUBLIC MEETING
REPLY TO ATTENTION OF
5WFI
Region V of the U. S. Environmental Protection Agency will hold a Public Meeting
on Wednesday, July 21 at 7:30 p.m. at the Henry Ford Centennial Library Audito-
rium, 16301 Michigan Avenue, Dearborn, Michigan to discuss the Report on Combined
Sewer Overflow Facilities Planning for the Detroit Water and Sewerage Department.
This report was prepared to summarize and review all Combined Sewer Overflow
(CSO) facilities planning to date and to provide a conceptual framework for CSO
planning when it is resumed. Copies of this report are available for your in-
spection at the following locations:
Baldwin Public Library
351 Martin
Birmingham, Michigan 48021
Attn: Ms. Lee Tuttle
Troy Public Library
510 W. Big Beaver Roac
Troy, Michigan 48084
Attn: Mr. Joseph Howey
Beacon Memorial Public Library
45 Vinewood
Wyandotte, Michigan 48192
Attn: Ms. Tinsley
Detroit Public Library, Main Library
5201 Woodward
Detroit, Michigan 48202
Attn: Mr. Dance
Henry Ford Centennial Library
16301 Michigan A,venue
Dearborn, Michigan 48126
Attn: Ms. Fran Delaney
erely yours,
Wayne State Universtiy, Purdy Library
Room 130 •
Detroit, Michigan 48202
Attn: Dr. Vern Pings
Bloomfield Public Library
1099 Lone Pine Road
Bloomfield Township, Michigan
Attn: Mrs. Bamberger
48013
Wayne Oakland Library Federation
33030 Van Born Road
Wayne, Michigan 48184
Attn: Ms. Dolores Hayden
Detroit Public Library, Downtown
121 Gratiot
Detroit, Michigan
Attn: Mr. Dance
SEMCOG Library
800 Book Building
Detroit, Michigan 48226
Charles H. Sutfin
Director, Water Divisiion
If you would like a personal copy please fill in the information requesTelT~D^low,
fold, staple, and mail (no postage is required if mailed in the United States).
Name
Street Address
City, State & Zip Code
10
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»»
SSfcsSM
COME TO
at the
Henry Ford Centennial
Library Auditorium,
16301 Michigan Avo.
Dearborn, Michigan
7:30 p.m.
Come to a discussion of the findings
of the Combined Sewer Overflow
Report issued by EPA as part of the
Detroit Water and Sewerage
Department's facilities planning
work. For further information call
ESEI, inc.; 313-961-3940.
Please note: This meeting was
rescheduled from the previous date
of May 26, 1982.
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SUMMARY OF ISSUES RAISED
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SUMMARY OF THE ISSUES RAISED
AT THE PUBLIC MEETING
ON THE
REPORT ON COMBINED SEWER OVERFLOW FACILITIES PLANNING
FOR THE DETROIT WATER AND SEWERAGE DEPARTMENT
The major issues raised by participants at the special meeting
on the Report on Combined Sewer Overflow Facilities Planning
for the Detroit Water and Sewerage Department are summarized
below. The response of USEPA to these issues is also briefly
summarized. A transcript of the meeting, including the presen-
tation, all questions and all responses is included in a later
section of this Responsiveness Summary.
Issue: Why was the recommendation of basin-wide planning
made by the Citizen's Advisory Committee (CAC)
omitted from the recommendations chapter of the
report?
Response: The Report recommends coordination of all facil-
ities planning work completed to date in the Rouge
Basin (a coordinated approach). The USEPA, however,
cannot dictate how the State of Michigan will con-
duct its water quality planning or how it will pri-
oritize its projects. Thus, basin-wide planning is
ultimately a state responsibility. Also, to imple-
ment basin-wide planning, some agency would have to
be designated as the "grantee" and currently none of
the participants, except the State, has authority
over the entire basin.
Issue: Is the USEPA and the City of Detroit setting a pre-
cedent for future CSO planning by suspending work on
the Detroit Facilities Plan?
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Response: No precedent was being set. The Detroit Facilities
Planning was suspended - not terminated - by the
July 6, 1981 Federal Court Order. (For elaboration
see Public Meeting Response by Novak on page 70.)
Issue: Wayne County had commissioned a study of the effects
of CSO's on the Upper, Middle, and Lower Branches of
the Rouge River. The preliminary findings indicate
that background water quality can be improved. Can
the DWSD Rouge River water quality models be rerun
to simulate the impact of cleaner background water
quality on the Rouge River alternatives for the
Detroit area?
Response: One of the recommendations in the USEPA report was
to integrate all of the information that has been
generated by the facilities planners in the Rouge
Basin.
Issue: Lake Erie has not improved since USEPA began to
implement facilities planning and DWSD has not
assisted in the lake's clean up.
Response: The USEPA has assisted DWSD to significantly reduce
the amount of pollutants from the treatment plant to
the Detroit River and thus ultimately to Lake Erie.
In fact for the past year, for example, the treat-
ment plant has been reporting an average concentra-
tion of phosphorus in the effluent below the 1.0 mg
per liter limit in the permit.
Issue: Does the Report on Combined Sewer Overflows consti-
tute official USEPA policy regarding CSO planning in
Detroit?
16
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Response: The document is not a policy statement but simply a
summary and commentary on the facilities planning to
date.
Issue: Shouldn't SEMCOG, as the regional planning agency,
coordinate all water quality planning?
Response: SEMCOG reviews the facilities plans after they have
been completed. SEMCOG is not in the position of
directing facilities planning.
Issue:
Is the report issued in final version at this time?
Response: The report is a final report, but a responsiveness
summary (this summary) will be prepared to address
all issues or questions raised at the public meeting
or sent to USEPA.
Issue: There were serious omissions of data and references
in the report, (Ph.D. or Master's Theses generated
in conjunction with the water quality modeling).
Response: The Responsiveness Summary can be expanded. (Sub-
sequently, a bibliography has been included in the
Responsiveness Summary.)
Issue: The most serious water quality problem is in the
Detroit River and not in the Rouge River as stated
in the special report. Considering that there are
18 bathing beaches and 60 marinas downstream of the
treatment plant, Lake Erie itself should be a major
concern.
Response: The Responsiveness Summary will include any further
elaborations and commentary that is contributed.
17
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Issue: The City of Allen Park may be required to spend 60 •
100 million dollars for sewer separation, for the
same water quality problems that USEPA is recommend-
ing that the City of Detroit take no action. The
same methodology and conclusions should be applied
to Allen Park as to Detroit.
Response: The Report on CSO does not recommend no action.
Facilities planning was suspended and no conclusion
on CSO was reached.
18
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COMMENT LETTERS RECEIVED
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COMMENT LETTERS RECEIVED
The following section is arranged to show the comment letters
on the left side page and the response to individual comments
directly to the right on the right side page.
21
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(Ettg of Alirn Park
OFFICE OF THE MAYOR
FRANK J. LADA
16850 SOUTHFIELD ROAD
ALLEN PARK, MICHIGAN 48101
PHONE: 928-1400
July 20, 1982
U.S. Environmental Protection Agency
Office of Grants and Administration
Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Re:
Gentlemen:
Report on Combined Sewer Overflow Facilities
Planning for the Detroit Water and Sewerage
Department
The City of Allen Park appreciates the opportunity to
comment on the "Report on Combined Sewer Overflow Facilities
Planning for the Detroit Water and Sewerage". We have a special
interest in this report for two reasons.
1. A portion of Allen Park is served by the Detroit
system, and, therefore, our residents are affected by any
changes in capital and 0 & M expenditures.
2. The remainder of Allen Park is served by a combined
sewer system, for which a Facilities Plan has been prepared,
coming to diametrically opposed conclusions to your report.
Our general comments on the above report are as follows:
1. The conclusion of the report, which is based on
extensive modeling and analysis, indicates that little or no
activity relative to combined sewer overflows is warranted at
this time. Particularly, in regards to the Detroit River over-
flows. Allen Park agrees with this finding, generally, and has
found, that using nearly the same methodology of analysis, that
for a similar, but smaller, combined system in Allen Park that
little or no action will result in the most reasonable solution
there, also.
22
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RESPONSE
As a point of clarification, the Report on CSO does recommend further
evaluation of potential improvement to the System Control Center. No
other activity is recommended at this time since facilities planning was
suspended, but this in no way should be construed to be equivalent to a
recommendation of No Action. On the contrary, a recommendation of the
"No Action" alternative would require completion of the Facilities Plan
as would the recommendation of any "Action" alternative.
23
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U«S. Environmental Protection Agency - July 20, 1982 - Page 2
2. We find it ironic and tragic that EPA is encouraging
the expenditure of about $60 million to $100 million for sewer
separation in Allen Park (about $5,000 - $8,500 per household
with all its disruptive and destructive effects) while the sewer
separation alternatives in the Detroit study area ranked amongst
the poorest choices of the 25 evaluated. The cost of the high-
est ranking alternatives in the Detroit report are $130-145 per
capita. How can EPA/DNR justify the extreme disparate treatment
to different portions of the same small City?
3. Allen Park believes that the basic recommendation,
that when planning is resumed, that primary consideration be
given to in-line storage and inter-basin transfers is appro-
priate. Allen Park would like to submit that similar finding
should be applied to that portion of the City of Allen Park
served by the Wayne County system.
4. Allen Park requests that the EPA/DNR consider these
findings and bring uniformity to CSO planning in the southeast-
ern Michigan area, or at least Allen Park, before $60 million to
$100 million is wasted on sewer separation in Allen Park. We
suggest that EPA/DNR take proper action to alleviate this
serious discrepancy.
5. Allen Park agrees with the finding that there is a
need to look at the overall collection and treatment system in
detail before a conclusion can be reached. This was not done in
the City of Allen Park and has led to erroneous conclusions.
Our specific comments on this report will be submitted
in writing in the next few weeks.
Again, we appreciate this opportunity to comment and
strongly urge EPA/DNR to act to bring about uniformity on CSO
planning in southeastern Michigan, before a major misappropria-
tion of public funds is made. Since it currently appears that
24
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RESPONSE
2. A finding of the July 6, 1981 Federal District Court Order was that the
parties (DWSD, MDNR, U.S. EPA) have agreed to suspend further CSO
facilities planning, but that U.S. EPA and MDNR reserve their rights to
petition the court in the future for further relief on CSO control.
The suspension of Detroit's CSO facilities planning effort was primarily
due to the questionable status of future federal funds to construct CSO
control facilities. Further expenditures for facilities planning would
prove unwarranted if construction never occurred, or if it occurred years
from now under different conditions. Under the present situation of
limited funds, while it is still necessary to meet the requirements of
the Clean Water Act, the project priority system mandated by the Act
determines the allocation of funds within the State. At this time, CSO
projects generally are not ranked high within the priority system. On
the other hand, the decision to obligate funds for the Ecorse Creek pro-
ject, of which Allen Park is part, was made under different (lesser) fund-
ing constraints. The funds have already been made available for the
Ecorse Creek project, quite a different situation than an evaluation of
planning in light of the December 1981 amendments to the Clean Water Act
and corresponding regulations which means a general reduction in funds
for CSO projects.
The "disruptive and destructive effects" of sewer separation is a factual
determination to be made for each project.
The total cost for the Ecorse Creek project is approximately $65 million,
of which 75 percent or $48.8 million is funded by a federal grant; 5
percent, or $3.2 million by a state grant; and the remaining 20 percent,
or $13 million by apportionment among the four communities within the
Ecorse Creek basin (Lincoln Park, Taylor, Dearborn Heights, and Allen Park)
3. The Ecorse Creek project has an approved facilities plan, construction
in the other communities is substantially complete, and a Federal Court
has ordered the grantee to complete the remainder of the project within
Allen Park. Accordingly, non-final facilities planning in Detroit cannot
be compared to the project in Allen Park.
4. See Response for Item 2.
5. The Allen Park project was evaluated in light of its role in solving the
water pollution problem within the Ecorse Creek basin along with the other
communities. Accordingly, the proposed project was to effect water
pollution control as an overall system. The water quality improvements
by completed work in the other communities cannot be realized until the
full system is complete.
25
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U.S. Environmental Protection Agency - July 20,1982 - Page 3
EPA/DNR intend to pursue the wasteful sewer separation project
in Allen Park, we request that some indication be given now by
these agencies that a rational policy will be pursued.
Yours truly,
Frank J. Lada
Mayor for the City of Allen Park
cc: Mr. Richard Hindshon
Grants Administration
Department of Natural Resources
Mr. Charles N. Youngblood
Wayne County Drain Commissioner
Mr. John D. Dingell
Congressman of the 16th District
Mr. Valdaz Adamkus
U.S.Environmental Protection Agency
Region 5
Ms. Ann Gorsuch, Director
U.S. Environmental Protection Agency
Ms. Janis Bobrin
AWQB Coordinator
SEMCOG
26
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RESPONSE
Again, it should be noted that the federal district court has ordered the
grantee and the City of Allen Park to complete the project in Allen Park.
Thank you for your comments.
27
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Giffels/Black& Veatch
A Joint Venture
200 Renaissance Center, Suite 1220, Da*fbit. Michigan 4S243 (313)259-5300
Detroit, Michigan
Facilities Plan
Mr. Charles M. Beckhara, Director
Detroit Water and Sewerage Department
Water Board Building
735 Randolph Street
Detroit, Michigan 48226
Attention: Mr. John McGrail
Dear Mr. Beckham:
July 21, 1982
B&V Project 7889
GAI ProJ
File.A.I
\
Re: DWSD
DWSD PM^ect, CS--'806-
EIS Consultant Final,Report
Group 14 C^J" ! If'-! '
••— -i3., - - •-'
Attached are comments on the Environmental Consultant's audit of the
combined sewer overflow studies conducted by the Joint Venture. The
comments are intended to be constructive and we trust will be accepted as
such by all parties concerned. We were surprised to receive on July 16 a
bound copy of the CSO Report marked "Final". We trust this was an error
and that these comments can be incorporated into the report.
In addition to the attached comments, we feel there are four primary points
regarding the combined sewer overflow studies that should be made:
o Had the facilities planning effort on combined sewer overflows
not been stopped short of completion, it is likely that the
"Future No Action" alternative would have been selected. This
would have eliminated the need to try and pick up the work and
continue planning at some future time when funds become available
for construction.
o The Environmental Consultant's report does not document the 1980
field data, which are available even if only in unanalyzed format.
These were the most important field data of all, as they are
vital for recalibration and verification of the several complex
and interrelated system models.
o Most importantly, the project was terminated before the user's
manuals for the several complex modeling programs were written.
Without this documentation, the immense amount of time and effort
that went into modification and development of these specialized
models is lost to the City and to the profession. At this point
even the subconsultant, who had the major input into developing
the models, would have some difficulty in reactivating them.
Giffels Associates. Inc.
Architects Engineers Planners
28
Black & Veatch Michigan
Consulting Engineers
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RESPONSE
The report on CSO is a final report, but as stated in the public meeting of
July 21, 1982 - a responsiveness summary addressing meeting comments and
written comments will be prepared and distributed.
When planning is completed, a selection will then be made.
The Environmental Consultant did not document the 1980 field data since it
was not available to them. We agree that these data would be very valuable.
We will be formally requesting the submittal of this data from the grantee.
The lack of documentation is also frustrating to the USEPA. One reason this
report on CSO was completed, was to assess the status of the CSO facilities
planning at the time of suspension.
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Mr. Charles M. Beckham 2 July 21, 1982
o The model programs and the massive amount of quantity and quality
data entered into the computer data base has been stored on tape,
a copy of which was delivered to DWSD at the termination of the
project. Every effort should be made by the City to ensure that
this data bank and the computer programs are not lost. Any con-
tinuing charge for storage would be minor compared to the cost
and effort in reestablishing the programs and the data base.
We appreciate the opportunity to comment on the Environmental Consultant's
summarizing report.
Very truly yours,
R. 'E. Filardi
Giffels/Black
Project Manager
Giffels/Black^& Veatch'
WEF/MJG/REF/lhj
cc: J. McGrail - DWSD
P. Swinnick - ESEI
G. Cottrell - G/B&V
C. Sutfin - EPA
30
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RESPONSE
Agreed.
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COMMENTS BY GIFFELS/BLACK & VEATCH
ON THE
"REPORT ON COMBINED OVERFLOW FACILITIES PLANNING FOR THE DWSD"
BY ESEI Inc.
June 1982
1. PAGE i, PARAGRAPH 1. The statement "Certain methodologies... seem
inappropriate given the data and circumstances" is not supported by the
report. The text of the CSO Report suggests alternatives but does not
demonstrate or call any methodology inappropriate. We suggest a re-phrasing
as follows: "Facilities planning results to date, plus the new or changed
circumstances surrounding the subject matter, indicate that resumption of
planning will probably involve different assumptions and, therefore, modi-
fied methodologies".
2. PAGE i, LIST OF CENTRAL DOCUMENTS. We recommend the addition of
two reports: "Flow Management Report", May 1981 and "Existing Preliminary
Treatment Complex Evaluation Report", April 1981.
3. PAGE ii, LAST PARAGRAPH. The phrase "very complex and difficult
to understand" is suggested as a substitute for the word "confusing".
4. PAGE 1-1, PARAGRAPH 1. The phrase "... summarizes much of..." is
suggested instead of "...is their summary of ...". The AFIR was originally
only a progress report on some of the planning activities, and was never
intended to provide full coverage of all the planning; witness the fact
that modeling was not extensively covered. Some increase in scope was
attempted when the Federal Court mandated that the planning process cease
with the AFIR, but time and other constraints did not allow full coverage.
1
32
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RESPONSE
The Summary of Comments on FFP Environmental Analysis by Parameter (Table
10-10, page 10-43) lists several FFP environmenal analyses which were
considered inappropriate for preliminary and/or final screening of alter-
natives. The reasons are also listed. This Table is supported by a complete
discussion of the FFP Environmental Evaluation, Section 10.3, pages 10-33 to
10-42. For methodologies other than for environmental evaluation, we agree
with your re-phrasing.
We accept this and these reports should be included on our list as 4d and
4e, respectively.
We agree.
We agree.
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5. PAGE 1-1, LIST OF OBJECTIVES. Two more objectives are considered
to be of prime importance and should be added:
"5. To provide documentation for all available water quality data.
6. To provide user's manuals for all of the water quality model
programs developed and used in the Facilities Planning."
Full documentation of the data base should include the Spring 1980 monitor-
ing data. It was crucial to model recalibration and would prove extremely
useful to future planning. Project constraints caused DWSD to trade off
full documentation and generation of water quality data in hard copy for
other deliverables, but data are currently (and have been since project
termination) available on magnetic tape at DWSD.
The recalibrated and verified models, which represent a substantial
investment, would be very useful to future planners, who could immediately
implement them if their use and basis were described in user's manuals.
Project budget and schedule constraints also caused DWSD to trade off
generation of user's manuals for other products. Although some documenta-
tion is available through Wayne State graduate student dissertations, this
is not enough. Generation of user's manuals should proceed while the
people involved are available, and they still have some recollection of the
various programs.
6. PAGE 1-2, LAST PARAGRAPH. In line with Comment No. 4 above we
suggest the following rephrasing:
o "... AFIR became the final deliverable..." instead of " ... AFIR
was the..."
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RESPONSE
The four objectives listed on page 1-1 are specific to the subject CSO
Report, June 1982. The two objectives you have listed are applicable to
the Final Facilities Planning effort. These were never carried out, as
you have stated, but we believe, would still be a worthwhile endeavor of
the DWSD.
We agree.
35
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o "Early in 1981 the Federal District Court mandated that it was
to serve as a stopping point..." instead of "It was mandated...,
and was to serve as a stopping point...".
7. PAGE 3-2, PARAGRAPH 2. The last two sentences should be expanded
to properly describe the current status of the NI-EA. We suggest the
following: "A third major ...(NI-EA) is almost finished, with approximately
2500 ft more required to bring it into the DWWTP. A pump station would be
required to allow it to convey suburban sanitary sewage and/or to transport
and store combined sewage. However, work on both the interceptor and the
pump station have been stopped by Court Order, with MDNR concurrence,
because of the lack of construction grants funding."
8. PAGE 4-1, PARAGRAPH 1. The first statement, "The determination of
CSO...rather than direct measurements" could be misinterpreted. We suggest:
"Current CSO quantity and quality were ascertained through statistical
analysis of direct measurements. The statistical characteristics and
trends observed were incorporated into the models and utilized to estimate
variation over time and under changed operational conditions." The latter
phrasing expands on the actual sequence of analysis, which is standard
practice, and which led up to the "CSO Quantity and Quality Report", whose
tables and figures represent or were extrapolated from actual collected
data.
9. PAGE 4-6, TABLE 4-1. Most of the Baby Creek East (BCE) watershed
flows are received by the DRI through the Livernois, Morrel and other
sewers, not by the 0-NWI.
10. PAGE A-25, PARAGRAPH 1. Field problems had nothing to do with
the makeup of the calibration set. The six storms were selected from the
available data because they provided the best representation of total
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RESPONSE
We agree.
We agree.
We agree.
You are correct. This change should be noted.
37
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system and receiving stream operation during storm conditions. The full 25
storm set was not used because it does not always overflow at all locations
and, due to cost and logistic constraints, Detroit River receiving quality
cruises were not scheduled for all events. It is suggested that the text
be modifified to "Of the 25 monitored storm events the six providing the
best representation of storm conditions were selected for model calibration."
11. PAGE 4-26, PARAGRAPH 2. "...the 1980 data is unavailable." See
Comment No. 5 above. No hard copy or documentation was generated due to
project constraints, but the data was and is available on magnetic tape at
DWSD, as part of the Water Quality Data Base. To fulfill the purpose of
the CSC Report, both documentation and hard copy production should be
provided.
12. PAGE 4-32, PARAGRAPH 3. We suggest that "While this provides...
or by seasons" be modified to read "This provides information on any one
mean value. To compare the amount of variation by river, season or among
different parameters at the same site, the investigator must access the
water quality management programs data base and perform the desired sig-
nificance tests." The programs to operate on the data and the data them-
selves are on magnetic tape at DWSD. Some such tests were performed but
the results were not included in the hard copy tabulations. The Joint
Venture believes that direct interpretation of the statistical data is open
to speculation, because of the complexity of the system.
13. PAGE 4-46, PARAGRAPH 2. The criteria cited as used for average
year selection are not totally correct. They should be replaced by the
ones provided on Page 6-1, last paragraph, of the CSO Report.
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RESPONSE
This clarification is quite acceptable.
We agree.
39
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14. PAGE 5-18, LAST PARAGRAPH. Current phrasing could be misinter-
preted and thereby mislead the reader. The fact is that QUAL II was selected
for dry weather flow, steady state condition simulation because stream
flows and input are essentially constant during these conditions and because
extreme flow variations do not happen at these times. RECEIV II was selected
to model dynamic storm (extreme) conditions. We suggest rephrasing to
read: "QUAL II was selected to model dry weather flow steady state conditions
because it assumes essentially unvarying stream flows and input waste
loads, conditions which accurately reflect dry weather periods. Extreme or
dynamic conditions, such as those experienced under storm conditions, were
simulated by another model, described in Section 5.3.2.2 below."
15. PAGE 5-24, LAST PARAGRAPH. The statement "The basic difference...
water quality planning" could easily be misinterpreted. RECEIV II i^
specifically geared to model storm (high flow) conditions. It is the
modified version of the SWMM Receiving Water Block, modifications that
enhanced rather than detracted from its urban storm modeling role. We
suggest that the text be modified to read: "The basic difference between
SWMM Receiving Water block and RECEIV II is one of degree and flexibility;
while both simulate storm (high flow) conditions associated with urban
drainage problems, RECEIV II is better geared toward water quality planning."
16. PAGE 5-46, PARAGRAPHS 2 AMD 3. It is correct that no sampling
data were available for many (in lieu of most) of the 36 data points.
Preliminary investigations of existing sources led us to believe these were
sufficient and therefore no sampling was scheduled. When in fact some
locations were found to have little or no data, in line with accepted and
40
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RESPONSE
Your rephrasing is agreed with and should be considered as replacing the
last paragraph of page 5-18.
We agree with your modification.
We could not confirm that sampling data were available for most of the 36
data points, although two staff members spent a day in the Black and Veatch
library searching. We do not question that accepted methods were used to
derive missing data, but we did wish to call attention to the fact that
sampling data was not the basis of the majority of the 36 data points.
41
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standard practice for similar cases, we assumed values satisfying observed
upstream and/or downstream steady state conditions. We suggest insertion
of a phrase in the CSO Report indicating the procedure used to be accepted
practice.
17. PAGE 5-57, PARAGRAPH 3. To reflect the circumstances more
accurately we suggest that the statement "As with the Rouge River model,
these...contained certain errors..." be rephrased to read "As with the
Rouge River model, in order to meet a stringent deadline, Detroit River
model outputs were distributed as they became available, without the benefit
of the analysis normally performed before release. Review indicated the
need for changes and modifications, requiring output to be corrected in
updates."
18. PAGE 8-8, PARAGRAPH 1. In the AFIR report (see Page 1-11), based
on project data and analytical results, the JV recommended that the FNA be
included with the "few best" for future analysis. This decision was based
on the observation that only minimal incremental benefits accrued from
increased control, a conclusion only made possible by the analytical effort
up to that date. The statement "Although the FNA..., no assessment was
made of whether any alternative should be chosen over the FNA alternative."
neglects to mention that selection of one preferred alternative was always
scheduled for the last planning phase, which the JV was not allowed to
perform. There is the strong possibility that the FNA alternative would
have been recommended. We therefore suggest that the text be changed to:
"Although the FNA alternative was used to calculate benefits and costs of
the 25 specific control alternatives, the planning process was halted by
42
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RESPONSE
We agree with this clarification.
We agree with this restatement.
43
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Court Order before assessment was made of whether any alternative should be
chosen over the FNA alternative."
19. PAGE 8-1A, PARAGRAPH 2. Three issues require clarification.
First, the revised cost figures were not available until mid-May, but the
results and the support calculations were made available to DWSD at the
project end as part of the back-up calculations; anyone could have accessed
them. The JV suggests the note be deleted altogether or modified to reflect
cost figure availability.
Secondly, the FNA was not suddenly assigned a substantial cost; the
May AFIR included a cost within 12% of the final figure. The reasons for
the cost were amply discussed with DWSD and the EIS consultant and are
clearly explained in the (final) June AFIR. The sentence "Also, a substan-
tial cost...zero." should be deleted.
Finally, the JV internally reiterated not only the cost/benefit
analysis, but the total screening and ranking, and saw no reason to change
the report since the same "few best" alternatives resulted. This is further
explained in Comment No. 20 below. The statement "However, the facility
planner did not..." would better reflect what happened if rephrased as
follows: "An internal revision of all the alternative screening and ranking,
including the cost/benefit analysis, did not modify the alternatives included
in the few best."
20. PAGES 9-1, PARAGRAPH 1 AND 9-2, PARAGRAPH 2. The costs of the
FNA was not radically changed (see Comment No. 19 above); thus the statement
"The cost of the FNA alternative also was radically changed," on Page 9-1
should be deleted. Paragraph 2 of Page 9-2 should also be deleted; it
44
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RESPONSE
The EIS Consultant verbally requested the revised cost data twice and was
told that it was not available. The matter was not pursued further.
Although the May AFIR did include a cost for the FNA, the costs the EIS
Consultant analyzed were obtained in February of 1981 and in this cost data
FNA was assigned a cost of zero. Since the February cost data are presented
in Tables 8-3 and 8-4, the reader should be forewarned that the costs were
later modified. We agree that the assignment of costs to the FNA was
amply discussed and we do not disagree with the decision to make such an
assignment.
We agree.
45
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apparently results from a misunderstanding. The costs attributed to the
FNA alternative result from items considered as "givens", such as the NI-EA
and Pump Station No. 2. This affected all the alternatives in like manner,
making the FNA cost a base cost. The benefit cost computations were redone,
but were unaffected by this cost increase, since the basis is the difference
in cost between an alternative and the FNA. The cost difference was only
affecLed by the changes in storage and treatment shown on Table 9-1, and
not by the FNA cost.
As noted in Comment No. 19 above, the facilities planner did engage in
the rescreening and reranking of the alternatives with the revised costs
and conditions. The matter was not pursued officially because the same
"few best" alternatives resulted, confirming a prior sensitivity analysis.
While modeling indicated that the reduction of excess storage and the
elimination of unused treatment modules did not affect water quality, it
still affected related elements such as cost, disruption to the environment,
etc. The rescreened and ranked alternatives mostly maintained their
relative positions with respect to these factors, but the difference between
these and other alternatives was less marked. The few alternatives that
did change rank did not change enough to be included in the "few best".
Thus the statement on Page 9-1, "These revisions were not used..." should
read: "The Facility Planner reevaluated the cost/benefit, environmental,
implementability, technical, and economic analyses with these incorporated
revisions; the same "few best" alternatives resulted, confirming prior
sensitivity analyses."
46
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RESPONSE
We agree. The CSO Report should make the reader fully aware of the rescreen-
ing and reranking.
47
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21. PAGE 10-1, PARAGRAPH 1. The circumstances mentioned in "The
subject areas covered...without regard to the circumstances..." are an
integral part of (in many cases the sole reason for) the subject areas.
While objective critique certainly requires that the circumstances be
excluded, more explanation is necessary to do them justice to the subject
area and avoid misrepresentation of the facts and issues. We suggest
inserting the following sentence before the above quoted statement. "The
reader should also understand that these circumstances are an integral
part, of the planning techniques used and, in many cases, are the sole
reason for them."
22. PAGE 10-3, SECTION 10.1.1.1, REACTION RATES. While it is true
that the rates were not supported by field data, the JV had indicated that
it considered setting these rates equal to zero reasonable because of the
rapid travel time in the Rouge River. Flow reaches the Detroit River in a
matter of hours, rendering any effect of the rates negligible.
As mentioned in Comment No. 5 above, although some calibration and
verification documentation is available, the absence of complete documen-
tation and user's manuals was a conscious DWSD trade-off. We recommend it
be carried out as soon as possible, enabling a reassessment of the CSO Report
comments with regard to calibration/verification and related issues.
23. PAGE 10-7, PARAGRAPH 1 AND 10-8, PARAGRAPH 2. See Comment No. 22
with respect to calibration/verification. Furthermore, no claim was ever
made by the modelers of absolute numbers at the current planning stage; the
models were only intended to differentiate relative effects. The small
observed difference was interpreted by the modelers as having no sigficant
difference between the alternatives or between the alternatives and FNA.
This should be brought out in the CSO Report.
9
48
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RESPONSE
Agreed.
We agree that lack of complete documentation and users manuals makes inter-
pretation of the models and the supporting data difficult, however, your
recommendation is more appropriately directed to your former client, DWSD.
Agreed.
49
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24. PAGE 10-17, PARAGRAPH 2 AND PAGE 10-19, PARAGRAPH 2. See Comments
No. 18 and No. 23. The JV interpretation was that only minimal differences
exist between the alternatives and the FNA, a conclusion shared by the
CSO Report.
25. PAGE 10-20, PARAGRAPHS 2 AM) 3. The authors of the CSO Report
were able to suggest redefinition of the optimal point after they observed
the results of current definition analysis. In like manner the CSO Report
suggestion to use dB/dC = maximum could be questioned. With this differ-
entiation, the public decides whether to spend more money or less, rather
than the more basic question of should any money be spent at all? The AFIR
addresses this by recommending that FNA be considered as one of the "few
best", and therefore that it be subject to a future analysis that could
result in its selection as the preferred alternative.
A rough calculation and re-ranking, using the CSO Report's alternate
strategy ranking for cost/benefit, along with the rankings of the other
categories (implementation, environment, etc.), still produced the same
"few best". The JV suggests modification of Section 10.2.2 - Optimization,
to reflect these comments.
26. PAGE 10-29, PARAGRAPH 1. The assumption that society values the
benefits of pollution in direct proportion to cost was not made in a vacuum.
It was recognized as one value system within the context that other societal
values would be reflected and adequately weighted in the other ranking
categories. Other value systems were in fact accounted for. The JV suggests
rewriting of Section 10.2.3, Value Systems, to reflect the above comments.
10
50
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RESPONSE
Agreed.
Agreed. This conclusion should be stated more clearly in the CSO Report.
The CSO Report does not suggest that value system employed by the Facilities
Planner was made in a vacuum. In fact, without knowing the results of the
cost benefit analysis, the chosen value system was the most logical choice.
We simply wish to point out that other value systems exist, which could lead
to the selection of different alternatives.
51
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27. PAGE 11-1, PARAGRAPH 2. The DWSD, EPA and the EIS consultant
were all knowledgeable about the assumptions referred to as questionable,
and either accepted them or did not question them. The statement "Facili-
ties planning...now appear questionable" should be modified as follows:
"Results to date, coupled with changed project related circumstances,
require a change of assumptions before resumption of planning activities."
11
52
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RESPONSE
Agreed.
Thank you for your comments.
53
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Wayne Sidle University
College of Engineering
Department of Chemical and
rvtetallugical Engineering
Detroit, Michigan 48202
July 29, 1982
Mr. James Novak
USEPA Water Section
Environment Impact Section
12th Floor
230 South Dearborn St.
Chicago, IL 60604
Dear Mr. Novak:
As a practicing professional in the area of water resources, I
have reviewed the EPA Region V Final Report on Combined Sewer Overflow
Facilities Planning for the Detroit Water and Sewerage Department. I
attended the public meeting held on July 21, 1982 and commented on the
report. I wish to add the following written comments to the Responsive-
ness Report which I understand will go to all recipients of the Final
Report as well as all future requestors of that report.
The major purpose of the CSO report was to facilitate the resump-
tion of the CSO facilities planning in Detroit. As it stands, the
document does not accomplish that objective as it omits references to
all professional papers and Wayne State University thesis and disser-
tations which are in the public domain and which were intended to docu-
ment specific portions of the work. Not only were the references
omitted, but the work was apparently not reviewed and many statements
made in the report are therefore misleading or incorrect. An Auxilliary
Bibliography is attached to correct this oversight of thousands of pages
of detailed results, data and interpretation.
With respect to the recommendations, the oversights could signi-
ficantly change a number of conclusions; a quantitative assessment of
the impact is beyond the scope of this critique. Recommendation 11.1
is questionable as it is based upon ESEI's inability to find all the
Rouge River initialization data that was used. The MDNR 73 survey
alone lists more data than that published in Table 5.5. 11.2 should
be revised to indicate that substantial additional quantities of data
exist in the present study.
The impact of the CSO's upon the Detroit River should be reviewed
again, as the ESEI study did not address the entire river and new
marinas and canals with total body contact recreation will be added to
the river. The report should have addressed the environmental impact
of the existing and future no action conditions. The Chemical Engi-
neering Department of Wayne State University should be noted to have
been a major subconsultant to the Joint Venture and a considerable
resource of information.
54
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RESPONSE
We appreciate your bibliography which should be very helpful to present and
future planners.
The EIS Consultant made numerous requests for the initialization data to
Black & Veatch and to USA. All of the information supplied by these two
sources was used. If you possessed additional information, it would be of
great value to future planners.
Table 5.5 lists the arithmetic means of STORET data and not the individual
samples. Therefore you are correct in saying that the MDNR 73 survey con-
tains more pieces of data than are displayed in Table 5.5.
The scope of study did not include the entire Detroit River or Lake Erie.
Future basin wide planning should certainly cover the impacts of alternatives
on a larger area than was analyzed for this study.
We agree that the Chemical Engineering Department of Wayne State University
should be noted as a major subconsultant, and we apologize for this omission.
55
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Mr. J. Novak
Page 2
July 29, 1982
There are many additional technical issues raised by the report
which are definitively answered in the attached bibliography. I would
be pleased to make copies of those papers available in their entirety
for the Responsiveness Summary, if desired.
Sincerely,
Ralph' H.
Chairman
56
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RESPONSE
Thank you for your comments.
57
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AUXILIARY BIBLIOGRAPHY FOR RIVER MODELING ON THE
DETROIT SECTION 201 FINAL FACILITIES PLAN
Alternate Facilities Interim Report, Giffels/Black and Veatch, Report on the
Detroit Section 201 Study, June 1981.
Anderson, H.M., "A Dynamic Simulation Model for Wastewater Renovation Systems,"
Doctor of Philosophy Dissertation, under R.H. Kummler and R.V. Edwards, Department
of Chemical Engineering, Wayne State University, Detroit, Michigan, 1981.
Anderson, H.M., "Combined Sewer Overflow Modeling: STPSIM2, A Dynamic Model of
the Wastewater Treatment Plant," Symposium on Section 201 Planning; Modeling for
Combined Sewer Overflow Abatement, Paper 7d, 91st National AIChE Meeting, Detroit,
Michigan, August, 1981.
Anderson, J.A., C.D. Harlow and J. Baranec, "Combined Sewer Overflow Modeling in
Detroit 201 Study Using SWMM," Symposium on Section 201 Planning; Modeling for
Combined Sewer Overflow Abatement, Paper 7c, 91st National AIChE Meeting, Detroit,
Michigan, August, 1981.
Anderson, J.A., C.D. Harlow, J. Baranec and H.M. Anderson, "Combined Sewer
Overflow Modeling in the Detroit 201 Study using SWMM," Proceedings of the USEPA
(SWMM) Stormwater Management Model User's Meeting, January 19-20, 1981, Austin,
Texas.
Fl Sharkawy, Alaa, "Water Quality Modeling for One-Dimensional Rivers," Master's
Thesis under R.H. Kummler, Department of Chemical Engineering, Wayne State
University, Detroit, Michigan, 1981.
El Sharkawy, Alaa and Esmail Jamshidi, "A Comparison of an Analytical, One
Dimensional River Simulation with Numerical River Models," Symposium on Section
201 Planning; Modeling for Combined Sewer Overflow Abatement, Paper 8d, 91st
National AIChE Meeting, Detroit, Michigan, August, 1981.
Filardi, Raul and Barbara Harvey-Brayton, "CSO Control Alternatives Analysis,"
Symposium on Section 201 Planning; Modeling for Combined Sewer Overflow Abate-
ment, Paper 8f, 91st National AIChE Meeting, Detroit, Michigan, August, 1981.
Giffels/Black & Veatch, Segmented Facilities Plan prepared under Section 201
Facilities Planning Grant for the Detroit Water and Sewerage Department,
January 31, 1978.
Graham, Malaise, J., "Field Data Collection for Calibration of Models," Sym-
posium on Section 201 Planning; Modeling for Combined Sewer Overflow Abatement,
Paper 7b, 91st National AIChE Meeting, Detroit, Michigan, August 1981.
Harlow, C.D., E. Jamshidi, R.H. Kummler, J.G. Frith and J.A. Anderson, "One
Dimensional Water Quality Models for Dynamic, Small Rivers: The Rouge River,"
Proceedings of the USEPA (SWMM) Stormwater Management Model User's Meeting,
January 19-20, 1981, Austin, Texas.
58
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Harlow, C.D. and J. Frith, "Numerical Water Quality Models for One Dimensional
Rivers," Symposium on Section 201 Planning; Modeling for Combined Sewer Overflow
Abatement, Paper 8a, 91st National £IChE Meeting, Detroit, Michigan, August 1981.
Harlow, C. and R. Kummler, Detroit Water and Sewerage Department Wastewater
Treatment Plant Flow Analysis for 1974-1979, Report to Black and Veatch,
February 1980.
Harvey-Brayton, Barbara L. and Raul E. Filardi, "Combined Sewer Overflow
Abatement Alternative Development," Symposium on Section 201 Planning; Modeling
for Combined Sewer Overflow Abatement, Paper 7a, 91st National AIChE Meeting,
Detroit, Michigan, August 1981.
International Joint Commission Great Lakes Water Quality Board, Surveillance
Subcommittee Reports Appendix B for 1975, 1976, 1977, 1978 and 1980, available
from the International Joint Commission, 100 Ouelette Street, Windsor, Ontario,
Canada.
Jamshidi, E., A. El Sharkawy, R.H. Kummler and C. Harlow, "An Analytical Model
for a Dynamic, One Dimensional River with Axial Dispersion and Chemical Reaction,"
2nd World Congress of Chemical Engineering, Montreal, October 1981.
Kummler, R.H., J.G, Frith and C-S. Liang, Final Report on the Planning Level
Model Sensitivity Analysis, Task 1232.1, May 25, 1981.
Kummler, R.H., G. Roginski, C-S. Liang, S. Winkler and J. A. Anderson, "Two
Dimensional Water Quality Models for Dynamic, Large Rivers: The Detroit River,"
Proceedings of the USEPA (SWMM) Stormwater Management Model User's Meeting,
January 19-20, 1981, Austin, Texas.
Kummler, R.H., J.G. Frith, L-S. Liang and J.A. Anderson, "Uncertainty Analysis
in Stormwater and Water Quality Modelling," Proceedings of the SWMM Users Group
Meeting, USEPA and McMaster University, Hamilton, Ontario, Canada, September,
1981.
Lake Erie Report: A Plan for Water Pollution Control, U.S. Department of the
Interior, Federal Water Pollution Control Administration, Great Lakes Region,
1968.
Liang, Chein-Sung, "Use of Multispectral Remote Sensing Data to Predict the
Turbulent Diffusion Coefficient in the Detroit River," Master's Thesis under
R.H. Kummler, Department of Chemical Engineering, Wayne State University,
Detroit, Michigan, 1981.
Liang, Chein-Sung, S. Winkler and R.H. Kummler, "A Guassian Plume Model of a
Two Dimensional River," Symposium on Section 201 Planning; Modeling for Combined
Sewer Overflow Abatement, Paper 8d, 91st National AIChE Meeting, Detroit,
Michigan, August 1981.
Michigan Water Resources Commission, Bureau of Water Management, Department of
Natural Resources, "Rouge River Basin: General Water Quality Survey and Storm-
water Survey, June-September, 1973, March 1974.
2
59
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Roginski, Gregory T., "A Finite Difference Model of Pollutant Concentrations
in the Detroit River from Combined Sewer Overflows," Doctor of Philosophy Disser-
tation under R.H. Jummler, Department of Chemical Engineering, Wayne State
University, Detroit, Michigan, 1981.
Roginski, G. and R.H. Kummler, "A finite Difference Model of a Two Dimensional
River," Symposium on Section 201 Planning; Modeling for Combined Sewer Overflow
Abatement, Paper 8c, 91st National AIChE Meeting, Detroit, Michigan, August 1981.
Roginski, G., C-S. Liang, S. Winkler and R.H. Kummler, "Simulation of Pollutant
Concentrations in the Detroit River," 2nd World Congress of Chemical Engineering,
Montreal, October 1981.
Upmeyer, D.W., G. Roginski and R.H. Kummler, "Impacts of Detroit's CSO Discharges
on the Detroit River," 54th Annual Water Pollution Control Federation Conference,
October 1981, Detroit.
Upmeyer, D.W., "The Alternative Analysis Procedure," Symposium on Section 201
Planning; Modeling for Combined Sewer Overflow Abatement, Paper 8e, 91st National
AIChE Meeting, Detroit, Michigan, August 1981.
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PUBLIC MEETING TRANSCRIPT
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Edited Transcript of Public Meeting Held Wednesday, July 21, 1982 on the "Report
on Combined Sewer Overflow Facilities Planning for the Detroit Water and Sewerage
Department"
Representing the DWSD - Mr. John McGrail
Representing ESEI - Mr. David Vance
Mr. Peter Swinick
Mr. James Williamson
Representing USEPA - Mr. James Novak
Mr. Novak
Why did we do this report on CSO? During the facilities planning one of the
elements being covered was Combined Sewer Overflow (CSO). That planning (CSO) was
suspended rather abruptly. While the planning was proceeding, there was a con-
current Environmental Impact Statement (EIS) but since the planning on Combined
Sewer Overflow was halted, there was technically no need for the USEPA1 s EIS to
address Combined Sewer Overflow. At that time, however, the agency did not have a
detailed overview of what was done. Therefore, this report was generated and had
the following four objectives.
0 To review and summarize the Combined Sewer Overflow planning
that was accomplished to date.
0 To evaluate quality improvements associated with the alternatives
that were determined in facilities planning.
0 To independently evaluate the procedures used in facilities
planning, and
0 Most importantly, to provide some basis from which a resump-
tion of CSO planning can proceed.
I should make something very clear, that this is by no means any kind of decision
rlocument. It was put together for the previously mentioned reasons and is intended
primarily to facilitate subsequent planning.
Mrv. SwinLck
We've handed out two things already. Two dozen CSO reports were distributed first
f.-Irst: ser\ e and we are already out of those. There were about. 150 of them
d otr: to individalj who requested tbein. It, she eld have been about 10 days
-------
ago and most people should have gotten those already although I just got word that
they haven't been received. That was the five hundred page report that was up
here that has a greenish cover on it. We still have about 100 copies of those
available if any one would like a copy and does not have one or does not expect to
get one in the mail. For anybody who did write, you should get one within the
next 2 days or 3 days if they haven't already been received. If anybody would
like a copy, either Region V USEPA or ESEI can get you one. Everyone of the
Citizens Advisory Committee should have gotten one. But the place to write to is
ESEI, you can write to my attention, Peter Swinick, 1 Bank Street, Rockaway, New
Jersey 07866. We should be able to get it out in a few days.
The second package that was handed out is really an outline of today's presenta-
tion and since we are trying to limit questions until after the meeting, if you
have a question, just jot it down and this way we can remember and call all those
questions together later. We are going to try to present about 45 minutes worth
of information and then open it up for questions. Try to make it short and sweet.
I'm going to start with the history of planning for upgrading of sewage treatment.
I'm not going to go too far back, only to 1966. And then I'm going to turn it over
to Dave Vance who's going to talk about the work that was done by the facilities
planners and the review done by ESEI and the USEPA.
In 1966 the State of Michigan and the City of Detroit came to an agreement to limit
discharges into the Detroit River. At that time, limits were set for those dis-
charges and Detroit during that time tried to meet those limits. Between 1966 and
1972 the City met those limits and didn't meet those limits in an inconsistent
fashion. In the early 1970's, studies came out of places like the International
Joint Commission and some of the universities around Lake Erie citing the City's
publicly owned treatment plant and many other sources that were major pollutants of
the lake. This, combined with the entrance of the federal government into regulat-
ing the waste water discharges in 1972 with the passage of the Federal Water Pollu-
tion Control Act, required the City of Detroit, USEPA and the State of Michigan to
put their heads together; forced the meeting of the minds if you will; to try and
solve the problems that were occurring in the City. In 1974 MDNR, which is the
Department of Natural Resources, USEPA and the City agreed to an orderly progres-
sion of study and upgrading of the treatment plant. They started an upgrading
process, phosphorus removal was initiated or at least the construction was initi-
ated and studies were begun on the upgrading of secondary treatment. Also in 1974,
MDNR issued an interim permit for the wastewater treatment plant to operate, again
setting up some standards for discharge requirements. In 1975, a plan was presented
to MDNR and the agencies on how to meet upgraded standards. The plan was reviewed
by the agencies and in certain areas it was deemed inadequate to document the need
of the federal funding. In 1976, two things happened; first the interim permit was
revoked due to continued violations of the standards that were set up and a mori-
torium was declared by MDNR on new connections to the systems. No new collectors
64
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were suppose to be built and no more home or industries were suppose to be con-
nected to the system. The moritorium was later suspended and dropped when the
City, MDNR and the USEPA again agreed to a schedule to study and upgrade the treat-
ment plant and try to find solutions to the problems, very complex problems because
of the size and complexity of the treatment facilities. It was also agreed to
develop a facility plan which has come to be known as the Segmented Facility Plan
but at the time was called the Overview Plan with an Environmental Assessment. In
1976 it was agreed by those parties to complete a facility plan by August, 1977 and
that facilities plan was suppose to study upgrading to secondary treatment levels.
DWSD also agreed to meet secondary treatment standards by December of 1979. They
also agreed to study the Combined Sewer Overflow problem which was thought to be a
major contributor of pollution to Lake Erie and the Detroit River. In 1976, the
Overview Plan with Environmental Assessment was started, and it was completed in
June of 1977, on time and on schedule. The document studied the Combined Sewer
Overflow problem and recommended the construction of a West Arm Interceptor which
was designed to carry sanitary sewage and follow a route along the Rouge River. It
was designed to separate the system carrying pure sanitary sewage down to the
treatment plant, leaving the existing system mostly unmodified to handle storm
water runoff. That report was then reviewed by MDNR and the USEPA. The review,
published in the Environmental Impact Statement on the Overview Plan and Environ-
mental Assessment, determined that the data presented was inadequate to justify the
expenditure of federal dollars on a West Arm Interceptor. In other words, there
wasn't enough information to make a decision to spend that much money to separate
the sewers and stop or eliminate to a great extent the Combined Sewer Overflows on
the Rouge River. Thus, although the Overview Plan with the Environmental Assess-
ment was completed, it became a Segmented Facilities Plan because things were to be
studied further. The Combined Sewer Overflow problems on the Rouge River and the
Detroit River were not solved in 1976. And that more or less brings us to the
start of this program as we know it and are concluding here today. In 1977, the
need for a final facilities plan or for further study on a couple of selected
elements (one of which as the Combined Sewer Overflow problem) was recognized and
was initiated into a final facilities planning document. That kicked off this
process. I will now turn the meeting over to Dave Vance who will tell us the
technical details of what happened.
Mr. Vance
Peter gave you an idea of what the segmented facilities plan did. I'll start now
by recapping the Final Facilities Plan. We'll start with the problem definition
on the Final Facilities Planning process. The papers you have in front of you go
along with the slides and will help you. The slides will help you write down your
notes so you don't forget when you have questions. The goal of this portion of the
Final Facilities Planning effort was intended to see if CSO in the immediate
Detroit area was a serious problem. If so, how much of a problem and, if it was a
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problem, what alternatives could you give them to correct Combined Sewer Overflow
problems into the Rouge River? Other questions concerning the treatment plant and
other things were not covered in this particular facilities planning effort that we
wrote a report on here today, such as incinerator improvement, upgrading the treat-
ment plant for solid handling or site selection for solids disposal. Those items
and others were covered in separate reports. Before we begin in our evaluation of
that planning process and our recommendations, I want to spend a few minutes going
over the Detroit system and the methodology the facilities planners used in order
to better evaluate our recommendations and evaluations. The Detroit system is com-
posed of about 3500 miles of combined sewer and, as Peter said, it means that one
sewer handles most of the storm water runoff, domestic and industrial waste. The
next slide shows the nature of the combined sewer system showing both the runoff
rain and the family sewage going into the same pipe. The next slide shows a com-
plete combined sewer system, including a river. Notice that again the runoff goes
into the same pipe as the industrial and domestic waste and comes down here by
various size sewers into an interceptor which parallels the river. There is an
outfall here, a place where overflows go into the river without being treated.
These combined sewers were originally constructed to prevent basement flooding,
street and parking lot flooding. However, in the past twenty years they've become
far less popular because of the water pollution associated with such a system. An
interceptor, shown in this slide, is a major sewer who's purpose is to intercept
the flow of tributary areas before they transport it on to the treatment plant.
The next slide should show the major interceptors in the Detroit area. The Oak-
wood Northwest Interceptor parallels the Rouge River. It runs this way. The
Detroit River Interceptor is the other very large one, which follows the Detroit
River and goes up this way. The North Interceptor, West Arm being referred to in
discussions, would approximately parallel this Oakwood Northwest Interceptor along
the Rouge River and East Arm Interceptor, now unconnected generally parallels the
Detroit River Interceptor. Those are the four major interceptors you'll hear
people talk about. The West Arm does not exist and the East Arm is about 90% com-
plete. The treatment plant is located near the mouth of the Rouge River right
where all these interceptors come together. The treatment plant is one of the
largest in the country handling more than 800 million gallons of waste per day so
it's very large. These slides should give you an idea of the facility. For those
of you who haven't seen it up close, these slides just give you an idea of what a
treatment plant looks like. We're not going into detailed processes tonight.
That's not our purpose.
The wastewater which doesn't make it to the treatment plant is overflowed into the
Rouge River and Detroit Rivers. That happens along the Detroit Interceptor and
Oakwood Northwest Interceptor. This slide shows, and your packet will show it more
clearly, the 49 locations of the CSO sites in the immediate Detroit area, within
the City of Detroit and along the Detroit River. The next slide shows the loca-
tions of the Rouge River Combined Sewer Overflow sites. Again, these are not all
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the sites on the Rouge River, just the ones within the immediate Detroit area.
There are 30 of those along the Rouge River. There are also two more outfalls from
the plants itself. Combined Sewer Outfalls vary in size. Some are quite large as
indicated by this slide and the next slide. Those are very large, about 10 feet
square or more; or they may be small as indicated here. They come in all different
sizes. Now, needless to say, the impact of such a large overflow may have very
harmful effects on water quality and on any recreation. To give you a feel for the
impact it may have, we'll show you the width of the Rouge River at a location of-
where one of those very large interceptors is. Now the river at this point may be
15 to 20 feet wide and about 18 inches deep, and you saw the size of the outfall.
Combined sewage coming out from the outfall can totally dominate the river at that
point. There's no contest. For other CSO's that are smaller or where the river is
bigger, the effect would not be so great. It's just interesting to know how small
the river is at places where there are very, very large outfalls. It's important
to realize here and as you read the document that the study we are talking about
tonight focused on the impact of CSO on only a portion of the Detroit River and
Rouge River. For instance, the entire Rouge River basin is shown by the outline.
Now you can see how big the basin is, being of course the area where all the water
flows into the Rouge River. Keep in mind how large that area is, how far out it
goes. Of this basin, the Detroit Water and Sewage District's service area includes
maybe one third of that area. Of course, the Rouge River basin is a very much
wider area. Most of this area is served by combined sewers. Those are the colored-
in areas here. Now for purposes of this study, the planning area for which the
plans were developed was defined as the immediate Detroit area shown by the color.
So out of all that we started with, out of the basin down to the total DWSD service
area, we now have a planning area defined as just this area. For planning purposes
this area was further divided into two watersheds, the Rouge River watershed and
the Detroit River watershed. Those were further subdivided into subwatersheds.
Those were even further divided. All this was done with a detailed analysis of the
rainfall, the runoff and the sewer system characteristics. It covered such a big
area that the only way to handle the problem is to start breaking into smaller
components. It gives you just a flavor as to how that process went.
The facilities planners then developed alternatives to reduce the volume of Com-
bined Sewer Overflow. Five control options or methods of controlling that Combined
Sewer Overflow were examined to reduce pollution. These were: inline storage,
which is utilizing the inherent storage capacity of very large interceptors; off-
line storage, which usually means the construction of storage tanks below ground to
hold the wastewater until the treatment plant can handle it; increased treatment
Cjapji£ity_ either at the treatment plant or by building remote treatment units
wherever you needed them; sewer separation, which was discussed earlier; and best
manajgemjent_jgrac_tices such as street sweeping, sewer flushing or some of the others.
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These five control options were used to develop specific control alternatives. The
five control options were examined over four levels of pollution control (i.e. 20,
40, 60 and 75%) and two location systems (i.e. 1 facility/basin or 1 facility/2 or
more basins), to produce 25 specific control alternatives. So facility planners
looked at various levels of control from very little to as much as possible. They
looked at locating facilities in different areas. They looked at the different
control options, and tried out a combination of those to see what turned out to be
a superior specific control alternative. There were some duplications so we end up
with about 25. There are two special cases that did not come directly out of that
process that are important. The Future No Action case that you'll see abbreviated
FNA, Future No Action, which assumed that all the improvements already under con-
struction were finished. And Existing Conditions, which you may see abbreviated
EC, which represented the facilities as they existed in 1979. The Future No Action
alternative was far more important because all the alternatives had to be compared
to something. That base is the Future No Action. Now there is a slight difference
between what we've used as that Future No Action and what will come to be in a year
or two. But when you look at the actual data, it doesn't end up making much dif-
ference. So, the Future No Action alternative can be used as a base to compare
other alternatives to.
Once the specific control alternatives had been developed, they were evaluated in
five different categories. First was the cost benefit category, second was the
environmental analysis, third the implementability, fourth technical and fifth
economic. There had to be some way to evaluate alternatives so it was broken down
into these five categories and these five categories were weighted by a complex
process. You can see by the chart the categories have just about equal importance.
Before the cost benefit analysis or the environmental analysis can be performed,
the actual impact of the alternatives on the water quality had to be determined.
The only way to do that is to model water quality changes. After you know what the
water quality is (the place where you begin to model) you have to know what the
flow is up there. You need to know the quality and quantities of the Combined
Sewer Overflows coming into it. As well as any other discharges coming into it.
You need various streamflow characteristics. So for purposes of this study,
facility planners had four headwater locations here near Inkster, near Garden City,
up here near Farmington and right over the line here in Southfield. Each of these
points here are where the model had to start off. So those are our four headwater
locations. I'll come back to that later.
The water quality model was used to predict concentrations of different parameters.
Some of the parameters in one model are represented here. Each parameter or vari-
able is used to gauge impact of pollution on a certain beneficial use. That bene-
ficial use may be wildlife protection, it may be recreation, or drinking water
supply; and there are a number of others. All of these parameters are used to
determine suitability of the water quality for the designated beneficial use.
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Dissolved oxygen is used to measure the beneficial use of propagation and mainte-
nance of fish. Fecal coliform is a measure of the potential for recreation. After
each alternative has been modeled, the data (concentrations) were then used for
cost/benefit analysis and environmental analysis. Cost/benefit analysis is a tool
which is used to measure efficiency of the alternative. It measures how much more
benefit that last dollar bill will achieve. For instance, here we have three cases,
each with an equal cost. Here this same amount of cost going from this point
brings this much benefit. Up here, this same amount of cost from this point brings
this much benefit; a smaller amount than down here. Up here, the difference is
quite clear, the same amount of cost brings a smaller amount of benefit. For any
project, there comes a certain point where you can spend more and get less benefit
than the last increment of expenditure. The facility planner defined benefit as
the improvement over the Future No Action case divided by the maximum possible
improvement. Now this definition is right below. What this basically means is
that benefit is measured with percent improvement toward the maximum possible;
towards the best you can do in that part of the river. That will be determined by
looking at the results of the alternative and using those that did the best as max-
imum. Since the facility planners chose a control level range to encompass all the
total control of CSO, you can identify the best one by looking and use that to
determine the maximum improvement. The difference between the Future No Action
alternative and the best alternative is the maximum possible you can improve the
water quality.
The environmental analysis has the same importance as the cost/benefit analysis. In
the environmental analysis the impact of each alternative was examined in 6 areas.
Each of these six areas had many, many sub-categories. It became quite detailed and
complex. You can see by this chart here that the water environment was rated as
most important followed by biological. The alternatives were also evaluated for
technical considerations and economic; considerations. Most of our time was spent
on the two that are most important; the cost/benefit and environmental analyses.
After alternatives were ranked in each of these five categories, rankings were
combined to produce the few best alternatives. Eight few best of the original 25
were produced. Of these eight few best, the top three were Alternative #10, which
maximized potential inline storage through using inflatable dams making better use
of the space in those very large interceptors. That came out to look like it might
be the most preferred. Next was Alternative #9 which was increasing treatment cap-
acity at the plant itself via small amounts. Third was Alternative #2 using poten-
tial inline storage but not to the extent that alternative #10 did. The Report goes
into great detail on these three alternatives as well as the other alternatives for
anyone who is interested in pursuing the details.
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It was originally intended to subject these few best alternatives, these top eight,
to a more detailed evaluation. This detailed evaluation would have included
detailed modeling, detailed costing or cost/benefit analysis, and detailed environ-
mental analysis. So view this as a result of the first cut, not the final word
just the first cut. It was intended to provide further analysis to select the best
alternative instead of just the few best. However, about this time the facilities
plan was halted. And now we will turn for a moment to Jim and John to explain why
facilities planning was halted.
Mr. Novak
There was an ongoing consent judgement that had date requirements in it. It was
obvious that some of the dates could not be met. That meant that an amended con-
sent judgement had to be developed. At the same time, there were fiscal problems
in the State and the DNR. The DNR, Michigan Department of Natural Resources,
expressed a desire to reduce the amount of dollars being expended on planning for
Detroit at this time. The preliminary information (from facilities planning)
showed that there is a minimal improvement in water quality in both Detroit and the
Rouge River; that was the initial indication. As far as the agency perspective, we
were undergoing a change in administration and a change in our administrator. There
was an uncertainty of funds. All these factors contributed to the findings of the
July 6, 1981 Federal Court Order to suspend CSO facilities planning.
Mr. McGrail
As you might imagine, Detroit sees it a bit differently. The facility planning
work began way back in 1975 or 1976 and produced the segmented facility plan in
early winter 1978. January 1978 was when it was published. Now the way Detroit
has historically considered the two facility plans, the segmented and then the
final facility plans, is one building upon the other. That is the segmented
facilities plan looked to a large extent at the entire needs of the department but
ended up considering mostly the dry weather needs; the sludge handling related to
dry weather needs, etc. In fact it has become the cornerstone of our modern
wastewater capital improvements program. Many of the projects that appear today in
Step 3 (in the construction phases) can be traced quite readily back to the seg-
mented facilities plan. The second phase of facility planning came, as Pete in-
dicated, when EPA felt that there wasn't sufficient analysis to warrant plunging
forward on the West Arm, on CSO control and on other facets of the wastewater pro-
gram. So consequently we embarked on the final facilities planning program. Now,
originally, back in August 1980 there was a grant application prepared which would
have finished the facility planning program. The total cost of facilities planning
work would have been in excess of $22 million; just the planning. Now consider
that for $28 million we're building two 300 foot diameter clarifiers and with
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justification MDNR said, for that kind of money we could build concrete rather than
paper. It was a convincing and compelling argument in so far as DNR was concerned.
The Director was a little less tenuous about that, but there was feeling within the
Department that perhaps we have planned enough. As Jim pointed out, by February of
1981 we were beginning to get preliminary modeling outputs that suggested that
water quality improvement on both rivers; the Rouge and Detroit; was not that sig-
nificant. Indeed, even given the highest level of CSO control we still would not
have brought the rivers into compliance with dry weather standards. In other
words, to bring them into compliance, we would have had to change the law to allow
for wet weather standards. Then perhaps we would have complied. Because the water
quality conditions would not significantly improve the dry weather standard, we
could not encourage the development of full body contact recreation. And if some-
one in the audience could explain to me what partial body contact recreation is,
I'd be glad to know. It seems to me that either you're all wet or you're not. The
fact of the matter is and I must admit it came out in many of the interagency
meetings, that there was a certain weariness on the part of the department in terms
of further facility planning. In fact that weariness not only ended in the
termination of final facilities planning but it also ended up in the elimination
of a lot of other Step 1 work as many of those in the audience can testify to.
Also, a lot of termination of Step 2 work as a matter of fact. It seemed to get
easy after a while. You dump one facility planning program and you can dump 2 and
3 others and it gets fun. You find youself accomplishing something. Now I'd like
to return the presentation to Dave Vance.
Mr. Vance
Now we've given you an idea of what went into facilities planning and why it was
halted. For our evaluation tonight we are going to confine our comments to two
very important areas, water quality modeling and the cost/benefit analysis. The
water quality results, as John mentioned, are very interesting and begin to answer
one of the original questions of the study. We want to know, "why the CSO's are a
problem particularly in the Rouge River? What is the CSO contribution to water
quality problems? and What can be done about it?" Now the water quality modeling
results give us some ideas, give us some direction on how to answer those ques-
tions. The water quality modeling results indicate that water quality is a problem
in the Rouge River. Dissolved oxygen, fecal coliform and phosphorus all show
significant hours of violation of the state's standards. Now when you look at
this, this column has the standards set by the state. Here we have the average
concentration and over here the hours of violation. Now look at those hours of
violation. The Rouge River was modeled for 6600 hours; 9 months, 24 hours a day.
That comes to a total of 6600, the most hours you could have. You can see that
phosphorus is very nearly a unanimous winner. 6584 violates almost all the
possible hours and you can see this here.
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Unfortunately, as John said the alternatives provide only modest improvement in the
water quality. Notice here the unresponsiveness of both the hours of violation in
fecal coliform and dissolved oxygen to the reduction in CSO volume. Now, the alter-
natives can physically reduce the amount of CSO that goes into the river, and this
gives you an idea of how much. Remember our base is the Future No Action here in
this column. That's what we have if we don't do anything. So you can see, as the
alternatives go this way, the control gets a little better. Until here you've
reduced the CSO volume quite substantially compared to what it was in the FNA
alternative. These lines which indicate the hours of violation, don't drop accord-
ingly. Alternative 19 shows the most improvement. It reduced the CSO by 80% but
only reduces the hours of violation by 17% for dissolved oxygen and 56% for fecal
coliform. This still leaves 1809 hours of violation for fecal coliform. This is
what the best alternative can do. Alternative 19 has a capital cost of 578 million
dollars, that's half a billion dollars, so its a very expensive alternative and
disappointing in performance. There are less expensive alternatives which result
in lower benefits as you might imagine. Alternative 10 is a very efficient
alternative and was listed by facility planners as perhaps the most desirable at
this tentative first cut stage. Alternative 10 reduces combined sewer overflow
volume by 24%, reduces the DO violations by 11% and reduces the hours of fecal
coliform violations by 8%. This costs only $8.2 million. So for $8 million, you
can get a more efficient alternative but unfortunately it still doesn't do much.
We're only talking about 10% improvement for 8 million dollars still leaving many
hours of violation of fecal coliform and dissolved oxygen. Now at this point, you
should be wondering why even the best alternative, Alternative 19 at half a billion
dollars, doesn't substantially improve the water quality. If you can spend $578
million why don't you get more for it. Well, the answer appears to lie in the
background water quality, the incoming water quality. Even if DWSD were to elimi-
nate all its overflows on the Rouge River, the fecal coliform counts might not
improve enough to substantially reduce hours of violation. During wet weather
there are numerous other overflows on the lower, middle and upper branches,
contributing to the main Rouge and the upper Rouge itself. Other communities have
combined sewer overflow. Thus during wet weather you might expect that the water
quality wouldn't be that good. Communities of Dearborn, Inkster, Garden City,
Farmington and Southfield all contribute combined sewer overflow to the Rouge
River.
The alternatives performed better for the Detroit River than the Rouge River. You
can see that with the CSO volume up here there is great variability in the amount
of CSO. Some alternatives do control quite a bit of it and you do get some real
reductions compared to the Future No Action in fecal coliform concentrations
brought about by the alternatives. Alternative 12 achieves the highest water qual-
ity in the Detroit River by reducing overflow 76%. The hours of violation for
fecal coliform are reduced by 54% by this alternative. Quality doesn't change very
much. Alternative 12 for the Detroit River has a capital cost of $229 million.
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Having presented a summary of these water quality modeling results, we will now
turn our attention for the last few minutes to the components of the model that
produced these results. The combined sewer overflow study addressed many detailed
questions and provided many insights into the problems produced by DWSD and the
USEPA. We're not going to go into all those questions tonight; they're far too
complex and would take a long time. What we are going to do tonight is take one of
those we feel would be especially important. And that's the issue of initialization
data, (data used to describe incoming water quality). It is important not just be-
cause its an academic study but because those of you who are concerned about water
quality in this area should keep it in mind when facility planning is resumed.
In the Rouge River there are four headwaters location, again at the end of the blue
model portion. Now facilities planners used monthly average, dry weather concentra-
tion for each parameter and each of those headwaters to start the model. Given
enough other information you can generally tell what the water quality is along
here. But at each starting point you've got to tell the model what to start with.
The model was set up so that it needed a concentration for each month. They didn't
want one for each day, that would have been far too difficult. And a year wasn't
really enough. So we started with one concentration per month for each of those
parameters at each of those points. So for dissolved oxygen for the month of April
you need a concentration here, here, and here and so on. Now since the model is to
run for 9 months and there are four headwaters to model, you need a total of 36
average concentrations to start up the model for each of the parameters; nine
months times the 4 headwaters. Now ideally, of course, there would be data; actual
sample data which you could use to get these initializing concentrations. However,
that might not be expected to exist in reality and it didn't. Often times in water
quality modeling, the modelers are forced to rely on some of their own judgement to
fill in points that just don't exist in sample data. Unfortunately in this case of
the 36 average concentrations required, for dissolved oxygen, fecal coliform, and
phosphorus, the existing data gathered by others in the past and stored in a
retrieval system supplied concentrations for only 5 of the 36 necessary points.
Which is 5 out of 36. The other 31 had to be supplied with the best engineering
judgement. In the case of other water quality parameters, it was even less en-
couraging because there was only 1 sample, and that wasn't even an average. That
was just one sample, of the 36 that were necessary. So although some estimates are
always necessary and are expected in water modeling, it was unfortunate in this
case that there was not more data available with which to initialize the model. Now
fortunately for the most important parameter, dissolved oxygen, facilities planners
undertook a very extensive sampling campaign to get good data of dissolved oxygen.
They spent 31 days at various locations and collected quite a bit of data on dis-
solved oxygen. So for dissolved oxygen there is a high degree of certainty in the
accuracy of the initialized input data. For the other parameters, unfortunately,
there weren't very many dry weather samples to be used to start up the model. Now,
it needs to be understood at this point that the modeling was developed at. this
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stage to rank alternatives relative to one another, not to predict absolute or
actual water quality. To decide how much better or worse Alternative 5 might be
than Alternative 1, is an example. For that purpose, extensive use of best
engineering judgement is all right because once the model is calibrated and the
methodology is down correctly, it won't make much difference what values you start
with, the rankings can still come out the same. Alternative 19 will be better than
Alternative 11, no matter what you started with. The difficulty comes in trying to
use the data to describe the actual water quality. For that purpose, the extent of
these engineering judgements prohibits us from placing much confidence in the re-
sults of the water quality model. It's important to keep in mind the different
purpose the model was developed for. Remember also that it was originally intended
in the next stage, the detailed stage, to do more detailed analysis, and perhaps at
the end of that be able to predict absolute water quality. At the stage the process
was stopped, the information was not sufficient except dissolved oxygen, to predict
with high confidence the input data to initialize the model.
The other area of comment tonight is the cost/benefit analysis. Although the def-
inition of benefit is quite reasonable, the alternatives did not produce suffi-
ciently different water quality results to permit meaningful calculations of bene-
fit. As it turned out, this definition did not allow a very good idea of the
alternative. Look at how the numerator and the denominator are calculated in the
definition of benefit. The denominator is the difference between the concentration
in the Future No Action and the concentration of the best alternative and that
makes up the maximum possible improvement of the river in terms of quality.
Now we'll look at these differences in that slide, also included in your packet.
Looking at these differences, we can see that only for fecal coliform is this
difference greater than 10%. Here's the concentration for the Future No Action,
and here's the best alternative. Subtracting those two gives you the difference.
Now how great is that difference compared to Future No Action. In most cases, the
difference turned out to be very small. Now the small difference is not only a
problem itself, because it's so small you're not quite sure how much faith to put
in it, but it masks the meaning of benefit value itself. Consider a case where the
denominator is 4%. If the particular alternative offered an improvement of 2%, and
the next slide will show this, the benefit would be calculated as 50%. So let's
say the denominator was 4%, the numerator was 2%, the benefit turns out to be 50%.
Now as you're reading the report if you just opened to this page you might think a
50% improvement is quite sensational. That's quite good unless you realize that it
was based on just a 2% difference. Such a small difference may not even be statis-
tically different. Now again, for simply ranking alternatives this system will
work.
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The other important point that needs to be considered about evaluating the cost/
benefit analysis is that of choosing which project or which level of spending is
the most desirable. We mention this tonight because this is a tactic that's going
to concern all of us, not only in this project, but in the future when government
or any one else wants to spend money. The question though is, "How far should they
go?" When the project is driving, you're basically in favor of how much should you
spend. Should you buy a Cadillac or an electric powered car. Just how far should
you go? In cost/benefit analysis, you move up this curve you get less and less
benefit for each additional dollar you invest. That's the way most things work.
The question to be answered then is where along the curve do you want to stop.
Traditionally in economics, resources have been assumed to be unlimited, and if
that's the case and if both benefit and cost are in the same terms (dollars) then
you usually want to stop spending money at a point some where about right in here.
Up to that point, you were getting more than $1 benefit for each additional $1 it
cost. Maybe you spent $1 and you go an additional $3 in benefits. You were doing
real well. Then some point, in here, you spend the next $1 and you get $1 back.
Beyond that you spend $1 but you get less than $1 in benefit back. So the logical
place to stop is where that additional benefit equals the additional cost. That is
a traditional stopping point.
However, when there are scarce resources as we face today, the question we should
all ask ourselves in the future is "might it be better, if we still have the scarce
resources, to choose a point some place down here where we clearly get more than $ 1
worth of benefits for the dollar it costs?" Now you don't want to take that to an
extreme because if the curve looks like this, you'll never get off the ground.
You'll stay right down here at the origin. But some place in between here and the
origin is a place future facility planners might want to consider targeting for
their level of spending for the project, not carrying all the way to the point-
where you only get $1 worth of benefits for the last dollar it costs, but, stopping
at some point where you get $2 or $3 of benefits for the last $1 it costs. As you
might expect the method of trying to maximize additional benefits for the last
dollar you spend and the method used by facility planners produces different
results. You're going to select different alternatives based just on cost/benefit
analysis. So it's not just an academic point, it will produce different results
for you.
That concludes our most important comments like I say, in your documents you'll
find these more fully explained, we simplified a great deal tonight. You'll find
these subjects fully explained as well as many other topics which we did not have
time to touch on tonicrht.
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Mr. Swinick
The final chapter in any study, of course, is recommendations and that's what I
want to cover briefly. It's Chapter 11 in the volume. It's four pages long.
Before I get into specific recommendations, let me set the background. This is a
USEPA document and USEPA works within a specific system. It was given a situation
where facilities had been suspended. It was given a situation where there were
basically no recommendations from the grantee, the City of Detroit to the USEPA on
what to do about the combined sewer overflow. The City provided an interim report
which was supposed to identify the few best alternatives. It didn't choose any
alternative for funding. As such and because of its role, the USEPA had basically
no request to act upon. So this document doesn't recommend a combined sewer
overflow action alternative. The document as stated by David and Jim Novak before,
is the USEPA's attempt to briefly review and summarize the efforts that have been
made to date. The report also raises some questions and suggests areas where
further information may assist greatly in the future evaluations.
There are four major areas on Chapter 11. The first is alternatives for evaluation.
Because of many uncertainties, the evaluation of alternatives in the future should
not be limited to the few best that were chosen in the Alternatives Facilities
Interim Report as it is known. Those uncertainties include the use of the North
Interceptor East Arm, the size of pump station #2 which is the pump station that
would connect the North Interceptor East Arm to the existing treatment plant. (It's
not as yet known what size that would be or what would be done with that intercep-
tor. ) Also, uncertain is the participation by communities within the DWSD system.
That's quite a hot issue right now and that will affect alternatives in terms of
their size and flexibility of the DWSD system to handle flow in the future. Thus,
when all of that is settled and when facilities planning is resumed, it is recom-
mended that the development of alternatives take those new situations into consid-
eration.
The second area is in the area of modeling considerations. As Dave just explained,
there is some unresponsiveness in the alternatives. The report concludes that this
should be analyzed to determine how to structure the future analysis to avoid this
problem.
In the area of benefit analysis, it is recommended that rather than using a single
point on the curve to choose the optimum alternative, (be that the area where one
more dollar of expenditure gets you one more dollar worth of benefit or the area
where the technician would say that the change in benefit compared to the change in
cost is maximized), that somewhere between those two points on the curve is the
area where one would consider potentially funding an alternative that would deal
with Combined Sewer Overflow problems.
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The fourth area is systems control and this is the area where there is quite a bit
of discussion. There are four major areas under systems control: operating
philosophy; computer systems; instrumentation survey; and a preventative mainte-
nance program which are discussed in the recommendations section. Given the
circumstances where we have basically a hold on combined sewer overflow planning,
the system control center presently provides the best opportunity to maximize the
ability of the treatment plant, interceptors and collection system, to reduce
combined sewer overflow pollution. The existing system should be utilized to its
maximum capacity. The system holds opportunities to do that. To start, an
explanation and a further evaluation of the operating philosophy of the entire
system should be presented. Also, verification of the potential storage volumes,
that have been reported, within the system would be helpful. In terms of the
computer system itself, it has been reported that the computer system currently
doesn't reliably perform its function all the time, and that major components such
as the central processing unit, memory and disc drive are also unreliable. It has
been recommended that they be reevaluated and if they are unreliable, then those
findings should be presented to the agencies. In addition, it has been stated that
the software program which has been built into the system, that takes in informa-
mation from the various sensors, was developed some time ago, and that it has been
modified maybe on an annual basis, and that an overhaul of that entire software
program might result in considerable benefit to the system. Documentation of this
situation should be presented. An instrumentation survey might be required since
it has also been reported, although we don't have significant data to back up these
details, that the sensors in the field might not be operating properly. There is
not thorough documentation regarding the status of level sensors in the intercept-
ors and proximity sensors. It is, therefore, recommended that a thorough survey of
that equipment be done to determine: what the remaining sensor life might be; how
sensors might be protected from damage (what procedures might be necessary), and
whether to replace or upgrade those devices to help maximize the system's ability
to store combined sewage and minimize overflow. The final recommendation was a
preventative maintenance program consisting of all the elements that I just des-
cribed. These together would be designed to minimize the reported quick erosion of
the sensor reliability and provide a method whereby the City can minimize combined
sewer overflow problems by efficiently using the facilities that it has in place
with a minimal amount of capital expenditure.
Those then, are the recommendations of this CSO report.
Mr. Novak
And keep in mind these are recommendations. Since facilities planning was sus-
pended on CSO, it is the best we can offer at this time. Now I guess it would be a
good time to open it up for questions, if anybody has any questions.
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Mr. Dean Elworth - (City Engineer, Dearborn)
We were told by EPA we were not in compliance with PL 92-500, that we should clean
up our overflow. We applied for a permit to discharge into the Rouge River our
combined sewer overflow and we were told that by a certain date, we have to submit
a plan on how to comply with EPA standards, which was plainly speaking to have
fishable, swimmable waters. We hired a firm, completed our plan, submitted it to
MDNR where it's been sitting. Why did we waste our time doing it? What are the
standards now? Is someone going to come and pick up our mayor and council and
throw him in Jackson because we haven't complied with those standards and violat-
ing permit? What are we doing?
Mr. Novak
First of all, I wish there was a representative from the State at this time to ans-
wer your questions. As far as how you completed Step 1, I don't know where you are
on the priority list and the possibility of getting funding. But in exploring the
problems within the U.S. or just the problems within this State, just the higher
priority projects are the ones that go forward. As far as the standards of the
State, the standards to meet, there is and will be a continuing program to permit
discharges we refer to the NPDES permit program. There is no more Step 1 and Step
2 funding per se, as of the latest amendments to the construction grants program.
But there is funding for construction and combined sewer overflow is eligible for
funding through fiscal year 1984 and then in fiscal year 1985 there is a set aside
which is under the discretion of the governor which would take care of those
projects which would no longer be eligible. Combined sewer overflows are in that
category. If the State determines that a particular problem is such that it is of
high priority, then that project will go forward.
Mr. Elworth
I realize that, but does this decision mean that you're going to amend or reduce
your standards and requirements. We're in the same boat you guys (City of Detroit)
are, we can't do anything with combined sewer overflow before anybody else does.
Mr. McGrail
The standards of course are set by DNR. They have to be more or less consistent
with what EPA desires or at least as stringent. But generally they are set by DNR.
The problem we have, the problem that you have, is that if you have one CSO a year
during a low flow period which is perfectly possible; a July thunderstorm during a
low flow period; you're going to have contamination of the streams, or violation of
the water quality standards. So you never, with CSO, so long as you still have
CSO, are you going to be able to control the quality of the stream. That's a fact.
So you're running up into a catch-22 situation. We propose facilities that we know
are doomed to a modest level of failure at the instant that they're put into
operation.
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Now in a situation like this you have to play the part of Cheshire cat. You have
to ask the question where you want to go depends on what you want to do. If the
City of Dearborn feels that water quality and the public good will be preserved by
improving the Rouge River, installing the CSO control facilities, I think that has
to be said as a high agenda item. You have to essentially go to the State and de-
mand money for it. On the other hand, you might say, "Look, if you're not going to
do anything, you're going to put it so low on the priority list that you'll never
get funded, then why not just tell us to go away and don't waste your time."
Essentially, that's what we ended up doing. That's about all I can say. Go to the
State and demand money or demand to get off the priority list.
Mr. Elworth
Nobody is going to spend that kind of money if nobody else does.
Mr. MeGrail
I agree. Absolutely!
Mr. Novak
I don't know how to really address your problem. It has to do with the prioritiz-
ing of projects based on the limited amount of dollars. I think that it is going
away from the report on the CSO which was the purpose of this meeting. I
appreciate your concern.
Mr. Makinerny - Resident (City of Dearborn)
From the City of Dearborn. Just as a point of information, the suspension of the
facilities planner, what's the date that that happened, approximately?
Mr. McGrail
DWSD officially terminated Giffels/Black & Veatch - a joint venture, the facilities
planning consultant on June 25, 1981. I think that's right. Some people in the
audience might remember that. But somewhere right around that date, June 25, 1981.
Now the decision to terminate on or about that date came a good deal earlier than
June 25, 1981.
Mr. Kevin Tourneur - (Southeast Michigan Council of Governments)
Just to clarify a point, we should understand the USEPA and the City of Detroit are
not setting a precedent for CSO planning within a region by suspending their work
or their future plans, etc.
Mr. Novak
That is correct, there has been no decision to terminate the planning. It was a
matter of suspension. (The Federal District Court decided to suspend CSO planning).
I again disagree with John on some of the major reasons why the planning was
terminated, but if you look at the total dollars at this time that would be
required to complete planning for construction, with capital costs esti-
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mated over a billion dollars in the more costly alternatives, it is questionable if
those dollars will be available in the near future. A good question would be, "Why
spend the dollars to complete the planning portion now when we aren't sure that the
dollars will be available in the future for construction?" That kind of picks up
on the earlier question, perhaps one of the reasons why CSO planning was suspended.
Mr^ Swinick
Let me interject, I think that's a fairly critical point. The law is on the books,
the Water Pollution Act has been amended by the Clean Water Act and then amended
again this past year. Fishable, swimable waters is still the intent of the
Congress. The State still sets standards, the EPA still funds combined sewer over-
flow planning. In the City of Detroit's case, it has been suspended, not stopped.
A decision hasn't been made to quit and not do it again. It's just been suspended
because of circumstances.
Mr . Kevin Tpurneur
There's a number of other projects currently being worked on, and studied within
the region that are considering abatement alternatives and it's important to know
where they should focus their efforts.
Mr. Ken Bonner - (Wayne County Department of Public Works)
To add to what the gentlemen from SEMCOG just said, one of the problems you indi-
cated for being unable to improve the main branch is because of the background
water quality of the branches. We are undertaking, we have just completed essen-
tially, the study of those three branches. Looking at some 63 CSO sites on the
three branches, our Alternatives indicate that we can improve the background water
quality and it would seem most unfortunate if you could not pick up on the improved
background water quality and rerun your model with those improvements built in to
finally get a coordinated study. This study has been proceeding apparently
concurrent with yours but never together.
Mr . Novak
The study that has been going on has been a facilities planning study. This is
just the review of the work that was done. We are aware that there have been many
efforts to coordinate the facilities planning in this area. That is also one of
the recommendations in this report, to make sure that you have a combined look, so
you have a better idea of the quality of the water upstream, and a basis for vali-
dation of the models.
Ms . Mary Richardson - (League of Women's Voters, Citizen Advisory Committee - DWSD)
Was there anything put in there about the recommendations that came through from
the Combined Sewer Overflow Committee on DWSD? Were those incorporated in there?
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Mr. Novak
There is. I think the best person to answer that would be Peter Swinick because he
most intimately worked with them. But there is the section on public participation
recommendations.
Mr. Swinick
It's fair to say that the recommendations of the CAC were considered in detail. As
you know, we have a very good "give and take" between the Citizens Advisory Com-
mittee and the consultants, the City and USEPA. Are you speaking of something
specific that you feel is missing?
Ms. Richardson
Yes, coordinated approach that was right on from the very beginning for the need
for a coordinated approach and the fact that this is a piece meal approach to split
off DWSD, our feeling on that committee was right from the beginning to split off
from to put DWSD through that kind of thing when it's just a portion of the total
watershed and that's the same thing we're telling them that the Rouge Valley sewer
service area.
Mr. Swinick
Can you touch upon basin planning? - John/Jim
Ms. Ri chardson
You need basin wide planning on something like this. This was a strong recommenda-
tion of the CAC. I don't see how you can do it any other way. And you left another
big fat hole in there, its storm water management apart from the combined sewer
overflow and its structural consideration you're thinking about having it (storage)
in a floodplain area and if you don't control the storm water or have some plan for
that coming in, you're going to be in wet water more ways than one.
Mr. Novak
The recommendation of the report is to coordinate the effort of facilities planning
that is going on, to use the information that is developed so that you get an
approach which is taking into account other planning done in the area. Facilities
planning requirements require you to look at the effect of whatever action you're
doing on the receiving stream. But in looking at the effect of what you're doing
on the receiving stream, you have to take into account the effect on other things,
other facilities, other discharges, to the streams. So it should be a coordinated
effort that way. As far as the basin approach, that would best be left to the
State to propose as a project to go ahead if its presumed to be the high priority.
It would not be appropriate for the DWSD to get into the planning of all stretches
of the Rouge and Detroit Rivers to do facilities planning for areas which are out-
side of their service area. To get information from these areas, yes, but to do
the facilities planning for these areas would be inappropriate.
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Ms. Richardson
You're dumping your responsibilities right here.
Mr. McGrai1
Mary, we recognize that there is a problem with the lack of coordinated approaches.
Between, for example, Wayne County and Oakland County and ourselves.
Ms. Richardson
That intercounty coordinating committee hasn't worked out at all.
Mr. McGrai1
The so-called Act 200 committee has come to some reasonable conclusions on the
subject which sort of indirectly relates to CSO. For example, Oakland County, the
Evergreen-Farmington District of Oakland County, wanted service through the Depart-
ment's sewer system. Well, as you know, the Hubbell and Southfield sewers are
strained under wet weather conditions, they've been strained for years. In fact,
the West Arm Interceptor was partly to relieve those two sewers. Take the dry
weather flow out. Well, we're not going to have the West Arm. But we still have
the relief problems in the Hubbell and Southfield sewers and the CSO to go with it.
One of the approaches that we are considering now is to divert flows from the Hub-
bell Southfield system over to the First Hamilton relief sewer which is quite a
large sewer but relatively unutilized. Now, what that will do is provide adequate
service for Evergreen-Farmington but at the same time it relieves the Oakwood
Northwest Interceptor system sort of indirectly. If we can relieve the Oakwood
Northwest Interceptor all the way down the line, down towards the plant, we also
will be able to relieve some of the combined sewer overflow problem. But that's an
example of a coordinated effort because what that will require is the connection of
a linkage between the Hubbell-Southfield and the First Hamilton. Money from that
will come from Oakland County. Oakland County may see it a little differently, but
it's a question of negotiation. The fact of the matter remains that this is an
example of regional cooperation. Now that also provides some benefit to Wayne
County, because Wayne County has some, we have some capacity problems in the face
of Wayne County. If we could relieve the Oakwood Northwest Interceptors, then
Wayne County would have more spaces in the system which would also be relieved.
Ms. Richardson
But historically speaking from the League's standpoint, Detroit and Wayne County
haven't even talked to each other which is not very good from the citizens' stand-
point. Everybody gets shortchanged on that. I didn't know whether this was a
meeting, whether we could make a recommendation, that some group could be able to
do that for the citizens, because everything has come to an impasse up till now. I
do think that the facilities planning has opened up the process so that we got a
real good start on getting something going and I hate to see that go down the
drain. Speaking of drains. Either through SEMCOG or particularly on the Rouge or
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a beefed-up Rouge watershed council get some coordination. There are things going
right now. Maybe you could get talking together again but I know it's a problem
but I think it deserves something more than having these things just pulled out
from the shelf and not being handled any further because some of these things could
be addressed.
Mr. Swinick
I think your point is very, very well taken. It runs into a very interesting sit-
uation in that its one of the few situations across the country that I know of
where the problems extend into many many jurisdictions, three counties, you have
such a large utility agency that still doesn't cover the whole area.
You also have situations where the federal law, the construction grants program,
doesn't necessarily lend itself easily to solving the problem either. Because, to
fund it under what we knew as Step 1 , requires a grantee or an agency, and there
doesn't seem to be any convenient agency around to fund it under. That leaves
other sections of the law, and as Jim said, it appears to be best left in the hands
of the State to make the decision on. Maybe a basin-wide planning analysis needs
to be done, but that's not something that the federal agency can recommend for-
mally. It's really a state decision. Maybe they can talk in the back room with
the State on it.
Ms. Richardson
But where do our recommendations go? They don't go to the EPA, do they go to the
State? Does EPA want a copy of this? It used to be a public hearing on what you
did. Now is this the whole thing?
Mr. Swini c k
Well, one subtlety, this is not a public hearing, this is a meeting. (Audience
breaks out in hysterical laughter) I knew I shouldn't have said that. Somebody
had to say it and I guess I was the goat. That's another one of those little
federal regulations. They mean different things. Jim that's a question for you.
How to they get that recommendation to the state? Copy you?
Mr^Novak
Okay, you're talking about a basin-wide approach.
Ms.Richardson
Any river that needs it.
Mr. Novak
The State has the responsibility for water quality within the confines of a basin.
So your recommendation should go to the State agency. As far as your input into
the public participation program, the concept of the basin wide study didn't
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make it into the final document. Coordinated facilities planning, reemphasized
that it needs to be done, was included. Basin-wide planning itself was not
recommended because of the limitation that was alluded to before about the need
for a singular grantee to take on that responsibility. The "coordinated effort,
working together" type of approach is necessary or a lot of money will be spent in
a direction where we're only dealing with pieces and parts and not the whole. So
that recommendation, the concept of that part of your recommendation, was put into
the report.
Mr. John Chasesa - (Lake Erie Clean-Up Committee)
Talked about solving problems at a local level, claimed no benefit from EPA
involvement and wants DWSD to assist in clean up of Lake Erie.
Mr. No vak
The concept of looking at these things locally as opposed to the regional concept
illustrates a philosophical change or redirection nationally. Initially, when the
program started from a EPA perspective, one looked at the megopolis. You look at
the large project because there was an economy of scale, you built one plant to
take the waste of the surrounding communities, and that plant, by building it
larger, is going to have a lower unit cost. That was the philosophy at that time,
but that has changed. There has been a redirection or reemphasis. The great
example of that is when you look at your rural or almost rural communities where
the emphasis today is on innovative and alternative methods of treating waste. It
gets back to on-site systems, mound systems, cluster systems, cluster-mound
systems. It's a redirection of how to solve problems. You have to identify the
problem, you have to define the problem and you have to look at reasonable
solutions to address it. So from an agency perspective, we have contributed on the
Detroit project. We've provided money, we've done an environmental impact state-
ment on the segmented facilities plan, we were doing one on the final facilities
plan. We have provided input throughout. Our input on the EIS has changed and
redirected the planning for Detroit and has limited expenditures. We can go into
cost savings in dollars saved by not doing some construction. There has been quite
a bit of benefit derived from our participation.
You're talking about Lake Erie clean up? There has been a remarkable reduction and
I don't have numbers in front of me and I'm not a number quoter anyway. But there's
been a remarkable reduction in the amount of phosphorus, which was originally
attributed to the wastewater treatment plant, which now is treated because the
plant has been providing secondary treatment since June of last year. The limit in
the permit is 1 milligram per liter and from, this is off the top of my head, from
looking in the past monitoring reports for the year, it's averaging somewhere in
the neighborhood of .6, .5. So there have been improvements. While the goal of
our agency is pure water, you have to work at it over a time, with the limited
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amount of dollars that are available and you have to do it by prioritizing and
approaching the problems the best way you can. I don't mean to jump back at you or
anything like that but it's just that there have been improvements. This is the
system that we have now, this is what we're trying to work with and we're doing the
best we can.
Mr. Chascsa
I'm not up here to pick an argument with anybody. But I am very disappointed, very
disgusted. Since 1962 when Jerry Reeves made the statement that we would want the
people in Detroit to put diapers on ducks before they flew over our part of the
community in Lake Erie and I have to tell him to try some of the samples that I
presented at the first conference in 1962. Drink the sample water. For all of the
specialists to taste the water and use it for anything to dampen their hair, but
they wouldn't even do that and the water was supposedly cleaner than it was in the
past 40 years. You're having the same problem now on the Rouge River and the only
solution is for the industries to treat their own waste. You can't take all the
waste and put it together and expect Detroit to be able to take care of it.
Because I don't believe that's a matrix plant. If it's a matrix system you may be
able to do it. You would have to have the facilities to do it. It might cost a
little bit more money, but it would be something that would be workable. If each
industry took care of their own waste, and I know this can be done, because Detroit
Diesel did it. They were dumping in the Rouge River and we contacted Detroit Die-
sel plant and we suggested different things to them. They put in treatment and
they were a very good neighbor in that part of the Rouge River. They cleaned up
their water and put in better water than you can find in the Rouge River.
Mr. Novak
You're opening up a lot of questions, things like pretreatment requirements, and
other areas which are really going beyond the intent of this meeting.
Mr. Chascsa
I realize that, but if you intend to clean up anything or to make it any easier to
clean up, this is what will have to be done. You can't just push it off on the tax-
payers. The taxpayers are the people that are going to pay the bill and try to
pay it. Some of them will probably do without their cup of tea. I'm sorry that
I'm not in better condition because I had a heart attack. But I certainly thought
that I would hear something encouraging that would make me feel a heck of a lot
better than I have been feeling in the past three years. I know that this can be
done. I've seen it happen. I've seen the lake clean up. I've seen the time when I
couldn't eat the fish out of the lake and today I'm not afraid to eat them, be-
cause they do taste like fish not like fish full of dirt and oil or something and
they don't smell bad. But anyway I thank you for the opportunity to get a little
bit off my chest. But I have some pamphlets here if you would like to take it with
you. You'll find them quite interesting.
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Mr. Cruz
(For the record, Kenneth B. Cruz representing the City of Allen Park)
Mayor Latta asked me to read this statement into record and also submit it as an
exhibit of this meeting. The City appreciates the opportunity to comment on this
report. We've got a special interest in this report for two reasons. First a por-
tion of Allen Park is served by the Detroit System. Therefore our residents are
affected by these changes in capital and O&M expenditures. Secondly, the City is
served by a combined sewer system for which a facilities plan has been prepared,
which comes to diametrically opposed conclusions to your report. Our general
comments are as follows: First, the conclusion of the report which is based on
modeling and analysis indicates that little or no activity relative to CSO is
warranted at this time, particularly in regards to the Detroit River overflows.
The City of Allen Park agrees with this finding in general and has found that using
the same methodology of analysis that for a similar but a smaller combined system
in Allen Park that little or no action would result in the most reasonable solution
there. Second, we find it ironic and tragic that the EPA is encouraging the expen-
diture of approximately $60 to $100 million for sewer separation in Allen Park,
which comes to about $5,000 - $8,500 per household with all its disruptive effects,
while sewer separation alternatives in the Detroit study ranked among the poorest
choices of the 25 evaluated. The costs of the highest ranking alternatives in the
Detroit report are $130 to $145 per capita. How can EPA and DNR justify the
extreme disparate treatment to the different portions of the same small city. We of
the City of Allen Park believe that the basic recommendation when planning is
resumed, that primary consideration be given to inline storage and interbasin
transfer is appropriate. Allen Park would like to submit that this similar finding
should be applied to that part of the City of Allen Park served by the Wayne County
system. Allen Park's request that the EPA and DNR consider these findings and
bring uniformity to CSO planning in the Southeastern Michigan or at least to the
City of Allen Park, before $60 to $100 million dollars are wasted on sewer separa-
tion. We suggest that EPA and DNR take proper action to alleviate this serious
discrepancy. Finally, Allen Park agrees with the findings that there is a need to
look at the overall collection and treatment system in detail before a conclusion
should be reached. This was not done to the City of Allen Park which has led to
erroneous conclusions.
Our more specific comments will be submitted in writing in the next few weeks on
this report. Again we appreciate the opportunity to comment and we urge the EPA
again to act on bringing uniformity to CSO planning in Southeastern Michigan before
a major misappropriation of public funds is made. As it currently appears, EPA and
DNR intend to pursue a wasteful sewer separation project in Allen Park. We request
some indication from these agencies on these comments and their policies.
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Mr. Novak
The effects of concerns that are raised are really very difficult to handle one by
one at this time. That will best be handled in the responsiveness summary. As far
as consistency on how the citizens of Allen Park are treated, since you're talking
about a portion of Allen Park being served by Detroit versus the remainder of Allen
Park by another grantee, in the planning there is a cost effectiveness analysis
which determines the most cost-effective way of addressing the problems in an area
as defined within the facilities plan. I am not familiar with the planning effort
going on in Allen Park. Again, your comments will be addressed in the responsive-
ness summary as would your subsequent followup comments if they're received in a
reasonable amount of time.
Mr. Robert Pierce - (Consulting Engineer, Black & Veatch)
I just want to be sure we thoroughly understand the EPA position which evidently is
distributed here as a final document and has been received by the public some 10
days ago. Does this actually constitute the official EPA policy regarding combined
sewer overflow planning in Detroit in conjunction to the planning process?
Mr. Novak
First of all, it's not really policy. It's just a recapitulation of planning that
was done with our concerns about that planning. In other words, a way of approach-
the problem when it is picked again, and some areas that we think should be looked
at a little differently. Again, this is not a decision document. It is a comment
on planning that was suspended abruptly, so that we know what was done and we know
limitations, how good, how bad the product was and where we can go when we pick it
up again. That was the intent and why the report was generated.
Mr. Rama Cherukuri - (Consulting Engineer, Rama Rao & Alfred, Inc.)
(Paraphrased) - Isn't SEMCOG the regional planning agency, and shouldn't all plan-
ning be coordinated through them?
Mr. Novak
Facilities plans are reviewed by SEMCOG's A-95 review board. (The A-95 review
process was recently revoked by Executive Order 12372. SEMCOG's Water Quality
Board does review facility plans for consistency with the State Water Quality
Management Plan.) That is, after facilities plans have been generated. As far as
the input into processes, it comes after the fact. It would be better if the
system was set up such that before the plans were generated there were some overall
coordination which is part of the problem that has plagued this project, too. Yes,
they are responsible for review of sewerage planning in this area. They're not in
the position of directing the planning. The overall water quality responsibility
relies with the State.
Mr. Cherukuri
The law does not say what time they should become involved?
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Mr. Novak
It does, it specifies when A-95 review takes place. (The A-95 review process was
recently revoked, but U.S. EPA Region V is developing a regional policy for consis-
tency with the State Water Quality Management Plan.) Reality is that the planning
conceptionally should have been statewide, then regionwide and then countrywide.
Realistically the way the program has developed is at a specific facility level,
working up the wrong way. Let me explain the way the system had worked and
generated. When the program started, the problems were identified. There was a
priority put on the problems. The planning was started. But realistically, the
State should have identified the problems and then should have looked at them from
the State to the region, then to facilities planning. Unfortunately, it is not the
way things have generally gone.
Ms. Richardson
I hope I made it clear, I have served on the CAC for both studies. We got some
really good information out of both of those studies and if they could just get
that coordinated we'd be definitely along the way for getting cleaner water.
Mr. Bheam - (DWSD)
How does this report differ from the Facilities Interim Report put out by another
consultant for the Department for the City of Giffels/Black & Veatch-joint venture?
Mr. Novak
The interim report put out by Gif fels/Black & Veatch was just as inferred by the
title, an interim report. It looked at and identified problems, looked at water
quality of different alternatives and it got down to a reasonable number, but it
didn't do the last reiteration and go into the detail necessary to complete facil-
ities planning on CSO. There was an ongoing environmental impact statement, and
we had intended to have combined sewer overflow included in the environmental
impact statement. Since the facilities planning was suspended on combined sewer
overflow, we would have no document in which to include this. We invested time and
money in EIS process. Since the facilities planning was suspended, we as an agency
could review the AFIR (Alternate Facilities Interim Report), but we wanted to
evaluate it technically and we wanted to see where we were at, so that when CSO
finally was picked up again, we would know where to go. This report does reference
throughout the work done by Giffels/Black & Veatch. It doesn't redo their work,
but it provides an audit type of approach and it makes suggestions and provides
some guidance for our future work. It's not intended to be a decision document as
was said before, but it provides a critique and some basis to proceed. Our agency,
and I hope Detroit, feels a little more comfortable in the work that was done and
we have a good idea of how useful the information is and where we can go from
there. That was the intent.
Dr. RaIph Kummler - (Wayne State University)
Is this report issued in its final version at this time?
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Mr. Novak
I don't want to give you a bureaucratic answer, like the difference between a.
public meeting, public hearing, and suspended and terminating and things like that.
There are different meanings. This is a bastard report (Laughter).
Dr. Kummler
Yes, I believe we've stated that for the record.
Mr. Novak
Meaning a non-standard report. The requirement for this report does not fall
into any nice little neat category. There are public participation requirements
for both facilities planning and environmental impact statement. There is a
hearing requirement at the end of the EIS process. There are public meeting
requirements throughout the process. There is public input provided through
Citizens Advisory Committee. This, today, is a meeting on this report which does
appear in final form. What will be prepared subsequent to this meeting and which
will address comments received within a reasonable amount of time is the respon-
siveness summary. The responsiveness summary will address all comments. This re-
port does not fall into a category of an EIS, it doesn't carry the weight to the
decision makers that an EIS would. It doesn't carry the weight of facility plan.
It is just a recommendation and it's to be used as a tool and nothing else.
Dr. Kyrnmler
There are serious omissions in terms of data that was taken that was not addressed
in this report. For example, Wayne State University is not mentioned as a subcon-
tractor despite the fact that we generated over 1,000 pages ( 2 PhD dissertations
and two master theses) and also put together some dozen or 20 technical reports in
the professional literature. I've submitted a list of omitted references which
bear heavily on the findings in this report.
Mr. Novak
Was this information made available to EIS consultants in preparation of this docu-
ment?
Dr. Kummler
No one's ever asked for it. It is saddening to see that the report was done in the
absence of substantial amounts of information that was gathered by the original
contractors.
Mr.Novak
Do you disagree with any of the recommendations as outlined in this presentation?
Dr. Kummler
Yes.
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Mr. Novak
Specifically, which things do you disagree with?
Dr. Kummler
There are a number of them. We have put them in writing already and I can still do
so.
Mr. Swinick
I think it fair to say that a responsiveness summary will be created on this
report. It's not the intention to redo the entire volume with the responsiveness
summary attached. But there is no problem if in answering questions the respon-
siveness summary has to go into significant detail and be 150 or 300 pages long.
That won't be the first time. So all questions and comments, new data that wasn't
provided previously or 1,000 pages of information that's on a computer disc that
never got printed out should be submitted if it bears on this report! Whatever it
is it can be included if we are made aware of it. If we can get the comments, the
questions, the information provided to us, it will be incorporated within in the
document. And if it is that significant and there are resulting major changes in
recommendations, then that can be done within the responsiveness summary as well.
Dr. Kummler
One of the major points of information that probably should be said here is in
relation to what the gentlemen spoke of Lake Erie. Of the problems in the Detroit
River, all of the numbers that you quoted deal only with a small fraction of the
Detroit River and there was a lot more of that river that flows down to Lake Erie
and which was being modelled, and those calculations are available, and were not
presented in the bar charts that you presented. The impression that we gain from
your report is that there are not significant problems in the Detroit River. I
think that there are crucial problems on the Detroit River. The impact of CSO cer-
tainly deals more specifically with the Detroit River because there is nothing else
there to be a major factor. CSO is a major problem by itself and when the Mayor
dedicates parks, plans come out for part or full exposure depending where you fall
out of your canoe or you dabble with your hand on the outside in that area some
1,000 feet below Leib (overflow discharge) I think you have to take that seriously.
When you plan a marina, it's not going to be real easy to convince the kids not to
hop off the back of the boat after a rain storm. And, there will be serious health
problems that will be associated with the future development of the City. I think
that will be another problem for development along the Detroit River. Of course, no
one mentioned the some 18 bathing beaches down river with some 60 marinas, down
river which are all impacted by what we do up here. None of that was mentioned in
your analysis. But again if you read Dr. Razinski's dissertation, you will see
some of the information that pertains to the entire river.
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Mr. Swinick
I thank you for that and I do hope that when the questions and the comments and the
data does come in that everyone recognizes that this report is not going to pick up
where the interim report left off. At that it is again a summary of what occurred.
It is not a decision document to pick and choose a combined sewer overflow alterna-
tive, and to fund one. It is a rehash, a summary of that background information,
and we'll be happy to receive more of it then we have had in the past. Thank you.
Mr. Steve Ode n - (East Lansing)
I'd like to get a definition of the amount of rainfall which constitutes wet
weather?
Mr. Vance
I think the Rouge River, for the wet weather conditions, it was assumed - because
the flow would carry pollutants out in about 24 hours from the planning area, (the
model planning portion) that essentially for the 6600 hours (April - December) that
it was continually a mixed state of wet and dry weather. While earlier there might
have been attempts to separate dry weather out from wet weather in the Rouge River,
as far as running the model goes, I think that in the end it was assumed that wet
weather would always be masking the dry weather. So as far as running the model
for the Rouge River, it was assumed basically to be in mixed state. The Detroit
River was a different story. I don't remember right off hand how many hours might
have been used. Maybe someone from Black & Veatch can help me. 1634 wet weather
hours out of a potential 6600 for the nine months. For purposes of the initializ-
ing data, if that's what you're referring to, I think at least as we checked the
data that they used, that the dry weather data was defined as for those periods
where it did not rain for at least 24 hours before hand. And most often the data
went well beyond that to 48 or 72 hours of no previous rainfall if it was to be
counted as dry weather.
Mr. Oden
Some of the data I have read seemed to indicate that after a couple of tenths of an
inch of rain, real problems existed. And it seems to me that this system shouldn't
have been designed to carry only a couple of tenths of inches of rain.
Mr. McGrail
Unless I'm mistaken you have to decide what constitutes a rainfall of measurable
significance. In Detroit area you have pretty much distributed rain throughout the
year, or distributed precipitation. There was a figure arrived at that constituted
the beginning of a wet weather condition and I think if was like .0095 inches of
rain an hour. Something of that nature.
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Mr. Devanso (DWSD)
I don't know John, but a couple of tenths of an inch of rain is a significant
amount of rain. If a quarter of inch of rain falls and you have a catch basin area
of 140 square miles, if you just consider a runoff factor of just 50%, you start
multiplying out the number of gallons coming into the sewer system, a quarter of an
inch of rain or even a tenth of ar inch of rain is very, very significant. The
system is designed to tak° (drain) 1.95 inches per hour. That was based on the
rainfall curve from all the way up through the 1940's when those design curves were
established. But let's say a tenth of an inch of rain over this area would be a
significant amount of rain. And you have 70 some overflow points, which means that
you have 70 some drainage districts. And some of those are very small. If you go
back and look at some of the data that was done a number of years ago, some drain
districts hardly every overflow. Thev were way over-built and other ones will tip
at the drop of a hat. What we established way back in the early 70's was that the
system fell within the textbook analysis; they overflow 2% of the time, but some
overflow a lot more than 2% and some are a lot less.
Mr. Oden
Does the City of Detroit have a plan for requiring site retention of drainage on
new large projects such as parking lots, shopping malls?
Mr. McGrail
Let me say this. I suppose that they do. However, as you well know, there isn't a
great deal of large construction going on. I do know for a fact that the new Cad-
illac facility auto assembly plant, it's up in the controversial Pole town area,
has some storm attenuation facilities associated with that. Of course, that's 465
acres of virtually all paved territory which at one time probably had a run-off co-
efficient of 50%. But in that facility they do have some storm water attenuation.
Basically, I think it's just parking lots and roof retention, but insofar as the
rest of the city is concerned, there isn't a lot of brand new major construction
going on in the city. There is no attempt to go back and correct. For example, we
don't eliminate obvious inflow sources such as the footing drains around buildings,
we just live with them because there is no functional purpose for removal since it
flows into the same system anyway.
Mr. Steve Williams - (Consulting Engineer, Williams & Works)
In reading the Alternatives Facilities Interim Report, another aspect of the prob-
lem which may help address this gentleman's questions is that the Alternative
Facilities Interim Report states that there's relatively little difference in qual-
ity between urban storm runoff and combined sewer overflow. Some of the effected
stream quality parameters may not be from the combined sewer overflow but the urban
storm runoff.
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Mr. Novak
If there aran't any more questions, I'll close the meeting. I thank you all for
your comments and for coming. Does anybody know where the signup sheet is? If
anyone wants a copy of the document let us check your name off and we'll get you
one within a week. Thank you again.
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