United States
             Environmental Protection
             Agency
Region 8
1860 Lincoln Street
Denver, Colorado 80295
 v>EPA     Record of  Decision
EPA 908/5-79-002E?
September 1980
Northglenn Water Management Program
City of NorthgSenn, Colorado

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749315/
                 EPA - 908/5-79-002D
                 RECORD OF DECISION
           NORTHGLENN WATER MANAGEMENT PROGRAM
             CITY OF NORTHGLENN, COLORADO
                    EPA
                    Prepared by

          U.S. Environmental  Protection Agency
                   Region  VIII
                1860 Lincoln Street
               Denver, Colorado 80295
                        Approved by>
                                ' Rojfcr LV,Williams
                                   jgior&T Administrator
                        Date:

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                                TABLE OF CONTENTS

                               Record of Decision
                       Northglenn Water  Management  Program
                              Northglenn, Colorado

                                                                     Page

Scope of Decision                                                       1

Alternatives Including the Proposed Plan
     Descriptions of Options Within the Plan                            2
     Wastewater Treatment Alternatives                                  3
     Treatment Site Alternatives                                        3
     Water Supply Alternatives                                          7
     No Federal Action Alternative                                      9

Discussion of the Environmentally Preferred Alternative                15

EPA Decision                                                           17

Steps to Minimize Adverse Effects                                      25
     NPDES Permit Conditions                                           25
     EPA Grant Conditions                                              27

Response to Comments Received on the Final EIS                         35
     Agricultural Productivity                                         35
     Canal Lining and the Flow Augmentation Plan                       36
     Tailwater Control                                                 39
     Intergovernmental Agreement with Weld County                      40
     Reduction in Residential Property Values                          40
     Analysis of Recreational Potential                                40
     Provisions of the Clean Air Act                                   41
     Cost Analysis for the South Platte-Deep Well Alternative          41

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RECORD OF DECISION    .

 Scope of Decision"  ;.

     This Record of  Decision has been prepared  in accordance with  Che
regulations of the Council on Environmental Quality  (CEQ) and  the
Environmental Protection Agency (EPA) for  implementing  the  National  Environ-
mental Policy Act (NEPA) (40 CFR, Parts  1500-1508, dated November  29,  1978.)

     The National Environmental Policy Act requires  that Federal agencies  con-
sider environmental  factors and alternatives in their decision-making  process.
Section  102(2)(c) of NEPA establishes procedures for preparation of  Environ-
mental Impact Statements (EISs) for Federally-funded projects  which  have the
potential to "significantly affect the quality of the human environment".   The
scope of this record of decision includes all of the information and analysis
contained or referenced in the draft EIS,  final EIS, public hearing  records,
and public comment letters related to the Northglenn project.

Background

     Northglenn funded Step I and Step II plans without Federal assistance.
In September 1977, Northglenn presented  copies of their draft  facility plan to
EPA.  The Plan was revised in November 1977 and again in March 1979.   The
State of Colorado Water Quality Control  Division, in March  1978, submitted  to
EPA certification for Northglenn*s funding.  In accordance  with regulation,
EPA cannot award a grant until EPA has approved a facility  plan for  the
proposed project and performed an anlysis of the environmental impacts of  the
project under the National Environmental Policy Act.  EPA issued an
environmental appraisal/negative declaration on September 29,  1978 which
analyzed the current plan but left unanswered critical questions on  the impact
to agriculture and public health.  Subsequently, Northglenn modified its plan
to include purchase of agricultural water rights from the South Platte River
following denial by  the State Engineer of permits for nontributary deep
wells.  On June 27,  1980 EPA issued the  Final EIS analyzing the environmental
impacts of the Northglenn Plan.

ALTERNATIVES INCLUDING THE PROPOSED PLAN

Description of the Northglenn Water Management  Plan (Proposed Plan)

     The City of Northglenn, Colorado is proposing to construct a  multiple-
purpose water resource project that consists of a drinking  water supply,
wastewater collection and treatment system, an urban stormwater runoff
collection system and an agricultural reuse program.

     Northglenn has  entered into a water exchange agreement with The Farmers
Reservoir and Irrigaton Company (FRICO)  that allows Northglenn to  borrow from
FRICO up to 7,785 acre-feet per year of water stored in Standley Reservoir  for
municipal use.  Northglenn is committed  to return 110 percent  of the water
borrowed for municipal use to FRICO for  agricultural use.   Northglenn  proposes
to construct a year-round storage reservoir in Weld County  adjacent  to its
proposed wastewater  treatment facility.  Satisfying the payback requires the
development of a means of replacing the water borrowed by the  City plus
10 percent.  This plan for the water payback includes a proposal to  collect
and treat urban stormwater, plans to acquire sufficient ^surface and  shallow
groundwater supplies from the South Platte, and proposals to develop deep
nontributary groundwater.  Surface water supplies have been acquired through
the purchase of agricultural water rights and other water rights intended  for
developmental purposes.

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     Presently Northglenn's wastewater is conveyed by the Thornton system
and treated at the Denver Metropolitan Sewer District No. 1 (Denver Metro).
This service is provided by Thornton through individual contracts with
each property owner in Northglenn which will expire in 1988.  Consequently,
Northglenn has negotiated an agreement with Thornton whereby Northglenn's
wastewater treatment will be provided by Northglenn.  Northglenn's revised
facility plan makes the following recommendations for wastewater trans-
port, treatment, and disposal:

        Collection System - Northglenn will make improvements to the
        existing collection system which include sealing off several
        lines and connecting them to a new interceptor.

        Conveyance System - The proposed Northglenn Force Main (46,900
        feet) would carry sewage and augmentation water eight miles
        north of the City to the proposed plant site.

        Wastewater Treatment - The proposal is to construct an
        aerated, three cell lagoon system for treatment prior
        to storage and discharge.

        Storage and Disposal - A 4362 acre-foot reservoir (Bull Canal
        Reservoir) will be constructed in Weld County to provide for
        winter storage of the effluent.  During the irrigation season,
        FRICO has the right to call for release of water stored in the
        reservoir.  Consequently, the discharge rate will fluctuate
        based on the calls made for water from the reservoir.  Chlor-
        ination of the effluent will occur just prior to discharge from
        the storage reservoir to the Bull Canal irrigation ditch.

        Sludge Disposal - Sludge will be removed and injected in the
        surrounding agricultural land.

Description of Options Within the Plan

     Within the framework of the Plan four options dealing with water
supply have been identified by Northglenn and EPA.  Each of the first
three options assumes that wastewater and urban runoff are conveyed and
treated at the Weld County treatment site.

        Option 1  -  Northglenn obtains South Platte surface water
                     rights currently used for irrigation.

        Option 2  -  Northglenn is awarded 650 acre-feet per year
                     of nontributary groundwater, thereby reducing
                     the amount of South Platte surface water
                     rights needed.

        Option 3-  -  Northglenn is awarded 2300 acre-feet per year of
                     nontributary groundwater thereby eliminating
                     the need for South Platte surface water rights.

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     •Option 4 -    An alternative  to'these plans  is  for  Northglenn  to  acquire
                    its  future water  supply requirements  from FRICO  by
                    condemnation or purchase.  Wastewater under  this system
                    would be conveyed  to and  treated  at the  Denver Metro plant
                    with discharge  to  the  South  Platte River.

Wastewater Treatment Alternatives !

     Two wastewater treatment alternatives are identified for  Northglenn.   The
two alternatives consist of:  Northglenn's proposed three cell lagoons
followed by reservoir storage and discharge to the Bull Canal, and treatment
continued at Denver Metro.

     Northglenn's proposed wastewater  treatment  facility  has been described
previously.  Treatment at Denver Metro could  be  compatible with  all  water
supply alternatives considered with the exception  of  the  FRICO exchange
agreement.

     At present the wastewater from the City  of  Northglenn is  treated at the
Denver Metro Treatment Plant.  Expansion of the  secondary treatment  capacity
of the treatment plant is necessary in order  to  enable the treatment plant  to
continue to meet its present effluent  limitations  and treat  increased
projected flows from the service area.  In addition,  the  Denver  Metro
discharge permit requires that the  treatment  plant be upgraded to meet  more
stringent effluent requirements, including nitrificiation of the effluent.
Capital costs of the treatment of Northglenn's flow at the Denver Metro
facility were determined to be the difference between the costs  of building
facilities that are designed to handle the projected  design  year capacity with
and without the design flows from Northglenn.  The operation and maintenance
costs of the treatment of Northglenn's flows  at  Denver Metro were determined
by the prorated fraction of the total  operation  and maintenance  costs.

     If Northglenn were  to continue to have its  wastewa£er treated at Denver
Metro for the 20-year planning period, the capacity of the existing
interceptor system which conveys Northglenn's flow to Denver Metro through
Thornton (Northglenn is not a member  of Metro) would  be exceeded.  Costs were
also developed for an interceptor and  force main system that could accommodate
the increased projected  flows.  This  system would  serve Northglenn and  part of
Thornton.  The cost of this system that was attributed to Northglenn was a
prorated share of the capital and operation and  maintenance  (O&M) cost  based
upon Northglenn's flow and the total  flow.  The  cost  of these  two alternatives
for wastewater treatment are presented in Table  1.

Treatment Site Alternatives

     EPA conducted an alternative site analysis  for a wastewater treatment  and
storage system, which would be similar to  the currently proposed Northglenn
facility.  EPA recognizes that Northglenn has expended a  considerable amount
of time and money investigating and designing for  Site 10.  The  site analysis
evaluated three additional sites for  treatment and storage of Northglenn's
wastewater (see Figure 1).

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                                                       TABLE  1

                                              WASTEWATER TREATMENT
NORTHGLENN TREATMENT AND RETURN TO FRICO
. ITEM
Treatment Lagoons
Bull Canal Reservoir
Pump Sta. "A"
Force Main
Collection System
Field Monitoring

Dacono Disinfection
,
Tallwater Control

Maintenance Equipment

Construction Manager

Land & Easements
Contingencies
Engineering
Step 3 Engineering
Sub-Total
EPA Funding
TOTAL
Capital Costs
$ 2,643,100
4.354,700
597,800
1,729,000
10.151,100
57.400

20.000

110.200

150.000

429.700
,
161,400
1.082,570
2.212.600
513,000
24,212,600
6,948,000
$ 17,264,600
O&M
$ 260.800
86,000
32,190
14,430
98,160
35,100

1.600

1.500

0

0

0
0
0
0
529.780
0
$ 529,780
Salvage
$ 439,651
724,357
49,719
287.600
510.254
0

0

Land
72,000

f 0

0

0
180.074
0
0
2.198,855
0
$2.198.855
METRO DENVER TREATMENT
Item
Denver Expansion
So. Platte 15" Interceptor
Henderson Pump Station
Henderson Force Main
Washington Pump Station
Collection (Northglenn)
(Thornton)

Contingencies

Engineering'

Debt Service Existing

TOTAL



Capital Less
O&M (661,099
Capital
$ 662,679
670,312
866.700
1.847.376
49.819
546,800
8,991,900

900,777

501,400



$ 15.037,263


PRESENT WORTH
Thornton Pipes
Thornton Pipes
Sub-total
x 10.694644)
Salvage Value
Total P.W.
Annual Worth
llnlr C.nat

O&M
$ 383.389
21,400

18.100
300

97,900

0

0

88,800

$ 661,099



$ 6,045
7,991
14.037
7.070
(1,437
19.690
$ 1,839
1.41
Salvage
$ 66.822
132,973
85,966
366,473
0
71,594
713.507
Contained with-

•alvage value
0



$ 1.437.335



,863
,400
,763
,218
,335)
.146
,300 $/Yr.
S/1000 sal.
              PRESENT WORTH

Capital Less  Thornton Pipes
             Thornton Pipes
               Sub-total
O&M (529,780  x 10.694644)
Salvage Value
  Total P.W.
Annual Worth
Unit Cost
  4016 AF/Yr. from Northglenn
Average Household
  74x3x365
                                              4016 AF/Yr.  fron Northglenn
                                            Average household
                                              74x3x365
                                                                                                           114  $/Yr.
$  8,273,200
   7,991,400
  16,264.600
   5,665.808
  <2,198,855>
  19,731,553
   1,844,944  $/yr.
   1.41 $/1000  gal.

   114 $/yr.

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                                                             FIGURE 1
   LEGEND
2J1 STUDY AREA BOUNDARY
^ PROPOSED  SITE
II ALTERNATIVE SITES
   RESIDENTIAL DEVELOPMENT
~MAJOR ROADS
...-WATERWAYS
              Weld County
                                        ALTERNATIVE  SITE
                                          STUDY  AREA
                                                         N

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                                TABLE  2
             ENVIRONMENTAL EVALUATION MATRIX OF ALTERNATIVE TREATMENT AND STORAGE SITES
       CRITERION
                                      SITE A
                                                                     SITE B
                                                                                                   SITE C
                                                                                                                                  SITE 10
ijfology
Mineral Resources
Poult*
Suhftldr nee
Soils
Permeability
Suitability for Construction
Prime Agriculture Land
Tnpoftraphy,
Slop*
Flooding Potential
(>roundwater
Hcpth
Number of iells Onaltt .
L.ind Use
Current
Zoning
No. of Residences
Pronlmltv to Bull Canal
co.t y
No aand or gravel resources.
No active or potentially
active faults
Probably not of concern:
South of Boulder -
Weld Coal Field
Low pern., 0.06 - 20 in/hr
Hed. to low shear strength
Mod. to high ahrlnk-awell pot.
Yea - if irrigated

East half 3-5X slope to east
West half 0-31 slop* to es«t
Total elevation change 60 ft.
Slight

Perched: 6-12 ft.
Deepi 70 - 300 ft.
2(1 Municipal, 1 other uses)
Agriculture
A-J
None on sltet
20-30 within 1/2 mile
200 ft.
$30.247,900
No sand or gravel resources,
No sctive or potentially
active faults
Prohahly not of concern
South of Boulder -
Weld Coal Field
Low para., 0.06- 20 in/hr
Ned. to low shear strength
Hod. to high ahrlnk-awell pot.
Tea - if irrigated

0-31 slope toward southeast
Total elevation change 50 ft.
Moderate

Perched: 8-15 ft.
Dtep: 25 - 120 ft.
2(1 doneatlc, 1 irrigation
and stock)
Agriculture
A-3
-Non* on eite;
40 - 80 within 1/2 milt
900 ft.
$30,326,600
No sand or gravel reaourcea,
No active or potentially
active faults
Probably not of concern)
South of Boulder -
Weld Coal Field
Low pen., 0.06 - 20 In/hr
Med. to low sheer strength
Hod. to severe shrlnk-swell
pot.
Tea - If irrigated

3-91 dope around two knoll*
rear center of site;
total elevation change 35 ft.
Moderate

Perched: 8-12 ft.
Deep: 2) -70 ft.
0
Agriculture
A-3
None on tits;
30 - »0 within 1/2 sille
300 ft.
$30,110,400
No sand, gravel or recoverable
or gas.
No active or potentially
active faults
Probably not of concern:
South of Boulder -
Weld Coal Field
Low prra., 0.06 - 20 in/hr
Low ahear utrength,
Mod. ahrlnk-awell pot.
Yea - if irrigated

3-51 slope around knoll in
•outheaat corner; 0-31 (lope
to northwest corner, total
elevation change 60 ft.
Slight

Perched: 6-10 ft.
Deep: 28-30 ft.
0
Agriculture
Agricultural
None on site;
20-30 within 1/2 "tie
50 ft.
$30,242,300
II   Doea  not  Include coats of  delaying project.

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     The purpose of this analysis was to determine if another site is
environmentally preferred or whether Northglenn's proposed treatment
site is environmentally acceptable when compared to other sites.
Summarized in Table 2 are the conclusions of the alternative site analysis.

Water Supply Alternatives

     Municipalities within the Denver Metropolitan Area have several
options available for a water supply source.  The basic options consist
of developing a water resource on the West Slope or East Slope of the
continental divide or a combination of both.  Water from either the
West Slope or East Slope can be obtained by the following means:

        Development of new appropriations

        Acquire existing water rights

        Participation in existing water development projects

     West Slope Water

     New Appropriations.  New appropriations require the creation of
new water rights on the West Slope.  However, new appropriations in the
Colorado River Basin are not expected to be easily obtained and not
likely to provide a dependable water supply.  Energy development demands
are expected to use much of Colorado's share of the water allocated
under the Colorado River Compact.  Lower basin states are expected to
exercise their rights under the Colorado River Compact and Upper Basin
Compact.  Prior to the year 2000, it is expected that this new demand
will curtail the use of direct flow and storage water rights junior to
1970 and may even affect rights junior to 1960.

     Participation in Existing Water Projects.  Projects for which
Northglenn may be eligible for participation in with another municipality
include:

        Aurora's Homestake Project

        Colorado Big Thompson Project

        Windy Gap Proj ect

     Participation in the City of Aurora's Homestake Project is question-
able at this time.  The estimated yield from this project ranges from
10,500 acre-feet in an average year to 3,300 acre-feet in a dry year.
It is unclear if Aurora has water supplies in excess of its own require-
ments, and construction is not projected to be completed until 1988.

     Existing stipulations prohibit the use of Colorado Big Thompson
(CBT) water outside the boundaries of the Northern Colorado Water Con-
servancy District (NCWCD).  Northglenn is outside these boundaries and
currently ineligible for CBT water.  Northglenn could potentially be
annexed into NCWCD.  NCWCD is concerned with their ability to meet
present water demand projections and past court petitions for water have
been defeated on the basis of impairing the rights of present CBT water
users.  Furthermore, NCWCD*s present water supplies have been allocated

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to existing users within  the district.  The extent of Northglehn's?privileges
with a new subdistrict would only be that of attempting  to buy-out existing
user's rights.

     Windy Gap is a subdistrict of  the NCWCD.  Water resources  to be  developed
by this subdistrict have  been allocated.  Upon admission to  the  subdistrict,
Northglenn would have to  purchase part of the water allotment from an existing
participant.  Currently,  no excess  water is available from any  of the existing
participants.

     East Slope Water

     New Appropriations.  New appropriations would require new  water  rights
from the South Platte River.  Intense competition exists for any further
allocation of the South Platte River and its tributaries.  It is thought  that
the allocation of rights  on the South Platte have been over  extended. A  flow
of 5,000 cubic feet per second (cfs) in the South Platte River  at the Denver
gaging station is considered necessary to realistically  satisfy the perfected
direct flow water rights  on the mainstream, even though  the  decreed water
rights fax exceed 5,000 cfs.  Flows in excess of 5,000 cfs would represent
surplus water available to a new appropriation.  Flows in excess of 5,000 cfs
were experienced for only ten years during the period 1896 to 1975.   If the
Narrows Reservoir is constructed and its conditional water right perfected, no
surplus water upstream of Narrows would be available.  Because  of the
unreliability of new appropriations in the South Platte  River Basin,  municipal
water supplies would not  be feasible and new reservoir storage  development
would largely be supported by independent water supplies or  by  existing
decrees.

     New appropriations of nontributary water from the deep  underlying aquifer
of the Denver Basin are available.  Northglenn has applied for  such deep  well
water rights to supply a  portion of their water needs.   It now  appears such
deep well rights will be  granted.

     Acquiring Existing Water Rights and Deep Wells.  As explained  in the EIS,
Northglenn decided to purchase some South Platte surface water  (from
Consolidated Ditches among others)  to secure sufficient  make-up water
following initial denial  by the State Engineer of their  requested deep well
permits.  Based on recent opinions  of the Water Court, it now appears that
Northglenn will be permitted some if not all of the deep well water applied
for.  If so, Northglenn could drill and produce this water,  thereby having
excess supply for its design year needs.

     The South Platte - Deep Well alternative includes combining the  deep well
source and the South Platte surface source for raw water delivery.  Under
these circumstances, an exchange with FRICO is no longer essential  and a
wastewater system of transporting sewage to Denver Metro could  be
implemented.  The South Platte raw  water would be treated at the Northglenn
water supply treatment facility now under construction.   The South  Platte
water would be diverted in accordance with the priority  system  and  Northglenn
would return the historic depletion through Denver Metro supplemented as
necessary by release from storage.

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     Participation in Existing Projects.  The existing systems avail-
able for Northglenn to pursue as water supply options are:  Denver Water
Board, Thornton, FRICO exchange, purchase or condemnation..  . .  .  .

     Denver Water Board (DWB) has indicated in the past that it  would
be interested in providing Northglenn's water supply, although recent
reports indicate current supplies may not meet present water demands
beyond 1998.  The Denver City Charter prohibits water service outside
the City limits if there is not enough water for the inner city water
requirements.  Presently the DWB has adopted a policy of exercising
caution in entering into new contracts for outside service and is
limiting the number of annual taps for new service.  The DWB has stated
that it fully intends to scrutinize any additions to the service areas
of its existing raw water customers, and contracts for the distribution
of raw water supplies outside the service boudaries will be stopped.

     If water service was available from Denver, either raw water service
or treated water service could be considered as an available alternative.

     Northglenn currently is receiving water from the City of Thornton
and could continue.  Future service would be subject to Thornton's
agreement to provide water and Thornton having sufficient water  resources
to provide it.  Thornton officials have indicated in the past they are
capable and willing to provide an adequate quality and quantity  of water
to Northglenn in the future.  However, Thornton's current position is
that they have taken steps to sever their systems and believe it is not
feasible or appropriate for Thornton to reassess its water resource
development plan at this late date.  (See May 1, 1980 letter to  EPA from
Thornton.  Appendix A of Final EIS)

     Costs of the alternative water supply/wastewater treatment  systems
are shown in Table 3 and Table 4, and the estimated costs for Northglenn
to finance its portion of water supplied by Thornton is shown in Table 5.

NO FEDERAL ACTION ALTERNATIVE

     The "No Federal Action" alternative includes a refusal by EPA to
make a grant to the City of Northglenn for wastewater treatment.  Such
a denial by EPA could be based on a finding of ineligibility under the
Clean Water Act or significant unavoidable adverse environmental im-
pacts.  Northglenn's total water management program is expected  to cost
$67 million with $6.9 million eligible under EPA regulations.  As only
10 percent of the capital costs and none of the annual costs are expected
from the federal government, Northglenn has indicated to EPA that they
will still proceed with the project in the absence of federal funds.
Thus, it is possible that Northglenn will complete the water management
program entirely with local funds should EPA deny a grant.

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                                                         TABLE 3 (8/15/80)
                                Surface  Water
 MUTER SUPPLY
Deep Wells  &  Surface Water   Deep Wells
OPTION 1 OF
ITEM
Standley Lake Pipe
TreatjiHit Systan
Distribution, »tw&
Thornton Pipes
Deqj Wall d
Well #7
Maintenance Equip.
Const. Maintenance
6 Resident Engr.
Land & Eassnents
Contingencies, 25X
Eng. Legal &
Abninistrative, 15X
Overhead & AJnin.
Water Rights
Purchase
Subtotal
Replacement Water
Costs
TOTAL
CAPITAL COSTS
1,494,100
4,979,200
20,338,700
140,774
200,000
1,857,300
180,000
375,000
1,696,800
0
4.110,120
35,371,994
9,391,619
44,763,613
SALVAff
OSM VALUE
20,000 237,114
418,668 553,139
280,386 1,255,237
15,000 12,412
0 0
0 0
0 85,988
0 59,513
0 0
299,250 0
0 1.037.126
1,033,904 3,290,531
55,590 3,054,482
1,089,494 6,345,013
PRESENT WCRTH
Capital Cost Less
Thornton Pipes $27,650,313



Thornton Pipes
C&M
Salvage
Total P.W.
14,518,700
11,651,750
-6,345,013
$47,475,750
Annual P.W. ($/yr) 4,439,208

Unit Cost
(6840 AF/YR)
$1.99/1000 gal.
Annual Avg.
H>ushold Cost $261/>r
(131,400 gal/yr)
CAPITAL COSTS
1,494,100
4,979,200
20,338,700
629,984
200,000
1,857,300
180,000
375,000
1,696,800
0
4.110.120
35.861.004 1
6.512,560
42,373,564 1
TION 2
06M
20,000
418,663
280,986
116,171
0
0
0
0
0
299,250
0
,135,075
55.590
,190,665
OKflCm 3
SALVAZ
VALUE
237,114
553,139
1,255,237
55,543
0
0
85,988
59,513
0
0
1.037.126
3,333,660
2,009.431
5,343,091
PRESENT W3VTH
Capital Cost Less
Thornton Pipes
Thornton Pipes
C&M
Salvage
Total P.W.
$25,260,264



14,518,700
12,733,738
-5,343,091
$47,169,611
Annual P.W. ($/yr)
Uiit Cost
(6840 AF/YR)
Annual Avg.
Hxjsehold Cost
(131,400 gal/yr)
4,410,583
$1.98/1000 gal.

$260/y
CAPITAL COSTS
1,494,100
08M
20,000
4,979,200 418,668
20,338,700
2,240,860
200,000
1,857,300
180,000
375,000
1,696,800
0
4.110,120
37,472,080 1,
0
280,996
127,426
0
0
0
0
0
299,250
0
146,330
0
37,472,080 1,146,330
SALVAGE
VALUE
237,114
553,139
1,255,237
197,569
0
0
85,983
59,513
0
0
1.087,126
3,475,686
0
3,475,686
PRESENT MRTH
Capital Cost Less
Thornton Pipes
Thornton Pipes
O&M
Salvage
Total P.W.
Annual P.W. ($/yr)
Ihit Cost
(6840 AF/YR)
Annual Avg.
Household Cost
(131.400 gal/yr)





$20,358,780
14,518,700
12,259,591
-3,475,686
$43,661,385
4,082,547
$1.83/1000 gal.

$240/yr.
Cost updated fron Itrthglem Water Management Progran Vol. 2 4/20/77 IZS/jr.

Assurptions:  Capital  costs for the Standley Lake transnission main will not
             change.  Operational procedures dictate that a certain sis pipe
             will be  required to acconodate the diurnal flow variation Mien
             coupled  with reservoir facilities; therefore, it is assured that
             the transmission main has been designed on these operating
             constraints.
                   water right ptrchase  is for the  p-esently-owied
                   water in Standley Lake:
                       Total Water Rights Costs
                       Total Water Rights =
                         9.261.000   = S2940/AF
                         ~1EO
9,261,000
                                                                   10

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TABLE 3 (Continued)
HVTER SUPPLY
ITEM
Standley Late Pipe
Treatment Systan

FRICO EXCHANGE
CAPITAL COSTS
1,494,100
4,979,200

AGREEftNT OPTION !••
SALVAGE
(KM VALUE
20,000 237,114
418,668 553,139

Distribution, few&
Thornton Pipes
Deep Mell b
Well #7

feintenance Equip.
Cbnst. teirrtenance
& Resident Engr.

Land & Easanents

Contingencies, 25X

Eng. Legal &
20,333,70!)

140,774

200,000

.1,857,300

180,000

375,000


Administrative, 15* 1,696,800

Overhead & Adnin.

Water Rights
Purchase
Subtotal
Replacement Water
Costs

TOTAL


0


12.930.120
44,191,994
280,936 1,255,237

15,000 12,412

0 0

0 0

0 85,968

0 59,513


0 0

299.250 0


0 3,420,017
1,033,904 3,290,531
SOUTH PLAI it-uttp M-LL «.iuwi ivt
ITEM
Standley Lake Pipe
Treatment Systan

Distribution, few&
Thornton Pipes
Deep Wells

Raw Water Storage
at Treatment Plant
SB. Platte Alluvial
Wells, Puips & Trans


Maintenance Equip.

Const. Maintenance &
Resident Engineering

Land & Easanents

Contingencies

Eng. Legal & Adnin.
Overhead & Adnin.
CAPITAL COSTS
1,494.100
6,979.200


20.338,700
2,922,860


1,800,000

2,389,000


200,000


1,857,300

180,000

1,740,000

2,515,800
0
Mater Rights Purchase 4,110,120
9,391,619

53,583,613

55,590 3,054,432

1,089,494 6,345,013


Replacement Water

TOTAL
RESENT VCRTH












Capital Cost Less
Thornton Pipes
Thornton Pipes
04M
Salvage
Total P.W.
Annual P.W. ($/yr)
Unit Cost
(6840 AF/YR)
Annual Avg.
toushold Cost
(131,400 gal/y)

$36,470,313
14,518,700
11,651,750
-6.345.013
$56,295,750
5,263,920

$2.36/1000 gal.

$310/y














	 0_

46.527,080
SALVAGE
am VALUE
20,000 237,114
1,319,073 775,319


280,986 1,255,237
113,980 257,699


15,000 285,660

202,315 424,630


0 0


0 0

0 85,988

0 276,138

0 0
299,250 0
0 1,087,126

0 0

2,250,604 4,408,803


36*. 20 yr
64X, 50 yr


30>rs.




18t, 20 yr
82X, 50 yr

















WESENT WCRTH
Capital Cost Less
Thornton Pipes
Thornton Pipes
OLM
Salvage
Total P.W.
Annual P.W. ($/yr)
Ihit Cost
(6840 AF/YR)
Annual Avg.
Household Cost
(131,400 gal/*-)

$29,413,780
4,408,303
24,069,409
-4,408,903
$63,593,086
5,946,256

$2.67/1000 gal.

$351/yr













Cost updated fron Nrthglem Water  Rraganent Program Vbl. 2 4/20/77 13/>r.

Assumptions:  Capital  costs for  tte Standley Lake transnission main will rot
              change.   Operational  procedires dictate that a certain sis pipe
              will be required to  acconodate the diurnal flow variation vten
              coupled  with reservoir  facilities; therefore, it is assured that
              the transnission main has been designed on these operating
              constraints.

*Assunes 3,000 AF/YR additional  water for flow augmentation
 required die to adverse water court  ruling.
Water right purchase is for  the  p-esently-owied
water in Standley Late:
    Total W&ter Rights  Costs
    Total Water Rights  =
      9.261.000    = $2940/AF
      ~
$9,261,000
                                                                           11

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                                                           TABLE 4 (8/15/80)
                               COSTS CF ALTERATIVE NORTHGLENN WATER SUPPLY/W4STEW/\TER TREATMENT SYSTEMS
                                                          FRICO WVTER SUPPLY
        WINDY GAP W\TER SUPPLY
Capital ($)
  Water Supply
  Wastewater
  Total

Operations & Maintenance ($/yr)
  Water Supply
  Wastewater
  Total

Present Worth ($)
  Water Supply
  Wastewater
  Total

Annual Average hbusehold
  Costs ($/yr)
  Water Supply
  Wastewater
  Total
FRICO Agricultural Reuse Denver tetro
(Proposed Project Options) Wastewater Treatment
Option 1
44,764,000
24,213,000
68,977,000
1,089,000
530,000
1,619,000
47,476,000
26,680,000
74,156,000
261
155
416
Opt ion 1*
53,584,000
24,213,000
77,797,000
1,089,000
530,000
1,619,000
56,296,000
26,680,000
82,976,000
310
155
465
Option 3
37,472,000
24,213,000
61,685,000
1,146,000
530,000
1,676,000
43,661,000
26,680,000
70,341,000
240
155
395

56,191,000
15,037,000
71,228,000
1,066,000
661,000
1,727,000
55,336,000
19,690,000
75,026,000
305
114
419
                                                                                                         NDrthglerm
                                                                                                    Wastewater Treatement
                       Denver fetro
                   Wastewater Treatement
61,136,000
24.213.000
85,349,000
 1,392,000
   530,000
 1,922,000
66,966,000
26.680,000
93,646,000
       369
       155
       524
61,136,000
15.037,000
76,173,000
 1,392,000
   661.000
 2,063,000
66,966,000
19,690.000
86,656,000
       369
       114
       483
*Assunes 3,000 AF/YR additional water for flow augmentation due to adverse water court ruling.

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CO
                                                                        TABLE 4 (8/15/80) (Continued)
                                                 COSTS CF ALTERNATIVE  NQRTHGLENN WATER SUPPLY/WASTEWATER TREATMENT SYSTEMS
                                                                DENVER WVTER BOARD WVTER SUPPLY
SOUTH PLATTE CEEP WELLS
      WVTER SUPPLY
Raw Water Contract

Capital ($)
Water Supply
Waste water
Total
Operations & Maintenance ($/yr)
Water Supply
Waste water
Total
Present Worth ($)
Water Supply
Wastewater
Total
Annual Average hbusetold
Costs ($/yr)
Water Supply
Wastewater
Total
Itrthglem
Wastewater Treatment

51,834,000
24,213,000
76,047,000

2,112,000
530,000
2,642,000

65,333,000
26,680,000
92,013,000


360
155
515
Denver Mstro
Wastewater Treatement

51,834,000
15,037,000
66,871,000

2,112,000
661,000
2,773,000

65,333,000
19,690,000
85,023,000


360
114
474
Full
Service Contract
fbrthglem Denver tetro
Wastewater Treatment Wastewater Treatement

54,843,000
24,213,000
79,056,000

2,626,000
530,000
3,156,000

71,215,000
26,680,000
97,895,000


392
155
547

54,843,000
15,037,000
69,880,000

2,626,000
661,000
3,287,000

71,215,000
19,690,000
90,905,000


392
114
506
Denver Metro
Wastewater Treatement

46,527,000
15,037,000
61,564,000

2,251,000
661,000
2,912,000

63,593,000
19,690,000
83,283,000
j : '

351
114
465

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                                     TABLE 5

                                  COST SUMMARY

                        THORNTON WATER SUPPLY CONDITIONS


                          Condition 1   Condition 2   Condition 3   Condition 4

Total Capital Cost ($)    25,300,000    45,600,000    93,900,000    114,200,000

Operation &
  Maintenance ($)          2,940,000     2,940,000     2,940,000      2,940,000
$280,000 x 10.492
  (Present Worth Factor)3

Total Present Worth ($)   28,240,000    48,540,000    96,840,000    117,140,000

Annualized Cost ($)        2,690,000     4,630,000     9,230,000     11,160,000

Annual Average Household
  Cost ($)4          1821-/7352'  3431-/8962-      760            917


     1.  Existing homes, no tap or connection charges.

     2.  New homes, tap and connection charges.

     3.  Present worth of operation and maintenance costs calculated
           at 7 1/8% for 20 years.

     4.  Assumes 3.5 people per household.
                                          14

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DISCUSSION OF THE ENVIRONMENTALLY PREFERRED ALTERNATIVE

     The previous section describes the alternatives  to the Northglenn Water
Management Program that have been considered and evaluated by EPA.  According
to recent regulations promulgated by the Council on Environmental Quality,  the
sponsoring federal agency shall specify in the Record of Decision the
alternative or alternatives which are considered to be environmentally
preferable.  Selection of such alternatives is determined by their  impact upon
the natural and human environment rather than economic consideration,
technical factors or the agency's statutory missions.  Of the various
combinations of water supply alternatives and wastewater alternatives
available to Northglenn, EPA believes that three of these alternative systems
are environmentally preferrable over other systems.   These include: 1) water
supply from Thornton with Denver Metro wastewater treatment, 2)  South Platte -
Deep Well water supply with Denver Metro wastewater treatment and 3) the
proposed FRICO exchange using deep wells for a make up water supply source
with agricultural reuse and a treatment plant located at any of  the four sites
identified in the final EIS.  These three alternatives have been selected
based upon the following significant environmental factors:  agriculturial
productivity, water quality in the effected streams,  potential health risks,
and site impacts.

Agricultural Productivity

     The most severe environmental impact of transmountain West  Slope
diversions from the Colorado River basin has been associated with reduction in
the flow of high quality water in the headwaters and  the resultant  increases
in salinity in the lower reaches of the system.  Any  new appropriation from
transmountain diversions of Colorado River water will compound these impacts.
If Northglenn were to acquire existing water rights currently diverted on the
west slope, the associated impacts could potentially  be less in  terms of both
water quality and agricultural impacts.  West slope sources include the Denver
Water Board, the Colorado Big Thompson Project and the Windy Gap Project.

     The most severe environmental impact of developing East Slope water as a
water supply source is a reduction in irrigated agriculture.  This  impact is
most prevalent to agriculture along the South Platte  River and areas adjacent
to Metropolitan Denver.  New appropriation of surface water would have the
least effect on agricultural production.  However, new surface water is not
available in the overly appropriated South Platte system.

     The least impact to agricultural productivity of any alternative
considered is the FRICO exchange especially when the  make up source is
obtained from deep wells (Option 3).  This is due to  the following  factors:
1) Option 3 does not require the use of South Platte  surface water, 2) all
exchange options provide additional water to the FRICO system because of the
10 per cent bonus, 3) condemnation or purchase of the FRICO source would
reduce agricultural production in the FRICO system significantly while
additional return flow to the South Platte through the Metro treatment plant
is unlikely to increase agricultural production along the South  Platte where
                                         15

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irrigation water is available in adequate amounts- to agricultural
appropriators.  Option 3 is preferred over the Thornton water supply system
since Thornton's water purchases would dry up hay meadows in South Park and
like the South Platte - Deep Well alternative, expose the FRICO water to
further condemnation action.

Water Quality and Public Health Risks

     Water quality changes in the Bull Canal downstream of the proposed
reservoir may preclude its potential use for domestic supply and may increase
public health risk due to public exposure to treated effluent and uncontrolled
reuse of effluent on raw edible crops.  Such potential adverse impacts are
avoided by selecting an alternative which includes the Denver Metro wastewater
treatment alternative.  While discharging effluent to the Bull Canal may
represent a loss of a possible domestic water sources (it would be possible  to
deliver Standley Lake water by pipeline) it is the same action which further
enhances the liklihood that this water will remain for the purpose of
irrigation of agricultural lands.

     There is a difference among experts as to the likelihood of the effluent
from the facility meeting the suspended solids limit as specified in the
permit.  EPA1a analysis of the feasibility of the proposed system indicates
there is substantial likelihood that the proposed process will not limit
carbon, thereby not limiting algal growth.

     For environmental reasons EPA does not endorse the use of copper sulfate
to control algae since there is a chance that concentrations of copper could
be released which would be deleterious to crop production.  Acceptable
operational controls to reduce algal growth are readily available and the
environmentally preferred controls include selective discharge (controlling
the depth and timing of discharge) and the use of introduced fish to consume
algae.  This problem would be avoided by selecting the Denver Metro wastewater
treatment alternative.

Site Impacts

     Three alternative sites, all in Adams County, were identified as having
suitable locations, soils, and remoteness from residential communities.  While
these sites are acceptable environmentally, there is no apparent environmental
advantage of selecting any one of the sites.  The key issue regarding site
selection has concerned possible adverse odor and a possible reduction in
property values to nearby residences (within one-half mile).  At least 20
houses are within a half-mile radius of each of the sites.  Site B has 80
residences within one-half mile.  Because of recent developments in the area,
it is likely that in the near future residential growth will occur in the
vicinity of all sites.  Site C is slightly less desirable than the others
because one household would have to be relocated.  Otherwise, the agricultural
use of all four sites makes them equally suitable for the proposed facility.
It would be preferable due to possible odor problems to select a site that has
very few residences around it; unfortunately, rapid growth of residential
housing within the study area has made this impossible.   Site problems would
be avoided by selecting the Denver Metro wastewater treatment alternative.
                                    16

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EPA DECISION

     EPA has decided to approve the Northglenn proposal and offers  a grant,
with conditions, for approximately $7,615,000.   (The  final EIS  indicated  the
estimated grant at $6,948,000 based on capital costs,  to which  has  been added
the normal estimate for costs of architectural engineering fees,  inspection
fees and contingencies.  The final grant award will be dependent  upon  the
actual construction bids.)

     EPA recommends that the City of Northglenn  proceed with  the  construction
of the proposed wastewater treatment facility on Site  10 in Weld  County.   This
decision is based on the condition that all mitigation measures and grant
conditions contained herein or in the Final EIS  (1980) be accepted  and
undertaken by the City of Northglenn.

     If the applicant fails to comply with the mitigation measures  contained
in the Final EIS (1980) and the conditions set forth  in this  Record of
Decision, EPA may consider any of the following  actions:

1.   Terminating or annulling the grant
2.   Disallowing project costs related to noncompliance
3.   Withholding project payments
4.   Suspending work
5.   Finding the grantee to be nonresponsible or ineligible for future Federal
     assistance or for approval for future contract awards under  EPA grants
6.   Seeking an injunction against the grantee
7.   Recovery of funds expended
8.   Instituting such other administrative or judicial action as  may be
     legally available and appropriate pursuant  to EPA regulations
     40 CFR 30.920-5

     This decision and the conditions are based  on the Final  EIS  record,
specifically an analysis of the following factors:

     1)  the project includes certain benefits to agriculture as  compared  to
other alternatives or the situation if water condemnation litigation had
proven successful;

     2)  the proposal is the most cost-effective water supply and wastewater
system (see Table 4);

     3)  there are no significant direct adverse environmental  effects of  the
proposal other than a potential odor problem at  the treatment site  and in  the
canal system;

     4)  the proposed wastewater system and agricultural reuse  system  is
eligible for a grant providing partial funding as a multiple-purpose project
using alternative technology as defined under the Clean Water Act;

     5)  the State of Colorado has included the  project on its  fundable
project list for Fiscal Year 1979.
                                       17

-------
     6)  the Northglenn water rights applications, including change of water
rights and the augmentation plan, are a logical approach  to preventing injury
to other vested water rights.  There are a number of  legal issues  to be
resolved by the Water Court and some changes to the water plan as  filed  are
likely;

     7)  additional public health control measures beyond those originally
proposed in the Northglenn facilities plan are required and will be
implemented by Northglenn; however  the proposal identified in the  Draft  EIS to
prevent the sale of raw edible crops will not be required at this  time;

     8)  assuming the Bull Canal is currently suitable as a domestic raw water
source, if the proposal is implemented the Bull Canal downstream of the  Bull
Canal Reservoir will no longer be suitable as a source of domestic raw water,
since treated municipal effluent will on occasion comprise the entire flow in
the Bull Canal.  EPA concludes that since the Canal is not presently used for
a domestic water supply, nor has there been any formal request to  designate
the Canal for domestic water supply, there is no need to  protect the Canal for
water supply;

     9)  selecting one of the environmentally preferred alternatives that
includes continued wastewater treatment at Denver Metro ignores the legally
binding commitments that have been  entered into by Northglenn, FRICO,
Thornton, and Westminster.  Previous water condemnation actions against  FRICO
resulted in the agreement among these parties for the water exchange with
FRICO.  The exchange agreement between Northglenn and FRICO is a function of
water supply development which then translates into the need for Northglenn to
obtain control of its wastewater in order to satisfy  the water exchange
agreement.  Legal arrangements have been made to execute  the exchange
independent of federal action.

     Further detailed explanation of the analysis of  some of these factors
follows:

Benefits to Agricultural Productivity

     EPA analyzed the Northglenn water exchange plan  for  possible  adverse
economic and water quality effects  upon agriculture.  As  originally proposed,
the exchange plan included deep wells as the entire source of make-up waters.
With development of such a new water source there would not be an  adverse
effect upon agriculture.  The nontributary well permits were denied by  the
State Engineer and this matter is on appeal by Northglenn in Water Court.
Northglenn then purchased South Platte surface water, some of which is
currently used for agriculture, so  that their plan could  be implemented
without such deep nontributary wells.  Under the latter scheme the extent of
agricultural benefits of the proposal was unclear.  EPA decided that further
study of the possible economic impact upon agriculture was necessary.
                                     18

-------
     The agricultural economic analysis  indicates  that by utilizing  South
Platte irrigation water as make-up for the FRICO exchange a decrease  in
agricultural productivity of up to $370,000 during a year of normal
precipitation could occur along the South Platte River.  However,  this is more
than compensated by continued agricultural production in the FRICO system.   An
estimated value, of $1,950,000 in a similar year which productivity could be
lost if FRICO water was successfully condemned or  purchased outright  by
Northglenn or another municipality.  The proposed  Northglenn exchange plan is
therefore beneficial to the agricultural community.  Further,  EPA  concludes
that properly managed, the benefit of the nutrient values in the sewage
effluent will be a net asset which will  enhance agriculture production in the
area or reduce the costs of maintaining  current production levels.

     EPA concludes condemnation proceedings against the FRICO  water  supply
would likely be successful.  Therefore,  EPA supports the proposed  exchange as
being consistent with EPA policy to protect environmentally significant
agricultural lands.

     There are also possible adverse impacts  to agriculture with respect to
the changes in water quality created by  the return of treated  sewage  effluent
to the Bull Canal.  Possible adverse effects  are attributable  to increased
nitrates in water from the canal include:

          reduction in sugar beet purity
          reduction in barley starch content

     Based on comments from knowledgeable affected parties including  Great
Western Sugar Company and Coors, Inc., EPA concludes that with proper
management, such as reduction of nitrogen fertilizer applications  and correct
scheduling of sewage effluent and Standley Lake releases, such problems are
minor and should not affect crop production or value adversely.

Direct Effects of the Proposal

     EPA1 s conclusions as to the nature, extent, and significance  of  direct
adverse impacts are:

          Loss of tax base - The projected loss of $8,500 annually to Weld
          County and $300 annually to Adams County is a small  decrease in-net
          tax revenues to the two counties.   No mitigation for this  tax loss
          is recommended.  (A proposed draft  of an Intergovernmental  Agreement
          offered by Northglenn includes payments  in lieu of taxes.) ,

          Effect on Adjacent Land Values - A  decrease in adjacent  residential
          values up to five percent is possible.   No change in farmland values
          is anticipated.  No mitigation for  such  possible reduction  in
          residential property values is recommended.

          Groundwater pollution - The proposed clay liner of the reservoir and
          lagoon system will minimize any change in groundwater quality.
          Additional construction measures will be required by EPA and the
          Corps of Engineers to properly seal well penetrations and/or an
          inactive fault, if present.  No adverse  impact upon  groundwater is
          predicted.
                                      19

-------
          Odor problems - Under "worst case" conditions which include the
          unlikely combination of minimal atmospheric mixing and malfunction
          of the aeration system, the Colorado State Standard for odor could
          potentially be violated.  Noticeable increases in odor could
          result.  The probability is judged to be slight, and mitigating
          measures are incorporated into the plan.

          Reservoir Dam Safety - The design standards meet those recommended
          by the U.S. Bureau of Reclamation, U.S. Army Corps of Engineers and
          have been approved by the Colorado State Engineer.  No unusual risks
          are apparent.

          Aesthetics - The storage reservoir embankment will be revegetated
          and will have a low profile.  Therefore, it should not adversely
          affect the aesthetics of the area.

The Proposal Qualifies for EPA Funding

     EPA has proposed alternative methods for funding multiple-purpose
projects which involve innovative and alternative technology in order to apply
the incentives provided by the 1977 Clean Water Act Amendments.  EPA has
determined that Northglenn's proposed project is eligible for grant awards as
a multi-purpose project using alternative technology.  Using the formula of
115 percent of the ratio of the present worth cost of the most cost-effective
single-purpose option, to the present worth cost of the multiple-purpose
project the eligible fraction of the multiple-purpose project costs are
determined.  Portions of a multiple-purpose project which involve innovative
or alternative technology are eligible for an 85 percent grant rather than the
normal 75 percent grant.  Agricultural reuse of effluent is defined in the Act
as an alternative technology.  The total grant amount is therefore determined
by multiplying the fraction of the multiple-purpose project costs that are
eligible times 85 percent for those items necessary for agricultural reuse and
75 percent for all other wastewater elements.

     For EPA to participate in the funding of a multiple-purpose project, the
following rules apply.  The Northglenn proposal meets these requirements:

     1.  The cost of the multiple-purpose project must not exceed the sum of
the costs of the most cost-effective single-purpose options which accomplish
the same purposes.  (The Northglenn proposal combines wastewater treatment
with agricultural reuse less expensively than two single-purpose projects
providing similar functions.)

     2.  The primary and secondary environmental effects are assessed in
accordance with the NEPA review procedures.  (As a result of this review under
NEPA, EPA concludes that there are no significant net adverse environmental
impacts and that net environmental benefits will result from this project.)
                                    20

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     3.  The pollution control purpose of  the  proposed  project  must  be
necessary to meet an enforceable requirement of  the Act.   (Additional costs
associated with wastewater  treatment  are necessary for  Northglenn  during  the
20 year planning period to meet enforceable requirements  of  the Act  as  defined
in Denver Metro's discharge permit.   These costs  include  the need  to expand
conveyance facilities and to expand and upgrade  the Denver Metro Plant.)

     4.  There is no purchase of existing  facilities with federal  funds.
(Northglenn's purchase of existing water distribution and collection systems
has been eliminated from grant eligibility.)

     5.  The project meets  the definition of treatment  works, and  the works
are publicly owned.  (The wastewater  treatment project  will  be  publicly owned.)

     6.  The project is consistent with the adopted and approved water  quality
management plan.  (The Northglenn proposal is  in compliance  with the Denver
Regional Council of Governments (DRCOG) Clean  Water Flan. Adoption  of  an
Intergovernmental Agreement with Weld County as  required  by  EPA as a
prerequisite to final grant payment will mean  the project is also  in
compliance with the Larimer-Weld Council of Governments Clean Water  Plan.)

     7.  The applicant must demonstrate a commitment that effluent will be
applied to irrigated productive agricultural land for the design life of  the
project.  (Northglenn has committed to a contingency plan where they will
maintain sufficient land in agricultural use to  reuse all water generated by
the treatment plant throughout the design  life of the plant.

Protection of Vested Water  Rights

     Northglenn must receive approval of the Water Court  for a  plan  of
augmentation in order to implement its proposal.  In addition,  Northglenn has
purchased various water rights and intends to  transfer  such  water.  This  shift
in usage of the water in the over appropriated South Platte  system must comply
with Colorado Water Law and receive approval by  the State Water Court.

     EPA concludes, based upon expert opinion, that 1)  other complex plans
with similar principles have been approved by  the Water Court and  this  plan
can be administered by the  State Engineer; 2)  the amount  of  water  obtained
from surface sources is reasonable based on historic ditch diversions and
stream depletions; 3) the exchange plan will sufficiently protect  FRICO
shareholders; 4) through the Water Court process, out-of-priority  diversions
will be properly augmented; 5) the water rights  to be used for  augmentation
are sufficiently senior for that purpose; 6) South Platte water users will be
compensated for additional ditch losses; and 7)  the Water Court will ensure
that South Platte water users will be protected.

     In analyzing the water rights and augmentation plans of the Northglenn
project, a number of legal  issues have been identified  by EPA.

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     These legal-issues will be resolved through the judicial process.   EPA
concludes that some changes to the water plans as filed may thereby be  imposed
but the probable effect of any such changes during the court process will
likely be limited to requirements for additional water for augmenting
purposes.  Northglenn can acquire such additional water from non-agricultural,
agricultural or a mix of sources similar to their present plan.

Need for Additional Public Health Control Measures

     Based upon review of the medical literature, and EPA and Colorado
policies, EPA concludes that to provide the highest possible degree of
protection of public health, the following additional measures not initially
proposed by the applicant nor normally incorporated into NPDES permits  are
necessary:

     1.   Chlorination of Bull Canal effluent prior to discharge, to assure
          limitation of the concentration of fecal coliform bacteria to not
          more than 200 fecal coliform organisms per 100 milliliters (ml).

               A permit criterion of 1000/100 ml has been considered
               sufficient for agricultural use where some dilution of the
               effluent would occur.  Northglenn has agreed to meet a permit
               criterion of 200/100 ml for the discharge into Bull Canal.   For
               comparison, the fecal coliform limit in the NPDES permit for
               the Denver Metro facility is 1000/100 ml.  This effluent is  at
               times discharged into the Burlington Ditch.

     2.   Control of irrigation runoff into the Towns of Frederick and
          Firestone.

               Present agricultural practices combined with a lack of proper
               stormwater drainage allows runoff to flow along certain  streets
               of these communities.  Northglenn will be required to intercept
               and control these flows in order to further reduce public
               contact with tailwater runoff which may consist in whole or  in
               part of treated sewage effluent.

     3.   Disinfection of Bull Canal water supplied to Dacaono's nonpotable
          irrigation system.

               The Town of Dacono operates a nonpotable water system used  for
               lawn and garden irrigation.  Its source is Bull Canal water
               which may consist in whole or in part of treated wastewater
               effluent from the Northglenn facility.  In order to minimize
               the potential for disease transmission in this situation,
               Northglenn is required to disinfect this source of nonpotable
               water, or replace its source.
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     Based upon additional analysis and consultation with  the  Colorado   .
Department of Health, EPA concludes it will not be necessary at  this  time  to
require the prevention of sale of raw edible crops irrigated with  effluent
from the Northglenn facility.  The draft EIS contained  the following  proposed
grant condition:

          In order to receive a grant from EPA, Northglenn will  have  to  agree
          to a plan to prevent the public sale or distribution of  raw edible
          food crops irrigated with effluent from the Northglenn plant.
          Northglenn will assist farmers in marketing the  crops  to buyers  who
          will process the crops or Northglenn will otherwise  compensate the
          farmers for economic losses to the extent of  actually  purchasing the
          vegetables if no other satisfactory solution  can be  found.  This
          condition is necessary in order to minimize the  possibility of
          disease transmission through ingestion of contaminated vegetables.
          Northglenn will also issue and reissue an advisory that  will inform
          farmers and discourage direct contact with the water and its use on
          private gardens.

     EPA decided not to impose this condition as the analysis  indicates  the
potential for pathogen survival through the system is very low due to
reservoir conditions which provide sufficient detention time.  Pathogen
survival will be further reduced by chlorination of the effluent to meet the
limit of fecal coliform bacteria concentration of not more than  200/100  ml.
EPA concludes that public health risks under these conditions  are  not
significant and that the public health will be adequately  protected.  However
there is still some unknown albeit small risk that waterborne  disease could be
transmitted to humans who ingest raw vegetables irrigated  with water  from  the
Bull Canal.

     At this time, EPA has not developed criteria or guidelines  to establish
treatment criteria for the use of sewage effluent on raw edible  crops.   During
the next two years the Agency intends to establish national guidelines for
effluent criteria for unrestricted agricultural reuse.  Upon completion  of
Agency action in this regard and upon permit renewal, Northglenn will be
required to comply with these new guidelines.

     If the Northglenn facilty is capable of meeting such  new  requirements or
if it is determined that operational or design changes  are necessary  and
cost-effective to meet these requirements, then compliance will  be obtained.
In the event that compliance with future Agency guidelines as  applied to is
not cost-effective for the Northglenn facility, appropriate measures  to
protect public health will be required.

     Regarding the possible irrigation of private gardens, Northglenn will
develop an educational plan that will inform farmers of the problem and
discourage direct contact with the water and its use on private  gardens.   In
the event that raw edible vegetable crops are irrigated with treated
wastewater, EPA recommends farmers locate process markets  for  the  crops.
                                     23

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Protection for Potential Drinking Water Supplies is Not Necessary

     The Bull Canal is not currently used for a domestic water supply and
there has not been any petition to the State to designate this source for
domestic use.  Based on very limited data, it does appear the Bull Canal is
currently suitable for a domestic raw water supply.  The Town of Frederick
indicated to EPA they intended to use water from the Bull Canal to augment
their present surface supplies.

     The Town of Ft. Lupton has informed EPA of its intention to use Sand Hill
Reservoir, which may receive some flow from Bull Canal as their future
domestic water supply source.  Bull Canal discharges to Sand Hill Reservoir
are insignificant to the total inflow and, therefore, this proposal should not
adversely affect Ft. Lupton's intended use of this source.

     The use of treated municipal effluent for a domestic source is not
advisable because current treatment technology is unsuitable to treat such a
source.  In addition, the concentration of nitrates in the Canal would
adversely affect such plans since the concentration will exceed the National
Drinking Water Standard of 10 mg/1.  Water containing such high concentrations
of nitrates is not economically suited as a domestic source.  EPA recognizes
that this change in water quality potentially represents a resource lost.  EPA
concludes that the Town of Frederick should seek an alternative water supply
sour ce.
                                        24

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STEPS TO MINIMIZE ADVERSE EFFECTS

Summary of NPDES Permit Conditions

     Effluent discharge requirements of  the EPA and  the  State are enforceable
through the National Pollutant Discharge Elimination System  (NPDES) permit
system,  This program requires that an municipality,  industry, or other entity
discharging into waters of the United States may do  so only with an approved
discharge permit.  The authority for the NPDES permitting  system lies with
EPA, but in many states, including Colorado, the administration of the system
has been delegated to a state agency (in Colorado  it is  the  State Health
Department).  The NPDES Permit includes appropriate  limitations on the
quantity, quality, and location of the discharge.

     Northglenn has concurred that certain impacts will  require mitigation,
particularly those associated with changes in quality of the water of Bull
Canal.  EPA has developed the following mitigating programs  for the impacts
identified:

     1)   Potential for disease transmission through direct body contact with
Bull Canal water, as a result of farm irrigation practices and public
recreation around the Bull Canal.

          The NPDES permit effluent limitation is:   "The City shall chlorinate
the effluent prior to discharge to achieve a criterion such  that the geometric
mean of fecal coliform bacteria shall not exceed 200 colonies per 100
milliliters on a 30 day basis and shall not exceed a criteria of 400 fecal
coliform colonies per 100 milliliters on a seven day basis."

     2)   The Town of Dacono has a nonpotable water  system which draws water
from the Bull Canal and is provided without treatment, for irrigation in
certain parts of the town.  The change in quality  of the water in the Bull
Canal will unnecessarily cause an increased health risk  within Dacono.
Northglenn will resolve this problem by either substituting  an alternative
water source for Dacono's use in place of the Bull Canal water currently used,
or installing and operating a system to disinfect  the water  Dacono receives
from the Bull Canal.  If disinfection is chosen, the system will be designed
to achieve a level of disinfection acceptable to EPA which shall include a
residual a chlorine level of not less than 0.3 mg/1.

     EPA is negotiating to include the following as  a NPDES permit condition
and will also require it as a grant condition:  "Northglenn will undertake the
cost of installations, operation and maintenance of  a disinfection system for
the Dacono nonpotable water supply, to insure that the nonpotable water supply
for the Town of Dacono is properly disinfected to protect  public health."

     Alternatively, at Northglenn "s expense, a suitable  replacement for this
system could be provided, in which case this permit  condition would be
withdrawn.  Northglenn shall consult with the Town of Dacono to obtain their
concurrence with these plans.
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     3)   During  irrigation  periods,  Bull  Canal  tailwater  from lands nadj acent-
to Frederick and  Firestone  flows  through town  streets.  Northglenn  has  agreed
with EPA to provide necessary  facilities to  control  the tailwater so  that  it
will not enter the Towns  of  Frederick or Firestone.   The plan,  which  has been
conceptually developed, will consist  of three  ponds  that will  receive the
tailwater from collection ditches as  the edge  of these fields  adjacent  to  the
towns.  Low dikes will  reduce  stormwater inflow  into these ponds.   Water from
the ponds will be recirculated back to the irrigated land.   (Should these
fields be irrigated during rainfall,  some  diluted  tailwater could flow  into
the streets.)  According  to  the  filings Northglenn has made with the  Water
Court, their position is  that  this water is  from Standley  Lake  storage  and
impounding of this water  will  not create a water rights problem.  EPA ,
concludes that if the Water  Court disagrees, this  problem  would then  have  to
be resolved in Northglenn's  augmentation plan.

          EPA is  negotiating to  have  the following as an NPDES  permit
condition and will require it  as  a grant condition:   "Northglenn will provide
physical measures to prevent the  flow of tailwater from the Bull Canal  from
adjacent agricultural land into  any residential  area.  Consultation with
Frederick and Firestone on the design and  location of these facilities  is
necessary."

     Alternatively, at Northglenn's expense, a suitable replacement for this
system could be provided, in which case this permit  condition would be
withdrawn.  Northglenn  shall consult  with  the  Towns  of Frederick and  Firestone
and the property  owners to obtain their concurrence  with these  plans.

     4)   Protection of Treatment Capacity

     According to EPA's cost-effective regulations,  the design life for the
Northglenn facility is  20 years.  Northglenn is  expected to have a  population
growth rate of 3.1 percent per year resulting  in a population  estimate  of
42,500 people by  2000.  The  wastewater treatment facility  has been  designed to
accommodate flows for this population.  A  substantially higher  rate of
development in Northglenn or expansion of  the  service area would create the
need to expand the facility  before the year  2000.  Managing growth  within
these limits reduces the  likelihood the city would need to expand the facility
within the design period.  Measures to protect treatment plant  capacity are
encouraged by EPA.

     Northglenn1s ordinances as  described  in the section under  Air  Quality,
limit the number of new sewer  taps on an annual  basis and  prevent any
connections to the proposed  interceptor.   These  ordinances are  sufficient  to
protect treatment plant capacity.  In order  to ensure Northglenn will continue
to abide by these restrictions EPA is negotiating  to have  the  following NPDES
permit condition:

          "The City of Northglenn shall maintain an  ordinance
          providing for sewer  tap limits as defined  by Ordinance
          Number  529 dated December 21, 1978 or  as amended by  the
          City Council.   The City shall maintain a prohibition
          against connections  to  the  Northglenn  interceptor for
          areas outside the  current city limits  as specified in
          Section 16-11-5 or as  amended to the municipal code."
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Summary of. EPA Grant Conditions

     Under EPA's Construction Grants Program,  a  grant  offer  contains  a list  of
requirements to which the grantee must agree to  in  order  to  receive the
grant.  Usually these grant conditions involve certain steps  that  the grantee
must accomplish during the construction phase  (e.g.  finalization of an
operation and maintenance manual, completion of  an  industrial  cost recovery
system, etc.).  Withholding final grant payment  is  the usual mechanism that
EPA uses to insure compliance with grant  conditions.   Grant  conditions to
assure continuous requirements can also be  imposed  by  EPA effective for the
design life of the project.  The following  grant  conditions  must be met by
Northglenn to  receive final grant payment:

     1)   Regarding the possible irrigation of private gardens, Northglenn has
agreed to develop an educational plan that  will  inform farmers of  the problem
and discourage direct contact with the water and  its use  on  private gardens.

          The  EPA grant condition is:  "Northglenn  agrees  to  issue and reissue
an advisory on an annual basis for the design  life  of  the  plant, to all
shareholders of record in the Standley Lake Division of FRICO, and to~ all
shareholders of record of any other division of  FRICO  to  which waters from the
Northglenn reservoir are diverted.  This  advisory concerns the constituents  of
the wastewater in the reservoir and a notice that such water  should not be
used for the irrigation of raw edible vegetable  crops."

     2)   The  proposed project will result  in  delivery of  reclaimed effluent
and Standley Lake water to FRICO farmers.   The reclaimed water is  suited for
agricultural uses, with the exception of  raw edible vegetables.  There may be
some minor operational changes that can or  should be made by  the farmers for
certain crops.  For example, one change that would  be  advised  is the
modification of fertilization rates to compensate for  nitrogen content in the
wastewater applied.  The City of Northglenn has  agreed to  prepare  an
Agricultural Reuse Manual that will provide information on such matters. This
manual will be available to all farmers in  the FRICO-Standley Lake Division.
Projections regarding water delivery and  quality  would be updated  monthly.

          The EPA grant condition is:  "Northglenn  will develop an
Agricultural Reuse Manual to provide advice to farmers of the  Standley Lake
Division of FRICO on the use of treated sewage effluent for  crop irrigation.
Periodic public reporting in the advisory notices will be provided to the
FRICO Board and to anyone requesting this information."

     3)   Implementation of the Northglenn  agricultural reuse project
requires the commitment of large sums of  money, both from  the City and
EPA.  Assurance must therefore be given that the  City  of Northglenn
can and will continue the proposed means  of wastewater treatment
and disposal for the 20 year design life  of the project.  The proposed
plan of agricultural reuse depends on the availability of  sufficient
agricultural lands to receive the effluent.  While  EPA concurs with Northglenn
that future demand for this effluent should be adequate to insure  this,
Northglenn will develop a contingency plan  whereby  sufficient  land in
agricultural use and under the City's control  will  be  continuously committed
                                         27

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to receive the effluent.  This commitment can be in the  form of  land ownership
by the City, irrigation easements, effluent sale for irrigation, or effluent
lease for irrigation.  The commitment is for a minimum of 20 years beyond  the
date of the grant award.

     The EPA grant condition  is:  "Northglenn shall assure that  sufficient
land in agricultural use, approximately 1,100 acres, in  the FRICO-Standley
Lake system is under their control—through ownership, lease, or contract—for
the purposes of effluent disposal.  Further, Northglenn will assure that
discharge only occurs when there  is irrigation use.  This condition is binding
for the 20-year design life of the project."

     4)  The northwest corner of  the proposed reservoir may contain a
fractured zone from a fault trace known to exist in the vicinity.  If present,
this would provide a zone of  permeability potentially allowing communication
of the impounded fluid with the groundwater of the immediate area.

     Should the fracture pattern  be encountered under the dike area or on  the
reservoir side of the excavation, there are two possible remedies:  1)  move
the reservoir south of the zone,  or 2) design a sealing method.  Additional
sealing methods could include a combination of a partial membrane seal and
compaction of a mixture of the local clays and proper additives  to increase
the plasticity in order to combine with the fractured zone material.

     EPA has required as a condition:  "During construction of the cut-off key
for the reservoir dike, a trench  will be made along the  northwest boundary
that will penetrate down to a competent zone in the Arapahoe formation.  An
examination of the exposed units  will be made to determine if any fault traces
cut across this portion of the reservoir.  If a fault trace is located within
the proposed reservoir area,  either the dam will be relocated to exclude the
trace, or the trace will be sealed with an impermeable liner before
implacement of the clay liner.  The results of these investigations and any
mitigative measures must be inspected and approved by the Corps  of Engineers,
who will report the results to EPA.

     All shallow test holes within the reservoir site that have  a depth
greater than 30 feet below the pond base must be plugged with concrete.  Any
test holes that have a depth  of less than 30 feet must be back filled and
compacted.  The cased USGS test wells (BW-77-15B and BW-77-17B)  must be
pressure plugged with concrete from the bottom up to insure proper
abandonment.  EPA will be notified when the plugging is  to take  place so that
a staff member can observe the plugging operation.

     The thickness of the clay liner will be increased over the  proposed six
inch compacted seal for areas where the seal will be in  direct contact with
sand or sandstone.  Clean claystone material must be used.  In all cases the
inplace claystone that will be used for a seal must be ripped up to the
required depth before compacting  to the six inch thick seal.  The clay seal
will be kept moist to prevent cracking.  In areas where  claystone is not
present, a supply of claystone (from stockpile) must be  spread in the area and
a compacted seal of at least  one  foot thick provided."
                                     28

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     5)  Northglenn has agreed to monitor the agricultural exchange
program for the design life of the project.  Northglenn will collect
data that relates to the potential for surface water quality degradation
caused by agricultural tailwater, groundwater contamination from
reservoir seepage, agricultural lands or irrigation ditches, and contam-
ination of water and subsequently crops by heavy metals, and pathogenic
organisms.

         EPA has required the following grant condition:  "A monitoring
program will be developed to include locations and depths of ground-
water monitoring wells, locations of surface-water monitoring, and
procedures for monitoring crops.  Pollutant parameters and monitoring
frequencies must be given.  Domestic groundwater supplies in the area
that could be affected by the project must be identified and periodically
monitored.  The monitoring program shall be modified as information is
developed on items such as the potential for crop contamination by toxic
substances.

         Test procedures for the analysis of pollutants shall conform
to regulations published pursuant to Section 304(h) of the Clean Water
Act.  Northglenn will be required to retain all records and information
resulting from the monitoring activities required by this permit con-
dition including all records of analyses performed and calibration and
maintenance of instrumentation for the design life of the project.

         Northglenn must provide annual public reporting on the findings
of the monitoring program.  Northglenn must also identify any noncon-
formance with regulations concerning the level of contaminants in crops
set by FDA, USDA, State agriculture and health departments and other
government agencies.  EPA shall pay no more than 50 percent of the
federal share of the Step 3 project until the draft field monitoring
program is submitted to EPA.  EPA shall pay no more than 90 percent
of the federal share of the Step 3 project until the field monitoring
program is approved by EPA."

         EPA will provide the Larimer-Weld 208 and Weld County copies
of the draft program for their review.  A 90-day review period will be
provided.   EPA will review the Larimer-Weld 208 and Weld County comments
before the monitoring program is approved.  Northglenn has submitted to
EPA a preliminary program.

     6)  The City of Northglenn is located within the 208 Areawide
Planning jurisdiction of the Denver Regional Council of Governments
(DRCOG) and has been designated as a Management Agency under the DRCOG
Plan.  As such, Northglenn is eligible to receive EPA Section 201
Construction Grants funds.  Northglenn will have responsibility for
any facility they construct, for issuance of bonds, grant administration,
and operation and maintenance of the facility.

         In accordance with the approved Larimer-Weld 208 Plan, the
continuing planning functions in Weld County are the responsibility of
the Larimer-Weld Regional Council of Governments.   Weld County has been
designated as a Management Agency under the Larimer-Weld 208 Plan for
all unincorporated areas of the county.  As a Management Agency, Weld
                               29

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County has vital  interest  in  the planning, operation and management of all
wastewater treatment  facilities constructed within their boundaries.

          The proposed Northglenn wastewater treatment and reuse  facility will
service only the  city limits  within Northglenn with an eight mile interceptor
through Adams County.  The plant, however, will be located in southern Weld
County, within the jurisdiction of the Larimer-Weld Regional Council of
Governments' 208  Areawide  Planning Region.  This situation is unique in
Colorado and there have not been any precedents established for designation of
the Management Agency under these circumstances.

          EPA has required the following grant condition:  "The City of
Northglenn and Weld County shall share responsibilities as Management Agencies
under their respective 208 Water Quality Plans.  Designation of said
responsibilities  shall be  incorporated into an Intergovernmental Agreement
following as a minimum those  EPA recommendations as outlined above.  EPA shall
pay no more than  50 percent of the federal share of the Step 3 project until
the draft Intergovernmental Agreement is submitted to EPA.  EPA shall pay no
more than 90 percent  of the federal share of the Step 3 project until the
Intergovernmental Agreement is signed by the two parties and approved by EPA
and the State."

Previously Required Mitigating Measures

     When EPA issued  its initial environmental assessment on the Northglenn
facility in September, 1978,  several measures designed to reduce adverse
impacts were identified.  All Denver area communities which request EPA sewage
funds must comply with EPA provisions as developed in the Denver Overview
EIS.  (See Final  Action on the Denver Regional Environmental Impact Statement
for Wastewater Facilities  and the Clean Water Program, August, 1978.)  For the
City of Northglenn these conditions include:

     Compliance with  the State Air Quality Implementation Plan,
     including:

     a.   Limiting sewer taps, and
     b.   Limiting development to within the urban service area and
          contiguous  to existing development.
     c.   Conformance with Section 176(c) of the Clean Air Act regarding
          limitations of federal assistance.

     Urban Runoff Controls

     Erosion Controls

     Water Conservation Efforts

     Radiological Emergency Response Plan

     Archaeological/Cultural  Resources

     Analysis of  Recreational Potential
                                         30

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     With certain limited exceptions, EPA has accepted  Northglenn1s-efforts  to
fulfill these conditions.  The current status of  these  efforts  includes  the
following:

     1)   Air Quality

     The funding of wastewater treatment and collection facilities that
involve the addition of capacity to serve future  population growth should  be
done in a manner encouraging the implementation of measures to  reduce  the
existing air pollution problem.

     Northglenn will meet the four requirements specified  in  the  Denver
Overview EIS through the following provisions:

     a.   A resolution adopted by the City Council indicating a willingness  to
          comply with all measures developed in the Denver element of  the
          State Air Quality Implementation Plan.

     b.   An ordinance limiting the number of taps available  on an annual
          basis.

     c.   Ordinances prohibiting new taps along the proposed  new  interceptor.

     EPA accepts these actions of the City of Northglenn to be  in compliance
with agency policy to minimize air quality impacts within  the Denver urban
area.  EPA finds that the Northglenn Plan is in conformance with  the Colorado
State Implementation Plan (SIP) in accordance with Section 176(c) of the Clean
Air Act.  Accordingly, EPA has required the following grant condition:

          "Northglenn shall execute those items specified  in  City Resolution
     Number 78-94 regarding its intention to implement  and enforce compliance
     with the provisions of the Denver element of the State Air Quality
     Implementation Plan (SIP).  Specific measures required under the  SIP  for
     local governments including Northglenn include consideration of a local
     smoking vehicle control ordinance, bicycle and pedestrian  facility
     requirements for local zoning ordinances, and subdivision  regulations.
     Northglenn shall maintain an ordinance providing for  sewer tap limits as
     defined in Ordinance Number 529 adopted December 21,  1978  or as amended.
     The City shall maintain a prohibition against connections  to the
     Northglenn Interceptor for areas outside the current  city  limits  as
     specified in Section 16-11-5 or as amended,  of the municipal code.  The
     City shall not expand the wastewater treatment facility  or construct  any
     new interceptor to transport sewerage to the wastewater  treatment
     facility intended to serve areas outside the current  city  limits  unless
     they first obtain concurrence from the appropriate metropolitan planning
     organization designated under Section 134 of Title 23, United States
     Code, the State Air Quality Control Division and EPA  that  such actions
     conform to the State Air Quality Implementation Plan  in  accordance  with
     Section 176(c) of the Clean Air Act.  The Regional Administrator  may
     withhold, condition, or restrict the Step 3  grant  in  the event that he
     determines that the provisions of Section 316(fa) of the  Clean Air Act of
     1977 have been met."
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     2)   Urban Runoff Controls   . .   •

     The Denver Regional Council of Governments recommended in Che 208 Clean
Water Plan that urban runoff pollution be controlled by nonstructural controls
such as pollution control ordinances (see Denver Overview Final EIS, Volume 1,
page 33).  The use of the structural pollution controls to collect and treat
urban runoff was believed to be too expensive to justify at this  time.
Accordingly, EPA determined that prior to granting funds for construction or
expansion of the wastewater facilities the general-purpose governments within
the proposed service area must show progress, in the form of ordinances
adopted or recent efforts taken towards implementing the nonpoint source
controls recommended by the Clean Water Plan.  Northglenn has met this
requirement with respect to urban runoff control by adopting a new ordinance
to their municipal code entitled "City Urban Runoff Drainage Ordinance".

     EPA accepts this ordinance as written as suitable to meet the
requirements of an urban runoff control plan.  Accordingly, EPA has required
the following grant condition:

          "Northglenn shall maintain for the design life of the project an
     urban runoff control plan similar to the provision contained in Ordinance
     No. 531 entitled Urban Runoff Management Plan or as amended."

     3)   Erosion Control

     Northglenn had agreed to implement erosion control measures by passing
City Resolution Number 78-102, adopted December 21, 1978.  The resolution
called for adoption of an erosion control ordinance by June, 1979.  Northglenn
has not yet implemented this provision.  Accordingly, EPA will require the
following grant condition:  "Northglenn will adopt measures to limit erosion
and to control sediment prior to final payment of the grant.  Northglenn will
prepare and adopt an ordinance specifying erosion controls that follows: Guide
for Erosion and Sediment Control in Urbanizing Areas of Colorado;  Interim
Guidance, prepared by the U.S. Department of Agriculture, Soil Conservation
Service, Denver, Colorado, 1977.  EPA will not award final payment of the Step
3 grant until the grantee has adopted appropriate ordinances or requirement to
implement the erosion and sediment control requirements for new development as
included in the DRCOG 208 Clean Water Plan."

     4)   Water Conservation

     EPA regulations for cost-effective analyses specify that adequate
consideration be made for reducing wastewater flow (generally called water
conservation) for communities over 10,000 population discharging wastewater
greater than 70 gallons per capita per day (gpcd).

     Northglenn has adopted Ordinance Number 555 which establishes fees and
charges for connections to the water and sewer utility system which bases
charges on estimated use.  The graduated fee schedule establishes additional
costs for each 5,000 square feet of irrigated lawn with lower fees established
if a resident installs drip irrigation or automatically timed spray irrigation.
                                      32

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     In addition, Northglenn is also in the process of adopting a city
ordinance to specifically promote water conservation.  This recommended
ordinance is entitled "Water Conservation and Plumbing Code of 1979."

     EPA has imposed a grant condition which states:  "Northglenn shall
develop a water conservation policy similar to their proposed ordinance
entitled "Water Conservation and Plumbing Code of 1979", which encourages
further reductions in wastewater flows.  Said ordinance with amendments  shall
be adopted and remain in effect for the design life of the project."

     5)   Radiological Emergency Response Plan

     The City of Northglenn is located just beyond the area known as the
Category II area (10 mile radius) of the Rocky Flats Plant.  The proposed
water supply system, however, includes Standley Lake and Woman Creek which are
inside the Category 1 area (5 mile radius).  Accordingly, EPA has determined
Northglenn must comply with provisions of the Radiological Emergency Response
Plan for Rocky Flats.

     EPA has applied as a grant condition:  "The grantee shall develop a
notification procedure consisting of distributing and redistributing annually,
a pamphlet notice yet to be developed, approved, and furnished by the State,
for notifying existing homeowners within the Category II area as defined by
the State Radiological Emergency Response Plan.  The grantee shall provide EPA
with a copy of the procedures, as adopted prior to receiving a Step 3 grant
from EPA, provided the State and the Department of Energy have completed this
pamphlet at that time.  If and when the pamphlet is formally approved at a
later date, Northglenn shall then adopt and maintain for the project design
life, those procedures necessary for the City of Northglenn as specified in
the Radiological Emergency Response Plan."

     6)   Archaeological/Historical Resources

     The survey of archaeological/historical resources conducted of the
proposed interceptor route and reservoir site identified a possible area of
interest consisting of a turn-of-the-century dump along the interceptor
route.  No other significant historical resources were identified.  Northglenn
discussed the situation with the State Historic Preservation Officer and has
agreed to modify the interceptor route to avoid this area.  EPA has applied
the following grant condition:  "If archaeological or cultural artifacts are
unearthed, construction will be halted and the State Historic Preservation
Officer will be consulted immediately.  Accommodations will then be made as
necessary for excavation and/or assessment of uncovered archaeological
resources."

     7)   Analysis of Recreational Potential

     During the review of the final EIS, EPA was notified that the present
planning efforts failed to formally consider potential recreational
opportunities of the proposal.  While many informal discussions were held
regarding recreation at the proposed plant site such as waterfowl observation,
trails, etc., a complete review of options for recreation has not yet been
accomplished.
                                      33

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     Accordingly EPA has required the following grant condition: "Northglenn
will submit an analysis of recreational potential of the proposed exchange
plan.  This analysis shall he accomplished by close coordination with Adams
County, the Denver Regional Council of Governments, the Heritage Conservation
and Recreation Service and the State of Colorado.  Said analysis shall provide
opportunity for public involvement and shall be due to EPA prior to 50 percent
construction completion."
                                       34

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RESPONSE TO COMMENTS RECEIVED ON THE FINAL EIS

      Eleven written comments were received and  twelve  individuals  presented
oral statements at the public hearings  following the  publication  of the
final EIS on June 27, 1980.  Three of the oral statements were  duplicated  by
written comments.  Six of the respondents, of which  four were consultants  to
the City of Northglenn,  favored the project, with  eleven in opposition to
all or a portion of the  project.  Two other respondents asked questions  of
timing or specific effects.  EPA has reviewed all  of  these comments and
offers the following response to the major issues  raised.

Agricultural Productivity

      The Consolidated Ditches Company  engaged W.W. Wheeler and Associates
and Charles E. Turner, P.E., presently  associated  with  Colorado State
University, to review the impact of the project  and alternatives  upon
agricultural productivity.  In Mr. Turner's 25-page report entitled
"Analysis of Agricultural Productivity  as Used in  the Final Northglenn EIS",
June 1980, he criticizes the methodology and economic theory of the analysis
in the EIS.  The basic complaint is that by using  1979  year water use data
for FRICO and average year data for the South Platte  System, the  analysis  is
inaccurate, since 1979 was wetter than  normal.   Mr. Turner then provides an
alternative method (the  Blaney-Criddle  Procedure)  for determining economic
value per unit of water.  Use of this method alters the conclusion  that  the
Northglenn proposal provides some benefits to the  agricultural  community.
Turner's analysis indicates that an alternative  which relies on continued
wastewater treatment at  Metro and a return flow  to the  South Platte is
preferable.

      Only limited crop  yield data was  available for  FRICO, primarily 1979
data.  The EIS analysis  used 1979 crop  values for  both  systems.   Average
year water use data for  the South Platte system  was also used.  Since the
FRICO system is water short the estimated average  economic productivity  for
FRICO is not unduly affected by higher  precipitation.   The water  use pattern
of FRICO is to use all available supplies to irrigate more land or  crops
needing additional water.  In 1979, FRICO water  use was 40 percent  higher
than in the average year despite the additional  rainfall, because the wetter
year provided a larger Standley Lake reserve.  In  the adequately, even
overly irrigated, South  Platte system,  however,  where land not  water is  the
factor limiting agricultural productivity, water use  from direct  flow
ditches is less during wetter years.  The average  year water use  is the
appropriate data reference for the South Platte  system.  Therefore, the  use
of such a data base results in a conservative approach  for estimating
production value per unit of water.

      The Blaney-Criddle procedure is used as a  water supply planning tool.
The Blaney-Criddle procedure assumes that the crop evapotranspiration rate
varies directly with the sum of the products of  mean monthly air  temperature
and monthly percentage of daytime hours.  The consumptive use rate  of crops
determined by this procedure is valid to determine what water supply is
necessary for optimal production of a crop.  The irrigation requirements of
a crop are made up by the consumptive use requirement of the crop as
                                    35

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determined by the Blaney-Criddle procedure after accounting  for effective
precipitation plus water withdrawn from  storage in the soil  during  the
growing season.  (See "Irrigation Water  Requirements" USDA,  SCS,  Engineering
Division, Technical Release No. 21, September 1970).  In a report by  Blaney
and Griddle it is stated:  "Accordingly, the Blaney-Criddle  methods assumes
that with adequate water available, consumptive use varies directly with
monthly mean temperature multiplied by monthly percentage of daytime  hours
of the year, and with the type of crop grown." (emphasis added)   (From
Blaney, H.F. and Griddle, W.P, "Report on Irrigation Requirements for West
Pakistan", produced for Tipton & Kalmbach, Inc., Denver, April 30,  1957,
page 3.)

      Hence reliance on Blaney-Criddle as a method of comparing the
agricultural productivity of  two parcels of land is misplaced unless  there
is a comparable supply of water for each.

      The FRICO irrigation system does not have a full water supply
available for crop production and the "potential" evapotranspiration  rate
determined by the Blaney-Criddle procedure can not be achieved under  field
conditions since the full moisture supply is not available.

      In the South Platte system most of the canals have very senior  water
rights and are able to provide the optimal requirement for their  crops.
Under this circumstance the evapotranspiration rates estimated by the
Blaney-Criddle procedure are valid and can be achieved under field
conditions.  EPA believes the 0.67 acre-foot per acre of consumptive  use of
irrigation water for FRICO as presented  in the EIS is realistic,  primarily
because FRICO does not have a full water supply available to the  crops.
While the 1.66 acre-foot per  acre of consumptive use of irrigation water
developed by Turner may be optimal, it is inaccurate since it is  based on
the assumption that crop water requirements are completely satisfied.

      EPA believes the analysis of agricultural productivity as contained  in
the EIS is reasonable and warrants the conclusion that net agricultural
production is greater for the exchange options than for condemnation  or
purchase of FRICO water supplies with a  discharge to the South Platte
through Denver Metro.  The use of the South Platte - Deep Wells alternative
gives an intermediate result  (less than  Option 3 but greater than Option 2)
and also exposes the FRICO water to conversion from agricultural  to other
uses (see Table 6).  Therefore assisting Northglenn in this  project is
consistent with EPA policy to protect environmentally significant
agricultural lands.

Impacts Due to Canal Lining and.the Flow Augmetation Plan

      Several commentors stated that the EIS failed to fully analyze  the
agricultural and environmental impact due to canal lining.   FRICO intends  to
line most of the Bull Canal system in order to improve efficiency of  water
delivery.  The final EIS summarized studies undertaken by consultants for
FRICO and Northglenn which evaluated canal losses due to seepage.   The
report by Wright-Water Engineers concluded that seepage loss along  Big Dry
Creek was too small (five percent) to warrant lining and that due to
urbanization such losses may  eventually  be reversed.  Total  losses  along
                                   36

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                                                         TABLE  6
CO
                                        GROSS PRODUCTIVITY OF FRICO AND SOUTH PLATTE

                                    IRRIGATED LANDS AFFECTED BY THE NORTHGLENN PROJECT
                                                    (IN MILLION DOLLARS)

                                                        FRICO1
                                                                         SOUTH PLATTED
                          TOTAL GROSS
                          PRODUCTIVITY
Option               Description

  i        Without deep wells

  2        650 acre-feet from non-
             tributary wells
                 .1
  3        2300 acre-feet from non-
             tributary wells

  It        Water from Standley Lake
             Wastewater to Metro
                 i
           South Platte - Deep
             Well Alternative
Average Year
1.95
1.95
. 1.95
1.49
^1.90
Dry Year
1.76
1.75
1.74
1.04
1.61
                                                                        Average Year  Dry Year    Average  Year   Dry Year
0.16


0.33


0.53


0.53


0.53
0.15


0.31


0.48


0.48


0.48
                                                                                                      2.11
                                                                                                      2.28
                                                                                                      2.48
                                                                                                      2.02
                                                                                                      2.43
1.91
2.06
2.22
1.52
                                                                                                              2.09
     Based on  $342/acre-foot of  consumptive  use  of  irrigation water.   FRICO  deliveries  given  in Table 4 of  Final  EIS,
     irrigation efficiency = 65% in  average  year and  70%  in  dry year.

   ^ Based on  $259/acre-foot of  consumptive  use  of  irrigation water.

    Note:   All  lands  which are  removed  from irrigated  agricultural production are assumed to have a dry-farming
           productivity of $60/acre.
    Sample Calculation -  Option 1,  Average  Year:

                 FRICO
    Farm Headgate Delivery = 6390 A-F
    Productivity oE Irrigated Land  •=  (6390)(.65)(342)=$!.42 M.
    Irrigated acreage = 6390/1.04 = 6144  A.
    Non-irrigated acreage = 15,000  -  6144 - 8856  A.
    Productivity of Non-irrigated Land  =  (8856)(60)=$0.53 M.
    Total FRICO Productivity = $1.95  M.
                                                                                        SOUTH PLATTE
                                                                 Productivity of Irrigated Land = (2039.2-1667)(259)=$0.096^
                                                                 Non-irrigated acreage=(1667/2039.2)(1343.4)  = 1098 A.
                                                                 Productivity of Non-irrigated Land = (1098)(60)=$0.067  M.
                                                                 Total South Platte Productivity = $0.16 M.
                                       TOTAL GROSS PRODUCTIVITY - 1.95 + 0.16 - $2.11 M.

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Bull Canal were estimated by Hydro-Triad to be 40 percent of  the  Standley
Lake releases (see page 76 of final EIS).  Subtracting the estimated  five
percent seepage loss along Big Dry means that during an average year  changes
in flow affected by canal lining could amount to 3500 acre-feet per year
(35 percent of average annual release of 10,000 acre-feet).   This water  is
currently lost due to canal bank evapotranspiration and evaporation as well
as groundwater recharge.

      Several commentors indicated that  substantially all this water  has
historically recharged groundwater which then flows to the South  Platte
River.  If so, stream flow could be reduced by that amount.   Relatively
small changes in stream flow would not economically impact the direct flow
irrigators, since there is sufficient river flow to physically divert and
they are sufficiently senior so as to assure priority.

      If the water court determined that any quantified water losses  due to
canal lining must be offset by a flow augmentation plan there could be both
an adverse economic impact to agriculture and to the responsible  party.  If
one assumes that 3000 acre-feet must be  augmented annually and that the
source is other agricultural water, then agricultural production  could
drop.  (Note: In the EIS the agricultural productivity analysis eliminated
both the adverse effects of obtaining this water and any benefit  in the
FRICO system that canal lining provides).  It is not clear in the event  of
such a water court ruling whether FRICO, Northglenn, or another party would
be responsible to replace such water.  If Northglenn were responsible, then
it is possible that capital costs of the system could increase by the cost
of such water augmentation.  At the present price of water ($3000 per
acre-foot in the area) 3000 acre-feet would cost $9 million.  The cost of
the Northglenn proposal under these circumstances in shown in Tables  3 and
4.  It remains EPA1s position as presented in the EIS that lining of  the
Bull Canal by FRICO is a private action unrelated to EPA's or any federal
action and the issue will have to be resolved in water court.

      Several objectors to Northglenn's  flow augmentation plan have opposed
the plan on the basis that the exchange will increase historical  depletions,
i.e. decrease stream flow previously available to other water users.
Northglenn's plan includes a claim for 100% depletion credit  for  its  storage
rights.  These sources may have had some historical return flow to the South
Platte system.  In view of EPA policies  to protect agricultural land, EPA
considered and rejected the following grant conditions:

      "Northglenn shall revise its flow  augmentation plan so  that there  will
not be an increase in historical stream  depletions except if  such depletion
is due to canal lining".
                                     38

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      Such an admittedly ambiguous condition would be meant  to  force
Northglenn to revise its augmentation plan to met the environmental and
social objectives of further protecting farmlands and maintaining historical
stream flow.  If implemented the condition would be intended  to prevent
Northglenn from obtaining 100% depletion credit on its purchase of Standley
Lake (FRICO shares) storage water and its claims to 300 acre-feet per year
of sewer line infiltration.  Stream depletion due to canal lining would be
exempt since it is generally recognized that a farmer's ability to line
canals without augmentation is desirable in order to provide  an incentive to
improve irrigation efficiency.  Of course the legal contraints on water
transfers in Colorado are based upon a century of property rights experience
and not based upon such factors that may be considered to be  in the best
interests of the public.  Transfers of water are usually approved through
private bargaining for such property rights amoung those affected parties.
Public scrutiny of the effect is provided by the State Engineer's office and
subject to water court procedures.  Some prior appropriation  states have
recently revised their water law to avoid some of these abuses and
ambiguities and have therefore limited water transfers to those deemed to be
in the public interest.

      EPA decided not to apply this grant condition because  it would
interfere with Northglenn's rights under Colorado water law.  Anyway the
agricultural productivity of the proposed plan has been determined to be
beneficial and therefore sufficient to be compatible with EPA policy to
protect agricultural land without such a grant condition.  Nevertheless EPA
encourages Northglenn to resolve the objections to their flow augmentation
plan as expediously as possible.

      EPA also received several requests to delay grant award until such
time as the Northglenn Flow Agumentation Plan has been approved by the water
court.  Some of these objections were based on the concept that failure to
obtain water court approval of the plan as submitted could even mean federal
funds would be wasted on an unuseable system.  Based upon expert opinion
provided to EPA, the more likely situation is that water court approval may
change but not negate the exchange plan.  EPA believes it is  generally
unnecessary to delay any grant until all pending litigation  is resolved.  At
this point all EPA grant requirements have been satisfied.   The grant award
is limited to eligible portions of the proposed wastewater treatment and
reuse system.  If for any reason Northglenn does not construct and operate
this system in accordance with the facilities plan EPA could  terminate and
anull the grant seeking recovery of funds expended and other  such
adminstrative or judicial actions as may be legally available persuant to
EPA regulation 40CFR30.920-5.

Tailwater Control

      Several objectors to the plan indicated that the EPA requirements to
require tailwater control created additional problems.  It was stated that
elected officials are not likely to approve or allow construction of the
tailwater control structures due to community opposition to  the entire
                                    39

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project and a belief that:stored wastewater creates a public nuisance  such
as fostering mosquitoes.   It  is EPA's intention in placing this requirement
upon Northglenn to reduce  the  unnecessary public contact with treated
effluent which might result from tailwater runoff into residential areas.
If the community and land  owners continue to oppose the use of the land  in
this manner, Northglenn may need to use eminent domain to acquire this
property in order to-comply with the grant condition.  Alternatively,  if
future residential growth  or  the ongoing condemnation action against the
water right owner is completed, then the grant condition will be met by  not
irrigating these areas.  The  tailwater ponds will not create new mosquito
breeding habitat since the water will be pumped automatically until all
water is consumed by the crop or infiltrates the soil.

Intergovernmental Agreement with Weld County

      In response to EPA,  the Commissioners of Weld County indicate they are
reluctant to enter any agreement to enforce grant conditions.  Weld County
has misinterpreted EPA's requirement for Northglenn to negotiate an
Intergovernmental Agreement (IGA) with Weld County.  Although EPA recommends
that the IGA contain many  of  the same measures contained as EPA grant
conditions, the purpose is not for Weld County to enforce EPA requirements.
Rather if Weld County concurs that such measures or other measures are
necessary and desirable for the citizens of Weld County, they can mutually
agree with Northglenn to monitor compliance and be reimbursed by Northglenn
for their expenses.  EPA is prepared to enforce required grant conditions as
specified in the section on "EPA's Decision" in this Record of Decision.

Compensation for Reduction in Residential Property Value

      EPA has received several requests that EPA should require Northglenn
to pay property owners the difference in appraised real estate value.  The
facility has been designed and should be operated in accordance with
applicable state and federal  regulations.  There is the possibility as
analyzed in the Final EIS, that an odor nuisance could occur if the plant is
operated improperly.  The  course of action for these property owners may be
through the courts in order to quantify any losses.

Analysis of Recreational Potential

      The Denver Regional  Council of Governments suggested to EPA that a
formal review of recreational opportunities should have been included  in the
EIS analysis.  EPA concurs and notes that while Northglenn officials have
informally discussed such  opportunities including water fowl habitat
enhancement, a trail around the proposed reservoir and many other
recreational facilities, none of the suggestions are planned.  The DRCOG
1977 report entitled "Regional Parks, Recreation and Open Space Plan"  shows
a planned bike path between Barr Lake and Boulder which parallels the  last
mile of the proposed interceptor.  EPA suggests that this opportunity  as
well as options for other  bike routes, for tours of the facility, public use
of the facility site, and  other recreational facilities be evaluted by
Northglenn.  EPA has therefore added a grant condition that requires
Northglenn to prepare an analysis of recreational potential prior to
50 percent grant payment.  (See list of grant conditions in the preceding
section.)
                                      40

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Compliance with Provisions of the Clean Air Act

      The Denver Regional Council of Governments in comments  to EPA
indicated that they concur with EPA's  finding  that the project is consistent
with the State Air Quality Implementation Plan (SIP).  However, DRCOG
indicated that there are specific measures required under  the SIP for  local
governments to consider and that Northglenn has not yet considered  these
issues.  These measures include consideration  of a local smoking vehicle
control ordinance and bicycle and pedestrian facilities for new residential
development.  These requirements have  been added to EPA's  grant conditions
regarding compliance with the SIP.

Cost Analysis for the South Platte - Deep Well Alternative

      The analysis in the final EIS of the South Platte -  Deep Well
alternative did not include a detailed analysis of the cost of the
additional well fields, pipelines, storage and treatment facilities which
would be necessary to implement this alternative.  A detailed estimated cost
of this alternative is shown in Table  3 along  with the other  alternatives
considered.  In addition to the water  supply facilities proposed under
Option 3 which include the water treatment plant, (the Standley Lake
pipeline is still necessary under this option  in order to  deliver
Northglenn-owned water) and the purchase of the existing water distribution
system from Thornton, the following items are  also necessary:

                                                              Estimated
                     Item                                   Capital Cost

1.  South Platte well field, pumps, transmission              $2,384,000
line to treatment plant.

2.  Raw water storage reservoir near treatment               1,800,000
plant (1000 acre/feet).

3.  Additions to treatment plant for water                    2,000,000
softening.*

4.  Additions to the Deep Well field.                           542,000

5.  Engineering contingencies                                 2,324,OOP
legal and administration at 40%.
                                                 Total        $9,055,000

    * Due to the high dissolved solids content of the shallow well  water,
      water softening equipment would  be necessary.  The average total
      dissolved solids (TDS) of the alluvial shallow wells is 800 to  1000
      mg/1 and TDS of the deep wells would be  100-200 mg/1.   When blended,
      the TDS would exceed the 500 mg/1 the recommended limit under the Safe
      Drinking Water Standard.  Therefore precipitation of solids and
      hardness is necessary.
                                        41

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      As proposed by Consolidated Ditches, this alternative would also
require Northglenn to provide FRICO 500 acre/feet annually in order to meet
the minimum return flow called  for in the FRICO-Northglenn Exchange
Agreement.  If necessary,  this  item would be common to any alternative which
relied upon the Denver Metro wastewater treatment alternative.  For
consistency, the cost of this item, estimated at $1,580,000 is not included
here since it was not included  in the cost of the other Denver Metro
alternatives.

      The capital cost of  this water supply alternative when combined with
the less costly Denver Metro Wastewater treatment system  is less than the
proposed exchange plan. When the higher operation and maintenance costs, are
included, this alternative  is 12 percent higher based on  present worth cost
than the proposed exchange  plan under Option I.  Therefore, the results and
analyses stated in the EIS  regarding the cost selection of alternatives are
not changed.

      An estimate of agricultural productivity of this option has also been
made (see Table 6).  The results indicate that the estimated total
productivity of $2.43 million under the South Platte-Deep Well option during
an average year is slightly less than Option 3 and greater than other
options.  Hence the conclusions reached in the EIS that Option 3 has the
highest agricultural productivity remains the same.
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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.-
   EPA-908/5-5-79-002D
                             2.
                                                           3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
   Record of Decision
   Northglenn Water  Management Program
   City of Northglenn,  Colorado
             5. REPORT DATE

               September 9.  1980
             6. PERFORMING ORGANIZATION COOE
7. AUTHOR(S)
   Weston W. Wilson,  EPA
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   U.S. Environmental  Protection Agency
   Region VIII
   1860 Lincoln Street
   Denver, Colorado   80295  	
                                                           10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
   U.S. Environmental  Protection Agency
   Region VIII
   1860 Lincoln  Street
   Denver, Colorado   80295
              13. TYPE OF REPORT AND PERIOD COVERED
               Final    	
              14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
   Draft Environmental  Impact Statement dated January 11, 1980 and Final Environmental
   Impact Statement  dated June 27, 1980 issued by  EPA.
16. ABSTRACT
   This is a public  record of decision regarding  proposed construction of facilities
   to provide water  supply, wastewater treatment  and  agriculture reuse of sewage
   effluent for the  City of Northglenn, Colorado.   Under an exchange agreement with
   the Farmers Reservoir and Irrigation Company,  approximately 5,000 acre-feet of
   water will be diverted annually for Northglenn's municipal  use, treated, augmented
   from other sources,  stored, and then returned  for  irrigation purposes.

   The U.S. Environmental Protection Agency  (EPA),  Region VIII, Denver, under the
   authority of Section 201 of the Federal Water  Pollution Control Act Amendments  of
   1972, has authorized a grant for 75 and up to  85 percent matching funds for
   construction costs of the proposed wastewater  treatment facilities.

   The recommended action is to construct an 8 mile interceptor, aerated lagoon and
   a storage reservoir.   Implementation of the exchange  program negates the pending
   water condemnation actions that were in progress.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
   Wastewater Reclamation
   Sewage Irrigation
   Agricultural Reuse
   Alternative Wastewater  Treatment Techno!o
   Environmental Impact  Statement
   Record of Decision
iy
Denver Regional  EIS  fo
  Wastewater Facilitie
  and the Clean  Water
Denver Metro Sewage
Farmers Reservoir  and
  Irrigation Company
                           'rogram
18. DISTRIBUTION STATEMENT

   Release Unlimited
19. SECURITY CLASS (This Report)
                        21. NO. OF PAGES

                           43	
                                              20. SECURITY CLASS (This page)
                                                                         22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE
                                            43

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