United States
              Environmental Protection
              Agency
              Office of
              Water Programs Operations
              Washington, D.C. 20460
February 10, 1977
430/9-76-012
&EPA
Cost Estimates for
Construction of Publicly-owned
Wastewater Treatment
Facilities

Summaries of Technical Data for
Combined Sewer Overflows and
Stormwater Discharge

1976 NEEDS SURVEY
                                            MCD-48C

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Document Dumber

430/9—76--010
     (MCD-48A)
Title and Content

"Cost Estimates for  Construction  of
Publicly-Owned Wastewater Treatment
Facilities — 1976 Needs Survey"

This volume contains  cost  estimates
for needed publicly-owned wastewater
treatment facilities for eignt  Needs
Categories  in each of the States and
Territories.
 43i3/9 —76 — 011
     (MCD-483)
430/9--76--012
      (MCD-48C)
"Summary    of
(Categories  I-IV)
                  Technical
Data"
                            This volume consists of summaries  of
                            technical   data   collected  in  the
                            course of the field work of the Needs
                            Survey in Categories T through IV.
"Summary  of   Technical   Data   For
Combined     Sewer    Overflow    and
Stormwater Discharge"

This volume  contains  the  technical
rationale  and  supporting  technical
data  used for the estimation of need
in Categories V and VI.
       These Reports were prepared under the direction of:

                    James A. Chamblee, Chief
                Needs Assessment Section  (WH-547)
               Office of water Program Operations
              U.S. Environmental Protection Agency
                     Washington, D.C.  20460
                         (202) 426-4443
Copies of these reports are available from the address below,
When ordering, please include the title and MCD number.

              General Services Administration  (8FFS)
              Centralized Mailing Lists Services
              Bldg. 41, Denver Federal Center
              Denver, Colorado 80225

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      Cost Estimates for Construction of
Publicly-owned Wastewater Treatment Facilities
              1976 NEEDS SURVEY
          SUMMARIES OF TECHNICAL DATA
                     FOR
           COMBINED SEWER OVERFLOWS
                     AND
           STORMWATER DISCHARGES
            Contract No.  68-01-1984
          EPA Report No.  430/9-76-012
             MCD Report No.  48C
                Project Officer

               Philip H.  Graham
        Municipal Construction Division
        Office of Water Program Operations
        Environmental Protection Agency
              401 M Street S.W.
            Washington, D.C.   20460
               February 10,  1977

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                                 ABSTRACT
          The 1976 Needs Survey for Category V (correction of combined
sewer overflows) and Category VI (treatment and/or control of stormwater
discharges) was developed using a well defined, consistent nationwide
methodology.  The Needs Survey developed current and 1990 capital and
annual operation and maintenance cost estimates to attain three water
quality criteria:  Aesthetics, Fish & Wildlife and Recreation.

          A computer model, called the Needs Estimation Model for Urban
Runoff, was developed from intensive work with the literature of a de-
tailed analysis of ten specific urbanized areas.   The model calculates
the combined sewer and stormwater control needs for each urbanized area.
These estimates are then summed on a state and territory basis to provide
the national estimated needs for Categories V & VI.

          The estimated needs are significantly lower than those developed
by earlier Needs Surveys.  The consideration of receiving water assimilative
capacity, a relatively small design storm, a well defined area for storm-
water control, and a nationwide consistent methodology are the primary
reasons for the reduction in estimated needs.

          The methodology provides a reasonable and well defined estimate of
the eligible costs for water quality control required by combined sewer over-
flows and stormwater runoff.  They also provide a consistent basis for com-
parison of relative needs among the states.  The cost estimates for Category
V are of much better quality than the cost estimates for Category VI as more
is known about the variables affecting Category V costs than is known about
the variables affecting Category VI costs.
                             iii

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                              TABLE OF CONTENTS
                                                                        PAGE
                                                                        ill
Abstract
Table of Contents                                                       xy.
List of Figures                                                         vii
List of Tables                                                          viii
List of Abbreviations                                                   x
Acknowledgments                                                         xizi
Summary                                                                 xv

                    PART I - INTRODUCTION AND OBJECTIVES

Section 1 - Introduction                                                 1-1

     1.1  Needs Survey Background                                        1-1
     1.2  Summary of Previous Surveys                                    1-1
     1.3  1976 Needs Survey                                              1-3

Section 2 - Abatement Objectives                                         2-1

     2.1  Significant Pollutants                                         2-1
          2.1.1  Solids                                                  2-1
          2.1.2  Dissolved Oxygen                                        2-2
          2.1.3  Bacteria                                                2-3
          2.1.4  Other Pollutants                                        2-4
     2.2  Water Quality Criteria                                         2-4

Section 3 - Treatment and/or Control Facilities                          3-1

     3.1  Efficiencies of Controls                                       3-1
     3.2  Costs of Controls                                              3-8

References

                    PART II - SITE STUDIES

Section 4 - Site Study Procedure and Assumptions                         4-1

     4.1  Primary Criteria for Site Selection                            4-1
     4.2  Secondary Criteria for Site Selection                          4-2
     4.3  Sites Considered                                               4_2
     4.4  Sites Selected for Analysis                                    4-,,2
     4.5  Scope of Site Studies                                          4-4
     4.6  Site Data and Waste Sources                                    4-6
     4.7  Conceptual Sketch of Study Site                                4-7
     4.8  Design Storm                                                   4-9
     4.9   Pollution Loading from Design Storm                            4-14
                                     IV

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                         TABLE OF  CONTENTS  (Cont'd)
                                                                        PAGE
    4.10  Receiving Water Impact Analysis                                4-15
    4.11  Determination of Required Treatment Level                      4-18

Section 5 - Description of Study Sites                                   5-1

    5.1  Atlanta                                                         5-1
    5.2  Des Moines                                                      5-2
    5.3  Durham                                                          5-2
    5.4  Lubbock                                                         5-3
    5.5  Milwaukee                                                       5-4
    5.6  Philadelphia                                                    5-4
    5.7  Portland                                                        5-6
    5.8  Roanoke                                                         5-6
    5.9  San Francisco                                                   5-7
    5.10 Tulsa                                                           5-8

Section 6 - Analysis of Rainfall, Waste Loading and Treatment Data       6-1

    6.1  Analysis of Rainfall Data                                       6-1
         6.1.1  Mean Annual Rainfall                                     6-1
         6.1.2  Annual Number of Storms                                  6-3
         6.1.3  Time Between and Duration of Storms                      6-3
    6.2  Generalized Design Storm, Storage and Flow Parameters for
         National Needs Projection                                       6-5
    6.3  Estimating Required Organic Removal                             6-6
    6.4  Analysis of Lead Data                                           6-12

References

                      PART III - NATIONAL ASSESSMENT

Section 7 - National Assessment Methodology                              7-1

    7.1  Demographic Data                                                7-4
    7.2  Hydrologic Data                                                 7-5
    7.3  Model Description                                               7-7
    7.4  Example Urbanized Area Description                              7-7
    7.5  Runoff Quantity Calculations                                    7-7
    7.6  Runoff Quality Calculations                                     7-11
    7.7  Dry Weather Flow Quantity and Quality Calculations              7-14
    7.8  Receiving Water Considerations                                  7-16
    7.9  Level of Treatment Selection                                    7-18
    7.10 Other Required Calculations                                     7-20
    7.11 Cost Calculations                                               7-24

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                         TABLE OF  CONTENTS  (Cont'd)
Section 8 - Needs for Control of Combined Sewer Overflows

   8.1  Category V Cost Summary
   8.2  Non-Urbanized Combined Sewer Control Needs
   8.3  Previously Met Needs
   8.4  Comparison of Category V Needs Surveys
   8.5  Reliability of Category V Results

Section 9 - Needs for Control of Stormwater Discharges

   9.1  Category VI Cost Summary
   9.2  Comparison of Category VI Needs Surveys
   9.3  Reliability of Category VI Results
References

Appendix A

Appendix B


Appendix C


Appendix D
Site Study Results

Base Data for Needs Estimation Model for
Urban Runoff

Needs Estimation Model for Urban Runoff -
Computer Code

Comments on the Draft Report and Responses
to Comments
                                                         PAGE

                                                         8-1

                                                         8-1
                                                         8-1
                                                         8-5
                                                         8-5
                                                         8-8

                                                         9-1

                                                         9-1
                                                         9-5
                                                         9-5
                                                         A-l
B-l
C-l
                                                                         D-l
                                      vi

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                             LIST OF FIGURES
FIGURE                                                               PAGE
  NO.

3.1               Screening - Swirl Concentrator                     3-3
3.2               Sedimentation                                      3-4
3.3               Dissolved Air Flotation                            3-5
3.4               Flocculation - Sedimentation                       3-6
3.5               Filtration                                         3-7
4.1               Location of Selected Study Sites                   4-5
4.2               Conceptual Sketch of Urban Area Receiving
                  Water System                                       4-8
6.1               Long Term Mean Annual Rainfall versus
                  Five Year Mean Annual Rainfall                     6-4
6.2               Number of Storms per Year versus
                  Number of Days with Precipitation                  6-4
6.3               Relationship between Quality Parameter Value
                  and Required Treatment                             6-11
7.1               NEMUR General Computation Schematic                7-2
7.2               NEMUR Subprogram Functions                         7-3
7.3               Example Urbanized Area Schematic                   7-8
                                     vii

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                                  LIST OF TABLES
  ™
  NO.
 1.1                Comparison of Previous Needs Survey                  1-4
 2.1                General Wet Weather Criteria for All Water           2-6
 2.2                Fish and Wildlife Wet Weather Criteria               2-7
 2.3                Recreation Wet Weather Criteria                      2-7
 3.1                Estimated Control Option Efficiency                  3-2
 3.2                Median Removal Efficiency of Primary Sedimentation   3-9
 3.3                Cost Estimating Methodology -
                    Best Management Practices                            3-10
 3.4                Cost Estimating Methodology -
                    Screening - Swirl Concentrator                       3-11
 3.5                Cost Estimating Methodology -
                    Sedimentation                                        3-12
 3.6                Cost Estimating Methodology -
                    Dissolved Air Floatation                             3-13
 3.7                Cost Estimating Methodology -
                    Flocculation - Sedimentation                         3-15
 3.8                Cost Estimating Methodology -
                    Filtration                                           3-17
 3.9                Cost Estimating Methodology -
                    Disinfection                                         3-19
 4.1                Partial List of Cities with Urban Runoff or
                    Combined Sewer Overflow Data                         4-3
 4.2                Estimated Performance of Selected Storage
                    Treatment Systems                                    4-13
 6.1                Summary of Rainfall Data                             6-2
 6.2                Summary of Site Study Treatment Requirements         6-8
 6.3                Summary of Additional Receiving Water Impact
                    Analysis and BOD Treatment Requirements              6-10
 7.1                Verbal Description of Receiving Waters               7-6
 7.2                Input Data for Example Urbanized Area                7-9
 7.3                Example Runoff Quantity Calculations                 7-12
 7.4                Example Runoff Quality Calculations                  7-15
 7.5                Example Dry Weather Flow Quantity and
                    Quality Calculations                                 7-17
 7.6                 Example Receiving Water Considerations               7-19
 7.7                 Successive Treatment and/or Control Combinations
                    based on Cost Effectiveness Evaluation               7-21
 7.8                 Example Level of Treatment Calculations              7-22
 7.9                 Example Best Management Practices Calculations       7-25
 7.10                Example Cost Calculations                            7-29
 8.1                 State Category V Needs to Achieve Aesthetics
                    Water Quality Criteria                               8-2
8.2                 State Category V Needs to 'Achieve the Fish &
                    Wildlife  Water Quality Criteria                      8-3
8.3                 State Category V Needs to Achieve the Recreation
                    Water Quality Criteria
                                      viii

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                             LIST OF TABLES (Cont'd)
TABLE
 NO.                                                                    PAGE
8.4                Non-Urbanized Combined Sewered Areas and
                   Average Dollars Per Acre Control Costs               8-6
8.5                Comparison of Category V Needs Estimates             8-7
9.1                State Category VI Needs to Achieve the
                   Aesthetics Water Quality Criteria                    9-2
9.2                State Category VI Needs to Achieve the
                   Fish and Wildlife Water Quality Criteria             9-3
9.3                State Category VI Needs to Achieve ,,the
                   Recreation Water Quality Criteria                    9-4
9.4                Comparison of 1976 and 1974 Category VI
                   Needs Estimates                                      9-6
                                        IX

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                              LIST  OF ABBREVIATIONS
 Abbreviation

 ADR
 ARF
 ASCO

 BOD5, STATE1
 CM
 COSTCSO,CAP
 COSTCSO,0&M
 COSTSSA, CAP , PRESENT
 COSTsSA.CAP,  1990
 COSTsSA.O&M
 CSA
 CSAP
 CSI
 CTR

 DS
 DVCS
 DVGA

 DVSS
 DWB
 DWF
 1C
 IL
 IMAR
 K2
 LAND
 LEVELCSO
 LEVELsSA
 MNS
 MRF
 NSSTP
 NSP
 NTP
 PDCS

 PDSS
POLfiOD,CSO
POLBOD,SSA
            Description

Number of Storms per year
Average Yearly Rainfall
Average Drainage Area per Combined Sewer
Overflow
Five-Day BOD for Portion of Urbanized
Area in STATE1
Five-Day BOD for portion of Urbanized
Area in STATE2
Curb Miles in Storm Sewered Area
Category V Capital Costs
Category V O&M Costs
Category VI Present Capital Costs
Category VI 1990 Capital Costs
Category VI O&M Costs
Combined Sewer Area
Combined Sewer Area Population
Combined Sewer Area Imperviousness
Consolidated Treatment Rate for Combined
Sewer Overflows
Design Storm
Design Volume of Combined Sewer Treatment
Design Volume from the Urbanized Area
Growth Area
Design Volume of Storm Sewer Treatment
BOD Dry Weather Loading in Urbanized Area
Dry Weather Flow in Urbanized Area
Interceptor Cost
Interceptor Length
Impervious Land Area in Storm Sewered Area
Reaeration Coefficient
Land Area Containing Storm Sewers
Level of Treatment For Combined Sewered Area
Level of Treatment For Storm Sewered Area
Mean Number of Storms Per Year
Mean Annual Rainfall
Number of Storm Sewer Treatment Plants
Number of Combined Sewer Storage Facilities
Number of Combined Sewer Treatment Plants
Population Density of the Combined Sewer
Area
Population Density of the Storm Sewer Area
BOD Loading in Combined Sewer Area
BOD Loading in Storm Sewer Area

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                        LIST OF ABBREVIATIONS (Cont'd)
Abbreviation
POL
   'SS,CSO
POL,

POP
POP
   'SS.SSA
   GA
PPRS

PR1

PR2
PROS
PSF,
QDS
RF
ROC
   STATE1
ROCI

ROCS

RR
SAR
SM
SMSA?0
SMSAgo
SPTP
SSI
STATEEpA
STATE0BERS
STCS
STR
STRSTATE1

TRCS

TRSS

UA
            Description

Suspended Solids Loading in Combined
Sewer Area
Suspended Solids Loading in Storm Sewer
Area
Population in Storm Sewer Area
Population in the Urbanized Area Growth
Area
1990 Urbanized Area Population
Percent of Pollutants Removed by
Sweeping
Percent of BOD Removed by Treatment
Level
Percent of Suspended Solids Removed by
Treatment Level
Percent of Runoff Due to Streets
Percent of Streamflow Assigned to STATE1
Flow Downstream from Urbanized Area
Removal Factor
Runoff Coefficient in Combined Sewered
Area
Percent of Runoff From Storm Sewered
Impervious Area
Runoff Coefficient in Storm Sewered
Area
Percent Pollutant Removal Required
Percent Impervious Area Due to Streets
Street Miles in Storm Sewered Area
1970 SMSA Populations
1990 SMSA Populations
Storage per Storm Sewer Treatment Plant
Percent Imperviousness in Storm Sewered
Area
EPA 1990 State Ceiling Populations
OBERS 1990 State Populations
Storage per Combined Sewer Treatment
Plant
Receiving Stream Flow
Receiving Stream Flow Attributed to
STATE1
Discharge Rate of Combined Sewer Storage
Facility
Treatment Rate of Storm Sewer Treatment
Plant
Land Area of the Urbanized Area
                                    xi

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                        LIST OF ABBREVIATIONS  (Cont'd)
 Abbreviation                                 Description

IJAgg                             Urbanized Area 1990 Land Area
UAG                              Growth in Urbanized Area Land Area
UAP                              Urbanized Area Population
                                 XI1

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                               ACKNOWLEDGMENTS
          This report was developed by Jordan, Jones and Goulding, Inc. and
Black Crow and Eidsness, Inc. Billy G. Turner of JJ&G was the Project Manager
and provided overall project coordination and management.  Robert A.  Corbitt
and Robert F. Holbrook of JJ&G and Ronald L. Wycoff of BC&E served as Task
Investigators and were instrumental in preparation of the overall report.
Robert W. Olson of JJ&G developed the computer code for NEMUR.  Gregory
Tate of BC&E performed a large portion of the site study evaluations.

          Especially acknowledged is the leadership and review of Philip
H. Graham, Facilities Requirements Branch, Municipal Construction Division,
EPA, who was the Project Officer; and Michael Cook, Chief, Facilities
Requirements Branch, EPA.  Both of these individuals provided invaluable
guidance and review throughout the project. Numerous other individuals
from the EPA Storm and Combined Sewer Technology Branch and headquarters
offices provided significant cooperation and direct participation.
                                    xiii

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                                  SUMMARY
          By authority of the Federal Water Pollution Control Amendments
of 1972, the Environmental Protection Agency, in cooperation with the states,
is required biennially to update estimates of needs to meet the water
quality control provisions of that law.

          In previous years, national estimates have been made for water
quality control for various categories of needs but little emphasis has
been placed on needs for rainfall induced requirements of combined sewer
overflow correction (Category V) and treatment and/or control of storm
waters (Category VI).  Estimates for Category V were developed in 1973
and 1974 and an estimate for Category VI needs was developed in 1974.  It
is well known that these estimates were based often on minimal data and
there was little consistency in the methodologies utilized by the individual
states.

          For the 1976 Needs Survey, EPA chose to estimate the needs
with the assistance of a contractor using a well defined, consistent
nationwide methodology.  This methodology has as its objective the develop-
ment of present and 1990 capital as well as annual operation and maintenance
cost estimates for Categories V and VI.  Cost estimates were developed for
attaining three levels of water quality, which are:

          •  Aesthetics - waters which are aesthetically compatible with
             adjacent areas and contain no floating or settleable
             materials which would interfere with designated stream
             uses;

          •  Fish & Wildlife - waters which meet all characteristics of
             the Aesthetics criteria and in addition provide for dissolved
             oxygen (average daily >5.0 mg/1, minimum >4.0 mg/1), pH (6.0 -
             8.5) and solids (average monthly <80 mg/1, maximum <400 mg/1)
             concentrations compatable with the propagation of aquatic
             organisims; and

          •  Recreation - waters which meet all characteristics of the
             Aesthetics and Fish and Wildlife criteria and in addition
             provide for a monthly geometric mean concentration of
             fecal coliform organisms not to exceed 200 per 100 ml.

          The cost estimates were prepared to meet these water quality
levels through the use of a computer model which took into account numer-
ous factors.  Some of the input data used in the model are:

          •  Demographic data for 279 urbanized areas or 320 areas when
             subdivided by state boundaries.  This data consisted of
             1970 and 1990 populations and land areas;
                                     xv

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          •  Combined sewered areas;

          •  Cost indices developed from a 25 city index for January, 1976;

          •  Hydrologic data consisting of average annual rainfall;
             and the number of days with rain for each urbanized area;

          •  Average minimum receiving stream flow for a three month period;

          •  Reaeration coefficients based on a description of the principal
             receiving streams, and

          •  Percentage of the urbanized area draining to the receiving
             stream.

          Using these input data, the model, Needs Estimation Model for
Urban Runoff, progresses through a sequence of more than 400 mathematical
steps to calculate the Categories V and VI estimated needs for each urban-
ized area.  These estimates were then summed on a state and territory basis
to provide the national estimated needs for Categories V & VI.

          These needs estimate the present costs to control combined sewer
overflows from the U.S. Bureau of Census defined urbanized areas and the
areas outside urbanized areas that are indicated to have combined sanitary
and storm sewers.  It was assumed that no construction of combined sewers
would occur in the future.  Therefore, the Category V estimates are based
on the current condition.  Cost estimates for treatment of combined sewer
overflows to meet the three stream criteria are shown below.

Category and Water
Quality Criteria
Category V - Control of
Combined Sewer Overflows
Aesthetics Water Quality
Criteria
Fish & Wildlife Water
Quality Criteria
Recreation Water Quality
Criteria
Needs Estimate
(Millions of January, 1976 Dollars)
Current
Capital
Costs

5,586

12,088
18,262
1990
Capital
Costs

5,586

12,088
18,262
Annual
O&M
Costs

183

173
248
                                    XVI

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          The needs for storrawater treatment and/or control, shown below;
are based on providing control for storrawater runoff from urbanized areas.
Treatment and/or control levels were selected for each urbanized area
based on the stream criteria and the assimilative capacity of the receiving
water.
Category and Water
Quality Criteria
Category VI - Control of
Stormwater Discharges
Aesthetics Water Quality
Criteria
Fish & Wildlife Water
Quality Criteria
Recreation Water Quality
Criteria
Needs Estimate
(Millions of January, 1976 Dollars)
Current
Capital
Costs

866
31,071
34,528
1990
Capital
Costs

20,471
50,675
54,133
Annual
O&M
Costs

1,119
3,181
3,208
            The methodology was  developed  to  estimate  state-by-state needs and
 as  such should not be expected  to  predict accurately  the needs for any
 specific area.  Due to  the state of  the art  and  the fact that most of the
 actual cost data used in development of cost estimating equations came from
 combined sewer control  projects, the Category V  estimates are of much higher
 quality than those of Category  VI.   The Category V estimates are also better
 than the Category VI estimates  because the  effectiveness of the technologies
 used in Category VI to  improve  receiving  water quality is not as well known
 as  the effectiveness of combined sewer overflow  control technologies.
                                     xvi i

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                               PART   I



BACKGROUND  AMD   OBJECTIVES

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                                  Section 1

                                INTRODUCTION
          To comply with, the Federal Water Pollution Control Act Amendments
of 1972, the Environmental Protection Agency has conducted the 1973 and
1974 Survey of Needs for Municipal Wastewater Treatment Facilities.  This
report is to provide a consistent and realistic basis for estimating needs
in Category V, combined sewer, and Category VI, stormwater, of the 1976
Needs Survey.

1.1  NEEDS SURVEY BACKGROUND

          The Federal Water Pollution Control Act Amendments of 1972, P.L.
92-500, tasked the Environmental Protection Agency, EPA to estimate the needs
of publicly owned treatment facilities to meet the 1983 water quality require-
ments of P.L. 92-500.  Section 516(b) of P.L. 92-500 requires EPA to make a
detailed estimate of individual state needs as well as total national needs
for the construction of all publicly owned treatment works.  The national
needs survey is to be completed biennially and submitted to Congress not
later than February 10 of each odd numbered year.

          Due to shortcomings of initial needs surveys, Congress passed
P.L. 93-243 to emphasize the inclusion, among other things, of the needs
for control and/or treatment of stormwaters.

1.2  SUMMARY OF PREVIOUS SURVEYS

          The first comprehensive needs survey was the 1273 Survey of Needs
for Municipal Wastewater Treatment Facilities, 1973 Needs Survey.  With the
cooperation of EPA, the states and local governments, the 1973 Needs Survey
focused on the needs to achieve the 1977 requirements of P.L. 92-500.  The
needs were determined by five categories:  I - Secondary Treatment, II - More
Stringent Treatment, III - Infiltration/Inflow Correction, IVa - New Inter-
ceptor Sewers, IVb - New Collector Sewers, and V - Combined Sewer Overflow
Correction.  Identified needs totaled $60.123 billion.  Needs for storm water
control and major sewer system rehabilitation were not included in the 1973
Needs Survey.

          Following review of the results of the 1973 Needs Survey, Congress
established the allocation formula for fiscal year 1975, which was a result
of House Public Works Committee Print No. 93-28 and implemented by
P.L. 93-243.  The allotments were proportioned one-half on the basis
of needs reported in Categories I, II, and IVa  (treatment plants or  inter-
ceptors) , and one-half on the basis of total needs in  all five categories of
                                    1-1

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 the 1973 Needs Survey.  The 1973 Needs Survey identified a total of
 $35.910 billion for the cost of needed wastewater treatment facilities
 (Categories I and II) and interceptor sewers (Category IVa)-  The
 allocation gave each state at least the amount of funds allocated in
 fiscal year 1972.

           Even though EPA's final report on the 1973 Needs Survey was
 not submitted to Congress until November, 1973, a new survey was needed
 in 1974 to meet the requirement of P.L. 92-500 for an updated report by
 February 10, 1975.

           Recognizing a need to address the cost for achieving the 1983
 goals of P.L. 92-500, as well as the eligible costs for the treatment and/
 or control of stormwater, Congress, through passage of P.L. 93-243, required
 EPA to amend the 1973 survey approach to include these projects in the new
 needs survey.

           The 1974 Needs Survey divided Category III into: Ilia - Infil-
 tration/Inflow Correction, and Illb - Major Sewer System Rehabilitation,
 and added Category VI - Treatment and/or Control of Stormwaters.  The
 subcategories of Category IV were renumbered such that all collectors
 were reported in Category IVa and interceptors were reported in Category
 IVb.  As with the 1973 Needs Survey, a limited amount of time was available
 for the states and local authorities to complete the 1974 Needs Survey.
 During mid-May 1974, regional meetings were conducted by EPA to provide
 the states with guidance, including instructions on preparation of Category
 VI needs for the treatment and/or control of Stormwaters.  The time
 restrictions for the survey required the states to submit a summary report by
 July 26, 1974 and a final state report by August 20, 1974.  Also, EPA
 was required to supply Congress a preliminary report by September 3, 1974.

           The results of the 1974 Needs Survey showed that needs to meet
 the objectives of Categories I through IV totaled $76,360 billion.  The
 estimated needs for Categories V and VI were $31.076 billion and $235.006
 billion, respectively.  The reported costs for Category V in 1974 increased
by some 245 percent over those in 1973.   Both surveys considered needs for
the projected 1990 population and reported in June,  1973 dollars.

           EPA provided specific guidance to the states and municipalities
for Categories I through IV.  Some guidance was available for Category V
and only general guidance was presented for Category VI.  However, the
results were to be used as a basis for allocating federal funds and
varying methodologies were utilized which impacted the important factors
of estimates of population connected to the sewers, projections of per
capita flow and industrial flow, effluent limitations more stringent than
those actually required to meet water quality standards, and design storm
conditions.  The cost of facilities is quite sensitive to all of these
factors, which identifies the need for a uniform methodology to be applied
nationwide.

           Under authority of Section 315 of P.L. 92-500, the National
Commission on Water Quality, NCWQ, developed an independent survey to
estimate the costs of achieving the requirements of P.L. 92-500 for publicly
                                  1-2

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owned treatment works.  This assessment, done on a nationwide basis, involved
four basic steps;  1) an identification of needed facilities, together
with enough information to define the types of technologies that might be
applicable; 2) a determination of available technologies most likely to
be used to meet the needs identified, and for each technology, the costs;
and 3) an assignment of available technologies to individual needs,
followed by 4) addition of costs,  A similar approach was taken in
estimating quantities of residual wastes generated and requirements for
manpower, energy, materials and land.

           Nationwide totals for Categories V and VI from each of the
previous three needs surveys are shown in Table 1,1,  Each of the surveys
has significant shortcomings due to the variable data base used in the
assessment.  The most significant of these shortcomings were the lack of
a consistent nationwide methodology for the 1973 and 1974 Needs Surveys
and the lack of specific receiving water assimilative capacity considerations
in the NCWQ assessment.  Therefore, a new methodology was developed for the
1976 Needs Survey,

1,3  1976 NEEDS SURVEY

           By separate contracts, EPA is having consultants estimate needs
for Categories I through IV and for Categories V and VI, respectively.  In
accordance with Contract Number 68-01<-1984, this report is to estimate the
latter needs.  More specifically, EPA is to be provided updated nationwide
estimates on a state-by-state basis of various control strategies for
pollutant discharges from (1)  combined sewer and (2) stormwater collection
networks together with a clear, critically written, concise description of
the methodology, data base and assumptions necessary to produce these
estimates.  The states were to be afforded an opportunity for review and
comment prior to submittal of EPA's report to Congress.

           Unlike previous surveys, the Categories V and VI estimates are
 developed at three  different water  quality  levels for  selected pollutants.
 Also,  the contract  divided  the  estimates  into  the following  six  divisions:

           •  Current Year Capital Needs - Category V
                   Capital costs needed to fund alternatives, sized for
                   the current metropolitan development pattern, to control
                   selected pollutants in combined sewer overflow discharges,

           •  Current Year Capital Needs - Category VI
                   Capital costs needed to fund alternatives, sized for the
                   current metropolitan development pattern, to control
                   selected pollutants in stormwater discharges,

           •  1990 Needs - Category V
                   Capital costs needed to fund alternatives, sized for the
                   1990 metropolitan development pattern, to control
                   selected pollutants in combined sewer overflow discharges.
                                   1-3

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                                             TABLE 1,1

                                COMPARISON OF PREVIOUS NEEDS SURVEYS
     Category
                                       CAPITAL  COSTS   (Billions of June. 1973 Dollars)
1973 Needs Survey
1974 Needs Survey
NCWQ Assessment
V,   Correction of Combined  Sewer
     Overflows
VI.  Treatment and/or  Control
     of Stormwaters
               TOTALS
        12,7
        12,7
        31.1
                            235,0
       266,1
 61,3 ( 4.2-68,4)'
                      153   (46 - 349)
214.3  (50.2-417.4)-
         Indicates range depending  on  control  level.

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           •  199Q Needs ^ Category VI
                   Capital costs needed to fund alternatives, sized for
                   the 1990 metropolitan development pattern, to control
                   selected pollutants in stormwater discharges,

           •  Operation and Maintenance Costs - Category V
                   Annual equivalent operation maintenance and repair costs
                   during 20-year planning period for alternatives to
                   control selected pollutants in combined sewer overflow
                   discharges.

           •  Operation and Maintenance Costs <- Category VI
                   Annual equivalent operation maintenance and repair costs
                   during 20-year planning period for alternatives to
                   control selected pollutants in stormwater discharges.

           The methodology for developing cost estimates is based on
intensive work with the available technical literature.   Also, a cost
estimating model is developed from analysis of ten specific urbanized areas
and the resulting transferable principles, relationships, and constants
are applied to all urbanized areas.

           The required methodology is summarized by the following scope
of work elements:

           •  Pollutants to be Controlled
                   The pollutants selected to be controlled must be few in
                   number and must be selected on the basis of receiving
                   water quality.

           •  Water Quality Standards
                   The receiving water quality standards to be applied to
                   the pollutants selected will be drawn from "Water
                   Quality Criteria, 1972" EPA-R3-73-033, March, 1973, or
                   "Quality Criteria for Water", July, 1976.  In the event
                   that no recommendation is made as to  a parameter's
                   receiving water quality requirement under these docu-
                   ments, "Guidelines for Developing or  Revising Water
                   Quality Standards Under the Federal Water Pollution
                   Control Act Amendments of 1972" EPA,  Water Planning
                   Division, Planning and Standards Branch, Washington,
                   D.C., amended April 1973, shall be used.  These criteria
                   provide information on the factors necessary to achieve
                   the national interim goal for water quality stated in
                   Section 101 (a) (2), to provide for the protection and
                   recreation in and on the water to be achieved by July 1,
                   1983.  Three different values of receiving water quality
                   for each selected pollutant will be determined to provide
                   for a range of receiving water quality effects associated
                   with a range of costs.
                                   1-5

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           •  Costs  of Alternative  Technologies
                  Cost  functions and  associated pollutant  removal
                  efficiences  for  alternative technologies for  control
                  of  the  selected  pollutants will  be  identified from
                  the literature.   No original research  on cost functions
                  should  be  conducted,

           •  Total  Pollutant Loads from Dry-Weather Sources
                  A model will be  developed for determining the total
                  pollutant  load from dry-weather  point  sources, for the
                  selected pollutants,  to  the receiving  water after  the
                  the establishment of  1983 discharge controls  for
                  dry weather  point sources.

           •  Pollutant  Loads from  Wet-Weather Discharges and Runoff
                  A model will be  developed for determining the total
                  pollutant  load,  for the  selected pollutants,  to the
                  receiving  waters from wet-weather combined sewer over-
                  flows,  separate  storm sewer, and nonsewered urbanized
                  area  runoff  sources.

           •  Assimilative Capacity
                  A model will be  developed for determining the assimi-
                  lative  capacity  of  receiving waters for  the selected
                  pollutants based on simplified factors,  such  as type  of
                  receiving  water, available dilution flow, and reaction
                  coefficients of  selected pollutants.

           •  Pollutant  Control Levels Required for Alternative  Receiving
              Water  Criteria
                  The models will  be  applied to determine  the pollutant
                  control levels required  to achieve  each  of three
                  alternative  receiving water quality criteria.

           •  Types  and  Costs of Alternatives Necessary to  Meet  Water
              Quality  Standards
                  The type and costs  of pollutant  control  alternative
                  devices which me'et  each  pollutant control level will  be
                  determined.   The least cost control measures  shall be
                  determined for the  alternate receiving water  qualities.
                  Cost  will  include both capital as well as operation,
                  maintenance, and repair  costs of the alternative control
                  measure applicable  during a 20-year planning  period.

           Copies of the draft  report  of October,  1976 were sent to each State
Water Pollution Control Director,  State Needs Survey Director,  Interstate
Water Pollution Control Commission, and EPA Regional Office, as well as numer-
ous other individuals  on October 22, 1976.   Written comments on the draft
report were requested by December 1, 1976.
                                    1-6

-------
           A series of meetings was held in each EPA regional office
November 8 through 23, 1976 to present the report and receive verbal
comments.  Written comments received prior to January 21, 1977 were incor-
porated in the final report.

           Comment letters were received from 29 states, 1 territory, 3 inter-
state commissions, 3 cities, and 2 other organizations.  Numerous other organi-
zations were represented at the regional review meetings and offered verbal
comments.  The comment letters and the EPA responses are reproduced in
Appendix D.  The efforts of those who read and commented on the draft report
are appreciated.  It is hoped that the responses will be as helpful as the
comments.
                                   1-7

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                                Section 2

                          ABATEMENT OBJECTIVES
          Urbanisation causes many changes in the water quality and
hydrology of streams and other water bodies.  As an area becomes more
densely developed, there are changes in runoff water quality, in the
total runoff volume, in the peak flow and base flow characteristics,
and in the aesthetic values of the water body.  Abatement objectives must
be established to control these negative effects, while recognizing
beneficial effects, such as ground water replenishment and stream
flushing.

          The abatement objectives are for mitigation and prevention
of water quality problems due to combined sewer overflows and stormwater
runoff from urbanized areas.  In order to effectively meet this purpose,
significant pollutants and their impact must be identified along with
identification of receiving water standards.

2.1  SIGNIFICANT POLLUTANTS

          From a detailed review of state and federal water quality
criteria and available treatment and control techniques, the significant
pollutants considered for the Categories V and VI needs estimate relate
to solids, dissolved oxygen and bacteria.  The following discusses
these and other pollutants.

2.1.1  Solids
          Particulate matter may cause detrimental effects on fish life,
water supply, recreation and flooding potential.  There are four basic
effects of suspended solids on fish and fish food populations, namely by:

          •  acting directly on the fish swimming in water in which
             solids are suspended, and either killing them or reducing
             their growth rate, resistance to disease, etc.;

          •  preventing the successful development of fish eggs and
             larvae;

          •  modifying natural movements and migrations of fish; or,

          •  reducing the abundance of food available to the fish.

          Although no specific limits exist for inert suspended solids
below which damage to fisheries will not occur, the European Inland
Fisheries Advisory Commission   stated  the  following  conclusions
relating to inert solids concentrations and satisfactory water quality:
                                   2-1

-------
          •  there is no evidence that concentrations of suspended
             solids less than 25 ppm have any harmful effects on
             fisheries;

          •  it should usually be possible to maintain good or moderate
             fisheries in waters which normally contain 25 to 80 ppm
             suspended solids.  Other factors being equal, however, the
             yield of fish from such waters might be somewhat lower
             than with less than 25 ppm;

          •  waters normally containing from 80 to 400 ppm suspended
             solids are unlikely to support good freshwater fisheries,
             although fisheries may sometimes be found at the lower
             concentrations within this range; and,

          •  at the best, only poor fisheries are likely to be found
             in waters which normally contain more than 400 ppm suspended
             solids.

The Commission report also stated that exposure to several thousand mg/1
for several hours or days may not kill fish and that other inert or or-
ganic solids may be substantially more toxic.

          In raw water supplies, there are no specific criteria for
suspended solids concentrations.  However, turbidity is caused by sus-
pended material and finished drinking water supplies have a maximum monthly
average of 1 turbidity unit.   Thus,  elevated suspended solids concentrations
increase the difficulty and cost of providing an acceptable water supply.
Total dissolved solids are generally limited to 500 mg/1 by the U.S.
Public Health Service for acceptable sources of raw water supply.  These
limits indirectly limit suspended solids concentrations in specific stream
systems.

          Turbid waters also interfere with recreational use and aesthe-
tic enjoyment; and formation of sediment deposits contribute to flooding
potential by restricting streamflows.

2.1.2  Dissolved Oxygen

          Discharges of organic materials stimulate the growth of
microorganisms which consume oxygen faster than it is naturally replenished.
Dissolved oxygen, D.O., has always been a major constitutent of interest
in water quality studies.  It has generally been considered as signifi-
cant in the protection of the aesthetic qualities of water, as well as
for protection of fish and other aquatic life.

          The aesthetic qualities of water require sufficient D.O. present
to avoid the onset of septic conditions and the attendant odorous condi-
tions .
                                   2-2

-------
          The dissolved oxygen requirements for fish and other aquatic
life are perhaps the most critical concern.  It has been shown that fully
developed fish will seldom be killed in nature solely by a dissolved
oxygen as low as 3 mg/1 when such level persists for only a period of
moderate duration.  However, mere survival of fish does not indicate
successful long term production, since reproduction and growth are
significantly interfered with by lowered water quality .

          Fish growth has also been shown to be affected by fluctuating
D.O. levels.  Fish subjected to diurnally fluctuating D.O, concentrations
grew at a rate approximately equivalent to that which occurred at the
lower limit of the wide fluctuations.   Thus, minimum concentrations are
more important than average concentrations in restricting fish growth .

          Acceptable dissolved oxygen levels have been based on minimum
levels of 5 mg/1 normally with 4 mg/1 for brief periods for warm water
fisheries and 6 mg/1 normally with 5 mg/1 for brief periods for cold
water fisheries .    More recently, authors have proposed a variable limit
based on natural seasonal minimum oxygen concentrations and the required
degree of fishery protection with the additional inclusion of a 4 mg/1
minimum for all waters .

          Dissolved oxygen in waters used for water supply and recreation
is desirable as an indicator of satisfactory water quality but is not
necessarily required to produce a high quality finished water.  Dissolved
oxygen criteria for fish and aquatic life are sufficient for adequate
protection of water supply sources and recreation uses.

2.1.3  Bacteria

          The presence of excessive concentrations of objectionable
microorganisms can impair the ability to utilize waters for water
supply and recreational purposes.  Microbiological indicators have been
used to determine or indicate the safety of water uses and fecal coliform
bacteria is used most often as an indicator of pollution.

          The relationships between fecal coliform and pathogenic organ-
isms are not well known.  Similarly, the relationship between numbers
of specific disease causing organisms in water and the potential for
transmission of disease is not defined.  The use to which the water is
put, the type  of water, and the geographical location all are factors
to be weighed in determining safe microbiological criteria.

          Regardless of shortcomings,  fecal coliform densities have been
used as criteria for indication of water quality degradation and a
relative risk of disease transmission.  Therefore, the use of fecal
coliform must relate to the probable occurrence of known waterborne
pathogens.  Studies have shown that a sharp increase in the frequency of
Salmonella detection occurs when fecal coliform densities are above 200
                                    2-3

-------
organisms per 100 ml of fresh water.  The recovery^of Salmonella in
estuarine waters is lower than that in freshwater.s'
3
          Based on these observations, the fecal coliform densities in
waters used for water supply or body contact recreations should not
exceed a log mean of 200 per 100 ml based on not less than five samples
taken over not more than a 30-day period, nor should more than 10 percent
of the samples during any 30-day period exceed 400 per 100 ml.

2.1.4  Other Pollutants

          Many other pollutants have been found in stormwater runoff by
specific investigations, often at elevated concentrations .   Examples
of these pollutants and their respective impacts are as follows:

          Pollutant                          Water Quality Impact

          Nitrogen                           Stimulation of aquatic growth
                                             and dissolved oxygen depletion.

          Phosphorus                         Stimulation of aquatic growth.

          Dissolved Solids                   Degradation of water supply
                                             sources.

          Heavy Metals                       Long term effects on aquatic
                                             life and degradation of water
                                             supply sources.

          Pesticides                         Long term effects on aquatic
                                             life.

Although these pollutants may cause significant water quality problems
in specific areas, they have not been included in the proposed water
quality criteria because of scarcity of both concentration and impact
data and specificity of water quality problems.

2.2  WATER QUALITY CRITERIA

          Water quality criteria to be applied to receiving stream stand-
ards must provide information on factors to achieve the interim water
quality goals of P.L.  92-500.  These goals are to provide for the pro-
tection and propagation of fish, shellfish, and wildlife as well as for
recreational uses by July 1, 1983.  Also, a lower standard was evaluated.
The three alternative water quality criteria selected for this study are
termed Aesthetics, Fish and Wildlife, and Recreation.

          Most existing water quality criteria include provisions exempting
"natural causes",  and  some specifically do not apply to "wet weather conditions".
                                   2-4

-------
These provisions generally make existing criteria unenforceable during
periods of stormwater runoff.  Additionally, criteria vary widely between
states across the country.  It was very difficult, therefore, to develop
one set of criteria for nationwide application to streams receiving combined
sewer overflows and stormwater runoff.

          General wet weather criteria for application to all receiving
waters is presented in Table 2.1.  For the Aesthetics water quality
criteria, only the general criteria applies.  Additional specific criteria
for Fish and Wildlife and Recreation water quality are presented in
Table 2.2 and 2.3.
                                  2-5

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                      TABLE  2.1
    GENERAL WET WEATHER CRITERIA FOR ALL WATER
All waters are to be aesthetically compatible to adjacent areas.
All waters shall be free from oil, scum and floating debris
associated with cultural activities in amounts sufficient to
be unsightly.

All waters shall be free from materials associated with cultural
activities which will settle and form significant sediment
or sludge deposits that become unsightly or interfere with
stream capacities.
NOTE:   These criteria apply to all urbanized waters of the
        nation as a minimum.  Applies to streams which can
        be documented as being intermittent or ephemeral and
        whose major use is  aesthetic or drainage.
                        2-6

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                       TABLE 2.2
        FISH AND  WILDLIFE  WET  WEATHER CRITERIA
Dissolved Oxygen:  A daily average of 5.0 mg/1 and no less
                   than 4.0 mg/1 at all times.

pH:                Within the range of 6.0 - 8.5

Solids:            Suspended solids not be exceed a monthly
                   average of 80 mg/1 or a maximum value of
                   400 mg/1.
NOTE: These criteria shall apply to continuously flowing streams
      which can maintain a viable fishery.
                      TABLE 2.3
           RECREATION WET WEATHER CRITERIA
Dissolved Oxygen:  A daily average of 5.0 mg/1 and no less
                   than 4.0 mg/1 at all times.

pH:                Within the range of 6.0 - 8.5.

Solids:            Suspended solids not to exceed a monthly
                   average of 80 mg/1 or a maximum value of
                   400 mg/1.

Bacteria:          Fecal Coliform not to exceed a geometric
                   mean of 200 per 100 ml and not to exceed
                   400 per 100 ml in more than 10% of the
                   samples collected in any month.
NOTE:   These criteria shall apply to continuously flowing
        streams which can provide full body contact recreation.
                          2-7

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                                Section 3
                    TREATMENT AND/OR CONTROL FACILITIES

          To date, there have been few full scale facilities constructed
specifically for urban stonnwater treatment.  Therefore, cost and effect-
iveness data on specific treatment processes are scarce.  Operation and
maintenance cost data is almost non-existent due both to lack of treatment
facilities and to the reporting procedures of public works agencies 8.
Recently, however, several reports have been completed which developed
cost estimatine procedures for stormwater treatment and/or control
facilities 8, %  .fo

          Three of these recent reports were used extensively to develop cost
estimating functions for the 1976 Needs Survey, Category V & VI. "Esti-
mating Initial Investment Costs and Operating and Maintenance Require-
ments of Stormwater Treatment Processes"8 , a report .prepared under  spon-
sorship of the U.S. Environmental Protection Agency, developed data for
estimating average initial investment costs and operation and maintenance
requirements for stormwater overflow treatment plants ranging from about
5 to 200 mgd in capacity.  Estimating data were included for 14 separate
process functions associated with stormwater treatment plants and storage
facilities.

          "Assessment of the Impact of the Handling and Disposal of
Sludge Arising from Combined Sewer Overflow Treatment" * , another report
sponsored by EPA, determined the characteristics of sludges from combined
sewer overflow treatment and analyzed methods for the handling and disposal
of the resulting sludges. Cost estimating methodologies were developed
for required capital as well as operation and maintenance expenditures.

          "An Evaluation of Streetsweeping Effectiveness in the Control
of Nonpoint Source Pollution   , a report developed by the Catholic Univ-
ersity of America, analyzed urban street sweeping programs under rainfall
conditions for Washington, D.C. and for sweeping frequencies to determine
the cost and effectiveness of street sweeping for water pollution control.

          Many other reports sponsored by EPA's Office of Research and
Development and other agencies were utilized to develop the efficiency
and cost estimating models required by the 1976 Needs Survey.

3.1  EFFICIENCIES OF CONTROLS

          From a review of the literature, several treatment and/or
control schemes for combined sewer overflows and urban stormwater runoff
were developed.  Pollutant removal efficiencies were  estimated for  each
treatment scheme.  The treatment or control option evaluated and the est-
imated pollutant removal efficiencies for each alternative are identified
in Table 3.1. Flow schematics for each of the control options are depicted
in Figures 3.1 through 3.5.
                                      3-1

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             TABLE 3.1
ESTIMATED CONTROL OPTION EFFICIENCY
Treatment or
Control Option
I. Best Management Practices
street sweeping, catch
basin cleaning, construc-
tion practices, deten-
tion basins in developing
area.
II • Screening- Swirl Concentra-
tion
swirl concentrator,
storage, raw wastewater
pumping, screening
(stationary type) , flow
measurement, misc.
Ill- Sedimentation
storage, raw wastewater
pumping, sedimentation,
flow measurement, misc.
IV. Air Floatation w/Chemicals
storage, raw wastewater
pumping, rapid mix,
chemical feed equip . , air
floatation, flow measure-
ment, misc.
V. Flocculation-Sedimentation
storage, raw pumping,
chemical feed, rapid
mix, flocculation,
sedimentation, flow
measurement , misc .
VI. Filtration
storage, raw pumping,
chemical feed, rapid
mix, flocculation,
sedimentation, flow
measurement, misc.
VII. Disinfection
gaseous chlorine storage
& feeding to above options
Efficiency (% Removal)
BOD,;

0-25






0-25





25-40



40-60





60-80





80-95





-

Sus. Solids

0-25






0-25





25-50



50-70





70-90





90-98





-

Fecal
Coliform

-






-





-



—





_





-





99.9

            3-2

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f
CO
                                                           At Consolidated Treatment Sites
                             Storage
                        0.154 x Influent Volume
                                                                     Solids To
                                                                     Landfill
                                                                                  Discharge
                                            FIGURE 3.1
                               SCREENING — SWIRL CONCENTRATOR

                                    FLOW SCHEMATIC

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                  At overflow
Influent
            o"o
             Storage
At Consolidated Treatment Sites
                                               Sedimentation
                                       FIGURE 3.2

                                    SEDIMENTATION

                               FLOW SCHEMATIC
                                                                    Lime
                                                                    Stabilization
                                                                                   Disposal

-------
                  " At Overflow
                                            At Consolidated Treatment Sites
                                                          Chemical
                                                          Feed
                                                          Equipment
      Influent
Un
                                                                                              Discharge
                                                                                                Landfill
                                                                               Lime
                                                                               Stabilization
                                                 FIGURE 3.3
                                         DISSOLVED AIR FLOTATION

                                         FLOW SCHEMATIC

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Overflow Site
                            Consolidated Treatment Site
                                        Chemical
                                        Feed
                                        Equipment
                                  Lime
                                  Stabilization
                                                                        Discharge
                               FIGURE 3.4
                    FLOCCULATION — SEDIMENTATION

                        FLOW SCHEMATIC

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Overflow Site •
                            Consolidated Treatment Site
                                            Feed
                                            Equipment
                                           Coagulation
                                           FlocculaUon
                             FIHer
                             Press
Ume
Stabilization
                 Landfill
                             nitration

                      Sedimentation
Row
Measurement
                                  FIGURE 3.5
                                 FILTRATION

                          FLOW SCHEMATIC

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           Although pollutant removals are estimated for BOD,, and suspended
 solids  only,  the  treatment options should also provide removal of other
 pollutants.   A recent EPA contract, "State and Local Pretreatment Programs  -
 Federal Guidelines"12, evaluated existing municipal treatment facilities  to
 determine  effeciencies of unit processes. , Table 3.2 shows the median
 removals of fourteen pollutants achieved by primary sedimentation.

 3.2  COSTS OF CONTROLS

           The cost estimating methodology for treatment or control options
 are detailed  on Tables 3.3 through 3.9.  Capital costs and three categ-
 ories of operation and maintenance costs are estimated separately for each
 unit process.  Total costs for any treatment and/or control option can be
 determined by:

           •   Determining the level of control needed by water
              quality analysis or other methods;

           •   Estimating the stormwater capacity parameters
              required by the equations for each unit process; and,

           •   Summing the required unit processes to complete a
              treatment option and adding miscellaneous amounts for
              site work, engineering, architectural, legal, fiscal
              and administrative.

           For the 1976 Needs Survey, the following general assumptions
were made  to  develop the average cost equations:

           •  January 1, 1976 National Average EPA Cost Index = 255.7
              (1957 - 1959 base of 100);

           •  Operation and Maintenance Labor Cost * $10 per man hour;

          •  Power Cost - $0.03 per KWH.

Other assumptions related to each unit process are identified on Tables
3.3 through 3.9.  All capital and operation and maintenance costs are
adjusted by regional cost indices.

           It should be noted that the cost equations and the information
used in their development should be used for broad estimating purposes
only.  These equations do not consider all local variations in design
criteria, specific stormwater characteristics or other factors.
                                  3-8

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                   TABLE 3.2

         MEDIAN REMOVAL EFFICIENCY OF
             PRIMARY SEDIMENTATION
Pollutant                      Median Percent Removal

Cadmium (total)                           7
Chromium (total)                         16
Lead                                     20
Mercury                                  21
Copper                                   19
Nickel                                    6
Zinc                                     25
Iron                                     37
Manganese                                 8
Ammonia                                  16
TOC                                      20
COD                                      19
Suspended Solids                         52
BOD,.                                     28
                     3-9

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                                                         TABLE 3.3
                                                COST ESTIMATING METHODOLOGY
                                                 BEST MANAGEMENT PRACTICES
Process Function
Street Sweeping
Construction Practices
Detention Basins
Design Parameters
Curb miles swept
per year
Land area under
construction (acres)
Runoff from design
storm (mg)
Capital Cost
C$)
$17.33 per curb
mile for 20 year
period
-
$.50 per gallon of
storage volume
Operation and Maintenance Cost
($/Year)
$5 . 46 per curb mile
swept
$400 per acre under
construction each year
2% of capital cost per
year
u>

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           TABLE 3, 4
  COST ESTIMATING METHODOLOGY
SCREENING - SWIRL CONCENTRATOR
Process Function
Administration
Laboratory
Yardwork
Raw Wastewater
Pumping
Swirl Concentrator
Storage (CSO)
(15.4% of runoff
stored)
Pumping
Stationary Screens
Flow Measurement
Mis ce 1 laneous
Design Parameters

400 samples per year



70% concrete covered,
30% concrete uncover-
ed storage




Capital Cost
($)
-
-
-
98,800 PF0-602
13,309 PF°-598
34,790 VR°'598+
60,440 VR°-803
150,000 PR0'602
13,110 TR0'955
3130 TR0-484
25% of above
items
Operation and Maintenance Cost ($/ Year)
Labor
200 TR°-463
8600
875 PR0'798
2500+19 30PF°'468
2571 PF°'214
415 VR°:47°
2500+19 30PR °'468
1530 TR°-466
-
-
Supplies
75 TR°-471
2200
57 PR0'838
60 PF
1760
227 VR°-400
60 PR
678 TR°-281
-
-
Power
-
-
-
180 PF
-
5.4 VR°-510
180 PR
-
-
-
                                   Key:     PF - Peak Flow Rate (mgd)
                                            VR - Volume of Runoff (mg)
                                            XR - Consolidated Treatment
                                                 Rate (mgd)
                                            PR - Pumping Rate from Storage
                                                 (mgd)

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         TABLE 3.5
COST ESTIMATING METHODOLOGY
       SEDIMENTATION
Process Function
Administration
l,ab oratory
Yardwork
Storage - CSO
~ Stonnwater
Raw Wastewater
Pumping
Sedimentation
Sludge Pumping
Sludge Disposal
Flow Measurement
Miscellaneous
Design Parameters
-
400 samples per year
-
70% concrete covered,
30% concrete open
50% Earthen
50% concrete open
—
1,500 gpd/ft2
-
-
-
-
Capital Cost
($)
-
-
-
106,500 m°'fl+
271,500 VR0'80-3
15,200VR°'7cg8+
177,500 VR 5 8
150,000 PR0'602
43,120 TR°-817
247,655 TR°-503
50,112 TR°-698
3130 TR0'484
25% of above
items
Operation and Maintenance Cost ($/Year)
Labor
200 TR°-463
8600
875 PR0'798
1000 VR°-47°
1000 VR°-47°
2500+1930 PR1'46*
2900 TR°'732
1790 TR°-426
8580 TR
-
-
Supplies
75 TR°-471
2200
57 PR0'838
480 VR°-40°
480 VR°-40°
60 PR
1229 TR°-207
92 TR°-642
-
-
-
Power
-
-
-
14 VR°-51°
14 VR°-51°
180 PR
6.8 TR°-913
7.5 TR
-
-
-
                                            PR =  Pumping Rate from Storage(mgd_
                                     Key:   PF =*  Peak Flow Rate (mgd)
                                            VR =  Volume of Runoff (mg)
                                            TR =  Consolidated Treatment
                                                 Rate (mgd)

-------
         TABLE 3,6
COST ESTIMATING METHODOLOGY
 DISSOLVED AIR FLOATATION
Process Function
Administration
Laboratory
Yardwork
Storage - CSO
- Stormwater
Raw Wastewater
Pumping
Rapid Mixing
Chemical Feed
Air Floatation
Sludge Pumping
Sludge Disposal
Design Parameters
-
400 samples per year
-
70% concrete covered
30% concrete open
50% Earthen
50% concrete open
-
G=300 T = 2 min.
d
up to 75 mg/1 dosage
3600 gpd/ft2
-
-
Capital Cost
($)
-
-
-
106,500 v^-f8 +
271,500 VR J
15,200 VR°'7598 +
177,500 VR
150,000 PR0'602
5,343TR°'724
48,000 TR°>611
147,830 TR°-83°
247,655 TR°-503
50,112 TR°-608
Operation and Maintenance Cost ($/Year)
Labor
200 TR°-463
8600
875 PR°'798
1000 VR°-47°
1000 VR°-47°
2500+1930 P^'468
85 TR°-884
3465 TR°'332
2700 TR°-618
1790 TR°-426
8580 TR
Supplies
75 TR°-471
2200
57 PR0'838
480 VR0-400
480 VR°-40°
60 PR
26 TR°-698
36 TR°-662
1915 TR°-2°
92 TR°-642
-
Power
-
-
-
14 VR°-51°
14 VR°-51°
180 PR
54 TR
20 TR°-86°
2220 TR
7.5 TR
-

-------
                                                      TABLE 3,6 (Con't)
                                              COST ESTIMATING METHODOLOGY
                                               DISSOLVED AIR FLOATATION
Process Function
Flow Measurement
Miscellaneous
Design Parameters
-
-
Capital Cost
-($)
3130 TR°'484
25% of above
items
Operation and Maintenance Cost ($/Year)
Labor
-
-
Supplies
-
-
Power
-
-
I
M
4S
Key:  PF = Peak Flow Rate (mgd)
      VR - Volume of Runoff  (mg)
      XR = Consolidated Treatment Rate  (mgd)
       G = Mean Velocity Gradient  (sec   )
       X = Detention Time (min)
        d
      PR = Pumping Rate from Storage  (mgd)

-------
                                                       TABLE  3. 7
                                               COST ESTIMATING METHODOLOGY
                                               FLOCCULATION-SEDIMENTATION
Process Function
Administration
Laboratory
Yardwork
Storage - CSO
- Stormwater
Raw Wastewater
Pumping
Chemical Feed
Rapid Mix
Flocculation
Sedimentation
Design Parameters
-
400 samples per year
-
70% concrete covered
30% concrete open
50% Earthen
50% concrete open
-
up to 75 mg/1 dosage
G-300 Td * 2 min
G=110 Td = 30 min
1500 gpd/ft2
Capital Cost
C$)
-
-
-
106,500 VR°'598+
271,500 VR
15,200 VR°'7"8+
177,500 VR *
150,000 PR0'602
48,OOOTR°'611
5,343 TR°'724
19,420 TR°'612
43,120 TR°'817
Operation and Maintenance Cost ($/Year)
Labor
200 TR°-463
8600
875 PR0'798
1000 VR°-47°
1000 VR0-470
2500+1930 PR'46*
3465 TR°-332
86 TR°-884
230 TR
2900 TR°'732
Supplies
75 TR°-471
2200
57 PR0'838
480 VR°-40°
480 VR°-40°
60 PR
36 TR°-662
26 TR°-698
140 TR°-624
1230 TR°-207
Power
-
-
-
14 VR°-51°
14 VR°-51°
180 PR
20 TR°'86
54 TR
54 TR
6.8 TR0'91:
Ui

-------
                                                         TABLE  3.7  (con't)
                                                   COST ESTIMATING METHODOLOGY
                                                   FLOCCULATION-SEDIMENTATION
Process Function
Sludge Pumping
Sludge Disposal
Flow Measurement
Miscellaneous
Design Parameters
-
-
-
-
Capital Cost
($)
247,655 TR0'503
50,112 TR°-698
3,130 TR°-484
25% of above
items
Operation and Maintenance Cost ($/Year)
Labor
1790 TR°'426
8580 TR
-
-
Supplies
92 TR°-642
-
-
-
Power
7.5 TR
-
-
-
H
Key:  PF = Peak Flow Rate (mgd)
      VR = Volume of Runoff (mg)
      TR = Consolidated Treatment Rate  (mgd)
       G = Mean Velocity Gradient (sec~ )
       T = Detention Time (min)
      PR = Pumping Rate from  Storage (mgd)

-------
                                                         TABLE 3.8
                                                COST ESTIMATING METHODOLOGY
                                                        FILTRATION
Process Function
Administration
Laboratory
Yardwork
Storage - CSO
- Stormwater
Raw Wastewater
Pumping
Chemical Feed
Rapid Mix
Flocculation
Sedimentation
Design Parameters
-
400 samples per year
-
'0/£ concrete covered
30/£ concrete open
50% Earthen
50% concrete open
-
up to 75 mg/1
G=300 T, = 2 min
d
G=110 T , - 30 min
d
1500 gpd/ft2
Capital Cost
($)
-
-
-
106,500 VRJj-^® +
271,500 VR°'803
15,200 VR°'717 +
177,500 VR°'598
150,000 PR0'602
48,OOOTR°'611
5,343 TR°-724
19,420 TR°-612
43,120 TR°'817
Operation and Maintenance Cost ($/Year)
Labor
200 TR°'463
8600
875 PR0'798
1000 VR °'470
1000 VR°-470
2500+19 30PR0'468
3465 TR°'332
86 TR°'884
230 TR
2900 TR°'732
Supplies
75 TR°-471
2200
57 PR°'838
480 VR°-4°°
480 VR°-400
60 PR
36 TR°-662
26 TR°-698
140 TR°-624
1230 TR-207
Power
-
-
-
14 VR°-51°
14 VR°-51°
180 PR
20 TR°-86
54 TR
54 TR
6.8 TR°-913
u>

-------
                                                        TABLE 3,8  (con't)
                                                 COST ESTIMATING METHODOLOGY
                                                         FILTRATION
Process Function
Filtration
Sludge Pumping
Sludge Disposal
Flow Measurement
Miscellaneous
Design Parameters
10 gpm/ft
-
-
-
-
Capital Cost
($)
104,940 TR°'736
247,655 TR0'503
50,112 TR°-698
3130 TR°-484
25% of above
items
Operation and Maintenance Cost ($/Year)
Labor
22780+24 TR
1790 TR°-426
8580 TR
-
-
Supplies
761 TR°-256
92 TR °'642
-
-
-
Power
3.8 TR
7.5 TR
-
-
-
I
M
OO
                                                                                PR =  Pumping Rate from Storage (mgd)
                                                                         Key:   PF =  Peak  Flow Rate  (mgd)
                                                                                VR =  Volume  of Runoff  (mg)
                                                                                TR ~  Consolidated Treatment Rate (mgd)
                                                                                G =  Mean  Velocity Gradient (sec  )
                                                                                T ,=  Detention Time  (min)

-------
                                                       TABLE 3.9
                                              COST ESTIMATING METHODOLOGY
                                                     DISINFECTION
Process Function
Rapid Mix
Gaseous Chlorination
Mis cellaneous
Design Parameters
G*OOQ T<* 2 min
d
up to 7 mg/1 dosage
-
Capital Cost
C$)
5,343TR°'724
63,040 + 5,190 TR
25% of above
items
Operation and Maintenance Cost ($/Year)
Labor
86 TR°-884
1,780 TR°'597
-
Supplies
26 TR°'698
1134 TR°-69C
-
Power
54 TR
-
-
V
5
Key:  PF * Peak Flow Rate (mgd)
      VR * Volume of Runoff (mg)
      TR * Consolidated Treatment Rate  (mgd'
       G = Mean Velocity Gradient (sec  )
       T,= Detention Time (min)

-------
                                   PART I

                                 REFERENCES

 1.  Federal Register, National Interim Primary Drinking Water Regulations,
     December 24, 1975.

 2.  National Academy of Science-National Academy of Engineering Committee
     on Water Quality Criteria, Water Quality Criteria, 1972, USEPA Ecol-
     ogical Research Series Report EPA-R3-73-033, Washington, D.C., March,
     1973.

 3.  U.S. Environmental Protection Agency, Quality Criteria for TJatejr^ pre-
     publication copy, Washington, D.C.,  July, 1976.

 4.  European Inland Fisheries Commission, "Water Quality Criteria for
     European Freshwater Fish," report on finely divided solids and inland
     fisheries, Int. Jour. Air Water Poll., 9:151., 1965.

 5.  Doudoroff, P. and Shumway, D.L., "Dissolved Oxygen Requirements of
     Fresh Water Fishes," FAO Fish. Tech. Paper No.86, FAO of the United
     Nations, 1970.

 6.  Stewart, N.E. et.al. /'Influence of Oxygen Concentration on the Growth
     of Juvenile Largemouth Bass," Journal Fish. Res. Bd. Can., 24:475,1967.

 7.  Metcalf and Eddy, Inc., "Urban Stormwater Management and Technology;
     An Assessment," EPA-67012-74-040, December, 1974.

 8.  Culp/Wesner/Culp Consulting Engineers, "Estimating Initial Investment
     Costs and Operating and Maintenance Requirements of Stormwater Treat-
     ment Processes,"  Draft Report prepared for EPA under Contract No.
     68-03-2186, June, 1976.

 9 ,  Clark, M.J., and Geinopolos, A., "Assessment of the Impact of the
     Handling and Disposal of Sludges Arising from Combined Sewer Overflow
     Treatment", Draft Report prepared for EPA under Contract No. 68-03-
     0242, February, 1976.

10.  Adimi, R., et.al., "An Evaluation of Streetsweeping Effectiveness in
     the Control of Nonpoint Source Pollution," The Catholic University
     of America, April, 1976.  (Unpublished paper prepared under the
     direction of G.K. Young, Ph.D.)

 11.  Black, Crow & Eidsness, Inc. and Jordan, Jones & Goulding,  Inc.,
      Study and Assessment of the Capabilities and Cost of Technology
     for Control of Pollutant Discharges from Urban Runoff", NTIS Report
     No. PB-247-391/661, Washington, D.C., October 1975.

 12.  U.S. Environmental  Protection Agency, Municipal Construction Division,
      State and Local  Pretreatment Programs  -  Federal Guidelines (Preliminary
     Draft) , Contract No. 68-01-2963, Washington,  D.C., August  1975.

-------
          PART  II
SITE   STUDIES

-------
                              Section 4

                SITE STUDY PROCEDURE AND ASSUMPTIONS
            A major portion of this study is concerned with the analysis
of hydrologic data, waste loading data, and receiving water impact data
for ten selected sites located throughout the United States.  The results
of these site studies are then used to define design criteria, and to
develop generalized relationships and methods which were applied to 320
urbanized areas to produce the national needs estimate.

            Central to the site studies is the analysis of receiving water
impact based on wet weather loads generated by the selected urban area,
for a given design storm.  Data generated by the ten site specific
analyses are used to develop a generalized relationship between urban
area characteristics, receiving water characteristics and the degree of
treatment required for urban runoff and combined sewer overflow.  This
generalized relationship is then used, in part, as a basis for the
projection of national needs for the control of urban runoff and combined
sewer overflow.  Thus, the selection of the ten study sites and subsequent
impact analyses are important to the overall results of the project.

            Part of the site selection task was the development of rational
criteria which were used as a guide in the selection of the ten study
sites in order to insure the analysis of a representative range of
conditions.  These criteria are intended to consider all relevent para-
meters and to weight these parameters according to their importance.
4.1         PRIMARY CRITERIA FOR SITE SELECTION

            The following are the primary criteria applied to the selection
of the ten study sites:

            1.  Geographic distribution - study sites should be distributed
                throughout the U.S.

            2.  Size Distribution - study sites should be representative
                of the full range of urban population centers.

            3.  Severa.1 sites should have combined sewer systems and the
                remainder should be stormwater only.

            4.  The sites selected should have all or most of the following
                data available.
                                    4-1

-------
                a.  Water quality of stormwater/combined sewer runoff
                    data including:  BOD5, COD, Nitrogen (NO^, TKN), SS
                    and coliforms.

                b.  Drainage area, level of development (percent impervi-
                    ous area) slope, soil type, etc. for tributary
                    watershed.

                c.  Continuous rainfall data at or near the site.

                d.  Low flow data for receiving water.

                e.  Water quality data for receiving water for low  flow
                    conditions, including:  DO, Temperature, SS, Coliforms
                    and salinity.


4.2         SECONDARY CRITERIA FOR SITE SELECTION

            Secondary criteria applied to the selection of the ten  study
sites were:
            1.  Representative number (one or two) with discharge to an
                estuary.

            2.  Representative number (one or two) with discharge to a
                lake.

            3.  Preference to designated 208 areas to allow future
                updating of study.
4.3         SITES CONSIDERED

            A literature review was undertaken to identify cities where
previous urban runoff or combined sewer investigations had been conducted.
In general, cities which have been the subject of such investigations
could be expected to have some site specific demographic, hydrologic and
water quality data available in easily obtainable and usable form.  Only
completed projects which resulted in a published report were considered.
Table 4.1 presents a list of cities with urban runoff or combined sewer
overflow data available.  Each of these cities was then considered
relative to the selection criteria outlined previously in order to
arrive at ten selected study sites.
4.4         SITES SELECTED FOR ANALYSIS

            The data base for each of the 26 cities listed in Table 4.1
was examined and those cities with the greatest amount of information
                                    4-2

-------
                  TABLE 4.1

         PARTIAL LIST OF CITIES WITH
URBAN RUNOFF OR COMBINED SEWER OVERFLOW DATA
City
Ann Arbor, Michigan
Castro Valley, California
Des Moines, Iowa
Durham, North Carolina
Los Angeles, California
Madison, Wisconsin
New Orleans, Louisiana
Roanoke, Virginia
Sacremento, California
Tulsa, Oklahoma
Washington, D. C.
Cincinnati, Ohio
Detroit, Michigan
Atlanta, Georgia
West Lafayette, Indiana
Lubbock, Texas
New York, New York
Bucyrus , Ohio
Berkeley, California
Brooklyn, New York
Kenosha, Wisconsin
Milwaukee, Wisconsin
Racine, Wisconsin
San Francisco, California
Philadelphia, Pennsylvania
Portland, Oregon
Combined
Separate
S
S
S,C
S
S
S
S
S
S, C
S
S, C
S, C
S, C
S, C
S
S
S
C
C
C
C
C
C
C
C
C
No. of Sites
With Data
1
1
2
2
1
1
1
2
2
15
2
3
3
2
1
1
1
3
1
1
1
1
1
2
1
1
                      4-3

-------
available were considered first.  The locations of these cities were
then plotted on a base map to consider geographic distribution.  Popula-
tion of the city and the associated Standard Metropolitan Statistical
Area were also considered along with receiving water characteristics
(i.e., stream, lake or estuary) in the final selection.  The ten study
sites selected are located in the following cities:  Atlanta, Georgia;
Des Moines, Iowa; Durham, North Carolina; Lubbock, Texas; Milwaukee,
Wisconsin; Philadelphia, Pennsylvania; Portland, Oregon; Roanoke, Virginia;
San Francisco Bay Area, California; and Tulsa, Oklahoma.  The geographic
distribution of the study sites is illustrated on Figure 4.1.

            The final selected sample includes:  one east coast estuary;
one west coast estuary; one Great Lakes site; six sites with combined
sewer discharges; four sites with only storm water discharges; receiving
streams with large base flows; and receiving streams with small base
flows.  Also the geographic distribution of the sites as shown on Figure
4.1 compares reasonably well with the distribution of population across
the United States.  Therefore, the ten selected study sites represent
the range of conditions which are reasonably likely to be encountered on
a nation-wide basis.
4.5         SCOPE OF SITE STUDIES

            Each study site was analyzed individually in order to quantita-
tively estimate the impact of stormwater runoff and combined sewer
overflow on receiving water quality.   The same general procedure was
applied to each site in order to obtain comparable results.  The exact
procedure employed at each of the ten sites was dependent upon the data
available at that site since a given parameter or demographic character-
istic may have been measured and reported for one city and not for
another.  Preference was always given to site specific data.  However,
where such observed data were unavailable, a reasonable value for the
parameter was estimated or assumed and the analysis was carried out
including these assumptions.

            Receiving water quality,  as measured by suspended solids
production and dissolved oxygen residual, are of interest in the impact
analysis, since one or the other may control the degree of treatment
required for a given situation.  However, since suspended solids are a
conservative substance, they can.be addressed in a straight-forward
manner when determining the level of treatment required to meet selected
criteria.  Dissolved oxygen residual on the other hand, is a more complex
nonconservative constituent which depends on a number of factors.
Therefore, the emphasis of the ten site studies is on determination of
the dissolved oxygen response of each urban area/receiving water system.
Estimated suspended solids production for each study site are, however,
reported in Appendix A, and suspended solids considerations are included
in the computation of national needs.
                                   4-4

-------
Ol
                                   FIGURE 4.1. LOCATION OF SELECTED STUDY SITES.

-------
            The objective of each analysis was to determine the dissolved
oxygen response of the receiving water based on point and nonpoint waste
loadings generated by a selected storm for given receiving water flow
conditions.  Both the storm and receiving water flow conditions are
based upon uniform criteria which are applied to each of the ten sites
analysed.
4.6         SITE DATA AND WASTE SOURCES

            The first step in the analysis was to assemble all available
site specific data for each city under consideration.   These data include
demographic data, rainfall data, runoff water quality  data, receiving
water data and selected maps.  Specifically,  items which were sought out
included the following:

            1.  Demographic Data.  Demographic data of interest include:
                population, population density, land use, curb miles of
                major streets, curb miles of  residential streets, area
                served by combined sewers, urban area, and total watershed
                area.

            2.  Rainfall Data.  Rainfall records of interest are hourly
                precipitation data, obtained  and published by the National
                Oceanic and Atmospheric Administration environmental data
                service.  A minimum of five years of continuous records
                were obtained for each site.

            3.  Runoff Water Quality Data. Runoff water quality data of
                interest include:  BOD, TKN,  NO^, S.S., Coliforms, and
                heavy metals.  Where site specific values are not avail-
                able, estimates were based on regression equations and
                typical values reported in the literature.

            4.  Receiving Water Data.  Receiving water data of interest
                include both flow records and water quality records.
                Water quality parameters include:  DO, Temp, BOD, TKN,
                NO^, S.S., and salinity upstream of the urban area.
                These data are generally found in USGS publications,
                storet files, river basin plans and other engineering
                reports.  Where site specific receiving water quality
                data were not available, estimates were made based on
                generalized data reported in  "Simplified Mathematical
                Modeling of Water Quality"1

            5.  Maps.  Maps utilized in this  study include:  1:250,000
                scale USGS base maps, 7-1/2 minute or 15 minute USGS
                topographic maps and available street or road maps.
                                   4-6

-------
            Once the above information is assembled, then an appropriate
receiving water is identified.  The receiving water is generally the
main stream which drains the urban area or a significant portion of the
urban area.  This is an important concept since all analyses were carried
out on a hydrologic unit basis.  That is, only waste sources tributary
to the receiving water are considered in the impact evaluation.  For
example, in the case of Roanoke, the whole of the urban area is drained
by the Roanoke River and, therefore, all urban runoff will enter the
receiving water.  In the case of Atlanta, the urban area is tributary to
several river systems and only one, the Chattahoochee River, was selected
for analysis.  Therefore, only those waste sources tributary to the
Chattahoochee are considered in the analysis.
4.7         CONCEPTUAL SKETCH OF STUDY SITE

            The next step in the general site study procedure was to
prepare a base map of the study site showing the actual location of all
known waste sources discharging to the receiving waters.  These sources
will include wastewater treatment plants, combined sewer overflow, storm
sewers, local runoff, and streamflow directly upstream of the urban
area.

            Once the actual situation is known, then a conceptual sketch
or model of the urban area receiving water system can be prepared.  This
sketch illustrates a simplified representation of the urban area.
Appropriate simplifications included combining adjacent wastewater
treatment plants into one point source, combining major and minor combined
sewer overflow points into one or more discharge points, and uniformly
distributing urban runoff.  The geometry of the stream channel was also
idealized by considering a rectangular channel of mean width and depth
as determined from available maps and hydraulic computations.

            Figure 4.2 illustrates a typical conceptual sketch of an urban
area receiving water system.  Actual conceptual sketches of each study
site are given in Appendix A.

            The example shown in Figure 4.2 illustrates combined sewer
overflow as discrete point sources, which is generally the case.  However,
in some situations combined sewer overflow were represented as distributed
loads in a manner similar to urban runoff.  This was done when the
number of overflow points was large and generally within the same area,
such as in the case of Milwaukee.  Other waste sources were included,
such as industrial wastewater treatment plants when information regarding
flows and waste strengths were known.
                                    4-7

-------




Qus ^
(cfs) m

8
Qus — Upstream flow
^ Limits of w

1 WWTP — Municipal wastewater
treatment plant
Urban runoff (cfs/mile) cso Combined sewer overflow
\< \> \> \< " V V V V V v V V V
Receiving water Qds ^

t t t t
I _ Qds = Qus + inflows
i£o 1 — O 1
af 9,1
^ < _ w ^
~D T3
1 1 1 1
D 70 60 50 40 30 20 10 0
RIVER MILES
FIGURE 4.2. CONCEPTUAL SKETCH OF URBAN AREA RECEIVING WATER SYSTEM.

-------
4.8         DESIGN STORM

            The selection of an appropriate design storm is an important
part of any stormwater or combined sewer overflow impact analysis or
stormwater facilities design.  This selection will largely determine the
size of a suitable detention facility and the required capacity of
treatment works.  Therefore, the design storm magnitude determines, to a
great extent, the cost of pollution abatement.

            Ideally, the facilities design criteria should be determined
by continuous hydrologic simulation of the subject hydrologic unit to
establish site specific relationships between facilities' capacities and
overall pollution abatement.  Since the hydrologic process is stochastic
in nature, it follows that the pollution abatement process is a stochas-
tic process.  Therefore, the problem should be addressed from a probabi-
listic framework in order to assure realistic analysis.  Once relation-
ships between alternative pollution abatement facilities and probable
improvement in water quality (expressed as expected value of number or duration
of exceedences of wet weather water quality criteria per unit time) are known,
then relationships between cost and probable improvement in water quality can
be derived.  Only then will actual trade-offs be apparent and only then can
rational design decisions be made.

            In general, such hydrologic, probabilistic and economic analyses
have not been made and the accepted procedure has been to "select" a
design rainfall event and to proceed with the design of facilities.  In
many cases, the concept of an extreme rainfall event has been applied.
For example, a given detention facility may be designed to store the
runoff from a 5-year, 24-hour storm.  If this detention facility is
located in a region which receives 100 days with rain per year, then in
a 5-year period 500 rainfall events will have been recorded.  In any
given 5-year period, it is probable that only one rainfall event will
exceed the capacity of the detention facility and 499 events, or 99.8
percent, will not.  Thus, a very high level of treatment, probably on
the order of 99 percent of all runoff, will be achieved.  The exact
percentage will depend upon not only the detention capacity, but also on
the treatment rate and on the random variable, time between storms.

            The magnitude of rainfall events is not only random, but tends
to be exponentially distributed.  That is, the majority of rain storms
occur as small showers or long periods of low intensity rainfall, with
infrequent storms producing large volumes of rainfall.  When designing
storm drainage or flood protection facilities, it is appropriate to
design for flow rates produced by extreme rainstorms.  When designing
pollution abatement facilities, such extreme design criteria are probably
not warranted.
                                    4-9

-------
            As an example, consider the Atlanta area which experiences 115
days with rain per year and has a 5-year, 24-hour storm rainfall depth
of approximately 5.0 inches.  If storage and treatment, were provided for
the 5-year storm level, then required storage would be such that all
runoff from 99.83 percent of all storms would be stored.  As an alterna-
tive, assume that the criteria were to store and treat all runoff produced
by 80 percent of the rainstorms, instead of 99+ percent.  Then the depth
of the design storm would be 0.74 inches, or about 15 percent of the 5-
year value, yet a very substantial portion of the runoff would receive
treatment at a small fraction of the cost.

            It is beyond the scope of this investigation to undertake
complex hydrologic, stochastic and economic analyses of the ten study
sites to determine the optimum level of design at each.  However, we
believe that from a water quality standpoint, design for extreme storm
events will generally not be cost-effective.  Therefore, we have selected
design storm and related criteria based on the following assumptions:

            1.  The random variable rainfall depth is exponentially
                distributed.

            2.  Combined sewer overflow involves the discharge of untreated
                municipal wastewater and, therefore, requires a higher
                level of control to meet receiving water quality criteria
                than is required for stormwater runoff.

            3.  Allowable frequency of exceedance of wet weather dissolved
                oxygen criteria (5.0 mg/1 or less) for fish and wildlife
                waters is on the order of twice per year.

            4.  Allowable frequency of exceedance of wet weather fecal
                coliform criteria for recreation waters is on the order
                of twice per year.

            The design storm criteria selected are:  the 80th percentile
storm for all stormwater facilities; the 90th percentile storm for treatment
of combined sewer overflow to meet the aesthetics and fish and wildlife
criteria; and the 98th percentile storm for treatment of' combined sewer
overflow to meet the recreation criteria.  Thus, the design storm is
defined as that depth of rainfall at which the cummulative frequency of
observed rainfall depths is 80, 90, or 98 percent, dependent upon the
type of urban runoff and receiving water quality to be achieved.   These
values were computed for each urbanized area.

            The computation procedure was to first compute the mean depth
of rainfall per storm at each site by the following equation:
                                    4-10

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                MRF = ARF/MNS                           (4.1)

            Where:

                MRF = Mean depth of rain per event
                ARF = Mean annual rainfall
                MNS = Mean number of storms per year

The mean annual rainfall and the number of storms per year were obtained
by analysis of 5 years of hourly rainfall data.  Rain storm events were
considered independent when separated by a dry period of 6 hours or
more.

            Assuming that rainfall depths are exponentially distributed,
then the design storm depth can be computed as follows:

                DSX = Kx MRF                            (4.2)

            Where:

                DSX = Design rainfall depth based on x percentile storm
                 Kx = A factor which converts the MRF to 80, 90, or 98
                     percentile storm depth (K^g = 1.61; KQQ = 2.30; and
                     K98 = 3.91)

            The design duration of the storm event was determined by
linear regression of depth of rainfall against duration of rainfall.
Once a regression line for a given data set was established, then the
expected value of the duration corresponding to the design depth was
computed.  This value was then used as the duration of the design storm.

            Knowing the depth and duration of the design storm, several
parameters related to the capacity of the required facilities can be
determined.  The first is the volume of storage required, which is
assumed equal to the volume of runoff produced by the design storm, and
is computed by the following equation:

                DVS = DS x C x DA x 0.02715             (4.3)

            Where:

                DVS = Design storage volume in million gallons
                DS  = Design rainfall depth in inches
                C   = Runoff coefficient
                DA  = Drainage area, tributary to storage facility,
                     in acres
                                    4-11

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            The required treatment rate is simply equal to the total
volume in storage (DVS) divided by an appropriate emptying time.  For
the purposes of this study, the emptying time was taken as the duration
of the design storm plus the mean time between rain storms (TBS), which
was determined from analysis of the hourly rainfall data for each site.
The design flow rate is computed as follows:

                TR = DVS/(SD + TBS)                     (4.4)

            Where:

                TR  = Design flow rate of treatment facility in mgd
                SD  = Duration of design storm in days
                TBS = Time between summer storms in days

            Once criteria are selected for the design of storage and
treatment facilities, a storage treatment system is defined.   The overall
performance of such a system depends not only on rainfall characteristics
which are utilized in the design criteria but also on the receiving
water streamflow, quantity and quality, which like rainfall are random
variables.  In some cases, upstream receiving water streamflow is dependent
on local rainfall and in other cases these two variables are completely
independent.  In any case, accurate analysis of expected performance of
a proposed storage treatment system requires continuous hydrologic
simulation studies.

            The approximate performance of an urban runoff storage treatment
system can, however, be estimated by application of probability theory
with certain simplifying assumptions.  Such estimates were developed for
the three design storm criteria utilized in this study and are reported
in Table 4.2.  These estimates are based on an average of 104 storms per
year and a treatment rate such that the design volume is treated in 3.5
days (i.e., TR = DVS/3.5).  Additionally, it is assumed that runoff is
directly proportional to rainfall for all storm events.  The values of
104 storms per year, and 3.5 days to treat the design volume, are
average values obtained from the ten site studies.

            Inspection of Table 4.2 reveals several important points
concerning the selected storage treatment systems.  First of all, it can
be seen from columns 2, 3, and 4, that overflow events result from two
separate causes:  (1) storm magnitude; and (2) storm sequence.  Overflow
events resulting from storm magnitude are caused by the occurrence of a
storm greater than the design storm.  Additional overflow events may
result when a storm less than design storm magnitude occurs while the
storage facility is partially full.  This type of overflow is due to
storm sequence, and its frequency of occurrence can be estimated by
methods based on conditional probability.  The greatest number of overflow
events will result from the occurrence of a storm greater than the
                                    4-12

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-P-
I
                                                       TABLE 4.2

                              ESTIMATED PERFORMANCE OF SELECTED STORAGE TREATMENT SYSTEMS




Design
Storm
Per cen tile
(1)
801

902

983




Expected Value
of Overflow
Events per Year
Due to Storm
Magnitude1*
(2)
20.8

10.4

2.1




Expected Value
of Overflow
Events per Year
Due to Storm
Sequence5
(3)
2.7

1.2

0.1


Expected
Frequency of
Total Expected Wet Weather
Value of Percent W.Q. Criteria
Overflow of Annual Exceedence in
Events per Runoff Events per
Year Treated Year6
(4) (5) (6)
23.5 77 1 to 5

11.6 88 1 to 3

2.2 97 0.2 to 1.0

up to 2.2




Probable
Criteria
Exceeded
(7)
Suspended
Solids
Dissolved
Oxygen
Dissolved
Oxygen
Bacteria
          1Applies to treatment of stormwater  runoff only.
          2Applies to treatment of combined  sewer overflow to meet aesthetics and fish and wildlife criteria.
          3Applies to treatment of combined  sewer overflow to meet recreation criteria.
          ''Based on 104 storms per year.
          5Based on 104 storms per year and  3.5 days to  treat design  storm runoff volume.
          6Exact values will depend on receiving streamflow  characteristics but should fall within stated range.

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design storm (column 2, Table A.2); however, a significant number of
additional overflow events occur as a result of storm sequence (column
3, Table 4.2).

            It is noted that the values reported in column 3 are a function
of the treatment rate criteria and will become smaller as treatment rate
is increased.  If the design treatment rate is increased to the point
where all runoff is treated within one day of the beginning of the
storm, then the values reported in column 3 would approach zero.   However,
the values reported in column 2, which account for the major portion of
the overflow events, would remain unchanged.  Thus, substantial increases
in the design treatment rate will not result in greatly improved system
performance as measured by number of overflow events per year.

            Column 5 of Table 4.2 shows the estimated percentage of annual
runoff which will be captured and treated by the proposed facilities.
The remaining fraction of runoff will continue to be discharged directly
to the receiving water untreated.

            Column 6 contains the estimated range of frequency of exceedence
of wet weather water quality criteria and column 7 indicates which of
the water quality standards are likely to be exceeded, for each set of
facilities design criteria.  Exact values for parameters reported in
these two columns will be dependent upon receiving water characteristics
which vary significantly, but should in general fall within the estimated
range.
4.9         POLLUTION LOADING FROM DESIGN STORM

            In order to determine the receiving water impact from nonpoint
source loadings, it is necessary to estimate average runoff rates and
pollution loading rates resulting from the design storm.  Average runoff
rates were computed by one of two methods, depending upon the relative
value of the design storm duration and the approximate time of concentra-
tion of the urban catchment area.  If the time of concentration is less
than the storm duration, then the mean runoff rate was computed as
follows:

                Q = PS x C x DA x 640
                    (SD + 1.67 TC)                      (4.5)

            Where:

                Q  = Average runoff rate for the urban watershed in cfs
                DS  = Design rainfall depth in inches
                C  = Runoff coefficient
                                    4-14

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                DA = Drainage area of urban watershed in acres
                SD = Duration of design storm in hours
                TC = Time of concentration of urban watershed in hours

If the time of concentration is greater than the duration of the design
storm, then the mean runoff rate was computed by the following equation:

                Q = PS x C x DA x 484
                    (SD + 1.2 TC)                       (4.6)

Where all terms are defined above.

            The above equations are based on the Soil Conservation Service
triangular runoff hydrograph technique2 and should result in reasonable
estimates of the average rates of runoff from individual urban watersheds.
            Pollution loads expressed as pounds per day of carbonaceous
BOD and nitrogenous BOD were estimated by various methods.  If site
specific data were available, then mean observed concentrations of
pollutants were computed and used in conjunction with the estimated mean
runoff rates to compute loading rates.  If observed concentrations were
not available, then reasonable values were assigned based on typical
values reported in the literature. 3 >lt'5  The waste loading rates resulting
from the design storm, as estimated for each source for each of the 10
study sites, are reported in Appendix A.  Constituents reported include
five day BOD (6005), ultimate oxygen demand (UOD) and suspended solids
(SS).
4.10        RECEIVING WATER IMPACT ANALYSIS

            Receiving water dissolved oxygen response for each study site
was estimated based on the waste source flows and loading rates resulting
from the 80th percentile storm, and on the conceptual urban area receiving
water system as illustrated in Figure 4.1.

            The steady state water quality model (AUTOSS) developed as
part of the "Auto-Qual Modeling System,"6*7 was used to compute the DO
sag curve resulting from the waste inputs.  This computer program utilizes
the Eulerian mass transfer equation to represent dispersion and decay of
pollutants.  AUTOSS will account for nitrogenous oxygen demand, as well
as carbonaceous oxygen demand, and can be applied to freshwater streams
and estuary systems.

            The AUTOSS computer program is a plug flow or steady state
model and, therefore, represents the dissolved oxygen budget within the
discrete unit of water generated by the urban system.  Dissolved oxygen
transfers, including organic decay and atmospheric reaeration, are
                                    4-15

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included.  These computations result in knowledge of the dissolved
oxygen concentration as a function of time within the discrete plug flow
of interest.  Inspection of the resulting DO sag curve will reveal the
minimum or critical DO concentration occurring in the receiving water.

            Decay rates utilized in the computations were varied with the
type of waste source, as summarized below:

            Waste Source                        Decay Rate Day"1
                                                (base e)
            1.  Carbonaceous material
                Wastewater effluent                 0.23
                Combined sewer overflow             0.40
                Urban runoff (storm water)          0.16

            2.  Nitrogenous material (all)          0.10

            Reaeration rates were estimated by either the O'Connor Dobbin's
equation, which is built into the computer program6 or by the Tsivoglou
equation developed in 1972.8  In the case of the Delaware estuary previ-
ously reported values of the reaeration coefficient were utilized.

            The base flow condition of the receiving water is also an
important parameter which is considered in the dissolved oxygen budget
computations.  Streamflow is the sum total result of the rainfall-runoff
process and is, therefore, probabilistic.  At any given time, the flow
rate observed at a stream cross-section can vary from no flow, under
extreme drought conditions, to several thousand cfs, under extreme flood
conditions.  Like other hydrologic variables, streamflow is random and,
therefore, cannot be predicted with certainty.  Furthermore, it is not
the streamflow alone which is of interest, but a combination of stream-
flow and residual dissolved oxygen, which is a function of water tempera-
ture and background oxygen demanding materials.

            It is convenient to address base receiving water conditions
from the concept of oxygen resources.  Oxygen resources of a flowing
body of water can be defined as the rate of dissolved oxygen flow observed
at a given point along the stream.  In this case, the point of interest
is just upstream of the urban area being considered.  The rate of dissolved
oxygen flow is simply the product of the streamflow times the dissolved
oxygen concentration.  This computation will yield a flow rate of oxygen
in appropriate units (for example, pounds of Q£ per day) which is a
measure of the oxygen resources of the receiving water.

            The criteria used in the site studies to define receiving
water conditions were based on average monthly oxygen resource, which is
defined as the product of average monthly streamflow times the correspon-
ding average dissolved oxygen content.   This value was computed for each
                                    4-16

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month of the year and the lowest value was utilized in the receiving
water analysis.  Thus, the low oxygen resource month based on mean
monthly flows was utilized in the water quality impact analysis.  In
general, this condition occurs in late summer or ealy fall when streamflow
are low and water temperatures are high.  This parameter was evaluated
at each site by analysis of observed streamflow records.

            The above receiving water low flow is considerably larger than
the 7-day, 10-year low flow usually utilized in the impact analysis of
continuous point source waste discharge.  The new criteria was chosen
because the conditional probability of observing one or more design
storms during the 7-day, 10-year low flow period is extremely small.
For example, the frequency of occurrence of the 80th percentile storm
concurrently with" the 7-day, 10-year low flow is once every 30 years.
When the 90th percentile storm is considered, the expected return period
increases to 55 years; and when the 98th percentile storm is considered,
the return period becomes 255 years.  All of the above combinations
represent rare events.

            The 80th percentile storm and the low flow criteria discussed
above were utilized in each of the ten receiving water impact analyses.
The primary purpose of each site impact analysis was to determine receiving
water response for a known set of hydrologic and urban area conditions
and not necessarily to determine critical conditions for each of the ten
selected sites.  Section 6 of this report discusses in detail the analysis
of the data generated by the receiving water impact computations and the
general relationship developed from these data.  This relationship can
then be applied to any desired combination of design rainfall and receiving
water flow to determine treatment needs for the selected conditions.

            Receiving water impact analyses, as discussed herein, were
performed for all study sites except for the San Francisco Bay Area.  In
the case of the Bay Area, extensive water quality impact analyses have
been completed for the California State Water Resources Board and the
San Francisco Bay Region Water Quality Control Board.  These studies
were extensive and detailed and have been published.10  Information
contained within the published report included estimates of the assimila-
tive capacity of selected portions of the bay based on dynamic water
quality analysis performed by Water Resources Engineers, Inc.10  These
assimilative capacity determinations included the development of curves
relating residual minimum dissolved oxygen to ultimate oxygen demand.
Thus the procedure utilized in the present study was to estimate the
oxygen demand resulting from design storm runoff and point discharges
and to utilize the previously developed DO versus loading curves to
obtain an estimate of the residual dissolved oxygen.
                                    4-17

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4.11        DETERMINATION OF REQUIRED TREATMENT LEVEL

            Required level of treatment for storm water and combined sewer
overflow is a function of the percentage of organic load (UOD) which
must be removed in order to meet the minimum standard of 5.0 mg/1 of
residual dissolved oxygen.  If the receiving water analysis indicates
that the minimum dissolved oxygen level is 5.0 mg/1 or greater, then no
treatment will be required.  If the dissolved oxygen level is less than
5.0 mg/1, then removal of a portion of the oxygen demanding material
will be necessary.

            In those cases where the impact analysis identified a dissolved
oxygen level less than 5.0 mg/1 for the design storm condition, an
additional DO response curve for point source waste loads only was
computed.  Both curves, representing design storm and dry weather flow
conditions, were then plotted on a common axis.  Inspection of these
curves clearly establishes the extent of the DO depression which is due
to the nonpoint waste loads.  Once the magnitude of the DO depression
due to nonpoint waste loads is known, then the percentage removal required
to achieve a minimum residual of 5.0 mg/1 can be easily computed.

            In addition to the DO response of the receiving water, suspended
solids production and concentrations were estimated.  In certain cases,
the removal of suspended solids controlled the removal efficiency required
to meet receiving water quality standards.  Generally, suspended solids
problems are associated with stormwater runoff and dissolved oxygen and
bacteria problems are associated with combined sewer overflow.

            Knowing the required removal, an appropriate level of treatment
is selected.  The treatment levels utilized in this study along with a
listing of processes included in each level are presented in Table 3.1.
                                    4-18

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                                 Section 5

                        DESCRIPTION OF STUDY SITES
          The sites selected for receiving water impact evaluation
represent a wide range of conditions, from small, low density urban
areas served by separate sewer systems to large, high density cities
served by combined sewer systems.  Also, receiving waters considered
ranged from free-flowing mountain streams to sluggish tidal estuaries.
The selection of such a wide range of urban area/receiving water condi-
tions was a stated objective of the study as discussed in the previous
section.

          The following is a brief description of each of the selected
study sites, the associated receiving waters and the impact analysis.
Details of each site, including demographic data, receiving water charac-
teristics, waste loading data, and rainfall data, are presented in
Appendix A.  Also presented in this appendix is a conceptual sketch of
each urban area/receiving water system and the DO response curve, for
the receiving water, resulting from storm generated waste load inputs.
5.1       ATLANTA

          The Atlanta urban area is located along a ridge separating
three distinct river systems, including the Chattahoochee River, the
Flint River, and the South River.  The study area is that portion of the
Atlanta urban area tributary to the Chattahoochee River and includes all
of the urbanized Peachtree Creek watershed.  Approximately six percent
of the study area is served by combined sewers, the remainder is either
drained naturally or served by storm sewers.

          The receiving water is the Chattahoochee River beginning just
upstream of its confluence with Peachtree Creek and extending approxi-
mately 80 miles downstream.  The first 20 miles of this distance is
urban area.  Waste inputs include urban runoff, combined sewer overflow,
and municipal wastewater treatment plant effluent.

          Receiving water impact analysis indicates that no treatment of
combined sewer overflow or stormwater discharge would be required to
maintain minimum dissolved oxygen for the selected storm event.

          Major site specific references utilized to define urban area
and receiving water characteristics of the Atlanta study site include a
recent report dealing with nonpoint source pollution evaluation11 and
water quality data published by the state of Georgia.12
                                   5-1

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5.2       DBS MOINES

          The city of Des Moines is located in central Iowa at the
confluence of the Des Moines and Raccoon rivers.  The study area includes
all of the city of Des Moines.  Approximately seven percent of the Des
Moines urban area is served by combined sewers with the remainder served
by separate sewer systems.

          The receiving water is the Des Moines River beginning at the
upstream end of the urban area and extending approximately 45 miles
downstream.  Waste inputs include urban runoff, combined sewer overflows
and municipal wastewater treatment plant effluent.

          Receiving water impact analysis indicates a DO depression
within the receiving water to a value of 4.95 mg/1, which is less than
the minimum criteria of 5.0 mg/1.  An overall removal of approximately
two percent of the UOD due to urban runoff and combined sewer overflow
would be required to meet the minimum wet weather DO criteria for the
selected storm runoff event.

          Site specific data for the Des Moines urban area and the Des
Moines River were obtained from a combined sewer overflow abatement plan
developed in 1974,13 and from water quality publications of the state of
5.3       DURHAM

          The city of Durham is located on a ridge in east-central North
Carolina.  Surface waters drain both to the north and to the south
through a system of headwater creeks.  The selected study area consists
of that portion of the city of Durham and adjacent areas tributary to
Third Fork Creek upstream of the Third Fork Creek wastewater treatment
plant.  The total tributary area is approximately 8.7 square miles at
this point.  The study area is served completely by separate wastewater
collection systems.

          The receiving water is Third Fork Creek beginning within the
urban area and extending approximately 28 miles downstream.  Waste input
includes urban,  suburban and rural runoff as well as wastewater treatment
plant effluent.

          Receiving water impact analysis indicates that no treatment of
stormwater discharge would be required to maintain minimum wet weather
dissolved oxygen criteria for the design storm event.  These results are
in substantial agreement with a previous impact analysis of this watershed
reported by Colston.17  In this study, the impact of several storms,
including a "small storm" (0.10-inch of rainfall) was analyzed.  The
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small storm required no treatment to meet the 5.0 mg/1 criteria, whereas
the larger storms (1.0 to 3.3 inches of rainfall) would require some
treatment.  The present analysis indicates that a rainfall event of 0.69
inch will result in a minimum DO level of 5.8 mg/1, and thus does not
require treatment to meet wet weather criteria.  However, removal of
approximately 34 percent of urban and suburban area suspended solids
would be required to meet wet weather suspended solids criteria.

          Major site specific references included the previously cited
Colston report,17 the state of North Carolina Water Quality Management
Plan,18 and computer printouts of river basin water quality data, for
Third Fork Creek, supplied by the Division of Environmental Management
of the North Carolina Department of Natural and Economic Resources.
5.4       LUBBOCK

          Lubbock is located on the "high plains" of west Texas near
Yellow House Canyon.  The study site includes the entire Lubbock urban
area which is tributary to the intermittent Brazos River.  This stream
flows through Yellow House Canyon in the vicinity of Lubbock.  There are
no combined sewer systems within the study area and all wastewater
effluent are reclaimed by means of a land spreading (spray irrigation)
system.

          The receiving water is the North Fork of the Double Mountain
Fork of the Brazos River (Yellow House Canyon) which is normally dry.
Surface runoff from Lubbock is presently routed through a series of
overflowing lakes in Yellow House Canyon in an effort to reclaim this
water.  For the purposes of this study, the existing retention lakes
were ignored and a free-flowing river system was assumed for analysis.
This analysis allows a hypothetical receiving water which receives waste
loads from an urban area with Lubbock's runoff quantity and quality
characteristics to be compared with the receiving water impact analyses
of other study sites.  Because there are no combined sewers within the
study area, and because all wastewater effluent are reclaimed by spray
irrigation, the only waste input to the receiving water is urban runoff.

          Receiving water impact analyses indicate that no treatment of
urban runoff would be required to maintain minimum wet weather dissolved
oxygen criteria for the selected storm event.  Suspended solids removal
of approximately 26 percent will, however, be required to meet wet
weather receiving water criteria.

          Major site specific references include reports on urban runoff
for the Lubbock area prepared by Texas Tech University Water Resources
Center,19'20'21 and the Water Quality Management Plan for the Brazos
Basin.22
                                   5-3

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5.5       MILWAUKEE

          The Milwaukee study area consists of all urban area tributary
to the Milwaukee River south of the Milwaukee-Ozaukee County line.
Urban areas tributary to the Menomonee and Kinnickinnic rivers are not
included in this analysis.   Approximately 17 percent of the study area
is served by combined sewers.  The combined sewer systems are located in
the densely developed downtown area and consequently serve approximately
61 percent of the resident population.  There are approximately 62
discrete combined sewer overflow points discharging untreated wastewater
to the lower Milwaukee River.  The remaining urban area upstream of the
combined sewer systems is served by separate sewer systems and thus
discharge stormwater runoff only to the Milwaukee River.

          The receiving water is the Milwaukee River beginning at the
Milwaukee-Ozaukee County line and extending to the south into Milwaukee
Bay and ultimately into Lake Michigan.  Waste sources include suburban
stormwater runoff, urban stormwater runoff, combined sewer overflow and
treated wastewater effluent from the Jones Island wastewater treatment
plant which discharges into Milwaukee Bay.  As previously stated, flows
from the Menomonee and Kinnickinnic rivers were not included in the
analysis.  These rivers do, however, discharge to Milwaukee Bay and will
provide dilution during base flow conditions for the Jones Island plant
effluent.  Therefore, for the purpose of this impact analysis, only one-
half of the Jones Island effluent was considered tributary to Milwaukee
River flows.

          Receiving water impact analyses indicate that a minimum DO
residual of 4.3 mg/1 will occur in Milwaukee Bay, which is considerably
less than the minimum criteria of 5.0 mg/1.  Removal of approximately 55
percent of the organic load from stormwater and combined sewer overflow
would be required to meet the wet weather criteria.  If all the required
removal were obtained by treatment of combined sewer overflow only, then
this waste source would need to be treated to approximately 76 percent
reduction in UOD.  This level of treatment for combined sewer overflow
only is more cost-effective than treatment of both combined sewer overflow
and stormwater runoff to a lesser degree of organic removal.

          Site specific data for the Milwaukee River and the city of
Milwaukee, as well as water quality and hydrologic information were
obtained primarily from a comprehensive plan for the Milwaukee River
watershed prepared by the Southeastern Wisconsin Regional Planning
Commission. 23
5.6       PHILADELPHIA

          The city of Philadelphia is located in eastern Pennsylvania at
the confluence of the Delaware and Schuylkill rivers.  The entire urban
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area, consisting of some 200 square miles, is considered in this study.
The city is heavily industrialized and contains many industrial waste
sources as well as numerous municipal wastewater treatment plants.  The
central portion of the city, covering approximately 35 square miles, is
served by combined sewers.

          The receiving water is the Delaware River/estuary from Trenton,
New Jersey on the upstream end to a point approximately 40 miles down-
stream from the Philadelphia urban complex.  This portion of the Delaware
River is a tidal estuary and has been studied previously by Thomann,9
and Betz Environmental Engineers, Inc.21*  Most of the physical data used
to describe the Delaware estuary, including hydraulic and dispersion
data were taken from the Thomann study and much of the point source
waste load data was taken from the Betz study.  Additional data were
obtained from the city of Philadelphia Water Department25 and recent
unpublished waste load data were obtained from the Delaware River Basin
Commission.  Data concerning ultimate point source waste load allocations
(Table A-7, Appendix A) were obtained from the EPA regional office in
Philadelphia.  All types of waste sources including stormwater runoff,
combined sewer overflow, wastewater treatment plant effluent, and
industrial waste discharges are present within the limits of the study
area.

          Four dissolved oxygen profiles representing different waste
loadings were computed for the Delaware estuary.  The conditions consid-
ered were:  (1) existing point sources only; (2) existing point sources
plus urban runoff and combined sewer overflow; (3) allocated point
source waste loads only; and (4) allocated point source waste loads plus
urban runoff and combined sewer overflow.  The computed DO profiles are
presented in Appendix A (Figures A-12 and A-13).  The results of these
computations indicate that for all four waste loading conditions, a
minimum DO standard of 5.0 mg/1 will not be met.  Furthermore, for the
condition of existing point source waste loads plus storm runoff, the DO
level in the estuary will fall to zero.  This analysis indicates that
treatment of all stormwater runoff and combined sewer overflow to 100
percent organic load removal will not meet wet weather water quality
criteria.
                 Q
          Thomann  reported observed minimum values of DO in the Delaware
estuary of between 3.0 mg/1 and 0.0 mg/1 with a mean value of approxi-
mately 1.0 mg/1.  These observations were made during the summer of
1964.  The computed DO curves for wet and dry weather conditions, and
existing point source loads envelop these observed values.  Such agree-
ment with actual field observations tends to support the validity of the
impact analysis.

          The Philadelphia study site has the most severe receiving
water quality problems of any of the ten selected sites.  Theoretically,
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 157  percent  of all nonpoint UOD would have  to be  removed  to meet  the  5.0
 mg/1 criteria for existing point  source waste loads,  and  approximately
 123  percent  of the nonpoint UOD would have  to be  removed  to meet  the
 criteria with allocated point source waste  loads.   Obviously,  additional
 wastewater,  stormwater and combined sewer overflow  treatment  facilities
 will be required to meet water quality objectives.


 5.7        PORTLAND

           The city of Portland is located at the  confluence of the
 Columbia and Willamette rivers in northwestern Oregon.  The entire  city
 is tributary to either the Columbia or the  Willamette, with the large
 majority tributary to the Willamette.  Approximately  two  percent  of the
 Portland urban area is served by  combined sewers.

           The receiving water is  the Columbia River beginning at  its
 confluence with the Willamette River and extending  approximately  30
 miles downstream.  Since all waste sources  are tributary  to the Willamette
 River, in its extreme lower reaches, these  waste  loads were summed,
 added to the base flow of the Willamette, and input for computer  analysis
 as a single  waste source entering the Columbia River.  This procedure
 ignores a small amount of biological activity and reaeration  which  may
 take place in the lower reach of  the Willamette River; however, the
 error introduced by this simplification should be negligible.   Waste
 sources include urban runoff, combined sewer overflow and municipal
 wastewater treatment plant effluent.

           Receiving water impact  analysis indicates that  no treatment of
 urban runoff or combined sewer overflow would be  required to  maintain
 minimum DO or suspended solids criteria for the selected  storm event.

           The major source of site specific water quality data was  a
 report prepared by the State of Oregon.26
5.8       ROANOKE

          The city of Roanoke is located in western Virginia  at  the
confluence of the Roanoke River and Tinker Creek.  The  entire urban area
is within the limits of the Roanoke River drainage basin  and  all urban
area is considered in this study.  Roanoke is served  entirely by a
separate wastewater collection system.  The receiving water is the
Roanoke River beginning at the upstream limits of the urban area and
extending approximately 25 miles downstream.  Waste sources include
urban runoff and treated municipal wastewater effluent.
                                   5-6

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          ,From the receiving water impact analysis, it was determined
that no treatment of stormwater runoff would be necessary to meet minimum
wet weather DO or SS criteria within the receiving stream under the
selected storm conditions.

          Site specific data were obtained from two previous engineering
reports27'28 and from a water quality inventory prepared by the State of
Virginia.29
5.9       SAN FRANCISCO

          The San Francisco Bay system consists of two main arms, San
Pablo Bay located to the north of Golden Gate and San Francisco Bay
located to the south of Golden Gate.  This study is concerned with the
San Francisco Bay area located south of the Golden Gate.  The area
tributary to San Francisco Bay totals approximately 1,850 square miles,
of which approximately 70 percent is rural and 30 percent is urban.  The
urban areas are located adjacent to the Bay and include, among others,
the cities of San Francisco,  San Mateo, Redwood City, Palo Alto,  San
Jose, Union City, Hayward, San Leandro, and Oakland.  The combined 1975
population of these bay area cities and adjacent lands tributary to the
bay was approximately 3,422,000 persons.

          The San Francisco Bay area is by far the largest site selected
for this study.  It was necessary to include all bay area communities
within the study since they form a contiguous urban complex and all
discharge wastes to the same receiving water.  Waste sources include
approximately 45 square miles of combined sewered area located entirely
within the city of San Francisco and 2.5 square miles of combined sewered
area located in the city of Oakland.  Of the remaining urbanized area,
approximately 98 square miles are industrialized and 410 square miles
are either commercial or residential.  All of these areas are served by
separate wastewater collection systems.

          DO budget computations were not carried out for the San Fran-
cisco Bay area for two reasons.  First the San Francisco Bay system is
a huge estuary up to 12 miles wide which receives very little freshwater
inflow during the dry season.  Because of its geometry and because the
principal mechanism of water exchange is tidal flushing, the one dimen-
sional estuary model which performed well in the case of the Delaware
estuary would yield conceptually inaccurate results if applied to San
Francisco Bay.  Secondly, the bay system has been studied extensively by
others10 and the DO response to waste loadings has been defined.  This
determination was made utilizing a two-dimensional dynamic water quality
simulation of the bay or selected portions of the bay.10  The procedure
used in the present study was to estimate waste loadings resulting from
the selected storm and to apply these waste loadings to previously
                                   5-7

-------
 developed relationships between DO residual in mg/1 and UOD in Ib/day.
 In this manner, the impact of nonpoint source loads on San Francisco Bay
 was estimated.

           The previous study10 established that the vast northern portion
 of San Francisco Bay is well flushed by tides inflowing and outflowing
 through the Golden Gate and that dissolved oxygen conditions in this
 portion of the bay are quite good even with the discharge of combined
 sewer overflow.  Bacteriological contamination has, however, been
 identified as a problem in this portion of the Bay.  The southern portion
 of the bay, known as South Bay, and defined as that portion of San
 Francisco Bay south of Alameda Creek,  experiences severe DO problems.

           South Bay is located approximately 30 miles from the Golden
 Gate.  It experiences very poor tidal flushing, is shallow, and receives
 little freshwater inflow during the dry season.  South Bay is also
 surrounded by an urban complex supporting approximately 1,461,000 persons.
 The assimilative capacity of the South Bay has been estimated to be
 140,000 Ib/day of UOD if a DO residual of 6.0 mg/1 is maintained (Reference
 10, page 15-78).  Allowable UOD increases to 308,000 Ib/day if a DO
 residual of 5.0 mg/1 is maintained.  Total UOD loading for the selected
 storm is estimated to be 400,340 Ib/day,  which will result in a minimum
 DO level of approximately 4.4 mg/1.  This analysis indicates that removal
 of approximately 30 percent of all organic loads from stormwater runoff
 tributary to the South Bay would be required to meet a minimum wet
 weather DO criteria of 5.0 mg/1 within the South Bay.  Treatment of
 stormwater runoff and combined sewer overflow discharged to the main
 body of San Francisco Bay would not be required to meet DO criteria.

           In addition to previously cited sources, site specific data
 were obtained from a previous needs study30'31 and an engineering report
 on treatment of combined sewer overflow for the city of San Francisco.32


 5.10      TULSA

           The city of Tulsa is located in eastern Oklahoma on the Arkansas
 River.  The  entire urban area of the city is tributary to the Arkansas
 River and,  therefore,  the whole city is considered in this study.   Tulsa
 is  served  entirely by separate wastewater collection systems.

           The  receiving  water is the Arkansas River beginning at the
upstream end of  the urban area and extending approximately 45 miles
downstream.  Waste sources  include urban  runoff and wastewater treatment
plant effluent.

          Receiving water impact analysis indicates that treatment of
urban runoff is not  necessary to meet  minimum wet weather DO or SS
criteria in the Arkansas  River.
                                   5-8

-------
          Site specific data for the Tulsa area were obtained from a
previous study of urban stormwater quality,33 a water quality management
plan for the Arkansas Basin,34 and a regional environmental pollution
study of the Tulsa region.35
                                   5-9

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                                 Section 6

          ANALYSIS OF RAINFALL, WASTE LOADING AND TREATMENT DATA
          The ten site investigations resulted in the development of a
considerable volume of site specific data related to hydrology,  waste
loadings, and required stormwater and combined sewer overflow treatment.
It is the purpose of this section to report and analyze these data,  and
to develop appropriate conclusions and generalizations which can be
applied nationwide for the purpose of estimating national needs.
6.1       ANALYSIS OF RAINFALL DATA

          Five years of continuous hourly rainfall data were obtained
and analyzed for each of the ten study sites in order to develop estimates
of design storm parameters.  These parameters were then used in the
impact analysis and in the sizing of storage and treatment facilities.
Once storage volumes, treatment rates and required treatment levels are
known, construction and operation and maintenance costs for these facili-
ties can be estimated by application of the facilities costs equations
presented in Section 3.

          The following is an analysis of the design storm and facilities
design parameters obtained from the five years of hourly rainfall data
at each study site.  The objective of this analysis is to identify
appropriate simplifications or relationships among the rainfall variables
and to establish a procedure which can be used in the national needs
projection to estimate design storm and facilities design parameters
utilizing only easily obtainable climatological data summaries.  Such
data summaries are available for each of the 320 urbanized areas consid-
ered in the national needs projection.

          Table 6.1 presents a summary of rainfall data obtained from
analysis of hourly rainfall and from available climatological summaries.
Data reported in Column 2, long-term mean annual rainfall, and Column 5,
number of days with rain per year, were obtained from the climatological
summaries; whereas, data reported in Column 3, 5-year mean annual rainfall,
Column 4, number of storms per year, Column 6, mean depth, Column 7,
design duration, and Column 8, mean time between storms, were obtained
from the analysis of hourly observed rainfall records for each study
site.

6.1.1     Mean Annual Rainfall

          Long-term mean annual rainfall varies from 18 inches in Lubbock,
Texas, to over 48 inches in Atlanta, Georgia, and is one of the most
                                   6-1

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                                                     TABLE 6.1
                                             SUMMARY OF RAINFALL  DATA
I
N3
Site
(1)
Atlanta
Des Moines
Durham
Lubbock
Milwaukee
Philadelphia
Portland
Roanoke
San Francisco
Tulsa
Long Term
Mean
Annual
Rainfall
(inches)
(2)
48.34
30.88
42.50
18.00
29.07
39.93
37.61
41.23
-20.66
37.08
5-Year
Mean
Annual
Rainfall
(inches)
(3)
51.75
38.05
44.11
19.98
31.68
48.80
40.49
49.19
19.66
49.97
Number of
Storms
per Year
(4)
115
119
103
57
123
113
148
117
61
82
Number of
Days with
Rain per
Year
(5)
115
103
114
60
123
115
154
120
67
90
Mean1
Rainfall
Depth
MRF
(in.)
(6)
0.45
0.32
0.43
0.35
0.26
0.43
0.27
0.42
0.32
0.61
Design2
Duration
(hours)
(7)
10.3
12.65
9.63
11.35
7.76
16.46
9.57
11.76
9.53
20.20
Mean Time3
Between
Storms
(hours)
(8)
57.37
67.50
76.50
101.80
70.13
74.24
55.80
60.65
69.11
97.35
Symbol
(9)
A
I
D
L
M
P
0
R
S
T
       Mean Duration = 12 hours
       Mean Time Between Storms = 73 hours
       Mean Number of Storms per Year = 104

       !80 percent storm depth = 1.61 x MRF
       2Mean duration of 80 percent storm
       3Mean time between storms for low flow period

-------
significant of all rainfall parameters.  In addition to geographic
variations, annual rainfall can be quite variable from one year to the
next.  Thus, a certain degree of statistical risk is involved when
selecting a random 5-year period of record for analysis-  In order to
determine if the sample periods selected for analysis were representative,
the long-term mean annual rainfall for each city was compared to the
mean annual rainfall obtained from the selected 5-year sample.  This
comparison is shown in Figure 6.1, which is a scattergram of long-term
mean annual rainfall versus the 5-year mean annual rainfall.  On the
average, the sample period received 14 percent more rainfall than the
long-term period.  This small bias will, however, have no effect on the
national needs projection, since long-term values were utilized in the
national cost computations.

6.1.2     Annual Number of Storms

          A storm event, as defined for the ten site studies, is a
period of rainfall separated from the preceding period of rainfall and
from the succeeding period of. rainfall by dry periods of at least six
hours.  Thus, the procedure utilized to determine the number of storms
per year, the duration of each storm, and the time between storms,
involved detailed analysis of the 5-year period of record at each site.
The number of storms per year, as defined above, is not a readily avail-
able climatological parameter.  However, the number of days with rain
per year (Column 5, Table 6.1) is a climatological parameter which is
known for all urbanized areas in the nation.  For this reason, the
relationship between number of storms per year and number of days with
rain per year was investigated.  This investigation revealed that a
strong, positive correlation between these parameters does in fact
exist, as illustrated on Figure 6.2.  Inspection of Figure 6.2 indicates
that the relationship between these variables is linear and that the
line of best fit, as determined by regression analysis, is given by the
following equation:

               MNS = 1.0026 (ADR) - 2.58                    (6.1)

          Where:

               MNS = Mean number of rain storms per year
               ADR = Mean number of days with rain per year

Knowing the number of days with rain per year for a given city, the
number of storms per year can be estimated by application of the above
equation.

6.1.3     Time Between and Duration of Storms

          Possible statistical relationships between the time between
and duration of storms for critical period (low flow) conditions, and
                                   6-3

-------
                            10      20       30      40      50
                               Five-Year Mean Annual Rainfall (in.)
FIGURE 6.1. LONG-TERM MEAN ANNUAL RAINFALL VS. FIVE-YEAR MEAN
             ANNUAL RAINFALL.
                  160

                  150

                  140

                  130 -
                n
                > 120 -
                i
                | 110 -
                6
                3>
                •o 100
                6
                z
                i 90 -
                I
                  80 -

                  70 -

                  60 -
                  50
                    50   60   70   80  90  100  110  120 130  140  150  160
                               Mean No. of Days with Precipitation per Year
 FIGURE 6.2.  NUMBER OF STORMS PER YEAR VS. NUMBER OF DAYS WITH
              PRECIPITATION PER YEAR.
                                 6-4

-------
other climatological parameters, were also investigated.  Possibilities
considered included linear relationships between the following variables:

       ,   1.   Number of storms per year and mean time between storms;
          2.   Mean annual rainfall and mean time between storms;
          3.   Design duration and mean time between storms;
          4.   Design duration and design depth.

Each of these data pairs were plotted in a manner similar to that shown
on Figure 6.2.  However, in each case, strong linear correlations were
not indicated.

          The time between storms and duration of storms for critical
period conditions were also considered from a geographical standpoint.
However, variations in these variables were not readily explained by
this approach either.

          Because computed values of the design storm duration and the
mean time between storms for critical period conditions could not be
related to other rainfall parameters, or explained by geographic consid-
erations, it was assumed that the sum of these parameters could be
estimated as follows:

               (TBS + SD) = 365/MNS                         (6.2)

          Where:

               (TBS + SD) = The sum of the mean time between storms
                            plus the mean duration of storms, in days

               MNS        = Mean number of storms per year

The above equation will yield a good estimate of the overall annual
average sum of the time between and duration of storms at a given site,
but will not necessarily represent conditions prevailing during critical
receiving water conditions.
6.2       GENERALIZED DESIGN STORM, STORAGE AND FLOW PARAMETERS
          FOR NATIONAL NEEDS PROJECTION

          One of the stated objectives of the rainfall data analysis was
to establish a procedure which can be used in the national needs projec-
tion to estimate design storm and facilities design parameters.  This
procedure is outlined in this subsection.

          Two site specific climatological data parameters are available
for each urban area.  These are:  (1) mean annual rainfall (ARF), and
                                   6-5

-------
(2) mean number of days with rain (ADR).   Given site specific values for
these parameters, the procedure used to  estimate other design parameters
is given five steps, as follows:

          Step 1    Estimate mean number of rain storms per year (MNS)
                    MNS = 1.0026 (ADR) - 2.58               (6.3)

          Step 2    Compute mean rainfall depth per storm (MRF)
                    MRF = ARF/MNS                           (6.4)

          Step 3    Compute design depth for x percentile storm
                    DS = Kx MRF                             (6.5)

          Step 4    Compute design volume (DVS)
                    DVS = DS x C x DA x  0.02715
                    (mg) (in.)    (acres)                   (6.6)

          Step 5    Compute design flow  rate for treatment
                    facility (TR)

                    TR = DVS/(365/MNS)
                    (mgd)        (days)                      (6.7)

          One additional hydrologic variable is required for the receiving
water impact analysis.  This variable is the mean runoff rate from the
urban area, and is utilized in the evaluation of required treatment for
each urbanized area in the nation.  This evaluation is discussed in
Section 6.3 of this report.

          The mean runoff.rate resulting from the 80th percentile storm
was computed for each of the ten study sites, based in part on estimates
of the hydraulic time of concentration of the urbanized area tributary
to the receiving water.  The times of concentration of all urbanized
areas in the nation are not known, nor are they readily estimated.
Therefore, the procedure used in the national projection computations
was to assume that all excess surface water, resulting from the design
storm, would run off in a period equal to the mean storm duration (12
hours).  The mean flow rate in cfs is then equal to 3.09 X DVS, where
the volume (DVS) is expressed in million gallons.  This procedure will
tend to overpredict by a small amount the mean rate of runoff, since
some water will be held in temporary watershed storage and will runoff
after rainfall has ceased.
6.3       ESTIMATING REQUIRED ORGANIC REMOVAL

          The ten site studies identified four cities, Des Moines, San
Francisco Bay Area, Milwaukee, and Philadelphia, as requiring some
                                   6-6

-------
treatment of combined sewer overflows and/or stormwater runoff to meet
the selected wet weather dissolved oxygen criteria of 5.0 mg/1 in the
receiving water for selected storm and low flow conditions.  It is the
purpose of the analysis presented here to identify what urban area and
receiving water parameters are important in establishing whether or not
a given city will require treatment of these sources of pollution.  The
objective of this analysis is to develop, from the site study data, a
relationship between urban area characteristics and required nonpoint
source treatment which can be applied to all cities for the national
needs computation.

          A summary of the site study data and resulting treatment
requirements is presented in Table 6.2.  It is noted that the BOD5
loading rate (Column 5, Table 6.2) can generally be estimated somewhat
more easily and itfore accurately than can the UOD loading rate.  Therefore,
since this parameter accounts for all pollution sources, and can be
estimated for all urbanized areas, it should appear in generalized
relationships developed, from this data.  Also, the total flow downstream
of the urban area (Column 3, Table 6.3) is a function of all hydrologic
variables operating on the urban area, including base flow and storm
induced flows, and thus should appear in the generalization.  Considering
the above, an attempt was made to relate the BOD^ per unit of streamflow
(BOD/QDg) to the required organic removal.  BOD per unit of flow is a
measure of pollutant concentration and should logically be related to
the organic removal required to meet desired stream oxygen levels.
However, no relationship was indicated.

          Upon further consideration, it was reasoned that an important
parameter, the natural assimilative capacity of the receiving water, is
not accounted for when only pollutant concentration is considered.
Furthermore, a numerical measure of receiving water assimilative capacity
is available for all study sites.  This measure is the reaeration coeffi-
cient K£  (Column 4, Table 6.1) of the receiving water.  This coefficient
is a measure of the ability of a receiving stream's capacity to accept
oxygen demanding materials.  The higher the value, the more pollutants a
given receiving water can accept before DO problems develop.  Thus,
required organic removal should be inversely proportional to the value
of the reaeration coefficient, l^.

          Based on the above reasoning, a "lumped quality parameter" was
defined as the total BOD5 load in pounds per day divided by the product
of the total streamflow and the reaeration coefficient.  That is:

               RF =   BOD
                    QDS K2                                   (6>8)

          Where:

               RF  = Urban area quality parameter  (reduction factor)
                                   6-7

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I
00
                                                      TABLE  6.2



                                   SUMMARY OF  SITE  STUDY  BOD TREATMENT REQUIREMENTS
Study
Site
(1)
Atlanta
Des Moines
Durham
Lubbock
Milwaukee
Philadelphia
Portland
Roanoke
San Francisco
(South Bay)
Tulsa
Base Flow,
cfs
(2)
2,499
2,186
6.8
0
170
4,167
3,919
168
72
3,711
Total
Flow, cfs
(3)
4,708
3,346
94.4
219
467
9,622
5,465
512
Unknown
4,353
K2
day"1
(4)
1.5
1.9
2.5
7.1
1.1
0.17
2.0
16.0
Unknown
4.6
BOD 5
#/day
(5)
109,819
472,100
8,636
17,390
67,000
1,068,464
204,390
12,480
213,917
137,584
UOD
#/day
(6)
359,369
1,010,180
25,011
31,580
214,700
2,215,246
498,564
46,441
400,340
402,634
Overall BOD
Removal Req.
(7)
0
2%
0
0
55%
157%
0
0
30%
0
BOD5
Qtotal K2
(8)
16
74
37
11
130
653
19
2
—
7

-------
               BOD = Total BOD5 loading rate for urban area in
                     pounds per day
                     Total receiving water flow rate downstream
                     of urban area in cubic feet per second
               K£  = Reaeration coefficient of receiving water
                     downstream of urban area in day"-(base e)

Values of this parameter for each of the ten study sites, except for the
San Francisco Bay Area, are reported in Column 8 of Table 6.2.

          The basic waste loading data for Philadelphia, Milwaukee, and
Des Moines were modified, and receiving water dissolved oxygen response
curves were recomputed based on these new waste loadings, in order to
generate additional data.  These data are reported in Table 6.3.  In the
case of Philadelphia, the point source waste strengths were reduced to
conform with the allocated waste loadings assigned to these sources.
Because this case represents a possible future condition, the DO response
curves and waste load information are reported in Appendix A.

          Modification to the Des Moines data and Milwaukee data on the
other hand were arbitrary and do not represent likely future conditions.
The Des Moines analysis indicated a need for a small reduction in BOD
loading to meet standards.  Therefore, the stormwater runoff portion of
the BOD loading was doubled to generate a data point indicating a need
for greater BOD removal.  In the case of Milwaukee, a need for substantial
BOD reduction was indicated by the base data.  Therefore, the stormwater
runoff portion of the BOD loading was both increased by 100 percent and
decreased by 50 percent in order to generate two additional data points.

          All data points reported in Tables 6.2 and 6.3 were plotted on
semi-log paper as shown in Figure 6.3.  The heavy line shown on this
figure is the general relationship resulting from the dissolved oxygen
response analysis of the ten selected study sites.  This relationship is
general and can be applied to any desired combination of design storm
magnitude and receiving water flow conditions.

          Inspection of Figure 6.3 reveals that when an urban area
receiving water system produces a quality parameter value less than 70,
then no treatment of stormwater runoff or combined sewer overflow would
be required to meet a stream oxygen criteria of 5.0 mg/1, for the design
storm runoff.  If the quality parameter is in the approximate range of
70 to 300, then varying degrees of treatment will be required to meet
the 5.0 mg/1 standard.  For quality parameters greater than 300, treatment
of stormwater and combined sewer overflow, as well as additional point
source treatment facilities, will be required to meet wet weather criteria.
Values of the quality parameter, as defined above,, were computed for
each urbanized area and applied to the curve presented in Figure 6.3 to
estimate the required level of treatment for use in the national needs
computations.
                                   6-9

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                                              TABLE 6.3

        SUMMARY OF ADDITIONAL RECEIVING WATER IMPACT ANALYSES AND BOD TREATMENT REQUIREMENTS



1
H
0
Study Site
(1)
Philadelphia (Px) 1
Des Moines(Ij)2
Milwaukee (Mj) 3
Milwaukee (M2)'f
1Analysis based on
Base Flow Total Flow K2 BOD5 UOD Overall BOD
cfs cfs day"! #/day #/day Removal Req.
(2) (3) (4) (5) (6) (7)
4,167 9,622 0.17 888,434 2,054,828 123%
2,186 3,346 1.9 754,400 1,602,180 55%
170 467 1.1 42,400 162,800 0%
170 467 1.1 116,200 318,500 88%
allocated point source wasteloads.
BODs
QtotalK2
(8)
543
119
83
226

3Analysis based on one half actual stormwater and combined sewer overflow wasteloads.
^Analysis based on twice actual stormwater and combined sewer overflow wasteloads.

-------
,00,
80-

g
1 60-
'5
cr
V
O
0)
0 40.
O
CQ
20-
01
2
	 i-i 	 «--


Not
Atlc

e:
nta, Lub

oock,



Roanoke and Tulsa
hav<
valu
do r



0
3 quality
es less th
lot requir
tment


D
oaramet
an 20 ar
e



er
id












>































/
P""/

/

j
M2 /
7

f





r









(12







Pi
3%)







P
(15








7%)






























0 30 40 50 60 70 80 100 200 300 400 500 600 700 900
                                Lumped quality parameter-BOD5 (ppd)/Q total (cfs) K2 (day
                                                                          "2
FIGURE 6.3.  RELATIONSHIP BETWEEN LUMPED QUALITY PARAMETER AND REQUIRED BOD REMOVAL.

-------
6.4       ANALYSIS OF LEAD DATA

          Lead is a toxic metal that accumulates in animal tissues and
has no beneficial affects when found in water.  Recent studies indicate
that as much as 5,000 tons of lead per year may be added to the aquatic
environment from urban runoff.3

          The average concentration in urban runoff samples at Atlanta
has been reported to be 0.15 mg/1.11  However, the average concentration
of lead in the Chattahoocb.ee River during the summer months remained
below 0.001 mg/1, well within drinking water standards (0.05 mg/1).
Lead concentrations are also within drinking water standards in the
polluted Delaware estuary where observed values range from 0.004 mg/1 to
0.02 mg/1.  On the other hand, lead concentrations of from 0.10 mg/1 to
2.86 mg/1, with an average value of 0.46 mg/1, have been reported for
urban runoff samples in Durham.17  Such high concentrations are clearly
cause for concern.

          The ultimate role of lead in the aquatic environment is not
well understood.  However, it is known, that lead toxicity to fish is a
function of water hardness and pH and, therefore, safe concentration
limits are difficult to establish.  The estimated removal efficiencies
of lead and other toxic substances obtained by the primary treatment
process are shown in Table 3.2.   The national estimate of needs
developed in this study does  not  consider removal of  lead from storm-
water.   Should such removal become necessary,  treatment requirements
could be substantially increased.   However,  the use of source  controls
for toxic substances may be a more cost effective solution.
                                   6-12

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                                  PART II
                                REFERENCES
1.   Hydroscience, Inc.  "Simplified Mathematical Modeling of Water
     Quality," prepared for the Environmental Protection Agency.   March,
     1971.

2.   Mockus, V., et al.  "Section 4 Hydrology."  SCS National Engineering
     Handbook.  Soil Conservation Service, U.S. Department of Agriculture.
     Washington, D. C.  August, 1972.

3.   Metcalf & Eddy, Inc.  "Urban Stormwater Management and Technology,
     An Assessment."  EPA 670/2-74-040.  December, 1974.

4.   Betson, R.  "Urban Hydrology, A Systems Study in Knoxville,  Tennessee."
     Tennessee Valley Authority.  June, 1976.

5.   Heany, J. P., et al.  "Assessment of Combined Sewer Overflows,
     Urban Stormwater Discharges, and Non Sewered Urban Runoff."  University
     of Florida.  American Public Works Association.  Draft Report.
     December, 1975.

6.   Crim, R. L. and N. L. Lovelace.  "Auto-Qual Modeling System."  EPA-
     440/9-73-003.  March, 1973.

7.   Lovelace, N. L.  "Auto-qual Modeling System:  Supplement I,  Modification
     for Non-Point Source Loadings."  EPA-440/9-73-004.  September,
     1973.

8.   Tsivoglou, E. C. and J. R. Wallace.  "Characterization of Stream
     Reaeration Capacity."  EPA-R3-72-012.  October, 1972.

9.   Thomann, R. V.  "Systems Analysis and Water Quality Management."
     Environmental Science Services Division, Environmental Research and
     Applications, Inc.  New York.  1972.

10.  Brown and Caldwell, Inc., et al.  "Water Quality Control Plan San
     Francisco Bay Basin (2), Part II."  State Water Resources Control
     Board, Regional Water Quality Control Board, San Francisco Bay
     Region (2).  April, 1975.

11.  Black, Crow and Eidsness, Inc. and Jordan, Jones & Goulding, Inc.
     "Nonpoint Pollution Evaluation Atlanta Urban Area."  Savannah
     District Corps of Engineers, Metropolitan Atlanta Water Resources
     Study Group.  Contract No. DACW21-74-C-0107.  May, 1975.

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                    PART II -  REFERENCES - (continued)


12.  "Water Quality Monitoring Data for Georgia Streams."  Environmental
     Protection Division, Department of Natural Resources.  Atlanta,
     Georgia.  1974.

13.  Henningson, Durham & Richardson,  Inc.  "Combined Sewer Overflow
     Abatement Plan, Des Moines,  Iowa."  Environmental Protection Agency.
     EPA-R2-73-170.  April, 1974.

14.  "Iowa Water Quality Management Plan."  Water Quality Management
     Division Department of Environmental Quality.   State of Iowa.
     Draft.  July, 1975.

15.  "Water Quality Report."  Water Quality Management Division, Department
     of Environmental Quality.  State of Iowa.   April, 1975.

16.  "Quarterly Stream Monitoring Survey for the Raccoon and Des Moines
     Rivers."  University of Iowa, State Hygienic Laboratory.  State of
     Iowa.  April, 1976.  (unpublished)

17.  Colston, N. V., Jr.  "Characterization and Treatment of Urban Land
     Runoff."  EPA-670/2-74-096.   December, 1974.

18.  "Water Quality Management Plan Cape Fear River Basin, Sub Basin
     05."  Division of Environmental Management, Department of Natural
     and Economic Resources.  State of North Carolina.  Raleigh, North
     Carolina.  November, 1975.

19.  Texas Tech University, Water Resources Center.  "Variation of Urban
     Runoff with Duration and  Intensity of Storms."  Interim Report.
     September, 1970.

20.  Texas Tech University, Water Resources Center.  "Variation of Urban
     Runoff with Duration and  Intensity of Storms."  Project Completion
     Report.  August, 1971.

21.  Texas Tech University, Water Resources Center.  "Variation of Urban
     Runoff with Duration and  Intensity of Storms."  Phase II and III.
     August, 1973 through December, 1975.

22.  Brazos River Authority of Texas.   "Water Quality Management Plan
     for the Brazos Basin." Prepared for the Texas Water Quality Board.
     January, 1975.

23.  "A Comprehensive Plan for the Milwaukee River Watershed."  Planning
     Report No. 13.  Southeastern Wisconsin Regional Planning Commission.
     Waukesha, Wisconsin.  December, 1970.  (Vols.  I and II, 1139 pp.)

-------
                     PART II - REFERENCES -  (continued)


24.  Betz Environmental Engineers, Inc.  "Water Pollution Control Act of
     1972.  Regional Impacts.  Delaware River Basin."  Report No. NCWQ 75/28.
     National Commission on Water Quality.   September, 1975.

25.  "Annual Report, Fiscal 1975."  Research and Development Division.
     Philadelphia Water Department.

26.  "Water Quality Data June 1, 1965-March  24, 1973."  Environmental
     Quality Laboratories and Applied Research.  State of Oregon.  July,
     1975.

27-  Hayes, Seay, Mattern & Mattern.  "Engineering Investigation of
     Sewer Overflow Problem."  Federal Water Quality Administration,
     Department of Interior.  Contract No. 14-12-200(11024DMS).  May,
     1970.

28.  Hayes, Seay, Mattern & Mattern.  "Roanoke River Basin Comprehensive
     Water Resources Plan."  Virginia State-Water Control Board.  January,
     1975.

29.  "Water Quality Inventory (305(b) Report)."  Virginia State Water
     Control Board.  April, 1976.

30.  Metcalf & Eddy, Inc.  "1974 Joint State-EPA Needs Survey, State of
     California, Category III and Category V."  Report to California
     State Water Resources Control Board.  July, 1974.

31.  Metcalf & Eddy, Inc.  "1974 Joint State-EPA Needs Survey, State of
     California, Category VI."  Report to California State Water Resources
     Control Board.  July, 1974.

32.  Engineering-Science, Inc.  "Characterization and Treatment of
     Combined Sewer Overflows."  Federal Water Pollution Control Administration.
     November, 1967.

33.  AVCO Economic Systems Corporation.  "Storm Water Pollution from
     Urban Land Activity."  Federal Water Quality Administration, U.S.
     Department of the Interior.  1970.

34.  "Water Quality Management Plan Middle Arkansas River Basin."
     Department of Pollution Control.  State of Oklahoma.  January,
     1976.

35.  Tulsa City-County Health Department.  "Regional Environmental
     Pollution Study Inventory and Analysis:   Phase II."  Prepared for
     the Indian Nations Council of Governments.   September,  1973.

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                    PART II - REFERENCES - (continued)
36.  "Quality Criteria for Water."   U.S.  Environmental Protection
     Agency.   July,  1976.   (prepublication copy).

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              PART  III
NATIONAL NEEDS ASSESSMENT

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                                Section  7

                      NATIONAL ASSESSMENT METHODOLOGY
           The national assessment of needs  for control of  urban stormwater
 pollution must be based on accurate, readily available data which is
 directly related to the stormwater problem.   In the development of the
 resulting needs estimates, the data base must be current and well docu-
 mented;   the methodology must represent the technology available for  the
 control  and/or treatment of urban stormwater pollution, and any required
 assumptions must be reasonable.

           The Needs Estimation Model for Urban Runoff  (NEMUR)  was develop-
 ed specifically for the 1976 Needs Survey-Categories V and VI.   NEMUR
 utilizes a consistent methodology to calculate the  present and 1990
 capital  costs and operation and maintenance costs for  combined sewered
 (Category V) and separate storm sewered (Category VI)  control  and/or
 treatment needs for all urbanized areas.  The separate estimates are
 combined to provide a state-by-state and national needs estimate for  three
 receiving water quality criteria.

           Predictive methods, cost estimating equations and assumptions
 used in  NEMUR are based on an intensive search of the  literature related
 to urban stormwater runoff.  Where insufficient specific research could
 be found to adequately define a predictive  method;  information developed
 in the specific site analyses is utilized.

           For selected wet weather conditions, the  model determines the
 total pollutant loads discharged from wastewater treatment facilities,
 combined sewer overflows, and other stormwater discharges. The input data
 characterizes the individual drainage areas by population, land area, and
 receiving water factors, such as flow rate  and reaeration  capacity.  Using
 the calculated pollutant loadings, and receiving water factors, NEMUR
 then estimates the  level of treatment required to maintain water quality
 criteria within the urbanized area's major  receiving water.

           For the Aesthetics, Fish and Wildlife, and Recreation water
 quality  criteria, NEMUR computes the least  cost combination of pollutant
 control  options for combined sewer overflows and other stormwater dis-
 charges.  Discharges from wastewater treatment facilities  are  assumed to
 receive  adequate treatment.  Finally, NEMUR estimates  costs for the
 individual control  level found most effective in each  urbanized area  and
 totalizes the cost  estimates for all urbanized areas in each state.

           The program for NEMUR consists of numerous computations, which are
generalized in Figure 7.1, and five subprograms, each with  specific functions
as is shown in Figure 7.2.  The following sections of the  report provide a
concise and detailed definition and example  of the data base,  methodologies,
and assumptions utilized in NEMUR.
                                   7-1

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                                FIGURE 7.1
                                  NEMUR
                     GENERAL COMPUTATION SCHEMATIC
                                                 Sewered
                                               Population
                                  Density
          Number of
            Storms
                                  Percent
                              Imperviousness
                                                        Number of
                                                        Facilities
Other Wet
Weather Flow
Considerations
                                                Dry Weather
                                               Flow Conditions
Receiving Stream
 Characteristics
                                    Cost
                                   Curves
                                Categories
                              Capital  & 0 & M
                                  Costs
                                    7-2

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     FIGURE 7.2

        NEMUR
SUBPROGRAM FUNCTIONS
             MAIN reads and prints demographic,
             hydrological,  and control data

             CATS calculates population density,
             imperviousness, volume of runoff,
             curb miles, area growth and
             pollutant loading for the storm
             sewered area of each UA

             CATF calculates volume of runoff,
             pollutant loading and treatment
             rates for the combined sewered
             area of each UA and the total
             pollutant removal required to
             meet water quality criteria

             COST identifies the respective
             levels of treatment for stormwater
             runoff and combined sewer over-
             flows to best meet the total
             pollutant removal and calculates
             the capital and 0 & M costs for
             each UA

             POUT prints needs for each UA and
             sums by state and nation
        7-3

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 7.1  DEMOGRAPHIC DATA

           Regulations for the application of  the  NPDES Permit Program to
separate storm sewers were published in the Federal Register of March 18,
19761.  In these regulations, the term "separate storm sewer" is defined
as "a conveyance or system of conveyances  .  .  .  located in an urbanized
area and primarily operated for the purpose of collecting and conveying
storm water runoff"-  Based on this guideline, the geographical area which
requires control and/or treatment of urban stormwater runoff was assumed
to be the urbanized areas of the nation as defined by the U.S. Bureau of
Census.  The specific criteria for the delineation of an urbanized area
are aa follows:

            •  A central city of 50,000 inhabitants or more, or
               twin cities with a combined population of at least
               50,000, and with the smaller of the twin cities
               having a population of at least 15,000; and

            •  Surrounding closely settled territory, including
               the following:

               •   incorporated places of  2,500 inhabitants or more

               •   incorporated places with fewer  than 2,500
                   inhabitants, provided that  each has a closely
                   settled area of 100 housing units or more

               •   small parcels of land normally  less than one
                   square mile in area having  a population density
                   of 1,000 inhabitants or more per square mile

               •   other similar small areas in unincorporated
                   territory with lower population.density
                   provided that they serve to eliminate enclaves,
                   or to close indentations in the urbanized areas
                   of one mile or less across  the  open end, or to
                   line outlying enumeration districts of qualify-
                   ing density that are not more than 1 1/2 miles
                   from the main body of the urbanized area.

           As of January 1, 1976, there were 279 urbanized areas defined in
the nation.  Thirty-five of the urbanized  areas encompassed area in two
states and three urbanized areas encompassed area  in three states.  By
subdividing the urbanized areas encompassing more  than one state, a total
of 320 areas were defined for estimation of Category V and VI needs.
Category V needs for areas served by combined  sewers but outside of urban-
ized areas were included on a state-by-state basis.

           The 1970 census population and  land area for each of the 320
                                    7-4

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areas were obtained from the U.S. Bureau of Census.  The population and
area of each urbanized area served by combined sewers were developed by the
American Public Works Association (APWA) and the University of Florida .
Estimated state and standard metropolitan statistical area populations for
1990 were obtained from the U.S. Water Resources Council's OBERS project-
ions  and state populations were modified to be consistent with the 1990
ceiling populations utilized in the 1974 Needs Survey4.

           In the 1967 inventory of local authorities with combined sewer
systems, conducted by APWA5 , the number of combined sewer overflows and
the area served by combined sewer overflows was reported by state.  This
information was utilized to estimate the average drainage area to each
combined sewer overflow structure on a state-by-state basis.

           The cost indices used in the 1976 Needs Survey are the Environ-
mental Protection Agency Sewage Treatment Plant Cost Index for January
1976 of 255.7 for treatment plants and 266.5 for sewers.  These indices have
a 1957-1959 base of 100.  City multipliers are determined by EPA for twenty-
five index cities.  Areas of influence were assigned to each of the index
cities based on geographical proximity and other factors.  Cost indices for
specific urbanized areas are listed in Appendix B.

7.2   HYDROLOGIC DATA

           The amount of rainfall each year and the distribution of rain
throughout the year are factors which cause urban stormwater runoff.  Data
defining the average annual rainfall and the average number of days per
year with measurable precipitation for each urbanized area were obtained
from the National Oceanic and Atmospheric Administration6 .  This informa-
tion is required to determine the quantity and quality of urban stormwater
runoff for a specific area.

           Since this rainfall data alone does not identify the impacts of
the pollutant loads upon receiving waters, a detailed description of the
receiving waters for each urbanized area and complex dynamic water quality
modeling is required to specifically identify the level of urban stormwater
control needed to prevent water quality violations.  This level of detail
is beyond the scope of this project and, thus, readily available informa-
tion was utilized to describe the receiving waters of each urbanized area.
First, the receiving water draining the largest percentage of each urban-
ized area was identified from U.S. Geological Survey topographical maps.
This percentage was estimated and a verbal description of the receiving
water was selected from Table 7.1 based on information contained on the
topographical maps.  Reaeration rates were assigned to the verbal descrip-
tions based on the literature7r 8.

           The average flow for the lowest three months of the year for
each receiving water was then estimated.  When available, five years of
USGS streamflow records9 were summarized to obtain this flow value.  Where
                                    7-5

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               TABLE 7.1




VERBAL DESCRIPTION OF RECEIVING WATERS
Data
Code
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Receiving Water Description
Creeks and shallow streams
Upstream feeders
Intermediate channels
Main drainage rivers
Large rivers
Impounded rivers
Small ponds, backwaters
Large lakes
Shallow, high tidal velocity
estuary or bay
Shallow, low tidal velocity
estuary or bay
Medium depth, high tidal velocity
estuary or bay
Medium depth, low tidal velocity
estuary or bay
Deep, low tidal velocity estuary
or bay
Deep, high tidal velocity estuary
or bay
Open ocean or beach
Estimated Reaeration
Rate - K2
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there were no nearby gaging stations, where several streams flowed to-
gether, or other factors made direct calculation of flow values imprac-
tical, statistical flow summaries, water quality reports, and other data
were used to aid in estimation of the annual three month low flow.

7.3   MODEL DESCRIPTION

           By utilizing the demographic and hydrologic data described
above, which are listed in Appendix B, the receiving water quality method-
ology developed in Section 6, and the control and/or treatment cost equa-
tions developed in Section 3, a computer-assisted mathematical model was
developed to estimate the national needs for stormwater control.

           The Needs Estimation Model for Urban Runoff (NEMUR) utilizes
a consistent methodology to calculate the present and 1990 capital and
operation and maintenance costs for combined sewered (Category V) and
separate storm sewered (Category VI) control and/or treatment needs for
each urbanized area in the nation.  The needs estimates are then summed to
provide a state-by-state and national estimate.  The program listing is
shown in Appendix C.  The specific methodologies utilized in NEMUR are
developed in the following sections through the use of an example urban-
ized area.

7.4   EXAMPLE URBANIZED AREA DESCRIPTION

           A simplified map of a hypothetical urbanized area to be used
throughout the specific methodology development is shown in Figure 7.2.
The input data required for the example are shown in Table 7.2.  At each
step of the methodology development, the method is discussed and document-
ed and example calculations are shown.  Abbreviations are the same as used
in NEMUR to allow cross reference, are identified after each calculation to
assure easy comprehension, and are also defined in the List of Abbreviations.

7.5   RUNOFF QUANTITY CALCULATIONS

           The quantity of runoff requiring control is determined from a
design storm runoff coefficient approach similar to the methodology used
in STORM 10.  Although this approach neglects the variable volume and
spacing of rainstorms, the effects of storm size on runoff coefficients
and other specific phenomena, use of design storm and an average runoff
coefficient is a simplified technique which has been widely used.  Runoff
volumes are computed separately for the combined sewered and the storm
sewered portions of each urbanized area.

           Population densities for the combined and storm sewered areas
are computed directly from the imput data as follows:

           LAND   =  UA  -  CSA                                      (7.1)
           POP    =  UAP -  CSAP                                     (7.2)
           PDSS   =  POP/LAND                                        (7.3)
           PDCS   =  CSAP/CSA                                        (7.4)
                                    7-7

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KEY
    SMSA  BOUNDARY

    URBANIZED AREA  BOUNDARY

    STORM SEWERED AREA

    COMBINED SEWERED AREA

    DRAINAGE DIVIDE

    USGS  GAGE

    STATE  BOUNDARY
                        FIGURE  7.3
 XAMPLE URBAN IZED AREA SCHEMATIC
                               7-J

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             TABLE  7.2
INPUT DATA FOR EXAMPLE URBANIZED AREA
Input Data Description
1990 State Populations
OBERS (St^QBERs)
EPA Ceiling (State^^)
Combined Sewer Area (acres) (CSA)
Combined Sewer Population (CSAP)
Average Drainage Area per
Combined Sewer Overflow (acres) (ASCO)
Urbanized Area
Populations (UAP)
Areas (sq. mi.) (UA)
SMSA Populations
1970 (SMSA7Q)
1990 (SMSAgg)
Average Days with Rain Per Year (ADR)
Average Yearly Rainfall (inches) (ARF)
Receiving Stream Classification
EPA Cost Index
Example Urbanized
Area Values
AREA 1
5,438,000
5,488,000
14,200
60,000
415
75,940
30.7
87,205
89,300
95
34.18
4
1.0
AREA 2
2,281,000
2,509,000
200
500
381
1,283
1.2
87,205
89 , 300
95
34.18
4
1.0
                 7-9

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where:

           UA     =  area of urbanized area in acres

           CSA    =  combined sewered area in acres

           LAND   =  separate storm sewered area in acres

           UAP    =  1970 population of urbanized area

           CSAP   -  1970 population in urbanized area served
                     by combined sewers

           POP    =  1970 population of storm sewered area

           PDSS   =  population density of storm sewered area in
                     people/acre

           PDCS   =  population density of combined sewered area
                     in people/acre.

           Relationships between development parameters, such as impervi-
ousness and curb lengths, and demographic parameters, such as population
density,have been developed statistically by several investigators. Graham,
et  al. 1 *  developed equations predicting imperviousness and specific  curb
length based on the population densities of 32 census tracts in the Washington,
D.C. area.  Stankowski  2 developed similar equations based on 536 New Jersey
municipalities.  Stankowski's equation, which is used to estimate impervious-
ness in NEMUR, is;
                          (0.573 - 0.0391 log  PDSS)
           SSI =9.6 PDSS                    °                        (7.5)

where:

           SSI = Percent imperviousness in storm sewered area.

           The runoff coefficient,  ROCS,  for the storm sewered area is cal-
culated by weighing the pervious and impervious portions of the urbanized
area and assuming a runoff coefficient for each.   The equation is:

           ROCS =0.15  (1-SSI)  +0.90 SSI

or:             = 0.15  + 0.75 SSI                                     (7.6)

where SSI is  the imperviousness as  a fraction and the coefficients 0.15 and
0.90 are assumed runoff coefficients from pervious and impervious areas,
respectively.   This parameter allows the  direct estimation of runoff volumes
from rainfall  volumes.

           The design storm criteria selected are:  the 80 percentile storm
for all stormwater facilities; the 90 percentile storm for treatment  of
                                    7-10

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combined sewer overflow to meet the aesthetics and fish and wildlife criteria;
and the 98 percentile storm for treatment of combined sewer overflow to meet
the recreation criteria.  Thus, the design storm is defined as that depth of
rainfall at which the cummulative frequency of observed rainfall depths is
80, 90, or 98 percent, dependent upon the type of urban runoff and receiving
water quality to be achieved.  These values were computed for each urbanized
area as follows:

           DS  = K  MRF                                              (7.7)
             xx
where:
           DS  »  design rainfall depth cased on x percentile storm

           K   -  a factor which converts the MRF to 80, 90, or 98
            X     percentile storm depth (K   » 1.61; KQn - 2.30; and
                  "   - 3.91)              aU          yU
           MRF =  mean  rainfall depth per storm in inches, which is
                  estimated by:

                  MRF = ARF/MNS                                      (7.8)

and:              MNS - 1.0026 ADR-2.58                              (7.9)

where:

           ARF »  average annual rainfall in inches

           MNS -  mean number of rainstorms each year, and

           ADR »  average annual days of measurable rain

           By utilizing the design storm size and the runoff coefficient,
the design volume of runoff can be estimated as:

           DVSS -  DS (ROCS)(LAND)(.027158)                          (7.10)

where:

           DVSS =  design runoff volume from the storm sewered area in
                   million gallons

           Similar calculations are used to calculate the design runoff
volume from the combined sewered area.  Example calculations are shown in
Table 7.3.

7.6   RUNOFF QUALITY CALCULATIONS

           The American Public Works Association and the University of
Florida Developed a pollutant loading prediction methodology based on
precipitation and population density.  Measured mass pollutant discharges
from various combined and storm sewered catchment areas in the United States
and Canada were related functionally to precipitation and population functions.
The resultant equations allow the prediction of average annual pollutant


                                     7-11

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                                 TABLE  7.3


                    EXAMPLE RUNOFF QUANTITY CALCULATIONS
CATEGORY VI
Land Area Containing Storm Sewers (LAND)
     LAND = UA-CSA
          = 30.7 (640)- 14,200 = 5,448 acres
Population in Storm Sewer Area (POP)
     POP  = UAP - CSAP
          = 75,940 - 60,000 = 15,940
Population Density in Storm Sewered Area  (PDSS)
     PDSS = POP/LAND
          = 15,940/5,448 = 2.93 People/Acre
Percent Imperviousness in Storm Sewered Area  (SSI)

     SSI  = 9.6 PDSS(°-573- 0.0391 LOG^PDSS)
          - 9.6(2.93) (0.373 - 0.0391 LOG102.93)=
Runoff Coefficient in Storm Sewered Area  (ROCS)
     ROCS = 0.75 (SSI/100) + 0.15
          = 0.75 (17.43/100) + 0.15 = 0.28
Mean Number of Storms per year (MNS)
     MNS = 1.0026 (ADR) - 2.58
         = 1.0026 ( 95) - 2.58 = 92.67
Mean Annual Rainfall (MRF)
     MRF = ARF/MNS
         = 34.18/92.67 = 0.369 in.
Design Storm (DS)
            1.61
            1.61  (0.369)  = 0.59  in.
DSgQ = 1.61  (MRF)
Design Volume of Storm Sewer Treatment
     DVSS = DS (LAND) ROCS (0.027158 MG/ACRE-IN)
          = 0.59 (5,448)  0.28 (0.027158) = 24.44 MG
                                    7-12

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                            TABLE 7.3 (Cont'd)

                    EXAMPLE RUNOFF QUANTITY CALCULATIONS
CATEGORY V
Population Density of Combined Sewered Area (PDCS)
    PDCS = CSAP/CSA
         = 60,000/14,200 = 4.23 people/acre
Percent Imperviousness of Combined Sewered Area (CSI)

    CSI  = 9.6 PDCS(0-573 - °'0391 LOG10 PDCS)
Runoff Coefficient of Combined Sewered Area (ROC)
    ROC  =0.15+0.75 (CSI/100)
         = 0.15 + 0.75 (21.17/100) = 0.31
Design Volume of Combined Sewer Treatment (DVCS)
    DVCS = DS (ROC) CSA (0.027158 MG/ACRE-IN)
         = 0.59(0.31) ( 14,200) 0.027158 = 70.53 MG
                                      7-13

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 loading  rates  for various  pollutants  such  as  BOD,.,  suspended
 solids,  volatile solids, phosphate  and  nitrogen.  The  authors  state,
 "Unquestionable, the  data  base  for  estimating pollutant loads  is very weak
 and the  resulting estimating equations, supported by such a weak  foundation
 should be used with extreme caution."  Therefore, the pollutant  loadings
 developed must be considered as approximate estimates of a highly variable
 phenomena.  However,  the following equations provide the best  uniform means
 available for estimating pollutant loadings for the urbanized  areas.   The
 predictive equations  are:

                  rcn =  (1.73 DS(0.142 + 0.218 PDCS°'54)              (7.11)
                 »Cb°                                   + 1.9 DS) CSA

           POL0_ „„  =  (39.2 DS(0.142 + 0.218 PDCS°'54)              (7.12)
               SS)CSO                                    + 25.94  DS) CSA

           POLB__ COA =  (0.420 DS(0.142 + 0.218 PDSS°'54)             (7.13)
               BOD»SSA                                  +0.462  DS) LAND

           POL        =  (9.52 DS(0.142 + 0.218 PDSS°'54)              (7.14)
               bb'bbA                                    + 25.94  DS) LAND

 where:
            POL.  . -  the pollutant  loading of  the ith  constitutent
                '^     from  the jth area  in pounds per storm event

           BOD    =   BOD,,  in pounds per storm event

           SS     =   suspended solids in pounds per storm event

           CSO    =   combined sewered area

           SSA    =   separate sewered area

           DS     =   design storm size in inches

           PDCS   =   population density of the combined sewered  area
                      in people/acre

           PDSS   =   population density of the storm sewered area
                      in people/acre

           CSA    =   area  served by combined sewers in acres,  and

           LAND   =   area  served by separate sewers in acres

 Example  calculations are shown in Table 7.4.

 7.7   DRY WEATHER FLOW QUANTITY AND QUALITY CALCULATIONS

           The pollutant loadings from dry weather point sources, such as
municipal and industrial wastewater treatment plants, are assumed to  receive
                                     7-14

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                               TABLE  7.4





                   EXAMPLE RUNOFF QUALITY CALCULATIONS
BOD Loading in Combined Sewered Area (POLBQD CSQ)







   POLBOD CSQ = [1.73 DS (0.142 + 0.218 PDCS0'54) + 1.9 DS] CSA




              = [1. 73(0. 59)(0.142+(0. 218)4. 23°'54) + (1.9)0.59] 14,200




              =  24,860 pounds /storm event







Suspended Solids Loadings in Combined Sewerad Area (POLCO r-crJ
                                                       OO y ClOU





   POLSS cso  = [39.2 DS (0.142 + 0.218 PDCS0'54) + 25.94 DS] CSA




              = [39. 2(0. 59) (0.142 + (0.218) 4.230'54) + (25.94) 0.59] 14,200




              =  419,950 pounds/storm event
BOD Loading in Storm Sewered Area (POLBOD




   POLBOD,SSA =[ 0.42 DS (0.142 + 0.218 PDSS0'54) + 0.462 DS ] LAND



              =  [ 0.42(0. 59) [0.142 + (0. 218)2. 93°'54) + (0.462)0.59] 5,448



              = 2,200 pounds /storm event






Suspended Solids Loading in Storm Sewered Area (POLgg ggA)




   POLSS,SSA  =  t9'52 DS (0-U2 + 0.218 PDSS0'54) + 25.94 DS] LAND



              =  [9.52 (0.59) (0.142+(0.218) 2.930'54) + (25.94)0.59] 5,448



              = 99,645 pounds /storm event
                                   7-15

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secondary treatment and that each population equivalent contributes:

           •   125 gallons of wastewater per day,  and

           •   0.0255 pounds of BOD  per day after treatment.

           Therefore, the predictive equations developed for estimating the
quantity and quality of dry weather wastewater flows are:

           DWF    =  0.00019 UAP                                     (7.15)

           DWB    =  0.0255 UAP                                      (7.16)

where:

           DWF    =  dry weather flow in cfs

           DWB    =  dry weather BOD- in pounds per day

           UAP    =  urbanized area population.

Example calculations are shown in Table 7.5.

7.8   RECEIVING WATER CONSIDERATIONS

           A method for determining the required level of BOD  removal to
maintain the fish and wildlife criteria was developed in Section 6.  The
required removal of BOD  due to combined sewer overflows and stormwater run-
off was shown to be directly related to the total  6005 loading discharged to
the stream, and inversely related to the stream flow downstream of the urbanized
area and the reaeration rate of the receiving water.  The predictive parameter
used to estimate the required removal rate is:

           RF     =  BOD
and:
           "'DS
where:
           BOD    = ((POL       + POL      )/DSD + DWB) PSTR         (7.18)
                         BOD,CSO    BOD,SSA

           Q      =  (3.05 (DVCS + DVSS)  DWF)  PSTR + STR             (7.19)
           RF     =  predictive water quality parameter

           POL    =  as previously defined

           BOD    =  total BOD  loading from an urbanized area in
                     pounds/day
                                   7-16

-------
                               TABLE 7.5

                        EXAMPLE DRY WEATHER FLOW
                    QUANTITY AND QUALITY CALCULATIONS
Dry Weather Flow in Urbanized Area (DWF)
    DWF = 0.00019 UAP
        = 0.00019 (75,940) = 14.4 cfs
BOD Dry Weather Loading in Urbanized Area (DWB)
    DWB = 0.0255 UAP
        = 0.0255 (75,940) = 1,936 pounds/day
                                   7-17

-------
            Q      =  total receiving water flow downstream from an
                      urbanized area in cfs

            K2     =  reaeration coefficient - base e at 20°C in Day l

            DSD    =  design storm duration in days, assumed to be
                      0.5 days

            PSTR   =  fraction of urbanized area drained by selected
                      receiving water

            Dl.B    =  dry weather wastewater discharge in cfs

            SIR    =  receiving water flow in cfs.

            The required removal rate is then estimated by:

            RF  < 69     RR = 0                                       (7.20)

            69   < RF < 225  RR= 184.7 log1()RF - 339.6

            RF  > 225    RR = 95

where:

            RR     =  total required percentage of BOD,, removal
                      due to stormwater runoff

            Where two or more urbanized areas are located in close proximity
on the same receiving water, such as urbanized areas encompassing more than
one state but which were delineated by state for purposes of the 1976 Needs
Survey, the available receiving water flow was apportioned to each urbanized
area directly proportional to the total pollutant loads.  Example calcula-
tions are shown in Table 7.6.

7.9    LEVEL OF TREATMENT SELECTION

            Three water quality criteria and five levels of control and/or
treatment for combined sewer overflows and stormwater discharges were iden-
tified in Section 3.  After review of the available literature on the
effectiveness of stormwater treatment systems, the following assumptions
were made relating required treatment and/or control levels to water quality
criteria:

            1.  Aesthetic Criteria:  Best Management Practices (assumed
                to consist of sweeping all streets' once per week,
                construction practices, and provision of detention
                basins in newly developing areas) would be applied
                to all urbanized areas as a minimum control level
                for storm sewered areas.  Swirl Concentrators with
                                     7-18

-------
                               TABLE 7.6
                  EXAMPLE RECEIVING WATER CONSIDERATIONS
Percent of Stream Flow Assigned to STATE1


     PSFSTATE1 = BOD5,STATE1(PSTRSTATE2)/[BOD5,STATE1(PSTRSTATE1)

                 +BOD5 >STATE2(PSTRSTATE2) ^
       where :

        BOD5,STATE1 = (POLBOD,CSO,STATE1+P°LBOD,SSA,STATE1)/DSD + DWBSTATEl

                    = (24,860 + 2,200)/.5 + 1,936

        BOD5,STATE2 = 1,278.7

     PSFSTATE1 = . 8(56, 055) / [56, 055 (.8)+!, 278. 7(1.0)]

               = 0.972%

Stream Flow Attributed to STATE1 (STRsTATEi)


     STRSTATE1 = PSFSTATE1

               = 0.972 (1,250)

               = 1,215 cfs

Removal Factor (RF)

     RF = BOD5jSTATE1/[QDSjSTATE1(K2)]

      where:

        Downstream Flow for STATE1 (QDg STATE1)


        QDS,STATE1= [1'55 (DVSS+DVCS)/DSD+DWFSTATE1]PSTRSTATE1+STRSTATE1
                   = [1.55 (24. 44+70. 53)/.5+14. 4]. 8+1, 215
                   = 1,462 cfs

        Reaeration Coefficient (K2)
        K2 = 0.32 I/day

     RF = 56,055/[1,462(.32)] - 119.8

Since 69 < RF < 225

Percent Pollutant Removal Required (RR)
     RR = [184.7 LOG   (RF) - 339.6J/100
        = [184.7 LOG   (105.74) - 339.6]/100 = 0.443
                                    7-19

-------
                fine screening of the concentrate were sized
                for all combined sewered areas as a minimum
                control level.  These treatment,and/or control
                levels should provide significant removals of
                oil, scum, large settleable solids, and other
                unaesthetic debris.

            2.  Fish and Wildlife Criteria:  The total percentage
                of BOD  removal required to meet this criteria was
                determined earlier.   However, several combinations
                of Categories V and VI treatment could be used to
                meet that total removal.  Based on a cost-effective-
                ness analysis and noting that concentrations of
                pollutants from combined sewer overflows are much
                higher than from storm sewer discharges, higher
                combinations of treatment and/or control levels
                are progressively evaluated for each urbanized
                area to obtain the required removal of pollutants
                at the least cost.  The progression of treatment
                combinations is shown in Table 7.7.  After the
                BOD  criteria has been met, the concentration of
                suspended solids is calculated and checked against
                the maximum stream standard of 400 mg/1.  If the
                suspended solids concentration is greater than
                400 mg/1, the treatment combination is increased
                until both the dissolved oxygen and suspended solids
                criteria are met.

            3.  Recreation Criteria:  Disinfection to control pathogenic
                bacteria, is added to the treatment levels assigned for
                the Fish and Wildlife Criteria.  This estimate should
                be evaluated with care since chlorination is the
                selected method of disinfection, and in some cases
                dechlorination may be required.  Example calculations
                are shown on Table 7.8.

7.10   OTHER REQUIRED CALCULATIONS

            Several calculations relating to Best Management Practices are
required to obtain the costs and effectiveness of these practices.  First,
the growth of land area in each urbanized area between the present and 1990
must be defined.  However, projections of neither the 1990 population nor
area of urbanized areas was readily available.  Therefore, the OBERS pro-
jections for standard metropolitan statistical areas developed by the U.S.
Water Resources Council3 were used with several assumptions to define the
1990 area of each urbanized area.  First, it was assumed that no new
combined sewers would be constructed.  Thus, the present and 1990 needs for
Category V will be the same and all growth is assumed to be served by storm
sewers.   Next, the population density of the storm sewered area is assumed
                                    7-20

-------
                  TABLE 7.7

SUCCESSIVE TREATMENT AND/OR CONTROL COMBINATIONS
     BASED ON COST EFFECTIVENESS EVALUATION
Treatment and/or
Control
Combination
1
2
3
4
5
6
7
8
9
10
11
12
Combined Sewer
Treatment Level
(Predicted BOD Removal)
Screening -
Swirl Concentration (0-25)
Sedimentation (25-40)
Air Floatation (40-60)
Flocculation -
Sedimentation (60-80)
Air Floatation (40-60)
Flocculation -
Sedimentation (60-80)
Flocculation -
Sedimentation (60-80)
Filtration (80-95)
Filtration (80-95)
Filtration (80-95)
Filtration (80-95)
Filtration (80-95)
Storm Sewer
Control and/or Treatment
Level
(Predicted BOD Removal]
BMP (0-25)
BMP (0-25)
BMP (0-25)
BMP (0-25)
Sedimentation (25-40)
Sedimentation (25-40)
Air Floatation (40-60]
BMP (0-25)
Sedimentation (25-40)
Air Floatation (40-60]
Flocculation -
Sedimentation (60-80)
Filtration (80-95)
                     7-21

-------
                                TABLE  7.8


                  EXAMPLE LEVEL OF TREATMENT CALCULATIONS
For LEVELcgo = 1 and LEVELgSA = 1

Percent BOD Removed (PR1)

PR1 =  [0.25(POLBODjCSO)+PPRS(POLBOD)SSA)]/(POLBOD5CSo+POLBOD}SSA)

    =  [0.25 (24,860)+.22(2,200)]/(24,860+2,200) = 0.247

Since PR1 < RR you must proceed to the next treatment level  combination
For LEVELCSO = 2 and LEVEL    = 1
PR1 =  [(0.4)POLBOD)CSO+ (PPRS)

    =  [0.4(24,860) +  .22(2,200)]/(24,860 + 2,200) =  .385

Since PR < RR go to next treatment level combination
For LEVELCSO = 3 and LEVELgSA = 1

PR1 =  [0.6(POLBOD>CSO) + PPRS(POLBOD)SSA)]/(POLBOD>CSO+POLBOD>SSA)

    =  [0.6(24,860) + .22 (2,200)]/(24,860 + 2,200)
PR1 =  .57

Since PR1 > RR check to see if the suspended solids concentration is  less
than 400 mg/1

Suspended Solids Concentration (PR2)

PR2 =  [(0.3(POLSS>CSO)  +U-PPRS) POLSSjSSA)/2(DVCS+DVSS)] 0.12

    =  [(0.3(419,950)+(1-.22)99,645)/2(70.53 + 24.44)] 0.12
    = 128 mg/1

Since PR2 < 400 mg/1 LEVELcsO =  3 and LEVELSSA = 1 are the treatment  levels
required to maintain the desired water quality criteria.
                                   7-22

-------
to remain constant.  This means that the area will grow in the same pro-
portion as the population.  The 1990 population and land area of each
urbanized area is estimated by:

                ,  =  UAP (SMSA90/SMSA70)(StateEpA/StateOBERS)        (7


               os  -  POP90-CSAP                                    (7.22)

            LAND9Q -  POPgg/PDSS                                      (7.23)


            LANDGROWTH = LAND_Q - LAND                                (7.24)
                             OD

where:

            POP__  =  1990 estimated population of each urbanized area

            UAP    =  1970 urbanized area population

            SMSA7n =  1970 census population of standard metropolitan
                      statistical area containing the urbanized area

            SMSA   =  OBERS projected 1990 population for each SMSA


             tat8BERS =  OBERS projected 1990 population for the state
                         containing the urbanized area


             tateEPA  =  EPA 1990 ceiling population for the state

            POP
               SS  =  1990 urbanized area population served by storm
                      sewers

            CSAP   =  1970 population in urbanized area served by
                      combined sewers

            PDSS   =  population density of storm sewered area in
                      people/acre


                90 =  1990 urbanized area served by storm sewers in acres

            LAND   =  1970 urbanized area served by storm sewers in
                      acres, and

            LAND
                GROWTH =  growth of urbanized area in acres.

            Another factor related to Best Management Practices,which is at
best poorly defined in the literature,is the pollutant removal effectiveness
                                     7-23

-------
of street sweeping.   Some research1 3'ai* jl 5'ie'a 7 has been conducted on the
effectiveness of sweepers at removing pollutants from the street surfaces,
but no information was found defining the portion of urban runoff pollutants
which are washed from the street surface and the portion which are washed
from other impervious areas (i.e.,  rooftops, parking lots, etc.) and
pervious areas.  Therefore, a methodology was developed based on the
assumption that the concentration of pollutants from street surfaces prior
to sweeping is twice that of other runoff.

          Vacuum type street sweepers are assumed to be 95 percent effic-
ient at removing pollutants from the street surface with two passes and
considering the random occurrence of rainfall,  the net annual efficiency
of a once per seven day sweeping frequency was assumed to be 55 percent.
These assumptions were taken from a study of the Washington, D.C. street
sweeping program and computer analysis of rainfall patterns prepared by the
Catholic University of America13.  In each urbanized area, the acreage of
street surfaces was estimated based upon a statistical relationship between
curb miles and population density developed by Graham, et. al   and assuming
an average street width of 34 feet.  The street surface area was compared
with the total impervious area and with the pervious area to develop a
percentage of total runoff originating on street surfaces.  Then the total
pollutant removal efficiency of the assumed street sweeping program was
calculated by:

          PPRS    =  (0.55)(2)PRDS/(1-PRDS) + 2(PROS)                (7.25)

or:

          PPRS    =  1.10 PRDS/1+PRDS

where:

          PPRS    =  percent pollutant removal from streets,and

          PRDS    =  percent of urbanized area runoff from street
                     surfaces.

          Again, this procedure assumes that the concentration of stormwater
runoff from street surfaces is twice that of other urban stormwater runoff,
and that the street sweeping program assumed averages an annual pollutant
removal of 55 percent from the street surfaces.  Example calculations are
shown on Table 7.9.

7.11 COST CALCULATIONS

          Cost estimates for storage and treatment of combined  sewer overflows
are based on providing storage for the design storm  runoff  at each overflow
point and pumping this stored volume at a reduced flow rate  to  one of a
number of consolidated treatment plants throughout the urbanized area where
the stored flows are treated  and discharged.   The number of storage basins
                                   7-24

-------
                                 TABLE 7.9

               EXAMPLE BEST MANAGEMENT PRACTICES CALCULATIONS
Percent Runoff From Storm Sewered Impervious Area (ROCI)
     ROCI =0.9 (SSI/100)/ROCS
          = 0.9 (17.43/100)70.28 = 0.56

Impervious Land Area in Storm Sewered Area (IMAR)
     IMAR = LAND (SSI/100)
          = 5448 (17.43/100) = 950 acres

Curb Miles in Storm Sewered Area
                                     PDSS
     CM   = LAND [0.0782-0.0668(0.839    )]
                                       2 93
          = 5448 [0.0782 - 0.0668(0.839 '  )]
     CM   = 208.45 mi.

Street Miles in Storm Sewered Area
     SM   = CM/2
          = 208.45/2 = 104.22 mi.

Percent Impervious Area Due to Streets (SAR)
     SAR  = [SM(5280)34]/[43560(IMAR)]
          = [104.22(5280)34]/[43560(950)1
          = 0.452

Percent of Runoff Due to Streets (PROS)
     PROS = SAR  (ROCI)
          = 0.452  (0.56)= 0.25

Percent Pollutants Removed by Sweeping (PPRS)
     PPRS = [0.55(2)pRDS] / [1+PEDS ]
          = [0.55 (2)0.25 ]/[140.25]
          = 0.22
                                      7-25

-------
for combined sewer overflow treatment is based on the average drainage
area per combined sewer overflow.  These values were published state-
by-state in the APWA 1967 Survey 5 .   Pumping rates from storage to
consolidated treatment plants are calculated such that the volume of
storage basins will be treated in the average time between storms.  The
equations for these calculations are:
where:
NSP

STCS

TRCS



NSP


CSA

AS CO


DVCS


STCS


MNS

TRCS
                         CSA/ASCO

                         DVCS/NSP

                         STCS/(365/MNS)
(7.26)

(7.27)

(7.28)
                         number of combined sewer storage facil-
                         ities rounded up to avoid fractional plants

                         area served by combined sewers in acres, and

                         average area served by each combined sewer
                         overflow in acres

                         volume of runoff from combined sewered area in
                         million gallons

                         storage volume for each combined sewer overflow
                         storage facility in million gallons

                         mean number of rainstorms each year, and

                         discharge rate from storage for each combined
                         sewer overflow storage facility in mgd.
The number and flowrates of consolidated treatment plants in each urbanized
area is estimated by the following equations:
          NTP

          CTR
               (CSA/1000)0'435

               DVCS/NTP(365/MNS)
(7.29)

(7.30)
where:
          NTP
          CTR
               number  of  consolidated  combined sewer overflow
               treatment  plants  in each urbanized area,  rounded
               up such that  fractional plants  do not exist.

               consolidated  treatment  rate  in  mgd.
                                    7-26

-------
          The leneth of interceptors reauired in each urbanized area to
transport flows from each storaee facility to consolidated treatment plants
is estimated based on the following equation developed from analysis of
Chicago, Illinois data:

          IL     =     2.8876 CSA                               (7.31)

where:

          IL     =     Interceptor Length in feet

          CSA    =     area served by combined sewers in acres

The equation to estimate the cost of these interceptors was developed
based on information in the "Guidelines for 1976 Update of Needs for
Municipal Wastewater Facilities"18.  The equation is:

          1C     =     28.0 TRCS °'30                           (7.32)

where:

          1C     =     Interceptor Cost in dollars per linear foot
                       including all appurtenances

          TRCS   =     Discharge rate from each combined sewer overflow
                       storage facility in mgd.

          Capital and operation and maintenance costs for both storage
facilities and consolidated treatment plants were determined based on the
cost equations presented in Section 3.
                                    7-27

-------
          Due to a lack of other nationwide information, storage volumes
and treatment rates for storm sewer discharges are based on treating run-
off from the average combined sewer overflow drainage area at each treatment
plant.  Treatment rates are calculated such that the volume of storage
basins will be treated in the average time between storms.  The equations
for these calculations are:

          NSSTP     =     LAND/ASCO                              (7.33)

where:

          NSSTP     =     number of storm sewer discharge
                          treatment plants rounded up to avoid
                          fractional plants

          LAND      =     area served by storm sewers in acres

          ASCO      =     average area served by each combined
                          sewer overflow in acres

and:      SPTP      =     DVSS/NSSTP                            (7.34)

          TRSS      =     SPTP/(365/MNS)                        (7.35)

where:

          DVSS      =     volume of runoff from storm sewered
                          area in million gallons

          SPTP      =     storage volume for each storm sewer
                          discharge treatment plant in million
                          gallons

          MNS       =     mean number of rainstorms each year, and

          TRSS      =     treatment rate for each storm sewer dis-
                          charge treatment plant in mgd.

          Example calculations are shown in Table 7.10.  No costs for
collection or interceptor sewers to transport storm sewer discharges to
treatment plant sites are included since these costs are not directly
attributable to water quality control and should be highly variable
between urbanized areas.   When required, collection costs are dependent on
the existing collection system,  the availability of land, soil conditions,
land slope,  and many other localized factors.
                                    7-28

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                                TABLE 7.10


                         EXAMPLE COST CALCULATIONS
CATEGORY V
     Number of Consolidated Combined Sewer Overflow Treatment Plants
     (NTP)
           NTP =  (CSA/1000)   '    .
	=  (14.200/1000) "•*•" = 4	
     Consolidated Treatment Rate  (CTR)
           CTR = DVCS/NTP(365/MNS)
               = 70.53/4(365/92.67)=4.48 mgd

     Number of Combined Sewer Storage Facilities  (NSP)
           NSP =  CSA/ASCO
               = 14,200/415 = 35

     Storage per Combined Sewer Storage Facility  (STCS)
           STCS= DVCS/NSP
               = 70.53/35 = 2.02 MG

     Discharge Rate from Combined Sewer Storage Facility  (TRCS)
           TRCS= STCS/(365/MNS)
               = 2.02/(365/92.67) = 0.51 mgd

     Interceptor Length (IL)
           IL  = 2.8875 (CSA)
               = 2.8875 (14,200) = 41,002 feet

 CATEGORY  VI	

     Number of Storm  Sewer  Treatment Plants  (NSSTP)
           NSSTP  = LAND/ASCO
                  = 5,448/415  =  14

     Storage per  Storm Sewer  Treatment Plant  (SPTP)
           SPTP   = DVSS/NSSTP
                  = 24.44/14 = 1.75 MG

     Treatment Rate of Storm  Sewer Treatment  Plant  (TRSS)
           TRSS   = SPTP/(365/MNS)
                  = 1.75/(365/92.67) = 0.44 mgd

     1990 Urbanized Area Population  (POP™)
           POP9Q  = UAP (SMSA90 /  SMSA?0)  (

                  = 75,940(5,488,000/5,438,000)(89,300/87,205)
                  = 78,480
                                    7-29

-------
                          TABLE 7.10 (Cont'd)

                        EXAMPLE COST CALCULATIONS
      1990 Population in the Storm Sewered Area (POPGA)
            POPGA = POPgo -  CSAP
                  = 78,480 - 60,000 = 18,480
      Urbanized Area 1990 Storm Sewer Land Area
            UA90  = POPGA/PDSS
                  = 18,480/2.93 = 6,307 acres
     Growth in Urbanized Area Land  Area (UAG)
            UAG = UA   " LAND
                = 6,307 - 5,448 = 859  Acres
     Design Volume For The Growth Area (DVGA)
            DVGA= DS(ROCS)  UAG (0.027158)
                = 0.59 (0.28)859(0.027158)
                = 3.85 MG
For the Aesthetics Criteria the cost  equations associated with
and LEVELSSA = 1 and identified in Tables 3.2 and 3.3 were utilized to obtain
the following costs.

     Capital Costs for Treatment of Combined Sewer Overflows (COSTrSO CAp)

            /COSTCSO,CAP =  $16»781,068

     O&M Costs for Treatment  of Combined Sewer Overflows (COSTCSO 0&M)

            COSTCSO,0&M = $488>174

     Capital Costs for Treatment of Present  Storm Sewer Flow (COSTSSA CAp

            COSTSSA,CAP,PRESENT = $187,800

     Capital Costs for Treatment of 1990 Storm Sewer Flow (COSTSSA CAp 1990)

            COSTSSA,CAP,1990  =$2,112,800

     O&M Costs for Treatment  of Storm Sewer  Flow (COSTSSA Q&M)

            COSTSSA,0&M
                                    7-30

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                            TABLE  7.10  (Cont'd)

                          EXAMPLE  COST  CALCULATIONS
For the Fish and Wildlife Criteria the Costs are computed using LEVELCSO
and LEVELggA = 1» derived from Tables 3.2 and 3.4.

            COST  n  A  = $ 33,364,300
            COSTCSO;otM - $ 463,073
            COSTSSA,CAP,PRESENT = $ 187,800
            COSTSSA,CAP,1990 - $2,112,800
            COSTSSA,0&M - $380,430
 For  the Recreation  Criteria  the  additional Cost of Disinfection  is added
 to the costs  for  the  Fish  and Wildlife  Criteria.

            COSTCSO)CAp =  $  33,399,600
            COSTCSO,0&M =  $495,845
            COSTSSA,CAP,PRESENT  = $187,800
            COSTSSA,CAP,1990 = $2,112,800
            COSTSSA,0&M  - $380,430


 These costs are then  adjusted using the EPA Cost Index listed in
 Appendix B.
                                   7-31

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                                Section 8

              NEEDS FOR CONTROL OF COMBINED SEWER OVERFLOWS
          Needs reported for Category V - Control of Combined Sewer Over-
flows are to prevent periodic bypassing of untreated wastes from combined
sewers to an extent such that water quality criteria are maintained.  The
Needs Estimation Model for Urban Runoff (NEMUR) provides cost estimates
for control of combined sewer overflows in all urbanized areas to achieve
each of three water quality criteria.  The model estimates costs for each
of 320 urbanized areas based on a consistent methodology as defined in
Section 7 and sums these estimates to provide a state-by-state needs
assessment.

8.1  CATEGORY V COST SUMMARY

          The three Category V estimates required by the scope of this
study are:  (1) current year capital cost, (2) 1990 capital costs, and
(3) annual equivalent operation, maintenance and repair costs for a 20-
year planning period.  An assumption was made that no combined sewers would
be constructed between the present and 1990.  Considering this assumption
and since current and 1990 cost estimates are in January, 1976 dollars,
there is no difference in the current and 1990 cost estimates for Category
V. Category V needs estimates for each of the three water quality criteria
in each state and each state's percentage of total national needs are
shown on Table 8.1 through 8.3.

          Two adjustments of the model reported cost estimates are required
to obtain the final Category V.  needs.  The  combined  sewered  areas  of  municipal-
ities outside urbanized area must be considered, and since the methodology
assumes that there is presently no treatment or control of combined sewer
overflows, the funds previously spent for combined sewer control facilities
should be subtracted from the needs estimate.

8.2  NON-URBANIZED COMBINED SEWER CONTROL NEEDS

          The area and population served by combined sewers outside of
defined urbanized areas hereafter referred to as the non-urbanized combined
sewered area was obtained from an American Public Works Administration
report prepared for EPA 2.    This report was also used to define the com-
bined sewered areas in each urbanized area.

          The non-urbanized combined sewered area is located in numerous
small communities on many different receiving waters.  Therefore, it was
impractical to utilize the NEMUR methodology based on receiving water char-
acteristics for estimating the non-urbanized Category V needs.  It was
assumed that the average required cost of combined sewer control per
acre in the urbanized area of each state would also apply to the non-
urbanized combined sewered area of the same state.  Where there is no
                                    8-1

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                                         TABLE 8.1
                          STATE CATEGORY V (COMBINED SEWER) NEEDS
                      TO  ACHIEVE AESTHETICS WATER QUALITY CRITERIA
                              (Millions of Jan. 1976 Dollars)


STATE

ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
JLLAWARE
ilISr.OF COL.
FLORIDA
GEORGIA
HAWAII
lUAhO
ILLINOIS
INDIANA
IUWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NLVAUA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NLW YORK
NORTH CAROL IN/
NORTH DAKOTA
OLIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC.TR.TERR.
CURRENT AND 1990 CAPITAL COSTS
URBANIZED
AREA
NEEDS
0.000
0.000
0.000
4.216
103.404
1.562
141.657
26.606
44 . 944
0.000
62. 520
0.000
0.000
706.775
304 . 312
11.995
25.482
28.434
0.000
69.290
0.546
265.695
394.280
51.887
0.000
343.043
0.000
26.032
3.907
38.057
190.607
0.000
742.756
0.000
0.704
502.604
0.000
46.099
251.164
85.819
0.000
0.401
35.224
10.046
0.000
0.000
71.330
72.961
90.230
73.002
0.000
0.000
5.369
0.000
0.000
0.000
U.S. TOTALS 4,832.937
NEEDS FOR
NON-URBANIZED
AREAS
0.000
0.890
0.000
7.058
14.166
0.312
20.824
1.157
0.000
0.151
28.609
0.000
2.505
173.160
62.993
12.832
23.769
19.455
0.000
85.954
10.520
27.048
57.585
20.047
0.000
35.903
0.000
10.837
0.651
63.642
0.000
0.000
83.735
0.000
8.078
84.695
0.000
15.430
32.747
2.735
0.000
12.785
18.024
2.763
0.000
51.111
0.000
6.475
27.739
58.686
0.000
0.000
0.000
0.000
0.000
0.000
1,085.071
NEEDS
MET
BEFORE 197
0.000
0.000
0.000
0.000
12 . 339
0.000
3.539
0.000
0.000
0.000
0.000
0.000
0.000
96.526
4.313
0.000
0.000
0.000
0.000
2.625
0.000
57.111
72.044
0.000
0.000
0.000
0.000
0.000
0.000
14.179
0.000
0.000
38.021
0.000
0.686
5.105
0.000
0.000
0.000
10.155
0.000
1.216
0.000
0.000
0.000
0.191
0.000
0.000
0.000
14.220
0.000
0.000
0.000
0.000
0.000
0.000
332.270

TOTAL
ESTIMATED
NEEDS
0.000
0.890
0.000
11.274
105.231
1.874
158.942
27.763
44.944
0.151
91.129
0.000
2.505
783.409
362.992
24.827
49.251
47.889
0.000
152.619
11.066
235.632
379.821
71.934
0.000
378.946
0.000
36.869
4.558
87.520
190.607
0.000
788.470
0.000
8.096
582.194
0.000
61.529
283.911
78.399
0.000
11.970
53.248
12.809
0.000
50.920
71.330
79.43C
117.969
117.468
0.000
0.000
5.369
0.000
0.000
0.000
,585.761
PERCENTAGE
OF
NATIONAL
NEEDS
0.000
0.016
0.000
0.202
1.884
0.034
2.845
0.497
0.805
0.003
1.631
0.000
0.045
14.024
6.499
0.444
0.882
0.857
0.000
2.732
0.198
4.218
6.800
1.288
0.000
6.784
0.000
0.660
0.082
1.567
3.412
0.000
14.116
0.000
0.145
10.423
0.000
1.102
5.083
1.404
0.000
0.214
0.953
0.229
0.000
0.912
1.277
1.422
2.112
2.103
0.000
0.000
0.096
0.000
0.000
0.000
100.000
ANNUAL
OPERATION AND
MAINTENANCE
COSTS
0.000
0.020
0.000
0.182
1.833
0.078
4.415
0.881
1.269
0.003
1.720
0.000
0.083
22.619
9.878
0.662
1.327
2.122
0.000
6.329
0.588
8.987
11.565
2.518
0.000
8.982
0.000
0.599
0.198
3.829
5.733
0.000
23.083
0.000
0.574
24.129
0.000
1.536
11.083
3.418
0.000
0.518
1.391
0.300
0.000
1.924
2.632
2.450
8.676
5.237
0.000
0.000
0.102
0.000
0.000
0.000
183.3*9
1Sum of entries may not equal  totals  due to  round-off.
                                            8-2

-------
                                            TABLE 8.2
                            STATE CATEGORY V (COMBINED SEWER)  NEEDS
                     TO ACHEIVE THE FISH & WILDLIFE WATER QUALITY  CRITERIA
                                (Millions of January 1976 Dollars)


STATE

ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DIST. OF COLUM.
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC. TR. TERR.
U.S. TOTAL1
PRESENT AND 1990 CAPITAL COSTS
URBANIZED
AREA
NEEDS
0.000
0.000
0.000
11.119
237.366
1.562
234.218
26.606
101.723
0.000
135.532
0.000
0.000
1458.561
686.060
29.137
37.702
52.429
0.000
146.601
1.514
570.957
828.769
113.265
0.000
779.388
0.000
68.681
8.325
83.955
413. 'i90
n.ooo
1558.825
0.000
0.704
1037.696
0.000
104.84«i
377.807
181.998
0.000
0.401
71.860
26.008
0.000
0.000
150.907
167.740
162.947
142.282
0.000
0.000
15.355
0.000
0.000
0.000
10,026.293
NEEDS FOR
OTHER
AREAS
0.000
2.046
0.000
18.613
32.519
0.312
34.430
1.157
0.000
0.328
62.019
0.000
5.697
357.347
142.014
31.171
35.165
35.872
0.000
181.859
30.280
58.123
121.042
43.761
0.000
81.571
0.000
28.592
1.387
140.373
0.000
0.000
275.647
0.000
8.078
174.915
0.000
35.093
49.257
5.800
0.000
1.003
36.771
7.152
0.000
112.752
13.698
63.773
105.981
57.923
0.000
0.000
0.000
0.000
0.000
0.000
2393.521
NEEDS
MET
BEFORE 197
0.000
0.000
0.000
0.000
12.339
0.000
3.539
0.000
0.000
0.000
0.000
0.000
0.000
96.526
4.313
0.000
0.000
0.000
0.000
2.625
0.000
57.111
72.044
0.000
0.000
0.000
0.000
0.000
0.000
14.179
0.000
0.000
38.021
0.000
0.686
5.105
0.000
0.000
0.000
10.155
0.000
1.216
0.000
0.000
0.000
0.191
0.000
0.000
0.000
14.220
0.000
0.000
0.000
0.000
0.000
0.000
332.270
TOTAL
ESTIMATED
NEEDS
0.000
2.046
0.000
29.732
257.546
1.874
265.648
27.763
101.723
0.328
197.551
0.000
5.697
1719.382
823.761
60.308
72.867
88.301
0.000
325.835
31.794
571.969
877.767
157.026
0.000
860.959
0.000
97.273
9.712
210.149
413.490
0.000
1796.451
0.000
8.096
1207.506
0.000
139.939
427.058
177.643
0.000
0.188
108.631
33.160
0.000
112.561
164.605
231.513
268.928
185.985
0.000
0.000
15 . 355
0.000
0.000
0.000
2,088.120
PERCENTAGE
OF
NATIONAL
NEEDS
0.000
0.017
0.000
0.246
2.131
0.016
2.198
0.230
0.842
0.003
1.634
0.000
0.047
14.223
6.814
0.499
0.603
0.731
0.000
2.695
0.263
4.731
7.261
1.299
0.000
7.122
0.000
0.805
0.080
1.739
: . .'20
0.000
14 . 861
0.000
0.067
9.989
0.000
1.158
3.532
1.470
0.000
0.002
0.899
0.274
0.000
0.931
1.362
1.915
2.225
1.539
0.000
0.000
0.127
0.000
0.000
0.000
100.000
ANNUAL
OPERATION AND
MAINTENANCE
COSTS
0.000
0.030
0.000
0.425
2.666
0.078
4.794
0.881
1.265
0.004
2.651
0.000
0.098
22.800
10.346
0.708
1.314
1.566
0.000
4.761
1.155
8.228
12.430
2.089
0.000
8.792
0.000
0.957
0.117
3.113
5.263
0.000
24.469
0.000
0.574
18.152
" 000
1.797
10.087
2.576
0.000
0.084
1.503
0.523
0.000
1.565
2.200
3.355
5.973
3.561
0.000
0.000
0.349
0.000
0.000
0.000
173.299
1 Sum of entries may not equal totals  due to round off  errors.
                                           8-3

-------
               TABLE 8.3
STATli CATEGORY V ( COMBINED  SEWER) NEEDS
  TO ACHIEVE THE RECREATION  CRITERIA
    (Millions of Jan.  1976 Dollars)


STATli

AlAbAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DIST. OF COLU
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORX
WORTH CAROL IMA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROL IMA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC.TR.TERR.
U.S. TOTALS1
CURRENT AND 1990 CAPITAL COSTS
URBANIZE
AREA
NEEDS
0.000
0.000
0.000
17.509
349.564
2.807
340.764
38.118
149.297
0.000
206.659
0.000
0.000
2154.244
1U25.116
43.864
55.858
78.485
0.000
216.624
2.260
847.050
1238.602
161.139
0.000
1169.700
0.000
103.167
12.570
120.561
604,920
0.000
2295.529
0.000
1.084
1515.299
0.000
157.698
725.866
265.889
0.000
0.684
121.200
38.261
0.000
0.000
224.563
247.456
258.459
207.117
0.000
0.000
22.602
0.000
0.000
0.000
5,020.527
NEEDS FOR
NON-URBANIZED
AREAS
0.000
3.019
0.000
29.310
47.890
0.561
50.092
1.615
0.000
0.500
94.567
0.000
8.569
527.790
212.175
46.926
52.103
53.699
0.000
268.246
45.200
B6.230
180.898
62.258
0.000
122.421
0.000
42.948
2.094
201.578
0.000
0.000
405.918
0.000
12.439
255.418
0.000
52.783
94.639
8.474
0.000
1.710
62.180
10.522
0.000
161.913
20.384
94.080
168.102
84.317
0.000
0.000
0.000
0.000
0.000
0.000
573.568
NEEDS
MET
BEFORE 197
0.000
0.000
0.000
0.000
12.339
0.000
3.539
0.000
0.000
0.000
0.000
0.000
0.000
96.526
4.313
0.000
0.000
0.000
0.000
2.625
0.000
57.111
72.044
0.000
0.000
0.000
0.000
0.000
0.000
14.179
0.000
0.000
38.021
0.000
0.686
5.105
0.000
0.000
0.000
10.155
0.000
1.216
0.000
0.000
0.000
0.191
0.000
0.000
0.000
14.220
0.000
0.000
0.000
0.000
0.000
0.000
332.270
TOTAL
ESTIMATED
NEEDS
0.000
3.019
0.000
46.819
385.115
3.368
387.317
39.733
149.297
0.500
301.226
0.000
8.569
2585.508
1232.978
90.790
107.961
132.184
0.000
482.245
47.460
876.169
1347.456
223.397
0.000
1292.121
0.000
146.115
14.664
307.960
604.920
0.000
2663.426
0.000
12.837
1765.612
0.000
210.481
820.505
264.208
0.000
1.178
183.380
48.783
0.000
161.722
244.947
341.536
426.561
277.214
0.000
0.000
22.602
0.000
0.000
0.000
8,261.883
^um of entries may not cqual totals due to round_o£f errorB
PERCENTAGE
OF
NATIONAL
NEEDS
0.000
0.017
0.000
0.256
2.109
0.018
2.121
0.218
0.818
0.003
1.649
0.000
0.047
14.158
6.752
0.497
0.591
0.724
0.000
2.641
0.260
4.798
7.379
1.223
0.000
7.075
0.000
0.800
0.080
1.686
3.312
0.000
14.585
0.000
0.070
9.668
0.000
1.153
4.493
1.447
0.000
0.006
1.004
0.267
0.000
0.886
1.341
1.870
2.336
1.518
0.000
0.000
0.124
0.000
0.000
0.000
100.000

ANNUAL
OPERATION AND
MAINTENANCE
COSTS
0.000
0.047
0.000
0.752
4.232
0.146
6.585
1.054
1.913
0.007
4.084
0.000
0.153
33.960
15.236
1.072
1.780
2.093
0.000
6.773
1.365
12.179
18.792
2.899
0.000
13.462
0.000
1.559
0.149
4.037
7.693
0.000
36.098
0.000
0.674
25.500
0.000
2.811
12.053
3.697
0.000
0.119
2.596
0.748
0.000
2.029
3.172
5.026
6.737
4.610
0.000
0.000
0.578
0.000
0.000
0.000
248.070

                8-4

-------
urbanized combined sewered area in a state which has non-urbanized combined
sewered area, the average control cost per acre of the adjacent state is
utilized to obtain cost estimates.

          The non-urbanized combined sewer control needs are estimated
on Tables 8.1 through 8.3 for each of the three water quality criteria.
The non-urbanized acreage served by combined sewers in each state and the
dollars/acre cost of combined sewer control for each water quality criteria
in each state are listed in Table 8.4.  The non-urbanized combined sewer
control needs are approximately 20 percent of the total national needs for
combined sewer control.

8.3  PREVIOUSLY MET NEEDS

          The amount of funds previously spent for combined sewer control
was determined based on EPA grant records.  The Grants Information Control
System was queried to obtain information on all combined sewer control pro-
jects funded prior to January 1, 1976.  A total of 46 projects in 17 states
were identified and the total eligible cost for water quality control was
$332.270 million.  These costs are subtracted from the state needs estimate
to obtain the total 1976 estimated needs for each state.  Previously met
needs are itemized on Tables 8.1 through 8.3.

8.4  COMPARISON OF CATEGORY V NEEDS SURVEYS

          The total national combined sewer needs estimate for each water
quality criteria and the 1973 and 1974 Needs Survey, estimates for Category
V are shown on Table 8.5.  The costs estimated in 1976 are 42 percent of
those reported in the 1974 Needs Survey and 102 percent of those in the 1973
Needs. Survey after adjusting the earlier needs surveys to January 1976 dollars.
Th.e primary rea.scms for this significant decrease in the needs estimate are as
follows:

          »  The 1973 needs estimates  were developed independently
             by the  states  with a minimum of specific guidance from
             EPA.  Therefore,  there was  no consistent methodology
             with regard to cost-sensitive parameters such as design
             storm size, effluent limitations or cost estimating
             equations.   More  guidance was available for the  1974 Needs
             Survey.

          •  The 1976  needs estimate considers the capability of
             receiving waters  to assimilate wastewater discharges
             from combined  sewer overflows.  In the 1976 survey a
             mix of  control technologies,  including BMP's, was used which
             generally led  to  lower level? of required combined sewer
             control  than those which  were utilized in 1974.

          •  The 1976  needs estimates  are  based on a concept  of
             treating  all of a  relatively  small design storm  and
             the first flush of all larger storms.  This consideration
                                   8-5

-------
              TABLE 8.4
 NON-URBANIZED COMBINED  SEWERED AREAS
AND AVERAGE DOLLARS /ACRE CONTROL COST



STATE
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DISTRICT OF COLUM.
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANNA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
MINIMUM
MAXIMUM
AVERAGE

COMBINED SEWERED
ACREAGE OUTSIDE
URBANIZED AREAS
0
700
0
7,200
7,400
300
6,600
400
0
100
18,900
0
1,315
72,000
28,100
4,600
11,100
3,900
0
29,400
4,000
9,600
33,300
11,900
0
15,500
0
8,700
400
19,900
0
0
34,500
0
4,590
32,500
0
8,100
10,300
800
0
500
8,700
1,100
0
15,980
2,124
21,800
22,700
9,200
0


DOLLARS /ACRE CAPITAL COST - CATEGORY V

AESTHETICS
CRITERIA
_
1,272
-
980
1,914
1,040
3,155
2,892
_
1,514
1,514
_
l;905
2,405
2,242
2,790
2,141
4,988
-
2,924
2,630
2,818
1,729
1,685
-
2,316
_
1,246
1,428
3,198
_
-
2,427
.
1,760
2,606
_
1,905
3,179
3,419
_
2,006
2,072
2,512
-
3,198
3,048
1,272
2,585
3,230
980
4,988
2,371
FISH & WILDLIFE
CRITERIA
_
2,925

2,585
4,394
1,040
5,217
2,892
-
3,280
3,280
-
4,332
4,963
5,054
6,776
3,168
9,198

6,186
7,570
6,054
3,635
3,677

5.263
_
3,286
3,468
7,054

_
7,990
_
1,760
5,382
„
4,332
4,782
7,250

2,006
4,227
6,502
-
7,054
6,449
2,925
4,669
6,296
1,040
9,198
5,164

RECREATION
CRITERIA
_
4,316
-
4,071
6,472
1,870
7,590
4,038
-
5,003
5,003
-
6,516
7,330
7,551
10,201
4,694
13,769
-
9,124
11,300
8,982
5,432
5,232

7,898
_
4,937
5,235
10,130
_
_
11,766

2,710
7,859
_
6,516
9,183
10,592

3,420
7,147
9,565

10,130
9,597
4,316
7,405
9,165
1,870
13,769
7,710
              8-6

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                      TABLE 8.5
               COMPARISON OF CATEGORY V
                   NEEDS  ESTIMATES
  Category V Needs Estimates
 Total National Needs
(Millions of January,
 1976 Dollars)
1976 Needs Survey

   Aesthetics Water Quality Criteria

   Fish & Wildlife Water Quality Criteria

   Recreation Water Quality Criteria

1974 Needs Survey

1973 Needs Survey
     5,586

    12,088

    18,262

    43,506

    17,776
                          8-o7

-------
              generally leads to smaller treatment facilities
              than those identified in 1974.

              Conveyance systems costs were included in the
              1974 Survey to a much greater extent due to
              the use of sewer separation as  a control tech-
              nology.

Based on these considerations, it is our belief that the 1976 Needs Survey
provides a more uniform estimate of the eligible costs for water quality
control and a consistent basis of comparison  of relative needs among the
states.

8.5  RELIABILITY OF CATEGORY V RESULTS

        Due to the large number of assumptions which were required to develop
a systematic nationwide methodology, the minimum available data base defining
the extent of combined sewers, and the small  technology base for the treatment
of combined sewer overflows, the cost estimates should be considered only as
a best estimate.  Also, only a small amount of site specific data is available.
Therefore, the individual urbanized area needs should be used with care.  The
relationship between total state needs and the total national amount provides
an  equitable distribution of funds for water quality control of combined
sewer overflows.
                                    8-8

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                                Section 9
                NEEDS FOR CONTROL OF STORMWATER DISCHARGES

          Costs reported for Category VI are to provide control and/or
treatment of urban stormwater runoff channeled through sewers and other
conveyances used only for such runoff such that water quality criteria are
maintained.  As in Category V, the Needs Estimation Model for Urban Runoff
(NEMUR) provides cost estimates for control of stormwater discharges in
all urbanized areas to achieve each of three water quality criteria.

9.1  CATEGORY VI COST SUMMARY

          Three Category VI estimates are required: (1) current capital
costs,  (2) 1990 capital costs, and (3) annual equivalent operation, main-
tenance and repair costs for a 20-year planning period.  Estimates for each
of 320 urbanized areas are summed to provide a state-by-state and national
needs assessment.  The state Category VI needs estimates for each of the
three water quality criteria are shown on Tables 9.1 through 9.3.

          Costs to achieve the Aesthetics water quality criteria were
estimated based on applying Best Management Practices to the area served
by storm sewers in all urbanized areas.  Best Management Practices were
assumed to include effective street sweeping of all streets at a freq-
uency of once per week; application of construction practices to four
percent of the urbanized area each year; and construction of detention
basins for the area of growth between the current year and 1990.  Cost
functions for these practices were itemized in Table 3.2.  The current
capital cost estimates, listed by state on Table 9.1, include the cost of
street sweeping equipment; 1990 capital cost estimates include the cost of
street sweeping equipment and detention basin construction; and operation
and maintenance cost estimates include construction practices and the
operation and maintenance required for street sweeping and detention basins.
This assumed set of practices does not imply that they are the most effec-
tive or least costly pollutant control scheme, merely an assumed mix of
control methods whose cost and effectiveness could be evaluated in a con-
sistent manner nationwide.  A particular municipality conducting Best
Management Practices might decide to sweep heavily utilized streets more
often, clean catch basins, or use other 'combinations of effective control
schemes.

          Costs to achieve the Fish and Wildlife water quality criteria
were estimated based on the assimiliative capacity of the receiving water
in each urbanized area.  Best Management Practices are assumed to be a
minimum control level.  Where these practices do not provide enough pollu-
tant removal, structural control systems similar to those evaluated for
combined sewers are sized to treat the stormwater runoff from the urbanized
area.  Cost estimates are listed by state on Table 9.2 for the Fish and
Wildlife water quality criteria.
                                    9-1

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                                   TABU; 9.1
                     STATE CATEGORY VI (STORMHATER)  NEEDS
             TO ACHIEVE THii AESTHETICS WATER QUALITY CRITERIA
                      (Millions of Jan. 1976 Dollars)


STATE
ALABAMA
iOASKA
ARIZOKA.
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
UIST. OF COLUM.
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MltilttSOTA
MISSISSIPPI
MISSOURI
MONTANTA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TlinNESSEE
TLXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC.TR.TERR.
U.S. TOTALS1

CURRENT CAPITAL
COSTS
13.937
1.297
12.93A
4.151
128.358
10.990
24.111
2.879
1.736
41.111
13.260
6.194
0.841
35.940
13.646
9.849
6.233
9.530
10.992
1.049
19.220
34.977
27.920
16.282
3.177
14.465
1.395
3.150
3.731
1.170
64.219
2.652
33.723
9.396
0.397
48.631
10.693
7.375
56.786
4.719
4.989
0.663
15.364
61.217
6.811
0.000
21.848
15.601
2.181
17.439
0.000
0.000
7.241
0.000
0.000
0.000
866.464

1990
CAPITAL COSTS
224.733
15.202
523.084
116.067
3036.656
174.078
604.849
93.327
114.784
2593.454
355.982
137.020
8.855
887.248
411.193
134.712
124.876
152.933
226.572
38.944
359.383
652.287
701.385
272.816
46.626
515.075
8.116
65.407
124.654
102.873
1015.406
36.421
810.211
172.358
2.032
864.198
238.930
241.286
542.703
86.938
84.411
5.405
293.854
2122.355
100.178
0.000
431.039
224.918
19.734
192.014
0.000
0.000
163.376
0.000
0.000
0.000
20,470.871

PERCENT OF
NATIONAL NEEDS
1.098
0.074
2.555
0.567
14.833
0.850
2-. 955
0.456
0.561
12.669
1.739
0.669
0.043
4.314
2.009
0.658
0.610
0.747
1.107
0.190
1.756
3.186
3.426
1.333
0.228
2.516
0 040
0.320
0.609
0.503
4.960
0.178
3.958
0.842
0.010
4.222
1.167
1.179
2.651
0.425
0.412
0.026
1.435
10.368
0.489-
0.000
2.106
] .099
0.096
0.938
0.000
0.000
0.798
0.000
0.000
0.000
100.000
ANNUAL
OPERATION AND
MAINTENANCE COSTS
15.850
1.413
22.315
5.731
151.401
11.764
32.980
4.177
3.696
87.012
18.272
7.138
0.809
50.430
25.455
11.112
7.227
9.765
11.975
2.660
19.542
41.062
41.737
19.511
3.303
26.325
1.143
4.219
6.201
3.795
73.617
2.823
43.740
10.778
0.310
59.678
16.641
11.548
51.043
5.862
5.512
0.581
18.889
92.804
7.476
0.000
25.840
18.143
2.656
17.813
0.000
0.000
7.737
0.000
0.000
0.000
1,118.506
of entries may not equal totals  due  to round-off.
                                    9-2

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                                   TABLE 9.2
                     STATE CATEGORY VI (STORMWATER) NEEDS
            TO ACHIEVE T11E FISH AND WILDLIFE WATER QUALITY CRITERIA
                      (Millions of Jan.  1976 Dollars)


STATE
ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DIST. OF COLUM.
FLORIDA
GEORGIA
HAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOURI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NtW MEXICO
NliW YORK
NORTH CAROLINA
NORTH OAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTh CAROLINA
SOUTH DAKOTA
TKNNLSSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC.TR.TERR.
U.S. TUTALSl

CURRENT CAPITAL
COSTS
1U8.614
1.297
12.934
4.151
2268.985
10.990
308.813
2.879
1.736
4775.707
135.363
291.964
0.841
1038.487
326.545
9.849
6.233
9.530
35.246
72.256
716.791
1626.558
676.286
704.928
148.406
14.465
1.395
3.150
3.731
24.996
6165.676
2.652
1260.087
9.396
0.397
3325.437
12.072
7.375
2289.106
4.719
65.925
1.206
113. 846
1338.646
59.970
0.000
1004.297
35.075
2.181
1372.321
0.000
0.000
157.336
0.000
0.000
0.000
31,070.754

1990
CAPITAL COSTS
319.411
15.202
523.084
116.067
5177.266
174.078
1389.552
93.327
114.784
7328.039
478.085
422.790
8.855
1889.797
724.093
134.712
124.876
152.933
250.826
110.151
1056.953
2243.869
1349.752
961.462
191.855
515.075
8.116
65.407
124.654
126.699
7116.863
36.421
2036.577
172.358
2.032
4141.000
240.309
241.286
2775.024
86.938
145.348
5.947
392.336
3399.785
153.338
0.000
1413.489
244.392
19.734
1546.896
0.000
0.000
313.470
0.000
0.000
0.000
50,675.234

PERCENT OF
NATIONAL NEEDS
0.630
0.030
1.032
0.229
10.217
0.344
2.742
0.184
0.227
14.461
0.943
0.834
0.017
3.729
1.429
0.266
0.246
0.302
0.495
0.217
2.086
4.428
2.664
1.897
0.379
1.016
0.016
0.129
0.246
0.250
14.044
0.072
4.019
8.340
.004
8.172
0.474
0.476
5.476
0.172
0.287
0.012
0.774
6.709
0.303
0.000
2.789
0.482
0.039
3.053
0.000
0.000
0.619
0.000
0.000
0.000
100.000
ANNUAL
OPERATION AND
MAINTENANCE COSTS
19.113
1.413
22.315
5.731
208.013
11.764
67.692
4.177
3.696
359.317
22.742
19.928
0.809
144.166
49.626
11.112
7.227
9.765
12.808
10.006
62.686
106.741
66.773
51.620
9.492
26.325
1.143
4.219
6.201
4.999
579.402
2.823
118.403
10.778
0.310
372.198
13.680
11.548
228.727
5.862
7.653
0.602
22.651
149.840
13.297
0.000
103.977
19.134
2.656
202.781
0.000
0.000
12.961
0.000
0.000
0.000
3,180.900
of entries may not equal totals due to round-offs.
                                       9-3

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                  TABLE 9.3
        STATE CATEGORY  VI  (STORMWATER) NEEDS
TO ACHIEVE THE RECREATION  WATER QUALITY CRITERIA
         (Millions of Jan. 1976 Dollars)

STATE

ALABAMA
ALASKA
ARIZONA
ARKANSAS
CALIFORNIA
COLORADO
CONNECTICUT
DELAWARE
DIST. OF COLUM.
FLORIDA
GEORGIA
llAWAII
IDAHO
ILLINOIS
INDIANA
IOWA
KANSAS
KENTUCKY
LOUISIANA
MAINE
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
MISSISSIPPI
MISSOUKI
MONTANA
NEBRASKA
NEVADA
NEW HAMPSHIRE
NEW JERSEY
NEW MEXICO
NEW YORK
NORTH CAROLINA
NORTH DAKOTA
OHIO
OKLAHOMA
OREGON
PENNSYLVANIA
RHODE ISLAND
SOUTH CAROLINA
SOUTH DAKOTA
TENNESSEE
TEXAS
UTAH
VERMONT
VIRGINIA
WASHINGTON
WEST VIRGINIA
WISCONSIN
WYOMING
GUAM
PUERTO RICO
VIRGIN ISLANDS
AMERICAN SAMOA
PAC. TR. TERR.
U.S. TOTALS1

CURRENT CAPITAL
COSTS
113.466
1.297
12.934
4.151
2389.975
10.990
899.606
2.879
1.736
56U5.594
142.346
335.237
0.841
1144.551
368.607
9.U49
6.2'i3
9.530
36.195
85.694
78U.091
1716.528
656.929
19.180
168.158
14.465
1.395
3.150
3.731
29.927
7093.277
2.652
1389.363
9.396
0.397
3936.619
12.154
7.375
2611.604
4.719
68,701
1.282
126.777
1446.796
70.784
0.000
1141.297
39.210
2.181
1737.234
0.000
0.000
163.149
0.000
0.000
0.000
34,528.152

1990
CAPITAL COSTS
324.263
15.202
523.084
116.067
5298.258
174.078
1480.345
93.327
114.784
8237.926
485.067
466.062
8.855
1995.860
766.155
134.712
124.876
152.933
251.775
123.589
1128.254
2333.839
1330.395
275.714
211 . 606
515.075
8.116
65.407
124.654
131.630
8044.465
36.421
2165.852
172.358
2.032
4752.180
240.391
241.286
3097.523
86.93S
148.124
6.024
405.266
3507.936
164.151
0.000
1550.490
248.527
19.734
1911.808
0.000
0.000
319.284
0.000
0.000
0.000
54, 132. (03

PERCENT OF
NATIONAL NEEDS
0.599
0.023
0.966
0.214
9.788
0.322
2.735
0.172
0.212
15.218
0.896
0.861
0.016
3.687
1.415
0.249
0.23J.
0.283
0.465
0.228
2.084
4.311
2.458
0.509
0.391
0.952
0.015
0.121
0.230
0.243
14.861
0.067
4.001
0.318
0 , 004
8.779
0 .444
0.446
5.722
0.16]
0.274
0.011
0.749
6.480
0.303
0.000
2.864
0.459
0.036
3.532
0.000
0.000
0.590
0.000
0.000
0.000
100.000
ANNUAL
OPERATION AND
MAINTENANCE COSTS
19.412
1.413
22.315
5.731
212.136
11.764
69.635
4.177
3.696
370.545
23.037
20.561
0.809
116.463
50.324
11.112
7.227
9.765
12.869
10.160
64.261
106.272
64.646
19.631
9.835
26.325
1.143
4.219
6.201
5.062
592.902
2.823
121.378
10.778
0.310
379.664
13.684
11.548
233.825
5.862
7.811
0.603
22.927
152.688
13.401
0.000
106.132
19.183
2.656
205.608
0.000
0.000
13.404
0.000
0.000
0.000
3,207.932
ISum of entries may not equal totals due to round-off s.
                      9-4

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          Cost estimates for the Recreation water quality criteria included
disinfection of effluents from all structural treatment systems.  Other-
wise, treatment and/or control levels were the same as those evaluated
for the Fish and Wildlife water quality criteria.  Cost estimates for the
Recreation water quality criteria are listed on Table 9.3.

9.2  COMPARISON OF CATEGORY VI NEEDS SURVEYS

          The total national stormwater needs estimate for each water
quality criteria and the sum of 1974 state needs estimates for Category VI
are shown on Table 9.4.  The costs estimated in 1976 are significantly
less than those reported in the 1974 Needs Survey.  The primary reasons
for this significant decrease in the needs estimate are as follows:

           • The 1974 needs estimates were developed independently
             by the states with a minimum of specific guidance from
             EPA.  Therefore, there were widely varying methodologies
             between the states with no uniform estimating procedure.

           • Since there was no guidance or regulations defining
             the area requiring stormwater control, many states used
             population minimums to define urban stormwater runoff.
             These population minimums ranged from 500 to 25,000, all
             giving a significantly larger area requiring stormwater
             control than the urbanized area definition used in the
             1976 Needs Survey.

           • Large design storms, up to an intensity of 3 inches per
             hour, and a frequency-duration of 15-year-24 hour, were
             used to size storage and treatment systems.  Comparatively
             a relatively small design storm with a high recurrence
             interval is used in the present survey.

           • Collection costs included in the 1974 Needs Survey ranged
             from $328 to $8,000 per acre.  Collection costs are not
             included in the 1976 results.

           • The assimilative capacity of receiving waters is considered
             in the 1976 Needs Survey.  This generally leads to much
             lower levels of stormwater control than those utilized
             in 1974.

          Based on these considerations, the 1976 Needs Survey - Category
VI estimates appear to provide a more equitable distribution of needs
between states due to the consistent methodology utilized.

9.3  RELIABILITY OF CATEGORY VI RESULTS

          Since the technology base related to the control and/or treatment
                                    9-5

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                        TABLE 9.4
COMPARISON OF 1976 AND 1974 CATEGORY VI NEEDS ESTIMATES
        Needs  Estimates
 Total National Needs
 (Millions of January
t   1976  Dollars)
  1976 Needs Survey

     Aesthetics Water Quality Criteria

     Fish & Wildlife Water Quality Criteris

     Recreation Water Quality Criteria

  1974 Needs Survey
     20,471

     50,675

     54,133

     329,008
                           9-6

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of stormwater runoff is minimal, and many assumptions are required to develop
the cost estimates, they should only be considered as rough estimates.  The
needs survey results are only as accurate as the assumptions upon which they
are based.  The effectiveness of streetsweeping technology applied in an in-
tensive streetsweeping program on receiving water quality is not well known.
The accuracy of the suspended solids water quality criteria is also not well
known.  All needs estimates should be used with care.  The estimating methodol-
ogy was an effort to develop state-by-state and national estimates and may be
of limited value in any specific urbanized area.
                                 9-7

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                                PART III

                               REFERENCES
1.  Federal Register, 40CFR Parts 124,125, National Pollution Discharge
    Elimination System - Separate Storm Sewers, Final Regulations,
    March 18, 1976,

2.  American Public Works Association and University of Florida.  "Asses-
    sment of Combined Sewer Overflows, Urban Stormwater Discharges,
    and Non Sewered Urban Runoff," Draft Report to Environmental Protec-
    tion Agency, December 1975.

3.  U.S. Water Resources Council, 1972 OBERS Projections of Economic
    Activity in the U.S., Volume IV - States, Volume V - Standard
    Metropolitan Statistical Areas,, Washington, D.C., April 1974.

4.  U.S. Environmental Protection Agency, Municipal Construction Division,
    "Cost Estimates For Construction of Publicly Owned Wastewater Treat-
    ment Facilities - 1974 Needs Survey," Washington, D.C., May 6, 1975.

5.  American Public Works Association, "Problems of Combined Sewer Facil-
    ities and Overflows - 1967," FWPCA Report WP - 20-11, December 1,
    1967.

6.  U.S. Department of Commerce, National Oceanic and Atmospheric
    Administration, Climates of the States, Vol. 1 and Vol. II, 1974.

7-  Hydroscience, Inc., "Simplified Mathematical Modeling of Water
    Quality," prepared for the Environmental Protection Agency, March
    1971.

8.  Thomann, R.V., Systems Analysis and Water Quality Management, McGraw
    Hill Book Company, New York, N.Y., 1972.

9.  U.S. Department of the Interior, Geological Survey, "Water Resources
    Data for the States" Published annually for each state.

10. U.S. Army Corps of Engineers, Hydrologic Engineering Center, "Urban
    Storm Water Runoff - STORM", Davis, California, May, 1975.

11. Graham, P.H., Costello, L.S. and Mallon, H.J., "Estimation of
    Imperviousness and Specific Curb Length for Forecasting Stormwater
    Quality and Quantity," JWPCF, Vol. 46, No.4, April 1974.

12. Stankowski, S.J., "Magnitude and Frequency of Floods in New Jersey
    with Effects of Urbanization," Special Report 38, U.S. Geological
    Survey, Water Resources Division, Trenton, NJ, 1974.

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                             PART  III  (Cont'd)

                                REFERENCES


13.  Adimi,  R., et.al.,  "An Evaluation  of Streetsweeping Effectiveness
     in the  Control of  Nonpoint Source Pollution," The Catholic University
     of America,  April, 1976.  (unpublished paper prepared under the
     direction of G.K.  Young, Ph.D.)

14.  URS Research Co.  "Water Pollution Aspects  of Street Surface Contami-
     nants," EPA-R2-72-081.

15.  URS Research Co.  "Toxic Materials Analysis of Street Surface Contami-
     nants," EPA-R2-73-283.

16.  Biospherics  Inc.,  "Contributions  of Urban  Roadway Usage to Water
     Pollution,"  EPA Contract No.  68-01-0197.

17.  Sartor, James D.  and Boyd, Gail B., "Water Pollution Aspects of
     Street  Surface Contaminants," EPA Office of Research and Development
     Report  EPA-R2-72-081.  November 1972.

18.  Environmental Protection Agency,  "Guidelines for 1976 Update of Needs
     for Municipal Wastewater Facilities",  March 24, 1976.

19.  Environmental Protection Agency,  "Grants  Information Control System,
     Construction Grant Projecc Record," August 24, 1976.

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   APPENDIX A
STUDY SITE DATA

-------
  Qus
        •TTTl       f
       S-&
      80
            75
                Urban
                Runoff
                      Chattahoochee River
                  70
                        65
                              60

                            River Miles
                                   55
                                                QQ-S
f
                                         50
i-t
    FIGURE A-1. CONCEPTUAL SKETCH FOR ATLANTA, GEORGIA.
1
c

I
O

1
                                       Location — Atlanta, Georgia
                                    Receiving water — Chattahoochee River
                         ~20~
              10
                    15
                               25
                            Travel Time (hrs)
                                     30
                                           35
                                                 40
                                                      45
                                                            50
     FIGURE A-2.  D.O. CURVE FOR CHATTAHOOCHEE RIVER.
                         A- 1

-------
                                 TABLE A-l

                             SITE DATA ATLANTA
A.  DEMOGRAPHIC DATA (Chattahoochee River Basin)
     Land Use

     Urban
       Combined Sewer
       Storm Sewer
     Suburban
       Non Storm Sewer
     Undeveloped

     TOTAL
Area
(acres)
  9,062
 51,200

 92,800
241,920

394,982
Pop.  Density
Persons/acre
    3.72
    4.25

    4.25
    0
      Total
      Population
         33,711
        217,600

        394,400
           0

        645,711
B.  STREAMFLOH DATA

     Qus  = 2,499 cfs
     Temp = 18.0° C - upstream
            23.0° C - downstream
     DO   = 8.4 mg/1
     l<2   =1.5- downstream
  Qds = 4,708 cfs
C.  HASTE LOADING DATA

     Land Use
     or Source

     Upstream Flow
     Urban Combined Sewer
     Urban and Suburban
     WWTP

     TOTAL
 18,176
 44,179
 21,944
 25,520

109,819
102,863
 94,542
 36,212
125,752
SS
ton/day

  510
2,270
  210
   10
359,369    3,000
D.  RAINFALL DATA

     Total annual rainfall  (5 years
     Number of storms per year
     Mean depth per event
     80% storm depth
     Design duration
     Critical  period
     Time between storms critical period
        51.74 in.
        115
        0.45 in.
        0.72 in.
        10.3 hrs
        June, July and August
        57.37 hrs
                                     A-2

-------
            Urban
            Runoff
 Qus




ttt
§ o o
3 oo




1 fftt t
      45
              40       35       30       25
                                               20
                                         River Miles
                                                                10
      FIGURE A-3. CONCEPTUAL SKETCH FOR DES MOINES, IOWA.
O  6
  5-
                                                     Location - Des Moines, Iowa
                                                 Receiving water — Des Moines River
             Min standard = 5.0 mg/l
    0    24    6   8   10   12   |4   16   18   20   22   24   26   28   30   32   34   36  38  40
                                        Travel Time (hrs)
            FIGURE A-4.  D.O. CURVE  FOR DES MOINES RIVER.
                                   A-3

-------
                                 TABLE A-2

                           SITE DATA DES MOINES
A.  DEMOGRAPHIC DATA

Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
Rural
Undeveloped
TOTAL
Area
(acres)

4,830
3,878

23,639

37,681
70,028
Pop. Density
Persons/acre

8.33
7.74

7.83

0

Total
Population

40,000
30,000

185,000

0
255,000
B.  STREAMFLOW DATA

     Qus  = 2,186 cfs
     Temp = 23.5° C
     DO   = 7.1 mg/1
     l<2   = 1.883 - downstream
  Qds = 3,346 cfs
    HASTE LOADING DATA

     Land Use
     or Source

     Upstream Flow
     Urban Combined Sewer
     Urban
     WWTP

     TOTAL
149,000
 28,600
282,300
 12.200

472,100
  315,000
   48,400
  592,000
   54.780
SS
ton/day

  590
   90
1,320
less than 5
1,010,180   2,000
D.   RAINFALL DATA

     Total  annual rainfall  (5  years)
     Number of storms  per year
     Mean depth per event
     80% storm depth
     Design duration
     Critical  period
     Time between storms  critical  period
        38.05 in.
        119
        0.32 in.
        0.51 in.
        12.65 hrs
        June through August
        67.5 hrs
                                     A-4

-------
                Urban
                Runoff
Rural
Runoff
      Qus


i
3 CO
II
4; CT
3
i r < r v 
-------
    TABLE A-3



SITE DATA DURHAM
A.
B.
C.
D.
DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Urban
Suburban
Rural
TOTAL
STREAMFLOW DATA
Qus = 6.8 cfs
Temp = 25° C
DO = 7.4
K2 = 2.5
WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
Suburban
Rural
WWTP
TOTAL
RAINFALL DATA
Area
(acres)
None
1,250
3,060
1,050
5,360
Qds =
BOD5
#/day
249
None
3,881
3,090
416
1,000
8,636

Total annual rainfall (5 years)
Number of storms per year =
Mean depth per event =
80% storm depth
Design duration =
Critical period
Time between storms critical period =
Pop. Density
Persons/acre
6.0
3.0 (assumed)
0.5 (assumed)
94.4 cfs
Total
Population
7,500
9,180
525
17,205

UOD SS
#/day ton/day
725 2
None None
10,899 82
8,856 66
1,211 5
3,320 less than 1
25,011 155
44.11 in.
103
0.43 in.
0.69 in.
9.63 hrs
June, July and August
76.5 hrs


        A-6

-------
Qus
= 0
             Urban Runoff
                                    Yellow House Canyon
                                                                    Qds
            35'
                       30
                                 25
                                           20
                                                      15
                                             River Miles
                                                                10
           FIGURE A-7. CONCEPTUAL SKETCH FOR LUBBOCK, TEXAS.
     9.0
     8.0
   I7'0
   .2 6.0
   Q
    5.0-
     4.0
    Location — Lubbock, Texas
            (Idealized)
Receiving water   Yellow House Canyon
                                               10       12

                                           Travel Time (hrs)
                                                               14
                                                                       16
                                                                               18
                                                                                       20
            FIGURE A-8. D.O. CURVE FOR YELLOW HOUSE CANYON.
                                      A-7

-------
    TABLE A-4



SITE DATA LUBBOCK
A.
B.
C.
D.
DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
Undeveloped
TOTAL
STREAMFLOW DATA
Qus = 0.0 cfs
Temp = 27.0° C
DO = 8.0
l<2 = 7-1 - downstream
WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
WWTP (Wastewater Reclaimed)
TOTAL
RAINFALL DATA
Area
(acres)
None
6,012
13,872
29,115
48,999
Qds =
BOD5
#/day
NA
0
17,390
0
17,390

Total annual rainfall (5 years)
Number of storms per year =
Mean depth per event =
80% storm depth
Design duration =
Critical period =
Time between storms critical period =
Pop. Density Total
Persons/acre Population
7.48 45,000
7.57 105,000
0 0
150,
219 cfs
UOD SS
#/day ton/day
NA NA
0 0
31,580 320
0 0
31,580 320
19.98 in.
57
0.35 in.
0.56 in.
11.35 hrs
July through September
101.8 hrs
000



        A-8

-------
              Suburban
              Runoff
                          Urban
                          Runoff
                                   CSO
                                           Milwaukee Bay
Qus
                    Milwaukee River
                                                      Lake Michigan

f
         45
                    40
                               35
                                          30
                                                     25
                                                               20
                                             River Miles
      FIGURE A-9. CONCEPTUAL SKETCH  FOR MILWAUKEE, WISCONSIN.
   4.0
                                                     Location — Milwaukee River Watershed
                                                             Milwaukee County, Wis.
                                                 Receiving water — Milwaukee River/Milwaukee
                                                             Bay/Lake Michigan
                                                          10    11    12   13    14    15   16
 FIGURE A-10.  D.O. CURVE FOR MILWAUKEE RIVER AND MILWAUKEE BAY.
                                     A-9

-------
     TABLE A-5



SITE DATA MILWAUKEE
A.
B.
C.
D.
DEMOGRAPHIC DATA (Milw<
appn
Land Use
Urban
Combined Sewer
Urban
Suburban
Rural
TOTAL
STREAMFLOW DATA
Qus = 170 cfs
Temp = 22.2° C
DO = 8.9 mg/1
K2 =1.1 day-1
WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
Suburban
WWTP
TOTAL
RAINFALL DATA
lukee River Watershed within Milwaukee County
Dximately 52 square miles)
Area Pop. Density Total
(acres) Persons/acre Population
5,800
15,100
12,300
33,200
Qds =
BOD5
#/day
3,200
41,000
5,300
2,900
14,600
67,000

Total annual rainfall (5 years) =
Number of storms/year =
Mean depth/event =
80% storm depth
Design duration =
Critical period
Time between storms critical period =
27.3 158,
4.7 70,
2.5 30,
260,
467 cfs
UOD SS
#/day ton/day
8,700 46
81,500 56
14,500 107
7,800 74
102,200 4
214,700 287
31.68 in.
123
0.26 in.
0.42 in.
7.76 hrs
June, July and August
70.13 hrs
340
970
750
060



         A-10

-------
                                       Urban Runoff
                                       + CSO
                         Urban Runoff
               Suburban Runoff
          \i  \i \ i \ r \ I  \t \i \ I \f \ I  \ f \i \' \ i \i \i  \> \ i \ ' \I 1 r
Qus
                          CO
         TO   T3   T3
                      CO
                              Urban Runoff
                 Delaware River/Estuary
                                                M  M^i


                                                I   %
                                        -H H   H
                                        -O -D   T>
                                        2
                                        m
                                                 -o
                           CO
                           m
                       CO

                       §-
                       c
                       <
                                                        Qds
                                                  CSO — Combined sewer overflow


                                                 WWTP — Municipal wastewater treatment plant


                                                   IWS — Industrial waste source
            130
120
110
100
90
                                                River Miles
80
70
                                                       60
50
            FIGURE A-11. CONCEPTUAL SKETCH FOR PHILADELPHIA, PENNSYLVANIA.

-------
    11-
    10-
                                                                                       Philadelphia, Pa.
                                                                                       (with existing point
                                                                                       source waste loads)
                                                                                       Delaware River/Estuary
                                                                                       DO curve for design
                                                                                       storm runoff

                                                                                       DO curve for dry
                                                                                       weather conditions
                200         400        600        800        1,000       1,200
                                                        Travel Time (hrs)
1,400
1,600
1,800
2,000
FIGURE A-12. D.O. CURVE FOR DELAWARE RIVER/ESTUARY WITH EXISTING POINT SOURCE WASTE LOADS.

-------
       TABLE A-6



SITE DATA PHILADELPHIA
A.
B.
C.
D.
DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
TOTAL
STREAMFLOW DATA
Qus =4,167 cfs
Temp = 26.0° C
DO =9.3 mg/1
K2 = 0.17 - downstream
WASTE LOADING DATA (Present
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban and Suburban
WWTP (includes Schuylkill
TOTAL
RAINFALL DATA
Area
(acres)
22,400
105,600
321,920
449,920
Qds =
Conditions)
BOD5
#/day
89,801
165,202
515,797
R.) 297,664
1 ,068,464

Total annual rainfall (5 years) =
Number of storms per year
Mean depth per event =
80% storm depth
Design duration =
Critical period
Time between storms critical period =
Pop. Density Total
Persons/acre Population
9.86 220,864
9.67 1,021,152
8.487 2,732,135

9,622 cfs
UOD
#/day
288,599
335,886
866,360
724,401
2,215,246
48.80 in.
113
0.43 in.
0.69 in.
16.46 hrs
June, July and
74.24 hrs
3,974

SS
ton/day
1,750
280
3,710
40
5,780
August
,151



           A-13

-------
            11-
           10-
                                                                                           Philadelphia, Pa.
                                                                                           (with ultimate allocated
                                                                                           point source waste loads)
                                                                                           Delaware River/Estuary
                                                                                           DOcurve for design
                                                                                           storm runoff

                                                                                           DOcurve for dry
                                                                                           weather conditions
                       200
400
600
800
    1,000       1,200

Travel Time (hrs)
1,400
1,600
1,800
2,000
FIGURE A-13. D.O. CURVE FOR DELAWARE RIVER/ESTUARY WITH APPROXIMATE ULTIMATE ALLOCATED POINT SOURCE
               WASTE LOADS.

-------
                                 TABLE A-7

  WASTE LOAD ALLOCATION FOR MAJOR DELAWARE  RIVER  POINT SOURCE  DISCHARGES
Source Description
Morrisville WWTP
Trenton WWTP
Stauffer Chem. Co.
Hamilton WWTP
U.S. Steel
Levittown WWTP
Rohn & Haas
Paterson Paper Co.
Tennecs
Allied Chem. Corp.
Pennsauken
Philadelphia NE WWTP
Camden-North WWTP
Camden-Main WWTP
N. J. Zinc
Philadelphia SE WWTP
Mobil Oil
Philadelphia SW WWTP
Schuylkill River
Total #/day
River
(miles)
133. '9
133.5
133.2
130.0
126.5
126
122.5
122
118
106
105.5
105
104.5
100
97.5
97
92.5
92
91.5

Flow
(cfs)
6.15
32.0
0.10
17.0
54.0
13.06
1.80
4.50
4.05
0.20
5.9
326.0
5.42
47.0
17.2
210.0
10.9
265.5
1,500.0

BODpn
(mg/T)
23.5
13.6
9.5
8.0
8.6
34.3
283.6
18.1
27.0
15.5
48.1
39.5
43.8
47.0
5.4
29.4
72.4
20.3
4.2
197,777
NBOD
(mg/1)
167.4
72.21
6.86
61.7
26.96
85.87
34.28
4.57
143.96
13.71
114.25
62.93
137.1
59.41
57.58
34.55
32.9
39.99
4.57
366,206
D.O.
(mg/1)
7.1
1.7
2.0
4.2
6.0
3.0
1.7
2.0
2.8
2.0
0.7
2.1
0.1
2.6
0.0
3.6
1.4
3.7
7.0

BOD5 = 117,634 #/day
UOD  = 563,983 #/day
                                     A-15

-------
  Qus
                                   Columbia River
                                                        Note: The city of Portland is tributary
                                                            to the lower Willamette River. All
                                                            waste sources, including wastewater
                                                            treatment plant effluent, combined
                                                            sewer overflows,.and urban runoff
                                                            were added to the base flow of the
                                                            Wjllamette River, which is considered
                                                            the only waste source.
                                                            Qds
           30
                       25
                                    20
                                                15

                                              River Miles
                                                            10
        FIGURE A-14.  CONCEPTUAL SKETCH FOR  PORTLAND, OREGON.
  10'
                                                                Location — Portland, Oregon
                                                           Receiving water   Columbia River
O  9
8
5
  8-
             10        20        30        40        50

                                              Travel Time (hri)
                                                                      70
90
         100
              FIGURE A-15. D.O. CURVE  FOR COLUMBIA RIVER.
                                       A- 16

-------
                                 TABLE A-8

                            SITE DATA PORTLAND
A.
B.
C.
DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
Undeveloped
TOTAL
STREAMFLOW DATA
Qus = 3,919 cfs
Temp = 17° C
DO = 8.4
K2 = 2.0 - downstream
WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
WWTP
TOTAL
Area
(acres)
3,420
29,754
62,432
75,291
170,897
Qds =
BOD,
#/day
12,670
12,240
164,000
15,480
204,390
Pop. Density
Persons/acre
6.57
8.67
8.71
0
5,465 cfs
UOD
#/day
61 ,400
20,374
379,900
36,890
498,564
Total
Population
23,000
258,000
544,000
0
825,000

SS
ton/day
1,110
40
1,420
10
2,580
D.  RAINFALL DATA

     Total  annual  rainfall  (5 years)
     Number of storms per year
     Mean depth per event
     80% storm depth
     Design duration
     Critical  period
     Time between storms critical  period
40.49 in.
148
0.27 in.
0.44 in.
9.57 hrs
September through November
55.80 hrs
                                     A-17

-------
      Qus
                    Urban
                    Runoff
                              Roanoke River
                            T
                                                        Qds
            25
                      20
                                 15
                                          10
                                   River Miles
  FIGURE A-16.  CONCEPTUAL SKETCH FOR ROANOKE, VIRGINIA.
6-
                                         Location   Roanoke, Virginia
                                     Receiving water   Roanoke River
                                4       5
                                    Travel Time (hrs)
                                                                       9      10
          FIGURE A-17.  D.O. CURVE FOR ROANOKE RIVER.
                               A  18

-------
    TABLE A-9



SITE DATA ROANOKE
A.
B.
C.
D.
DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
Rural
Undeveloped
TOTAL
STREAMFLOW DATA
Qus = 168 cfs
Temp = 26.6° C
DO = 8.0 mg/1
l<2 = 16.0 - downstream
WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
WWTP
TOTAL
RAINFALL DATA
Area
(acres)
None
7,240
12,516
22,243
41,999
Qds =
BOD5
#/day
980
0
10,240
1,260
12,480

Total annual rainfall (5 years) =
Number of storms/year =
Mean depth per event =
80% storm depth =
Design duration =
Critical period =
Time between storms critical period =
Pop. Density Total
Persons/acre Popul
7.87 57,
7.99 100,
0 0
157,
512 cfs
UOD SS
#/day ton/day
2,200 45
0 0
31,690 404
12,551 2
46,441 451
49.19 in.
117
0.42 in.
0.68 in.
11.76 hrs
July through September
60.65 hrs
ation
000
000
000



        A-19

-------
                                TABLE A-10

                     SITE DATA SAN FRANCISCO BAY AREA
A.  DEMOGRAPHIC DATA (Total  Area)
Land Use

Urban
  Combined Sewer
Urban
Rural

TOTAL
                                   Area        Pop. Density
                                   (Sg. Miles)  Persons/acre
   47.8
  508
1,297

1,852.8
                                                  23.7
                                                   7.07
                                                   0.48
                             Total
                             Population
  725,000
2,300,000
  397,000

3,422,000
B.  STREAMFLOW DATA (South Bay Only)

     Qus  = 72.2 cfs
     Temp = 15.6° C
     DO   = 9.0
     !<    = Unknown - downstream
                                Qds = Unknown
C. WASTE LOADING DATA (South
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
Industrial
WWTP (all AWT)
TOTAL
Bay Only)
BOD5
#/day
Assumed
Negligible
None
153,421
53,626
6,870(±)
213,917
UOD
#/day
Assumed
Negligible
None
281,682
98,458
20,200
400,340
SS
ton/day
0
0
1,807
421
3
2,231
D.  RAINFALL DATA

     Total annual rainfall  (5 years)
     Number of storms per year
     Mean depth per event
     80% storm depth
     Design duration
     Critical  period
     Time between storms critical  period = 69.11 hrs
                                      19.66 in.
                                      61
                                      0.32 in.
                                      0.52 in.
                                      9.53 hrs
                                      November,  December and January
                                      A-20

-------
              Urban
              Runoff
Qus
                                  Arkansas River
                                                                     Qds
              40
                      35
                              30
                                      25
                                              20
                                                      15
                                        River Miles
                                                               10
     FIGURE A-18. CONCEPTUAL SKETCH FOR TULSA, OKLAHOMA.
                                                 Location  Tulsa, Oklahoma
                                             Receiving water - Arkansas River
                  10
                          15
                                  20
                                          25

                                      Travel Time (hrsl
                                                  30
                                                          35
                                                                  40
                                                                                  50
             FIGURE A-19. D.O. CURVE FOR ARKANSAS RIVER.
                                 A  21

-------
                                TABLE A-11

                              SITE DATA TULSA
A. DEMOGRAPHIC DATA
Land Use
Urban
Combined Sewer
Storm Sewer
Suburban
Non Storm Sewer
Rural
Undeveloped
TOTAL
Area Pop. Density
(acres) Persons/acre
None
10,925 7.6
37,628 7.65
66,447 0
115,000
Total
Population
83,000
288,000
0
371,000
B.   STREAMFLOM DATA

     Qus  =  3,711  cfs
     Temp =  28.0°  C
     DO   =7.0 mg/1
                                     Qds  =  4,353  cfs
          = 4.6 - downstream
C. WASTE LOADING DATA
Land Use
or Source
Upstream Flow
Urban Combined Sewer
Urban
WWTP
TOTAL
BOD5
ft/day
81,970
0
38,100
17,514
137,584
UOD
#/day
274,700
0
85,400
42,534
402,634
SS
ton/day
1,000
0
840
Negligible
1,840
D.  RAINFALL DATA

     Total  annual rainfall  (5 years)
     Number of storms per year
     Mean depth per event
     80% storm depth
     Design duration
     Critical  period
     Time between storms critical  period
                                          49.97  in.
                                          82
                                          0.61  in.
                                          0.98  in.
                                          20.2  hrs
                                          July  through  September
                                          97.35  hrs
                                      A-22

-------
               APPENDIX B




             BASE DATA FOR




NEEDS ESTIMATION MODEL FOR URBAN RUNOFF

-------
                                                              BASF DATA
                                                      1176  NEEDS SURVEY CATEGORIES  S  R  f
EPA ST»TF N[).  URBANIZED ARFA NAME
 NO.  NO.
                           ci
                BRISTOL CT
                OANP1IRY CT
                HARTFORD CI
                «E-»Il>€N CT
                NE* BRITAIN CT
                •NEW H^VE-N CT
                NOHWALK CT
                SP-NI NGF1EI D »ETRO  CT
                STAMFORD CT
                wAfffWHiPy CT
                       N - AUBURN  ME
                         »E
                       MA
                BRHCKTON MA
                FALL RIVER MA
                FITCH8-ORG MA
                LAWRENCE MA
                LOWELL HA
                NEW BEDFORD MA
                PITTSFIELO Ma
                PROVIDENCE "FTRO  ft
                SPRINGFIELD MA
                WORCESTER MA
                LAWRENCE METRO  NH
                MANCHESTER NH
                NASHUA NH
                FALL PIVEP MtTRO  PI
                PRDVIOENCF RI
                ALLENTIIWN METRO NJ
                ATLANTIC CITY  NJ
                NEW YORK CITY  MTU  nj
                PHIL ADEI PHIA  MTR  NJ
                IPENTflN NJ
                VlNfLANO NJ
                WILMINGTON METRO  NJ
                ALBANY NY
                HlNGHAMPTON NY
                BUFFALO NY
                Nfw YORK CITY  NY






-












1
1
1
1-
1
1
1
1
1
1
?
2
2
?
2
?
?
?
?
2
?
7-
7
7
7
7 •
7
— 7-
7
7
7
7 -
?0
?0
??
?2
2?
??
2?
2?
?.?
2?
??
- ??
??
3"
311
30
00
to
31
31
U
31
31
31
31
33
33
33
13
1
2
3
0
5
6
T
8
-9
10
1 1
12
13
10
IS
16
17
18
19
20
?1
2?
21
?0
?5
?6
27
?8
?«
30
SI
3?
31
JO
35
36
37
38
39
00
STATE POPULAIU'NS COM SEWER OVERFLOW
1990 OBERS
1990 EPA
10BO PERSONS 1000
37tO.
3710.
3/10.
3711).
1710.
3710.
1710.
1710.
T 3710.
1710.
1710.
E 99?.
99?.
6876.
6H76.
6876.
6876.
6876.
6876.
6876.
6876.
6876.
6876.
6876.
919.
919.
919.
1115.
tits.
89?3.
89?3.
J 89?3.
89?3.
89?3.
89?3.
89?3.
?0906.
20906.
20906.
?090o.
1906.
3906.
1906.
1906.
1906.
3906.
3906.
3906.
3906.
3906.
1906.
1 10?.
1 10?.
7052.
7052.
7052.
7052.
70S?.
70S?.
70S?.
70S?.
70S?.
705?.
70S?.
1019.
1019.
101°.
1 1 11.
1 130.
8622.
88??.
88??.
88??.
»8??.
88??.
88??.
?1799.
?1 799.
?1 799.
?1799.
AREA
ACRE*
5.8
0.0
0.0
?0 . 8
0.0
0.0
10.9
1.5
0.0
0.0
1.8
8.0
15.3
? 1 . ?
0.0
7.?
1 .7
1 ? . 0
8.3
8.9
0.0
0.0
3?."
? . 1
0.0
7.0
0.9
0.1
? 1 . 0
0.0
0.0
?2. ?
20. 3
0.6
0.0
0.0
19.3
15.?
38.3
9?. 1
POP.
1000 PER
-•- -72.0
0.0
o-.o
275.0
0.0
0.0
179.0
55.0
0.0
0.0
22.0
08.0
86.0
135.0
0.0
92.0
21 .0
1?3.0
87.0
101.0
0.0
0.0
250.0
30.0
0.0
71.0
36.0
10.0
333.0
0.0
0.0
1200.0
?01 .0
0.0
0.0
0.0
?7t .0
1 05.0
60?. 0
5760.0
URB4NTZED
POP.

013366.
7171?.
66651 .
065001 .
98050.
1 31 309.
308301 .
106707.
58173.
180898.
156986.
65? 1 ?.
106599.
2652575.
1 08600.
123091.
78053.
18?038.
182711 ..
1 31667.
6?87?.
65970.
056135.
207016.
17802.
95100.
60961 .
15901.
7?9337.
25201.
130016.
0837265.
700Q05 .
?0?673.
71579.
?I593.
086525.
167??0.
1086590.
1 1369576.
AREA
AREA SQMI

108. 8
37.3
50.9
1 30.5
70.7
39.1
107.3
01.5
?6.7
69.6
59.9
67.9
55.7
660.0
5?. 5
30.5
60.9
7?.0
6?. 1
33.7
03.fr
Ol.o
?1 1 . 1
8fl.o
1 ? . o
39.1
31.5
l?.o
?00.?
6.9
67.1
?005.0
09,1
50.8
65.3
1 ? . 7
150.5
5?. 3
?1 1.7
IbO. 1
SMS' PflPUL
1070

790588.
8l«565.
790588.
818565.
706610.
8)8565.
706610.
79058S.
580038.
790588.
706610.
170577.
19?786.
3715118.
371S118.
OOS069.
639071.
3715118.
3715) 18.
005069.
100fc60.
7708?0.
580018.
639071.
3715) 18.
??5?51 .
??5?5 1 .
005069.
770820.
5070B3.
17S8?0.
15S62?t7.
0853200.
3052?3.
121807.
SOI 198.
7??H15.
303?no.
1350597.
15862217.
ATTONS AVR I.J.
1990 f

986100.
1007200.
986100.
1007200.
859500.
1007200.
859500.
9861 00.
601700.
986100.
859500.
?61000.
?11000.
0567600.
0567600.
079100.
759100.
056760U .
0567600.
079)00.
180000.
890700.
601700.
759100.
0567600.
100000.
300000.
079|00.
890700.
601600.
1 99<,00.
18798000.
5678500.
010?00.
165600.
605100.
860900.
3?6800.
1170?00.
18798000.
>E" rsn

110.
110.
110.
110.
110.
310.
110.
110.
110.
110.
110.
138.
138.
?27 .
?27.
?27.
?27.
?27.
??7.
??7.
?27.
?27.
??7.
??7 .
107.
107.
107.
1 ?7.
t?7.
163.
161.
161.
161.
161.
161.
163.
?08.
?08.
208.
?08.
FPA
COST
INDEX
1 .3??3
1.3??3
1 . 3?23
1 . 3221
1 . 3??1
1 . 322. 3
1 . 3?23
1 . 3?21
1 ,3?23
1.3223
1 . 3223
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1.113?
1 .0826
1.1818
1 . 3223
1 . 1"18
1.0826
1 .1818
1.1818
1 . 3??i
1 . 3??3
1 .0700
1 . 3??1

-------
                                                                           (USE  04TA
                                                              EPA  197e  NEEDS  SlJOVFY C4TFGDRTES 5 i.
to
t M 4
NO.
?
2
?
3
3
3
3
3
•3
3
3
3
•3
3
3
3
J-
3
3
3
3
7
3
3
3
3
3
3
1
3
3
1
11
4
4
4
4
4
4
1
S 1 A 7 t
}7
33
33
8
9
21
21
30
39
39
3«
39
39
39
39
39
39
39
39
39
47
17
17
47
47
47
47
49
49
49
40
1
I
1
1
|
1
t
10
10
"JU.
11
42
43
44
45
46
47
48
49
50
51
52
57
54
55
56
57
58
59
60
61
t>2
6?
64
6S
66
67
68
60
70
71
72
75
74
75
76
77
78
79
80

ROCHESTFR NY
SYPACUSF NY
UTICA - ROME k!»
"ILMINGTDM Of
WASHINGTON r>C
BALTIMORE Mr)
WASHINGTON DC MTH
ALLENTUnN P4
ALTnilNA PA
ERIE PA
HAPRISHMWG PA
JOHNSTOWN PA
LANCASTER ^4
PHH 40ELPHIA PA
PITTSBURGH PA
READING PA
SC»»NTI1N PA
TRENTON MFTRU pi
hILKtS-BAPpF PA
YMRK PA
L'TMCH^ERG V4
nFuPURT NFnS VA
NO£Ff.H K V4
PE1FRSBURG V4
HICHHONO VA
R04NTIKE VA
*ASHINGTUN f^C '-iTR
CHARLESTiA *V
HUNTINGTllN >.V
SltHBENVH LF MTR
"HEELING WV
BIRMINGHAM AL
CIILI'MRUS ^ttRfl AL
GAQSDEN 41
HliMTSVlLL1: AL
MHBILF AL
MONTGOMERY 4L
TUSCALIjnSA 41.
FT LAHOEKOALE FL
GAINESVILLE FL
                                                  STATE POPULATIONS    C
                                                   loon imfRS  1090 FP4
                                                       HiOO PFKSOWS    I
20916.
20916.
20016.
707.
750.
5275.
5275 .
1 5416.
13416.
13416.
1 3416.
3416.
3416.
3416.
74 1 6.
3416.
1 311 6.
1 3116.
13416.
6135.
6] 35.
6135.
61 35.
6135.
6135.
61 35.
1815.
1845.
1845.
1845.
4090.
4000.
4 0 0 0 .
4000.
1 0 9 u .
1090.
400Q.
10978.
1007H.
21799.
21 799.
21 709.
793.
764.
5318.
5318.
17312.
1 3312.
1 7342.
1 3312.
17312.
1 "7312 .
17342.
17342.
1 7312.
17312!
1 3312.
1 5312.
50SR.
5958.
59SR.
5958.
595S.
5958.
= 9s8.
1815.
1815.
1845.
1845.
3850.
38^0 .
7850.
7850.
3850.
*850.
38^0 .
1 1728.
11728.
HER 1
RF4
CRES
11.3
13.2
2 . 5
9.2
12.7
0.2
0.0
0.4
1.5
1.1
0.1
2. 1
4.R
10.9
31 .5
0.0
17.1
0.0
5.9
0.0
10. U
0.7
0.0
0.0
11 -fc
0.7
0.0
6.8
10.1
6.6
6.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
0.0
WERFLOW
POP.
1000 PF»
?10.0
159.0
30.0
78.0
400.0
1.6
0.0
q . Q
17.0
51 .0
6.0
21.-0
54.0
159.0
667;0
0.0
148.0
0.0
71.0
0.0
70.8
0.9
•0.0
0.0
200.0
3.0
24.0
16.4
85.0
37.0
60.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
URBANIZED
pnp .

601 361 .
376169.
180355.
34°67l .
75651 0.
1570701.
10001 38.
738316.
81795.
1 7526J.
210751 .
06146.
1 17007.
327702] .
1816042.
167972.
204205.
31175.
222870.
1 23106.
70842 .
268263.
668250.
100617.
116563.
156o21.
715811 .
157662.
8^0 1 7 .
37230.
60705.
^58000.
25281.
67706.
116565.
257816.
138983.
85875.
617707.
60329.
AOt A
A P E a S G M I

115.7
96.?
74.6
97. 1
61 .4
709.6
24«.0
91 .6
1 °. 6
47.8
78.4
28.0
38.7
702.7
596.4
11.1
08.4
17.1
82.5
37.3
37.2
143.7
290.0
42.1
111.6
66.4
185. 1
61 .8
10.1
2-6,*-
?o.o
221.6
l».7
55.?
127. 1
168.1
51 .1
17.7
212.2
29. f,
•SMS4 PnPIIL
1070

883574.
637251.
741019.
Sfll IQfl.
2«65012.
2078370.
?8n5012.
•=47083.
1 36203.
2656^1.
4] 3440 .
264519.
322501.
4853201.
2116936.
?082Q2.
?3^1?1 .
70^223.
744275.
332022.
1235°3.
292442.
681261 .
1 1 3H22.
5J"39"33.
181612.
jflhs;01 2.
22°748.
254 157 .
166022.
187008.
740742.
23°107.
94371 .
228692.
777479.
201725.
1 16250.
627717.
1 05677.
ATHJNS
1 OOO

1247000.
747900.
351 100.
6451 00.
4383100.
2750400.
1787100.
607600.
152000.
33?oOO.
510400.
252300.
402000.
5678500.
2510200.
733500.
2881 01).
"10200.
12°200.
412800.
174200.
337300.
732000.
157400.
736010.
251 100.
178*100.
210500.
P60.00Q.
152100.
'7=300.
882900.
248100,
1 16100.
711 200.
157400.
235800,
1 40900.
1204500.
162400.
4vr- O.A.
PER C$r

20".
208.
208.
?2*> .
187.
210 .
210 .
111 .
111 .
141 .
Ill .
111 .
Ill .
111 .
141.
Ill .
141.
111 .
11' .
111 .
177.
17*.
17*.
177.
17*.
177.
1 7*.
75.
75.
75.
75.
10000.
1 0000 .
1^0 0 0 0 .
1 0000.
1 0000.
1 0000.
10000.
80.
88.
FP4
COST
IMnEX
.0714
.3227
. 3223
.1818
.0087
.0087
.0087
.0826
.0113
.0744
.0087
.0113
.0826
.1018
.0117
.0826
.3223
.0026
.3223
.0083
. OOB*.
.0087
.0063
.0087
.0087.
.0087
.0087
.0731
.07,31
.0117
.OH 7
0.8264
0.8717
0.8264
0.8264
0.9256
0.8?64
0.8?64
0.8843
0.8747

-------
                                                                            RASE DATA
                                                               EPA  1976  NEEDS SURVEY CATEGORIES 5 H 6
T
              EPA STATE Nil. -URBANIZED AREA NAME
               NO.   HO.
JACKSONVILLE FL
MIA»I FL
ORLANDO FL
PENSACDLA  FL
ST PETERSBURG FL
TALLAHASSEE FL
TAMPA FL
WEST PALM  BF.ACM Fl
ALBANY GA
ATLANTA GA
*UGU3TA GA
CHATTANOOGA METRO r.«
CIlLlWBUS GA
MACPN GA
•SAVANNAH GA
CINCINNATI  METRO Ky
HlHuUNGTON  METRO
LEXINGTON  KY
LOUISVI-LLE  KY
UWENS8I1PI1  KY
BILOXI  -  GULFPIIRI
JACKSON  MS
MEMPHIS  MFTRP MS
ASHEvlLLE  NC
CHARLOTTE  NC
DURHAM NC
FAVETTEVHLF NC
GREFNSBORO  NC
1-IIl.HPflINt  NC
RALEIGH  NC
•ILMlNGTON  NC
HlNSTr>N-S»LEM NC
AUGUST-A  MFTHfl SC
CHARLESTON  SC
COLUMBIA  SC
GPEENVILLE  SC
CHATTANtlllr.A TN
KNIIXVILLE  TN
MEMPHIS  IN
NASHVILLE  TN
«
4
a
a
4
a
4
4
4
4
4
4
4
4
•4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
U
U
te
10
10
10
10
10
10
10
It
11
1 1
11
11
11
1 1
1«
te
18
ifl
18
?s
25
25
34
34
34
34
34
34
31
34
il
41
41
41
ill

-------
                                                                          BASE  0«TA
                                                             EPA 1976 NEEOS  SURVEY CATEGORIES 5 & 6
            EPA STATE  MO.  URPAN'IZED AH^A NAME
             NiO.  NO.
W
STATE POPULATIONS    COM SEXffff OVERFLOW    US8AMZEO  AREA      SMSA POPULATIONS     A~VG  Pit.   E-PT* - -
 1990 06EHS  1990 EPA     AREA      POP.     POP.     AREA  SO"I   1970      1990    PER  CSD   COST
     1000 PERSONS    1000 ACHES 1000 PER                                                 '     I"0£-X~
	 5
5
' ~5
S
5-
5
- 5
5
5 '
5
5
5
5~
5
"- 5
5
5-
5
	 5-
5
5
5
"- 5
5
	 5 	
, 5
- 5
5
5
5
5
•S
5
5
5
-5
5
5
S
- ta-
li
1 a
1 4
14
1"
14
11
14
14
10
14
TV
15
15
15
15
15
"15
15
15
15
23
23
-2J
23
23
?3
23
23
23
23
23
20
24
2t
24
24
36
121
122
1"23
124
125
!?6
127
1?»
129
1 JO
131
132
"1 33"
134
T35
136
137
136
139-
140
101
112
143
114
115-
116
147
148
149
150
152
153
154
155
156
157 -
158
159
160
-A-ijRn
-------
                                                                        BASE  DATA
                                                            EPA  1976 NEEDS SURVEY CATEGORIES 5 & 6
W

Ln
PA STATE
NO. NO.

5-
5
5
5
5
5
• 5-
5
5
5
5
5
?-
S
5
5
5
5
'5
5
5
5
-5
5
— s~
6
6
6
6
6
~tf"
6
6
6
6
6
" »-
6
— 6-
6

- 36
36
36
36
36
36
36
36
36
36
36
36
36
36
36
50
50
50
5O
50
50
50
50
50
... ._(,
4
4
4
19
19
19
19
19
32
37
	 37-
37
	 JT-
44
NO.

16]
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
1"79
180
181
182
183
184
URBANIZED AREA NAME STATE POPULATIONS COM
1990 0«ERS 1990 EPA

CANTON OH
CINCINNATI OH
CLEVELAND OH
COLUMBUS OH
D«YTON OH
HAMILTON (1H
-HUNTINGTON "ETRO OH
LIMA OH
LORAIN - ELYRIA OH
MANSFIELD OH
SPRINGFIELD UH
STEUBENVILLE OH
TOLEDO OH
WHEELING METRO OH
YOUNGSTOWN OH
APPLETON Ml
DULUTH *ETRO WI
GREEN BAY Ml
LA CRDSSE WI
MADISON HI
MILWAUKEE WI
OSHKOSH WI
RACINE WI
185 	 FORT S«IITW AR
186
187
188
189
190
~m~
192
193
194
19?
196
T97-
198
199
200
LITTLE ROCK AR
PINE BLUFF AR
TEXARKANA METRO AR
BATON ROUGE LA
LAFAYETTE LA
MONROE LA
NEW ORLEANS LA
SHREVEPORT LA
ALBUQURQUE N*
FORT SMITH METRO OK
V»TOF TJK 	
OKLAHOMA CITY OK
"TtJLSA-UK ~ ' "
ABILENE TX
1000
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
12609
5013
5013
5013
5D13
5013
5013
5013
5013
5013
—2271
2271
2271
2271
3936
3936
3936
3936
3936
1131
2993
	 FTO
2993
-2**S
1 3580
SEWER OVERFLOW
AREA POP.
URBANIZED AREA
POP. AREA SQMI
SMSA POPULATIONS AVG D.A. EPA
1970 1990 PER CSO COST
PERSONS 1000 ACRES 1000 PER
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
13202.
5218.
5218.
5218.
. -' 521D. — -
5218.
5218.
5218.
5218.
5218.
.--- -2225.
2225.
2225.
2225.
. 4159.
1159.
. ' ' ' "U 139.
4159.
4159.
1159.
I30t>.
2912.
. 	 2942; - -
2912.
,' ' " "2^1 2v — —
15351.
o.a
73.1
39.2
11.2
0.0
2.1
1.6
10.1
0.1
0.0
7.3
1.2
15.9
0.7
13.7
2.0
0.0
0.9
1.4
0.5
0.0
17.8
0.0
0.0
*; 3
0.0
0.0
0.0
0.0
0.0
o-. o -
0.0
0.0
0.0
0.0
0.0
- o.-o
0.0
0.0
0.0
0.0
776.0
665.0
175.0
0.0
35.0
12.7
70.0
5.0
0.0
72.0
48.0
204.0
7.0
172.0
29.0
0.0
10.0
20. 0
6.0
0.0
419.0
0.0
0.0
30.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
244279.
913536.
1959880.
790019.
685942.
90912.
29250.
70295.
192265.
77599.
93653.
48262.
475928.
32239.
395540.
129532.
32713.
129105.
84262.
60231.
205457.
1252457.
55480.
117408.
75419-.
222616.
60907.
21682.
249463.
78544.
90567!
961728.
234564.
297451.
2098.
-—95-687;
579788.
371499-.
90571.
77.2
275.2
616.1
231.5
224.2
38.2
13.8
27.4
106.4
40.9
25.3
12.3
156.6
6.9
126.6
37.1
39.6
77.6
2li2
68.6
156.5
12.6
28.1
--57.6
95.3
20.8
6.8
64.6
24.9
33.5
10.1
- 84.0
94.3
1 1 4 ."4
2.7
— 	  1 - -0'. 9256—
2000. 0.9256
2000". 0 • 9256
2000. 0.9256
"2000 . ~0". 9256 -
2000. 0.9256
2OO"Ov —"0^8.843
2000. 0.7934
2000 . *. 7934
2000. 0.7934
"2ooo . r. oooo
544. 0.7934

-------
                                                           EPA
                                                                       BASE DATA
                                                                    NEEDS SURVEY CATEGORIES 5*6
W
tP»-STATE MO. URBAMZEn JREA NAME STATE POPULATIONS COM SE»ER OVERFLOW
N0- N0> 1990 08ERS 1990 EPA AREA POP.

--«-
6
6
6
6
f>
- 6~
6
6
6
- 6
h
6
- "6"
6
— -6-
6
fa
-fa
6
6
fa
— 7—
7
7
7
7
7
7
7
7
--T-
7
7
7

"44 201 A1ARILLO TX
44 202 AUSTIN TX
--44 203 BEAUMONT TX
44 204 BROWNSVILLE TX
aa 205 BRYAN TX
aa 206 CORPUS CHRISTI TX
- 44 207 DALLAS TX
aa 206 EL PASO TX
aa 209 FORT WORTH TX
aa 210 GALVESTON TX
44 211 HARLINGEN TX
44 212 HOUSTON TX
44 214 LUB80CK TX
" 44-215 TTCALLEN - PHARR TX
44 216 MIDLAND TX
04 2rr ODESSA TX
44 218 PORT ARTHUR TX
aa 220 SAM ANTOMIO TX
- 44 221 SHERMAN TX -
aa 222 TEXARKANA TX
aa 224 TYLER TX
aa 226 WICHITA FALLS TX
- 16— J2T- -CEDAR RAPTOS IA
16 228 DAVENPORT IA
Ifa 22^ Of S *IOINES IA
16 230 DUBUQUE IA
16 232 SIOUX CITY IA
16 233 WATERLOO I A
17 23a KANSAS CITY METRO US
17 235" ST JTJSEPH METRO KS
17 236 TOPEKA KS
- IT 237 -otrtRir* KS 	 	 —
26 238 COLUMBIA HO
26 239 KANSAS CITY MO
26 240 SPRINGFIELD MO
1000
13580.
13580.
13580.
135BO.
13580.
13580.
13580.
13SBO.
13580.
13580.
•13580.
13580.
13580.
13580.
13580.
13580.
13580.
13580.
1 3580".
13580.
13580.
13580.
13580.
2993.
2903.
2993.
2993.
2993.
2993.
2281.
— -3-381 .
2281.
2281v
5438,
- 5*38.
5438.
URBANIZED
POP.
AREA SMSA POPULATIONS AVf, n.A. EPA
AREA SQ*! 1970 1Q90 PE9 CSO COST
PERSONS 1000 ACRES 1000 PER
15351.
15351.
1S351.
15351.
15351.
15351.
15351.
15351.
15351.
15351.
15351.
15351.
15551.
15351.
15351.
15351.
r5351.
15351.
15351.
15351.
- 15351;
15351.
1 5 35 1 .
15351.
15351.
3053.
3053.
3053.
3053.
3053.
3053.
2509.
2509.
2509.
	 251f9-. —
5488.
548«.
5488.
O.n
0.0
2.8
0.0
0.0
0.0
0.0
0.0
0.0
1.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
o.o -
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.3
4.0
0.0
0.0
0.0
8.0
0.2
3.7
- - o.o -
0.0
21.0
0.0
0.0
0.0
38.0
0.0
0.0
0.0
0.0
0.0
0.0
40.0
0.0
1.0
0.0
0.0
0.0
0.0
0.0
0.0
o.-o-
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.0
11 e . o
0.0
0.0
0.0
76.0
1.1
45.0
-0.-0-
0.0
308.0
0.0
127010.
2641.99.
116350.
52627.
51395.
21?820.
133(684.
337471.
61*944.
61809.
50469.
1677863.
70197."
150135.
911*1.
60371.
81645.
116474.
63884.
772513.
55343.
36888.
84054.
59781.
97564.
132008.
126295.
255824.
63143.
87157.
112881.
350208.
1283.
132108.
502*34-.-
59231.
751579.
121340.
60.7
85. P
74.5
15.2
33.4
130.3
674.2
119.4
396.8
22.5
33.8
538.6
'22. 1"
76.9
32;7
32.0
-25.1
73.0
222.9
34. -5
2a.O
82.7
24.8
82.2
•fa-2.0
82.9
-i O9vi-
17.2
56.0
69v*"
85.9
r.2
52.8
	 t05^t—
42.0
-407.3
63.1
145135.
297027.
317558.
1111086.
58275.
286289.
15639«B.
361128.
765983.
170681.
141086.
1995164.
7JZS2,
180212.
182464.
65768.
-92275".
317558.
71410.
8fc8433.
-8-3651.
101592.
1 TO 611 1'.
97593.
3891fc6.
163500.
363344.
28
-------
                                                                         BASE DATA
                                                             EPA 1976 NEEDS SURVEY CATEGORIES 5 i 6
W
             EPA STATE NO. URBANIZED AREA NAME
              NO.  NO.
       ST JOSEPH f»9
       ST LOUIS MO
       LINCOLN NE
       OMAHA NE
       SIOUX CITY METRO N£
       BOULDER CO
       COLORADO SPRINGS CO
       DENVER CO
       PUERLD CO
       BILLINGS MT
       GREAT FALLS MT
       FARGO NO
       SIOUX CITY METRO SO
       SIOUX FALLS SD
       OGDEN UT
       PROVO UT
       SALT LAKE CITY  UT
       PHOENIX AZ    '
       TUCSON- *2  - - -
       BAKERSFIELD CA
       FRESNO CA
       LOS ANGELES CA

       OXNARD CA
  2*5 —3fttR*WEN7t> CA	
       SALINAS CA
       SAN BERNA9BINO  CA
       SAN DIEGO CA
       SAN FRANCISCO CA
       SAN JOSE CA
5—27 r -SAKTA-B-AIWUftA--C*	
       SANTA ROSA CA
       SEASIDE CA
       SIMI VALLEY CA
  275 -STOCKTON CA
       HONOLULU HI
     '— CHS VCGA3 ' WV
       RENO NV
       Borst -CTTY iti -
       EUGENE OR
• 7
7
7
7
- 7
8
' " 9
6
6
a
8
8
8
8
8
8
8
9
9
9
9
9
• 9
— -9-
9
• 9 -
9
9
9
9
- 9
9
—9
9
9
-to—
10
?6 ?41
26 242
28 243
28 ?44
28 245
6 246
6 247
6 248
6 249
27 250
27 251
35 252
42 253
42 254
45 255
45 256
45 257
3 258
5 260
5 261
5 262
5 265
5 264
- 5- 2*5-
5 266
5 267
5 268
5 269
5 270
- •« — »Tt—
J £11
5 272
5 273-
5 274
5 275
12 276
29 27«
TS "279-
38 280
STATE POPULATIONS
1990 OBERS
1990 EPA
1000 PERSONS
5436.
5438.
1557.
1557.
1557.
2890.
2890.
2890.
2890.
664.
664.
563.
647;
647.
1310.
1310.
1310.
2701.
24982!
24982.
24982.
- 24992.
24982.
24982 •
24982.
24982.
24982.
24982.
24982.
• " 24*992. .
24982.
24982.
24982.
-24992. -
979.
761.
	 -nr.
2537.
5488.
5486.
1562.
1562.
1562.
3400.
-3400.
3400.
3400.
757.
757.
606.
643.
643.
1509.
1509.
1509.
3384.
.- -—AUU. .
JJO"**
26601.
26601.
26601.
26601.
26601.
2660l!
26601.
26601.
' 26601.
26601.
26601".
26601.
— 866-0 1.
26601.
-"ZfctfOl •
1132.
-9^3.
933.
	 90-0.
2943.
COM SEWER OVERFLOW
AREA
1000 ACRES
14.2
112.7
0.0
20.9
0.0
0.0
9.0
0.3
1.2
0.0
0.0
0.4
0.0
0.2
0.0
0.0
0.0
0.0
'- 0.0
0.0
0.0
0.0
0.0
0.0
-•• 5.6
0.0
0.0
o.o
54.1
0.0
"- "0 .'0
0.0
0.0
0.0
0.0
0.0
2i4
	 o.o
0.0
POP.
1000 PER
75.9
1096.0
0.0
296.0
0.0
0.0
0.0
8.0
22.0
0.0
0.0
4.2
0.0
2.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
o!o
0.0
0.0
1410.0
0.0
- 	 — o.o- ,
0.0
0.0
0.0
0.0
0.0
3s!o
-• --o.o -
0.0
URBANIZED
POP.

75940.
1568466.
153443.
426929.
7920.
68634.
204766.
1047311.
103300.
71197.
70905.
53420.
660.
75146.
149727.
104110.
479342.
863357.
?9 ill" 61 7"
176155.
262908.
8351266.
106107.
244653.
6 33"7"3-2 V "
62456.
583597.
1198323.
2987850.
1025273.
75063!
93284.
56936.
16037-3.
442397.
99687!
85197.
139255.
AREA SMSA POPULATIONS
AREA SQMI

30.7
349.9
52.1
110.2
3.6
14.1
90. -0
292.8
31.5
26.9
21.8
15.3
0.7
26.9
61.0
65.0
184.3
387.5
57.2
79.1
1571.9
3*1.3
111.5
— 244.2 —
15.0
309.7
360.7
681 -.-0
277.2
38. 2
24.1
24.8
- -44.9-
115.0
37!s
-- -29.*
55.3
1970

87205.
2370219.
168694.
545273.
116431.
1237392.
237668.
1237392.
119188.
87692.
82109.
120474.
116431.
95173.
127057.
139691.
562678.
979151.
329753!
413590.
9607592.
H51W.
379415.
— 803997^
248913.
1147639.
1357482.
3363777.
1071796.
— 264502.
205046.
-249913.
379415.
292660.
621269.
275671 .
122124.
-tt£B59;
214440.
1990

85300.
2716800.
205400.
636500.
109400.
1783500.
- 271 tOO.
1783500.
130000.
99500.
79800.
127200.
1-09400.
110900.
160800.
177300.
717000.
1625100.
363200!
445700.
12000400.
238300.
505800.
" ' '1 006300 ;-
289200.
1481400.
1776700.
4155*00.
1688000.
349300 .'
240600.
- 299200.
505800.
- 325-700;
641800.
*1 900O;-
199600.
--135*00.
263100.
AVG D.A,
PER CSO

415.
415.
2000.
2000.
2000.
1608.
-t«-06-.—
1608.
1608.
920.
920.
193.
•9*f-; —
847.
277.
277.
277.
1786.
1766.
1635.
-1635-;-
1635.
- t-63^-.
1635.
— 1635. —
1635.
1"6 35 . - -
1635.
1635i -
16 35-.
- — 1635. —
1635.
-1*35"T
1635.
— 1635-r-
239.
	 276. —
276.
-1-Wr-
448.
. FPA
COST
INDEX
liOOO*
1.1570
i.oeoo
I. 0000
0.-9091
0.8643
-«-.-9*«3
0.8643
0.8643
1.0330
1.-0330
0.9091
0.9091
0.9091
0.9643
0.6843
*.9**3
1.0578
tACTn
• 05 f ™
1.0578
— 1-.-TKT
I. 0578
-1"i1l5^
1.0578
	 1 i 1 157
1.1157
— l'i"0576
1.0578
"Irt-t57
1.1157
— 1 .0570
1.1157
— 1.1157
1.0578
- 1 i~l 157
1.7000
— 1 .0570
1.1157
— 1.0330
1.0330

-------
                                                                            BASE  DAT*
                                                               EPA  1076  NEFDS  SURVEY  CATEGORIES  5  J  6
W

00
               EPA  STATE  NO.  UR6ANI7EO AhpA NAME
                 NO.   NO.
PORTLAND  HP.
SALEM OR
PORTLAND  METRO  HA
SEATTLE HA
SPOKANE *A
TACOMA MA
MELBOURNE - COCOA  fL
SARASOTA-SPADENTON
DAYTONA BEACH FL
NEH LONDON-NORWICH C
GASTONIA  Nt
RiCHLANO-KENNErtICk  #
POUGHKEEPSIE NY
ANCHORAGE AK
KINGSPORT TN
KINGSPORT MFTRO VA
FORT MYERS FL
FLORENCE  AL
ALTON IL
KILLtFN TX
CLAPKSVTLLE TN
CLARKSVILLE MFTRO  KY
ANNJSTON  AL
ALEXANDRIA LA
SPART'NBlfRG sC
SANTA CRUZ C»
BATTLE CREEK MI
BURLINGTON NC
LAKELAND FL
ELMIRA NY
ANTIUCH-PITTSBURG  CA
YAKTMA WA
WILIIAMSPOWT PA
PARKERSRUKG WV
PARKEHSRUPG METRO  i iH
ST CLOUD MN
CAGIIAS PR
MAYAGUEZ PR
PONCE pR
SAN JUAN PR
10
10
10
10
10
10
1
1
4
1
1
10
2
10
1
3
1
1
-•5
6
1
4 .
a
6
i
9
5
1
1
2
9
10
3
3
5
5
2
2
2
2
38
38
18
18
*8
18
10
10
10
7
3«
18
33
2
13
17
10
1
1*
11
13
18
--- 4
1«
11
5
23
31
10
33
5
18
39
19
36
21
53
53
53
53
281
282
283
281
286
286
287
288
289
290
2"!
292
293-
291
205
206
207
298
299
300
301
302
JO 3
301
305
306
307
308
309
310
311
312
313
311
315
316
317
318
319
320
STATE POPULATIONS COM
1990 01ERS 1990 FPA
SEHER OVERFLOW
AREA POP.
URBANIZED AREA SMSA POPULATIONS AVR '• , A .
POP. AREA SQMI 1970 1090 DER CSO
1000 PERSONS 1000 ACRES 1000 PER
2537.
2537.
3806.
5906.
3806.
3806.
10978.
10978.
10978.
5710.
6165.
5806.
?00(I6.
391.
5190.
6135.
10978.
1090.
13056.
13580.
519Q.
3982.
1090.
3936.
3122.
21982.
10045.
6165.
10978.
20916.
21082.
3H06.
i31it>.
1815.
12609.
1553.
3777.
3777.
3777.
3777.
2913.
29113.
ti 191 .
«1 "a.

-------
                                                                            BASE  DATA
                                                               EPA  1976  MEEDS  SURVEY CATEGORIES S
T
VO
                PA  STATE Nil. URBANIZED AREA  NAME
                NO.   NO.
BRIDGEPORT CT
PRISTHL CT
r>ANBLl»Y CT
HABTFURO CT
MtRIREN CT
NEW BRITAIN CT
NEW HAVEN CT
NIIHWALK CT
SP9IMGFIFLD METRO CT
STAMFOPD CT
WATE»BURY CT
LEWISTON - AUBURN It
POOTLAND ME
PUSTON MA
BROCKTON MA
FALL RIVFR KA
FITCH8URG MA
LAWRENCE MS
LOWELL MA
NEw BEDFORD MA
PITTSFIELO MA
PROVIDENCE MFTRO  "A
SPRINgFIFLfl MA
WORCESTER MA
LAWRENCE MFTRO  NH
MANCHESTER NH
NASHUA NH
FALL RIVER MFTRl)  t< I
PROVIDENCE RI
ALLENTOWN METRO NJ
ATLANTIC CITY NJ
NEW YORK CITf MTP NJ
PHILADELPHIA MTR  vj
TRFMTON NJ
VlNELAND NJ
klLMlNGTON MFTRU  f'J
ALBANY NY
RINGHAMPTIIN NY
BUFFALO NY
NtW YI.IBK CITY NY
7
7
7
7
1
1 7
7
7
1 7
1 7
1 7
1 20
I 20
1 22
1 22
1 22
22
22
22
22
?2
22
22
22
30
30
30
10
10
2 31
2 31
2 31
2 31
2 31
2 31
2 31
2 33
2 33
2 33
2 33
1
2
3
1
•S
6
T
8
4
10
11
12
13
11
IS
16
17
18
19
20
21
22
23
21
25
26
27
28
20
30
31
32
33
31
3S
36
37
38
30
10
NO. STORMS
PER YEAR
110.
128.
1 19.
128.
12fi.
128.
1 31.
11°.
1?R.
1 1".
128.
125.
125.
i2«.
135.
123.
129.
128.
128.
123.
IS?.
123.
128.
12°.
12".
120.
120.
121.
123.
1??.
1 1?.
1 1".
1 1S.
121 .
1 IS.
127.
IH.
1 33.
16S.
1 1".
AVERAGE
YEARLY RAIN
12.01
12.13
12.01
12.13
11. 11
12.11
11.99
12.01
US. 11
12.01
17.26
i3.se
12.85
12.77
10. °6
15.28
IS. 71
10. OB
13.31
11 .OS
11.12
30.63
IS. 11
IS. 11
10.06
13.20
12. t3
15.28
30.63
11.12
13.78
12.38
12.18
11 .28
13. 7a
11.36
37. OS
3h.21
3S.6S
12.37
STREAMFLOW
CFS
0.
3").
80.
6800.
131.
32.
106.
22.
sinn.
0.
65.
3200.
0.
100.
2.
220.
78.
2100.
2100.
0.
16.
270.
S100.
20.
2100.
1 700.
1700.
220.
270.
1300.
0.
S200.
7000.
S700.
105.
7200.
1020.
660.
160000.
S200.
PER CENT IIA
DRAINED STREAM
100.
100.
loo.
80.
loo.
"0.
100.
100.
100.
100.
100.
loo.
100.
loo.
to.
100.
100.
100.
100.
100.
00.
100.
100.
30.
loo.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
loo.
100.
100.
100.
60.
STREAM
CLASSIFICATION
is
1
1
3
2
1
1?
IS
%
3
2
3
11
10
1
q
1
3
3
is
1
Q
3
1
3
3
3
q
q
3
IS
11
1?
s
2
1 1
1
1)
s
11
 5
 6
 7
 8
 <>
1 0
1 1
12
1 }
11
15
16
17
18
10
20
21
?2
?3
2U
25
26
27
28
20
30
M
32
33
?J
3S
3t>
37
38
39
10

-------
                                                           BASE  DATA
                                               EPA  1976  NEEDS SURVEY  CATEGORIES S H  6
•A  STATE NO. URBANIZED AKFA N4MF
JO.   NO.
               POCHESTE9 NY
               SYRACUSE NY
               UTICA - »OHE NY
               WILMINGTHM OF
               WASHINGTON DC
               BALTIMORE MR
               WASHINGrnN DC MTR ME
               ALIENTOWN PA
               ALTOONA PA
               ERIE PA
               HARWISBURG PA
               JOHNSTOWN PA
               LANCASTER PA
               PHILADELPHIA PA
               PITTSBURGH PA
               READING PA
               SCRANTON PA
               TRFNTON METRO PA
               WllKES-BARRE PA
               YORK PA
               LYNCH9FRG VA
               NEWPCR.T NEWS VA
               NORFOLK VA
               PETERSBURG VA
               RICHMOND VA
               ROANOKE VA
               WASHING!"*. Of MTR VA
               CHARltSTON wV
               HUM TING TON WV
               STF.URENVTLLE MTR  WV
               WHEELING WV
               BIRMINGHAM 1L
               CULUMH'IS METBl) AL
               GAPSHEN AL
               HUMTSVILLE AL
               MUBILE »L
               MONTGOMERY AI
               TuSCALOOSA AL
               FT LAUOERDALF FL
               GAINESVILLE FL
2
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
33
33
33
8
9
21
21
39
39
39
39
39
39
39
39
39
39
39
39
39
47
47
47
47
47
47
47
49
49
49
49
1
1
1
1
I
1
1
10
10
41
42
43
44
45
46
U7
4d
49
SO
51
52
53
54
55
S6
57
58
59
60
61
62
63
04
65
fco
67
bd
69
70
71
72
73
74
75
76
77
78
79
80
NO. STORMS
PFR YEAR
153.
167.
167.
127.
111.
1 1?.
111.
122.
It?.
157.
124.
ISO'.
121.
1 IS.
146.
120.
137.
121.
! 37.
121.
1 1".
1 11.
111.
115.
11 3.
120.
107.
15?.
136.
146.
116.
118.
110.
1 IS.
11(>.
123.
111.
11".
127.
1 16.
AVERAGE
YEARLY RAIN
31 .SO
37.60
3«.73
44.36
40.78
44.21
40.78
44.12
43.83
37. SO
37. 6S
44.77
43.29
42.48
36.87
41 .43
38.48
41.28
39.37
42.00
«0. 30
41 .95
44.94
44.21
44.21
43.12
40.78
42.36
41.79
40.83
38.95
53.52
48.67
54.95
52.07
67. 57
53.66
52.77
60.29
52.45
STREAMFLOW
CFS
580.
21.
900.
7200.
3400.
134.
3400.
1 300.
136.
0.
99SO.
520.
2tO.
7000.
12000.
1020.
130.
S700.
?750.
100.
830.
1000.
1000.
116.
865.
170.
3400.
7600.
44000.
13500.
13500.
40.
4126.
3820.
32000.
17000.
8800.
1900.
0.
0.
PER CFNT 'IA     STRFAM
DRAINFD STREAM   CLSSSIFICATION
                                                                                                                       NO.
    100.
     60.
    100.
    too.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
     65.
    100.
    100.
    100.
    100.
    100.
    100.
     80.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
    100.
     30.
    100.
    100.
    loo.
    ino.
    100.
    100.
    100.
    100.
 3
11
10
1?
10
 3
 1
IS
 2
12
 4
 3
 1
 5
 3
 1
 3
1?
12
 2
 3
 1
10
 4
 «;
 4
 4
  1
 h
  3
 5
1 1
  4
  3
15
  7
41
42
"3
44
45
46
47
48
49
SO
SI
S2
S3
54
55
56
S7
58
^9
to
61
h2
63
h4
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80

-------
                                                            BASF DATA
                                                EPA 1976 NEFDS SURVEY CATEGORIES 5*6
;PA  STATf  Nil.  URBANIZED AREA N»ME
 NO.   Nil.
        JACKSONVILLE FL
        MIAMI FL
        ORLANDO FL
        PENSACULA FL
        ST PETERSBURG FL
        TALLAHASSEE FL
        TA»PA FL
        WEST PALM BEACH FL
        ALBANY GA
        ATLANTA GA
        AUGUSTA GA
        CHATTANOOGA METRO GA
        COLUMBUS GA
        MACON GA
        SAVANNAH GA
        CINCINNATI MFTH'.I KY
        HUNTINGT1N METRO nY
        LEXINGTON KY
        LOUISVILLE KY
        OwENSflORO «Y
        BILOXI - tULFPORT MS
        JACKSON MS
        MEMPHIS METRO MS
        ASHEVILLF NC
        CHARLOTTE NC
        DURHAM NC
        FAY-ETTEVILLE NC
        r-REENSBiJRO NC
        HIGrlPOINT NC
        RALEIGH NC
        KILMINGTON NC
        WINSTON-SALEM NC
        AUGUSTA *ETRn SC
        CHARLESTON SC
        COLUMBIA SC
        GRFENVILLE SC
        CHATTANOOGA TN
        KNOXVILLE TN
        MEMPHIS TN
13 120  NASHVILLE TN
It
1











1
1
1
a
i
4
1
i
u
4
1
1
1
1
1
4
1
4
1
U
a
4
1
4
1
1
10
10
10
10
to
10
to
10
11
11
It
11
11
11
11-
18
18
18
18
18
25
2*>
25
31
31
31
3i
31
31
34
3<4
31
11
i|
41
11
43
43
13
61
62
83
81
85
86
87
88
69
90
Of
92
93
91
95
96
97
98
99
100
101
102
103
t01
I 05
106
107
108
109
110
111
112
113
111
115
116
117
1 18
119
NO. STOPMS
PER YEAR
116.
127.
11 '4.
us.
106.
1 19.
108.
131.
110.
1 1*.
105.
131.
110.
112.
IIP.
131.
136.
133.
122.
US.
123.
107.
11?.
127.
1 in.
113.
113.
117.
117.
113.
M5.
117.
10?.
IIS.
10^.
112.
131.
132.
112.
120.
AVERAGE
YEARLY RAIN
53.36
57. as
51.37
62.87
55.11
56.1)6
51.57
61.70
1)7. Pa
17. 11
3<>. IS
53.60
18.67
ai.08
18.91
39.31
11.79
03.71
11 .17
41.29
57.59
50.86
16.81
37.88
13.38
12.65
U6.11
12. IB
IS. 69
16.28
51 .29
IS. 69
39.18
16.51
1*1.82
16.12
S3. 60
15.51
16.81
15.10
STREAMFLOH
CFS
2500.
0.
10.
3500.
150.
500.
t-5-0.
0.
22)10.
!700.
6800.
30000.
1126.
950.
7560.
36000.
11000.
5.
39flOO.
3=000.
0.
320.
305300.
1350.
30.
7.
1200.
10.
6.
221.
2000.
30.
6800.
0.
6000.
50.
30000.
10103.
305300.
10500.
PFR CFNT IIA
DRAINED STRFAM
100.
100.
10.
100.
100.
80.
100.
100.
too.
70.
100.
100.
100.
IPO.
100.
110.
100.
10.
100.
100.
too.
70.
100.
100.
25.
10.
100.
10.
?0.
90.
100.
70.
100.
100.
too.
95.
1(10.
100.
IPO.
100.
STRFAM
CLASSIFICATION
10
15
7
10
1ft
fc
1ft
15
14
3
(.
h
(•
5
10
5
q
1
«;
c;
IS
3
5
2
1
1
3
I
1
2
11
1
1
1?
1
2
6
1
S
1
                                                                                                                         NO.
                                                                                                                            81
                                                                                                                            82
                                                                                                                            83
                                                                                                                            «1
                                                                                                                            85
                                                                                                                            86
                                                                                                                            87
                                                                                                                            88
                                                                                                                            89
                                                                                                                            90
                                                                                                                            °1
                                                                                                                            "2
                                                                                                                            93
                                                                                                                            91
                                                                                                                            95
                                                                                                                            96
                                                                                                                            97
                                                                                                                            98
                                                                                                                            99
                                                                                                                           100
                                                                                                                           101
                                                                                                                           102
                                                                                                                           IP3
                                                                                                                           101
                                                                                                                           I 05
                                                                                                                           106
                                                                                                                           107
                                                                                                                           108
                                                                                                                           109
                                                                                                                           110
                                                                                                                           11 1
                                                                                                                           112
                                                                                                                           H3
                                                                                                                           111
                                                                                                                           115
                                                                                                                           116
                                                                                                                           117
                                                                                                                           118
                                                                                                                           119
                                                                                                                           120

-------
                                                                              BASE DATA
                                                                  EPA 1976 NEEDS SURVEY CATEGORIES  5  &  6
W
 I
I-1
PA STATE
NO. UK9ANIZED ARFA NAME
NO. f4Q.
•-5 —
5
- 5
5
5
5
'-?•
5
— 5"
5
5
5
~5
5
- -5 -
5
- 5
5
-"5 —
5
~5
5
5
5
5
"5 ~
5
5
5
—5 	
5
5
5
5
5
- 5 	
5
5
5
14
14
14
14
14
14
14
14
14
14
14
14
15
15
15
15
15
15
T5
15
15
15
23
23
23
23
23
23
23
•23
23
23
23
24
24

24
24
36
T21
122
123
124
125
126
\?T ~
128
129
130
131
132
133
134
135
136
137
138
~T5* —
140
141
142
143
144
1*5 —
146
"147 -
146
149
150
TSt ' '
152
153
154

156
157-
158
159
160
AOTORA TL
PLOGnINGTON IL
CHAMPAIGN IL
CHICAGO IL
DAVENPORT -1ETRCI IL
DECATUR IL
OUBU3UE "ETRO IL
JOLIET IL
PEnRIA IL
ROCKFORD IL
SPRINGFIELD IL
ST LOUIS METRO IL
ANOERSON IM
CHICAGO METRO IN
EVAKSVILLE IN
FORT WAYNE IN
INDIA>ifAPnLIS IN -
LAFAYETTE IN
UtJUTSVTLL* -"ETW" H»~
MUNCIE IN
SOUTH SEND IN
TERRA HAUTE IN
ANN ARflOR MI
RAY CITY MI
FLINT MI
GR-AM) RAPID'S Ml -
JACKSON MI
KALAMAZOO "I
LANSING MI
WJSKEGON MI -- -- -
SAGINAh Ml
SOUTH BEND METRO H
TOLEDO METRO MI
DULUTK HN
FARGO METRO MN

MINNEAPOLIS MN
ROCHESTER MN
AKRON OH
NO. STORMS AVERAGE
PER YEAR YEARLY
ISO.
109.
' T12.
120.
110.
112.
-109. ' "
120.
109. ' '
112.
112.
104.
124-. '
12".
115.
129.
"1S4.
124.
- - • ~r?2-. 	
124.
— 1 36T"
124.
I 30.
129.
130.
129.
13Ti -
137.
137.
137.
	 — IdO; —
129.
136.
131.
1"35.
106.

113.
115.
141.
-S3
36
37
33
33
37
35
33
34
35
34
36
' 36
33
41
34
39
36

39
•35
41
30
2*
~"St>
30
31
31
34
31
' "30
28
35
31
28
18
28
24
28
37
RAIN
.80
.20
.00
.49
.88
.13
.71
.80
.84
.62
.83
.46
.71
.49
.37
.21
.69
.06

.11
.59
.66
.67
.73
.14
.19
.15
.48
.18
.07
.04
.59
.84
.97
.73

.78
.46
.26
STREAMFLUW
CFS
•550. -
110.
3.
0.
25500.
330.
22000.
2500.
8SOO.
2700.
330;
123000.
140. -
0.
44300.
140.
4SO-;
2800.
39000.-
50.
1700.
4900.
230.
1200.
23o!
1850.
70.
700.
340.
135*.
1200.
1700.
1100.
1400.
180.
- - 12500; '
5200.
100.
190.
PER CENT UA STREAM
DRAINED STREAM CLASSIFICATION
100.
90.
20.
100.
100.
100.
100.
100.
--loo. -
100.
100.
100.
- -loo. 	
100.
10T).
100.
too.
100.
-too.- -
100.
too.
100.
- 100. -
100.
• - — 100.
100.
- too.
90.
100.
100.
	 too. - "
100.
100.
100.
too.
100.
- _ _ . 1 go -
100.
wo .
85.
3
2
1
6
5
3
4
3
3
3
3
5
-2 '
6
-^
2
2 -
3
-5 - —
1
3
3
2
8
ft—
2
3
2
3
2
8~" -
2
2
8
8 - —
2

4
2
4
                                                                                                                                           NO.

-------
                                                                          BASE  OAT*
                                                              EP*  1976  NEEDS  SURVEY  CATEGORIES  5  »  6
W

M
UJ
€P» STATE NO. ij
NO. MO
- -- s -
5
S
5
5
5
5
5
-5
5
5
5
5 -
5
5
5
5
5
5- -
5
5-
•3
5- -
5
-6 --
6
6
6
6
6
6 — -
6
6
6
b
6
-6T— -
6
-6- -
4
•
36 161
36 162
36 163
36 164
36 165
36 166
36 167
36 166
36 169
36 170
36 171
36 17?
36 173
36 174
36 175
50 176
50 177
50 178
so -m
50 180
50 181
50 182
50 163
50 184
-a i«s
4 166
a 187
U 166
19 189
19 190
1-9 m
19 192
19 193
19 194
32 195
37 196
37-197
37 196
37 199
44 200
                             URBANIZED  AREA  NAME
-CANTON OH
 CINCINNATI OH
 CLEVELAND OH
 COLUMBUS OH
 DAYTON OH
 HAMILTON OH
 MUNTINGTON METRO OH
 LIMA OH
 LORAIN - ELYRIA OH
 MANSFIELD OH
 SPRINGFIELD OH
 STFUBENVILLE OH
 TOLEDO OH
 WHEELING METRO DH
 YOUNGSTOWN OH
 APPLETON VI
 OULUTH METRO Kl
 GREEN PAY MI
•KCttOSH* *'
 LA CROSSE WI
 MADISON wi
 MILWAUKEE *I
 OSHKOSM WI
 RACINE til
-FORT -SMITH AR '   --
 LITTLE ROCK AR
 PI"E BLUFF AR
 TEXARKANA METPO AR
 BATON ROUGE LA
 LAFAYETTE LA
                              MONROE L«
                              "EH ORLEANS LA
                              SHREVEPORT LA
                              ALBUOUROUE NM
                              FORT  SMITH METRO  OK
                              lAFTON OK-
                              OKLAHOMA  CITY OK
                              TOT.-SA m
                              ABILENE  TX
MO. STORMS
PER YEAR
mi.
134.
156.
140.
132.
134.
136.
132.
156.
141.
132.
146.
131.
146.
166.
121.
135.
121.
tri.
112.
115.
119.
121.
119.
- - -95; -
102.
!»?.
96.
106.
107.
- — ro7. 	
90.
120.
90.
5fl.
93.
— Vf. 	
82.
—90. 	 -
65.
AVERAGE
YEARLY RAIN
37.26
39.34
12.08
34.36
35.15
39.85
11.79
36.28
34.03
33.93
38.07
40.83
31. M
38.95
41.33
28.23
28.97
26.51
SI. 9?
28.92
30.71
27.57
2B.12
31.95
' - 42.22
48.66
52.13
49.19
59.13
59.13
- - "57.-S2-
51.29
63.54
45.10
8.13
42.22
— SO.T«
32.58
37.08
23.32
STREAMFLOH
CFS
130.
36000.
0.
540.
780.
1100.
44000.
40.
0.
2.
308.
13500.
0.
13500.
470.
1950.
1400.
1950.
0.
12500.
60.
170.
1800.
0.
- -14000.
17000.
17800.
0.
280000.
100.
- -4?0.
3400.
320000.
6600.
150.
14000.
- 3.
2.
3700.
0.
PER CENT UA
DRAINED STREAM
90.
100.
ino.
100.
85.
100.
1 00,
100.
100.
100.
100.
100.
too.
100.
100.
100.
100.
too.
	 Inn 	
1 uO •
100.
100.
100.
100.
100.
- -t-00 -, - —
100.
100.
100.
too.
100.
- - - 100.
100.
50;
100.
100.
100.
65!
- -too.—
100.
STRFAM
CLASSIFICATION
3
A
8
A
4
U
6
6
8
1
3
6
A
6
6
3
8
6
4
6
0
-- 8
8
- 	 it —- —
U
4
2
5
6
3
•5
4
2
U
2
- - - o
2
                                                                                                                                      NO.
                                                                                                                                        192

-------
            BASF DATA
EPA ]976 NEEDS SURVEY CATEGORIES «i  8  6
 I
M
J>
I STATE NO. URBANIZED AREA NAME NO. STORMS
).
6
6
b
6
6
6
h






6
6
6
6
b
b
b
b
b-
t>
6
6
t>
7
7
7
7
7
7
7
7
7
7
7
7
7
7
NO.
14
an
in
44
44
40
55
1200
25500
2?00
22000
20000
19200
1 060
31700
27000
1080
200
30
31700
23

t
,
m
f
,
,
m
.
,
.
t
,
.
m
.
m
f

f
m
„
m
f
.
.
.
.
.
.
.
.
.
.
.
,
.
.
.
.
PFR CFNT lit
DRAINED STRFA"
?0.
95.
75.
100.
25.
100.
100.
100.
(on.
100.
100.
»o.
100.
100.
100.
100.
100.
100.
100.
«5.
70.
100.
100.
40.
80.
100.
100.
100.
100.
100.
100.
100.
100.
100.
ino.
100.
100.
70.
100.
?5.
STRFAM
CLASSIFICATION
2
f,
1?
a
?
10
4
2
?
15
4
3
3
?
3
1
1
7
?
2
2
?
10
?
3
2
3
4
3
4
4
4
3
4
4
3
?
1
4
1
                                                                        NO.
                                                                          201
                                                                          202
                                                                          203
                                                                          204
                                                                          205
                                                                          206
                                                                          207
                                                                          208
                                                                          209
                                                                          210
                                                                          211
                                                                          212
                                                                          21 3
                                                                          214
                                                                          215
                                                                          216
                                                                          217
                                                                          218
                                                                          219
                                                                          220
                                                                          221
                                                                          222
                                                                          223
                                                                          224
                                                                          225
                                                                          226
                                                                          227
                                                                          228
                                                                          229
                                                                          230
                                                                          231
                                                                          232
                                                                          233
                                                                          234
                                                                          235
                                                                          236
                                                                          237
                                                                          238
                                                                          239
                                                                          240

-------
                                                                           BASE  DATA
                                                               EPA  1976  NEEDS  SU"VEY  CATEGORIES  5  *-6
W

M
Ul
A STATE NO. UHBAMZEO AREA NAME NO. STORMS
0.
7
7
7
7
7
e
9
8
8
8
8
8
8
8
*
8
8
9
9
9
9
9-
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
10
10
NO.
26 201
26 242
28 243
78 244
28 245
b 246
b 247-
6 248
6 219
?7 250
27 251
35 252
1? 253
12 251
«5 255
45 25b
45 257
3 258
3 259
5 2*0
5 261
5 262
•5 203
5 264
5 265
5 2eb
5 267
5 2h8
5 269
5 270
5 271
5 272
5 273
5 274
5 275
12 276
29 277
29 278
13 279
38 280

ST JOSEPH «0
ST LOUIS MO
I U'CQLN NE
OMAHA NE
SIOUX CITY ME TRO NF
BOULDER CO
COLORADO SPRINGS co
DENVER CO
PUEBLO CO
BILLINGS HT
GRFAT FALLS MT
FARGO NO
SIOUX CITY MFTPO SO
SIOUX FALLS SO
OGOEN UT
PkOVO UT
S*LT LAKE CITY UT
PHOENK AZ
TUCSON A?
BAKERSF1ELR CA
FRPSNU CA
LOS ANGELtS CA
MIJDESTO CA
OXNARD CA
SACRAMENTO CA
SALINAS CA
SAN BERNARDINO CA
SAN OIFGO CA
SAN FRANCISCO CA
SAN JOSE CA
SANTA RARBARA CA
SANTA ROSA CA
SEASIDE CA
SIMI VALLEY CA
STOCKTON CA
HONOLULU HI
LAS VEf.AS NV
PENQ NV
BOISE CITY in
EUGENE 00
PER YEAR
95.
104.
93.
90.
98.
87.
86.
87.
71.
93.
99.
106.
98.
93.
87.
87.
07.
34.
SO.
37.
41.
35.
63.
35.
57.
6?.
35.
42.
67.
63.
35.
67.
62.
35.
50.
99.
25.
47.
91.
143.
AVF.RAGE
YEARLY RAIN
34.18
36.46
25.73
25.90
21.77
10.57
13.19
12.89
11 .84
13. ?3
14.07
IS. 73
2.36
11.14
14.68
12.17
14.75
IP. 02
14.14
17.71
10.40
20.70
13.11
17.63
29.25
14.14
14.22
14.31
23.96
4.35
6.96
11.43
37.51
STRFAMFLOW
CFS
27000.
123000.
70.
20000.
19200.
25.
6.
114.
244.
3100.
6300.
180.
19200.
42.
233.
10.
118.
510.
0.
500.
960.
0.
414.
0.
15000.
56.
50.
0.
13000.
17.
0.
0.
0.
0.
1600.
0.
79.
270.
140.
?440.
PER CFNT MA
DRAINED STRFAM
100.
100.
100.
100.
loo.
90.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
too.
100.
100.
100.
100.
100.
100.
100.
100.
100.
100.
'ino.
1 00.
too.
100.
100.
STREAM
CLASSIFICATION
4
5
?
a
u
1
1
2
2
2
4
2
4
2
2
fl
?
?
1
1
?
15
2
15
4
1
2
15
12
10
I*
15
15
15
ll
15
2
2
2
II
                                                                                                                                       NO.
243
244
245
246
2«7
248
249
2*0
251
252
253
254
255
256
257
258
2*9
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279

-------
                                                             WISE DATA
                                                 EPA  1976 NEEDS SURVEY CATEGORIES  5  J
EPA STATE Ml).  URPAMZEP AREA NAMF
 NO.  Nil.
                 PORTLAND OR
                 SAI. EM  OR
                 PORTLAND MFTRO WA
                 SEATTLE  WA
                 SPOKANE  MA
                 TACOMA  HA
                 WELSOUPNE - CMCDA FI.
                 SARASOTA-BRADENTON ^
                 OAYTHNA  BEACH FL
                 NEw  LONDON-NORWICH C
                 GASTONIA NC
10
10
10
10
10
10
1
1
1
1
•u
to
2
10
1
3
14
1
5
6
1
1
1
6
1
9
5
1
1
2
9
10
3
3
5
5
2
2
2
2
3ft
38
18
18
UB
in
10
10
10
7
31
18
33
2
13
17
10
1
1M
11
13
18
1
19
11
5
23
31
10
33
5
18
39
19
36
21
5*
53
13
53
281
2«2
283
211
285
28b
287
288
2«9
290
29]
292
293
291
295
296
897
298
299
300
301
30'8
2<"5
3no
311
302
305
306
307
308
309
310
31 1
312
31 3
114
315
316
317
318
319
320
                                                    END

-------
                 APPENDIX C




NEEDS ESTIMATION MODEL FOR URBAN RUNOFF




               COMPUTER CODE

-------
IV G -tEVfL   ?l                   MAIN              0*TF-T 7*36*          17/0»/S«             PAGE" 0001

     C
     c           NtMUR  . NEEDS  ESIIMAIION MODEL FOR  URBAN RUNOFF
     c
     C   DEVELOPED Hr JORDAN.JONES AND GflULDTNG, IMC.
     C   FflH TMt U. S. ENVIRONMENTAL PROTECTION AGENCY
     C   UNDER  CONTRACT N(j.  6H-OI-I9M   OCTOBER 1976
     C
     C   THIS PROGRAM ESTIMATES THE NEEDS FUR CONTROL  ANO/OR TREATMfMT OF  COMBINED
     C   *PHf=R  OVERFLOWS AH!) STORMHATER DISCHARGES  IN  ALL URBANIZED- AREAS  OF  THE
     C   I'.  S.   BOTH CAPITAL AMD UPERATION & MAINTENANCE COSTS ARE ESTIMATED
     C   AND SUMMARIZED ON A STATE-9Y-STATE AND NATIONAL BASIS.
     C
     C       »IMPUT DATA REQUIRED*
     C  i                NUMBER  (if URBANIZED AREAS
     C  NOU.KM         tPA  REGIONAL CODF
     C  NG(2.N)         Thll  DIGIT STAFF CtlDE  1-50
     C  wOf'iiN)         IIHHANI7En 4REA CODF NUMBER   1-N
     C  ALPHA(S,N)      U(«RA>1I?ED »RFA NAME
     C  «e-T«(f,Nl       1990 STATE POPULATIONS -FROM t)P€«S PROJECTIONS
     C  BETA(2,N)       1990 STATE POPULATIONS -EPA  CEILING
     -C  WTAO.N)       COMBINFD SFrlfH OVERFLOW »RFA -1000 ACHES
     C  RETA(U,N)       CDMRINED SElLASfJ,N)       INOICATFa IF URBANIZED AREA  IN  ADJACFNT TO ANOTHER U.A.
     C
     C        "VARIABLES CliMP'IIFD IN MEMUP *
     C
     C   «CATEGU"»r MVF VARJAHLES*
     C
     C POCS  - POPULATION UFNS1TY IN CuMfiTNEO SFWFR  AREA
     C CSI   - PER CENT IMPERVIOUSNESS IN CDMRINED SEWER AREA
     C R'tc   - RUNOFF COEFFICIENT
     C MNS   - MEAN NUMHfcR (IF STIIRMS Pt* YEAR
     C MHF   - "E1N RAINFALL  PER STURM
     C DS    - DESIGN ST(;Rr
     C DvCS  - DESIGN yrlLUMF  Fll" CIlMBlN^D SFNER ARE*
     C NTP   - NUWSEW I'F TKEATMF.NT PLANTS PFR URBANIZED  AREA
     C N«1P   - NUMtlFp I1F. Sl
-------
                  FORTRAN  IV U LfVFL   ?1
                                                                               OATK = 7t>3t>0
                                                                                                                           PAGE OOP?
O

N3
                   0001

                   000?
                   0003
                   0004
                   OOOS
                   OOUh
                   0007
                   ono«
                   000°
                   0010

                   0011
                   001?
                   0013
r
c
c
c
c
c
r
c
c
c
c
c
c
c
r
~
C
C
C
C
C
c
c
c
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c
c
c
c
c
c
r.
c
c
c
c
c
c
STCS -
KF

PPL ( 1 ,
POLI?,
Pl~)L( 3,
POI_ ( t| ,
RP -
K3 -

LANO
pnp
PPSS
POP1
SSPUP
LAND1
LAolll?

CM

SSI
OVSS
NSSTP
SPTP

KOGI
JMAR
Saw
PROS
PPW?
5SGI
PDG -
ROCG -

VOL
MONf Y


STnutKF RtniiTriFD PFR STIIPAGE FACILITY
•Jt«UVAL Ftfinfi UStD I«J CHMPIJTING PER CFNT BOO RfMUVAl BEOUIRFD

Nl - RDO-F1VE L'lAOIwf, FriR c'TFGnuY FIVE
Nl - SUSPFN.OtD S'll IDS LOAPIMG POP C4TFGORY FIVE
NT - Wiin_F[vt lnAOING FlIK CATEGORY SI*
NI - susPF'woen SULIDS tfuniMt FOP CATFGOKY six
pl=P UFNT BLD iJflK'Al StniUPFD
•}£ AFPATTllN CCNSTAN1

- URHANI2FI, AREA MUT SEHVFP BY COMBINED SFwFRS
- t-opiiLAT TUN NUT SE.RVF') bY COMBINED SEWERS
- PHPHLA1 TUN DENSITY OF AREA NUT SERVFO «Y COMBINED SEwFRS
- 19QO UKBAM7EO AP.FA POPULATION
- IQQO POPULATION MDI SFRVEO RY COMHINEO SEWERS
- 1990 UWRANiZftl AREA NOT SFRVEO RY COMHINEO SEWERS
- GRdWTH l\i ARE* rtETwFEN 1P70 AND 1990

- CUPR HUES IN I'^HANIZFO ARFA

-"ER CENT TMPEHVInuSNFSS FOR APEA NOT SFRVI-n RY CPMBIN.tr> HEWERS
-PESir:fJ VOLIIME F(|R STORM sfwFP ARFA
-NUMBEw OF TREATMENT PLANTS FOR STORM SFKERED AREA
-STORAGF PER TpFATMFriT PLANT

-Pt» CENT RUNOFF FROM IMPERVIOUS 4RFA
-TOTAL IMPERV Il'OS AREA
-PER CENT IMKFI'VIOUSNESS HUE TO STREETS
-PE^ CENT Kllf'flf-F I^UF TO STREETS
-PtR CENT rF DOLuTA-jTS PfcMQVEn RY STREET SWEEPING
- PER CENT TMPt RVIHUSNtSS 111 GROnTH AREA
DOPHLATIO'. DEl.SITY IN GROWTH AREA
WUN()FF CI'lEFf Tr IE-NT TN GROWTH AREA

-VOLUME 'IF Ri.MnFF FPiJM GROnTH AREA
-COST OF Rl.ILI'INC, DETENTION BASINS TO THE.AT RUNOFF FROM THE GROWTH
AREA

    COMMON      N.BETA(ll,VO),RAIr.!(?,3JO),STR(2,3?0),KLAS(3.3?0),OSr3?
   . 01 ,Pdl ( "/ 3?0) , Pvsbl 3?0)
    COM Ml IN  /PR IN I /!,r, ( 3, 3?0) , A I PHA f 5, 3? CM
    REAnC^, 100)':
10,1 FORMAT! 151
    nn so  J=I,N
    ^EAnCr, ,11)1)
101 FORMAT  ( I" , ?I ^,S»u,?Fh.O,Fb. l ,F(i.o,Fl o.n,F10. 1 )
 ^0 CONTINUE
   . (KLASf K , J) , K=l , 3)
106 FilrfhAKFl 1 .0., F 10.0,F.,.o,F!J.O,F9.<4,FU.n,F6.?,F15.0,F3.0,T?,IU,I3)
 h8 CONTINUE
    W&I If f o,«0(M

-------
n
u>
                  FORTRAN
                   oo i«
OOlf.
0017
uOirt
001"
00?0
00?I
00??

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OOPS
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0035

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                   0037
                   0038
                   003"

                   onqo
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                          iv r, LFVFL   ?i
                                                          "A IN
                                                                             OATF = 7fe36HiS? OATS '/'JBX. 'EP« l«7h NEfD.S SURVFY  CATFGnRItS S
                                     .  H  h1//)
                                     00  700  J=1,M
                                     IF  (UO.GT.NPPT)
                                  71
                                  7?
                                 700
                                      nPITE(b,u001
                                      up  son  J=I,M
                                      If  (10. Gl .Mill-T) i;il  Til d?
                                      MflP T = il
                                  fl?  KOITt(6,?.0(ll    (ri'.K J, J), I = 1.3
                                     .2),(STR(L,Jl,l=l.?).(hLAS(I,J),I=1,?)
e.OO CfNTIMJE
202 FORMAT  MH  /ix, 'E
        AVEPAGE
   . 'NT.'/IH  ,!»,'NH
   .x,'npAiNEf>  siRtA"
?01 FOHMAT  OH  /I«,|(-
   .MS   CU^ StH^R  "'.'
   • AViJ O.A.   EPl'/lH
        POP.      PUP.
   ./I- ,
   . ant, 'innn  p^^>,n^!
inn FIV-AT  (1»  , i"r !(-
203 FPSMATdH  ,T3,I'>,
   .9.U)
    WRITE  (h,133)
134 FORMAT  ( 1HU,SOX, '
    CALL CATS
    STOP
                                     PA  STATH  NT. UP64NIZED AREA  NAME     NO. STnW*S
                                     SlREAMFLU'.i      PER CFNT  UA      STREAM', 1UX,
                                     .   NH. ' ,3UX, 'PER VFAR      YEARLY  R A I N ' , S 1 , ' CFS ' / "
                                        ci. ASSIF TCATTIIN' //i
                                     PA  sTATt  Nn. I>RHAM;FO AREA  NAME   STATE POPUIATIO
                                     FPFunw     URBANIZED ARFA      SMSA PCIPULATIMNS
                                      ,'  NO.   NP. ' ,?7Xi ' 1190 PBEMS 1990 EPA      AREA
                                         ARFA  Sn«I    1970       1990    PER CSO.   CflST'

                                     .s    1010  «c»ES 1000 PER' .5?x, • TNOEX'/)
                                     , l'J,?X,5AU,F]0.0,F16.?,F1 3.0,F1b.O, 1 ?X , 1?, 1 6X , I 3)
                                     U,2X,SA/),?F10.0,2F10.1,F10.0,F10.1,?F10.C,F7.0,F
                                        1 /1H1 1

-------
                 FORTRAN lv G LfVFL
                                                          CATS
                                                                             DATE = 76360
                                                                                                   17/01/^1
                                                                                                                         PAGF nnoi
?
                  ooo-i
                  000?
                  oou3
                  00011
                  ooos
                  0006
                  9007
                  0008
                  ono<»
                  0010
                  0011
                  001?
001 3
                  0015
                  0016
                  0017
                 0010
                 00?0
                  00??
                  00?3
                  oo?«
                  on?1;
                  00?6
                  oo?»
                          TlNE CATS
                   CIlMMdN     •J,ftTA(11,3?0),HAIN(?,3?0),STR(,?,3?01,KLAS(3,3?01,nS'3?
                  . 0) f OOLCI, 3^11) >UVSS( Vft)/PRlNl/MH 1, 3,?fl)
                   CHH-'IIN/CSIX/l ANn?(.i?0),CM(3?0),            NSSTP(3?0),PPRSC3?n),MnNE
       nlHFNSinN LA.'.OI(3?0)
       KE»L-    MRFylHAP  ,MnNfr     . HNS, LAND1 , LAND?, L«NO
c
C  THIS  SttBSOIITlNF HllL  CAi_COL»Tt 1 HF PRELlMlN*"* V»LIIE3 U3ED  TO  COMPOTE
C     THE CATFPIJBY SIX CHfTS
C
       on so 1=1 ,n
       STPf?, I )=SIR(?, I )/ini).
C
C THIS NEXT STEP rALCI'L»TFS THE POPULATION  OENSITV IN THE  AREAS  KlTHMIJT
C  COMBINFD SEhESS
C
       LANd =  RFTAfr,, I l»6UO.O-KfcTAf 3,11*1000.0
       PUP = BFT«(S,I)-MF1 A(u,I).lf»oo.O
       PnsS =  Pi.lP/lANCl
       IF (cnss.i r.1 ,%t>)  fnr.^i.Sh
       IF fPDSS.GE. l.bh)  PDG=PnSS
c
C THE  NEXT FUMATKl'i  CALCULATES THE CURH  MILFS IN EACH URBANIZED  APEA
C
       CM(I)=  LAND«(n.,i7fl2-0.06bB«ro.81<))»»PnsS)
C
C THE  MEXT STFF CA! Cl'l.t'hS  THF PtS CENI  IMPFRVinuSNFSS,  THE  RUNOFF
C  rOFFFlrlFNT.DEMP'- SIHRt.THE KFOilIREO STORAOF
C
       SSI= 9.fr«P!)SS««(0.573-0.03<»l«ALn6IO(POSS))
                   MRFIHA1M?, I )/KNS
                   l)S(I) = l.61«MHF
                   OVSS(T)=OSC l«H'',(,s»LAND».0?7lSfi
                   NS.STf (I )s(LAi»0)/(-F. 1 A(1, I)
                   NSSTP(11=NSS1P(I)»I
                   SPT"(I)=DVSS(I)/NSSTP(I1
             C
             C   THE NEXT  STEP TALC'ILArFS  Tht  PFR CFN-T HF  RUNOFF OUF TO STREETS AMO 1 Ht
             C    PER CFNT  HF  PlILUTAMS RFM.TvFD BY SWEEPING
             C
                      R = L AMU*SS1/I 1c).
                                                              t PHIS)
                              C
                              C THE  FOLLIIWING HtjijATKlNS CALCULATE  1HE  AMOUNT OF BnO-5  AMD SUSPENDED
                              C  SOLIDS I.'IE TO STIlk"  vitTtR RUNOFF
                              C
                                                                                                                 10
                                                                                                                 11
                                                                                                                 1?
                                                                                                                 13
                                                                                               16
                                                                                               17
                                                                                                                 ?5
                                                                                                                 ?6
                                                                                                                 ?7
30
31

3?
33
3"
3S
3^
37
                                                                                   110
                                                                                   111
                                                                                   11?
                                                                                   «3
                                                                                   uu
                                                                                   it*
                                                                                   qf-
                                                                                   U7
                                                                                   UP
                                                                                   ao
                                                                                   iO
                                                                                   51
                                                                                   5?
                                                                                   53

-------
                 F'lOTWAN IV i> LF.VFL
                                                           CATS
?
0030

0051
                   DOS?
                   OOJ"i
                   ooi»%
                   0037
0010
00<1|
0011?

OOUJ
0010
00«5
0|l«»
Oil«7
001H
                                                                              DATF  = 7b36U)=LAHli|{I>-LANr>
                                      IF  «L»1P?f D.LT.n.O)  LANO?(I)=0.0
                                      MONEYf I) = Vl>L*O.S
                                   SO  C'INTINUF
                                      WHITE (6, 856)   (LAND? (I ) ,C»l I ) ,CVSS( I ) ,NSSTP( I) ,PPRS( I ) »«ONE V CI } ,
                                     . TRSS(I),SPIPtll.WI(l,I),I = l,N)
                                  856  FtlRMATCIH , Jl- 15. i. J 1 0. 4FIS.?, 5X . IS)
               K'Xt FORMAT  C1H ,?F1S.?,10X. IS)
                   CALL CATF
                   RFtl.'fN
                   END
                                                                                                                 S5
                                                                                                                 5*>
                                                                                                                 57
                                                                                                                 5"
                                                                                                                 5">
                                                                                                                 6"
                                                                                                                 61
                                                                                                                 65
                                                                                                                 67
                                                                                                                 6*

-------
                 FOR I RAN IV U LEVEL
                                                         CATF
                                                                           DATE = 76361
                                                                                                 17/01/51
                                                                                                                      PAGE 0001
?
                  OOul
                  000?
                  0003

                  OOU1
                                    S'lHROMTlNE  CATf
                 000«
                 0007
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                 000"
 0010
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 0011
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                 0018
                 0019
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                  OOPS
                  00?7
       CUMMllN/CFIV/TRCS(3?n),DVCS(320),STCS(3?0),NTP(3?01,RRC3?.0),CIR(3?0
      .),NSP(3?0)

       REAL     K?,M|*F,«INS
C
C THIS  SUBROUTINE COMPUTES THE INITIAL  VALUES  WHICH  ARE  USED IN COMPUTING
C COSTS FOR  CATEGORY FIVE
C
C            COSTS FOP CATFGGCIRY FIVE  IN  197S  AND  1990  WILL Bt IDENTICAL SINCE
C IT  IS ASSUMED NO Ntw CO"hlNFl> SEWERS  HILL BE  BUILT.
C
C THE  FOLLOWING SFciMENCE OF CALCULATIONS  COMPUTE  THE RUNOFF COEFFICIENT,
c DESIGN STORM,NUM«FH DF TREATMENT PLANTS,AND  THE  REQUIRED STORAGE AND
C- TREATMENT  RATE
C
       Of) 3U  1 = 1,"1
       ROC(I 1=0.0
       IF  fBETA(3,I).rQ.0.0)  GO TO 9)3
       POCS=RETA(4,I1/RFT4(3,I1
C
C   CALCULATES THE DESIGN STROM FOR EACH  URBANI7ED AREA
c-
      CSI =9.6»PDCS**(fl.573-0.0391»ALOGIO(PDCS)l
      Rl"'C(Il = (0. 15* 0.75 *(C SI/10 0.11
      MNS=1.0()?6«RAIN(l,Il-?.58
      MRF=PAINC2,I)/MN5
      OS(T)=2.30*"«F
C
C CALCULATES  THE  DESIGN VHLUMF , NUMBER OF  TREATMENT PLANTS, TREATMENT
C RATE,  AND  STORAGE  PER TREATMENT PLANT FOR EACH  URBANIZED AREA.
C
      -PVesm=OS(I)«ROCU)*BETA(3,I)*?7.158
                       1«10HO)/ BETA(9,I)
                  00?9
                  0050
                   POLCl ,11-  (POLd ,I)*bETA(3,T)*2000.0*STR(?,I)l
                   POt«a,I)=  
-------
                FUKTRAN IV 6 iFVFi  ?|
                                                        C«TF
                                                                          DATE = 7636"
                                                                                               17/01/5"
                                                                                                                     PAGE  0002
n
0011
003?
OOS3
003U
003S
0036
0037






003R
0030
flOao
ooai
ooa?
00li3
OOua
00a5
00116
0047
00««

00 HI



OOiO



0051
005?
0053
005a
0055
0056
UOS7
;)05fl
005"
OOhO
000]
006?
0063
006«
0065
00e6
00o7
006»
0069
007"
TRCSU )=0.0
POL( 1, I)=0.0
POL(i?.n=0.0
DS(T)=0.0
CTkd )=0.0
NSP(I 1=0.0
30- CONTINUE
C
C THE NEXT SEQUENCE I'F CALCULATIONS COMPUTES THE PROPORTION OF STREAM FLOW
C ATTRIRUTtn Til EACH iJDHANIZtn AKFA, WHEN TWO UP MORE URBANIZED AREAS ARE
C ADJaCF-IT Tt) ()Nfc ANOTHER, SHARP THE SAME RECEIVING STKFAM, BUT ARE I"
C DIFFE^E"! STATES
C
01) 60 J = 1,3H
POLT=0
DO 70 I=1,N
IF (KLAS(3,I 1.EB..I) GO TO 61
GO Til 70
61 POLT=PULT*P.nL( 1 , 1)+POL(3,I ) +0. 0?55*BE T A f 5, 1 ) *STP (?, I )
70 CONTINUE
DO 60 1=1 ,N
IF (Kl AS(3, I) .fO.. I) GO TU 81
GO TO 60
SI STR( !,!)=( (Pill ( 1 , I) tPOL(3,I}-»0.0255*BETA(5.I)*STR(?,I))/POLT)*STRf
.1,1)
60 CONTINUE
C
C NEXT STEP C«LCUlATfS THE REMOVAL FACInP USED IN COMPUTING REMOVAL REQUIRED
C
00 35 I=1,N
C
C ASSIGNS K? yALUtS Til APPHOPHIATE STREAM CLASSIFICATIONS
C
IFCKL'SU, I )-1 ) 2, i,1
3 K?=a.75
GO Til 2
a IFCKLASC 1 , I)-?) ^,5,0
5 K?=1.75
GO TO ?
6 IF(KLAS( 1 , I)-il 2,7.P
7 K2=0.75
Gfl TO ?
8 IF(KLAS( 1 , I 1-1) ?,«,10
0 K?=0.3?
Gfl Td ?
10 IF(KLAS( 1, I )-S) f , 1 1 , 1?
11 K?=0.1H
GO Tu 2
1? IF(KLAS(1 , I )-61 i, ] 3, I"
1 3 K2=0.08
GO T'l I
la IF(xl/>S( 1,11-7) 2,15,16
15 K?=0.15






iaft






1 111
150
151
15?
153
15"
155
156
157
1 5fl
is?
160
161

161

16?




go
100
101
10?
103
loa
105
106
107
1 0**
1 09
110
111
1 1?
M3
l ia
1 1 *
116
117

-------
O

00
•ORTRAN
tftll
U07?
0073
007U
007S
Ol>7h
OOf7
UI178
0*79
0080
0081
OOfl?
0083
OOhu
0085
ons*
0087
0080
0989
0090
C'091
009?
0093
0090
Od *S
IV G LEVFL

16
17

18
19

?0
?"!"

?2
?3

?4
^5

?6
?7

?8
?9

3?
31
-2
?1
GO T'l ?
IF(KLAS' 1
K?=0 • 30
Gil 10 ?
IF(KL AS( 1
K ?=0 .80
«f> TO ?
IF(KLAS'l
K?=0.50
en rn ?
IF(KLAS(1
K2-O.UO
GO Til ?
1F(KLAS< 1
K?=0 .15
GO TCI ?
IF(HL»S(1
K?=0.06
eo Ttr i
IFCKLASM
K?=0.1?
GP Tl. i
IF-(KLA3( 1
K?=0.50
CONTINUE
CATF

,11-8) ?,17,18


•I)-9> ?, 19, ?o


1 1 )-io )?,?!,??


,n-it) ?,?3,?«


,I)-1?) ?,?5,?h


, I ) -1 3) ?, ?7 » ?s


.I)-1«) ?,?9,3?


,I)-15) ?,3t,?


                                                                            DATE = 7616U
                                                                                                 17/01/50
                                                                                                                       PAGF  000}
                  00°6
                  0099
                  0100
                  0101
                  610?
                  OlOi

                  V100
                  010S
                  OlOh
                  0107
                                                                                                             Its
                                                                                                             It'
C THE NEXT  SlFt>S  COMPUTE THF REMOVAL REQUIRED  FOR  EACH IIRBANI7EO AREA
C
      RF    =  (PHL(1,])+POL(3,T)tO.O?55*8ETA(5,I)*STP(?,I))/((?.»STR(?,1)
     .•(DvCS+r)VSS(I))*1.55+STRM,IltRETA(5,I)«STP(?,I)«O.Otl019)«K?)

      IF  (RF.GI.B9.0)  GO TO 56
      GO  Til 57
   56 IF  (PF.LT.??I,.(l)HB(I)i( l8U.7*ALf)G10fRF)-339.6)/100.

   3S CONTINUE
      •PlTEf6,688)(DS(I),NTP(I),CTR(I),NSP(I),T»CS(I),DVCS(I),STCS(I),Rn
                  (I I 0«
61*8 FORMAT  MH  ,f I 0.?, 11 0 ,F 1 0.3,11 0 ,5F 1 0.?,5X, IS)
    WRITE  (6,89B>    (POLd ,I),FOLr?,I) , N()( 3, I ) , 1=1 ,N)
898 F11HHAT  UH  , ?F 1 5.?, 1 OX , TS)
    CALL COST
    RETURN
    END
                                                                                                              130
                                                                                                              131
                                                                                                              13?
                                                                                                              133
                                                                                                              13"
                                                                                                              135
                                                                                                              136
                                                                                                              137
                                                                                                              13S
                                                                                                              139
                                                                                                              l£in
                                                                                                              141
                                                                                                              m?
                                                                              16U
                                                                              165
                                                                              16*
                                                                              167
                                                                              168
                                                                              169
                                                                              170
                                                                                                              171
                                                                                                              17?
                                                                                                              173

-------
FORTRAN  Iv  s  IFVFL  ?i
                                         cnsr
                                                            DATE =
                                                                                  17/01/51
                                                                                                       P»GF  nooi
0001
000?

ono3

OOOU

0005
000*.
0007
OOOA
ooo<>
UOIfl
0011
001?
0"13
0011
001S
OOlh
0017
0010
001"
ooao
no?)
00??

00?J
00?«
UPJh
00?7
00?"
00?9

1)030
0031
003?
0033
003«
0037
003H
Iinj9
                    SUBBOUTINE  CMST
                    CIWNIJN      N,HtT»m,3?n),rt»IN3?01»pVSS(3?n)
                                                                                              1 7S
      .»(3?0),THSS(3?0),SPTPf 3?0)/PRIN1/NtH3,3?0>
       cnM«IIN/CFJV/lf»CS(3?0),OVCS(3?0),STCS(3?0),NTP{3?01,RIU3?0),ClR<3?0
      .).NSP(3?0>
       C'I«"«UN/PRIN/LFVFL(2.3?0),CIISI1 ( ?, 320 ) ,cnST?(?, 3?0 1 .COST 3 ( 3?0) , NflPT
       HE»L    MHN£V,L*ND?
       00  hOO NiJPT = I,3
       0(1  UOO 1 = 1, M
       if  (NIIPT.EO.?) en  rn  ?as
       IF  (HOPT.ER.3) RO  10  3?A
       LFvFLM,l) = 1
       LEVEL(?,I)=1
       GO  TO e?0
C
C  IHE  NEXT  StnuEMCt (lF F.SUATInNS KlIL  COMPUTE THE  REQUIRED LEVEL OF
C  TREATMENT
C.
   3?6  PMLU.I)z 1.70«P(.L( If I)
       PHI.(?,1)= 1.70«PnL(?,I)
       OVCS(I)= 1.70»DV(S(l)
       TRCSC1)= 1.7U«TPCSm
       STCS(T)a 1.70«STCS(I)
       CTR(I1= 1.70*CTR(I)
   i?s  CIINTIWUF
       Pol=  (0.?5»Pi'L(1.I)tPPwSCT)«PiU( J.n)/(POL(1,I)*POL(3,I))
       PR?=((0.7";«Pi.Ll?,I)*(1-PPRSfI))«PnL(tt, !))/(?•(    OVCS(l)»DVSSm>
      .))«0.1?
       IF  (PHI .LT.Rk(I))C(l Tfl  750
   6SO  IF  fPR?.GT.anO.) GO TH  75,0
       LFVFLdrl):!
       LFVFL(?,I)=1
       GM  Tfl flSn
   T>0  PP1=  fO.«»P'IL» l,I)»PPRS(I)*Plll (3,T) )/(PDL(l , I
       Pt»?=( fO.S'PIU (?, r) + ( l-PPRSU))«PnL(/(Pni_n ,I
                                                                                              I"?
                                                                                              193
                                                                                              190
                                                                                              1 <";
                                                                                              197
                                                                                              19R
                                                                                              19°
                                                                                              ?00
                                                                                              ?03
                                                                                              ?0«
                                                                                              ?fl7
                                                                                              ?0«
                                                                                              ?|3
 oo
-------
                                        ?\
                                                                              D«TF. = 7656"
                                                                                                    17/01 /
n
                    ooaa
                    00145
                    OOilh
                    OOU7
                    O0a«
     IF  (PRI .LT.H"( I ) 1 GO TCI  H53
     IF  (PR?.Gf .UQO. 1  Gn TU  .155
0050
005-t
DOS?
0053
oosu
0055
0056
OOS'7
005»
005"
0060
006T
OOo?
0«h3
00fc«
0065
0066
0067
0068
006°
0070
0071
     LfvELf?,l)=1
     S(l  TH 850
S53  -PHIs  (0.6*PML(1 , I)t.(l»POLf }, l))/(POl (1 , I ) 1-POL ( 3, I ) )
     PH?r( (0.3«PlU(>>» I )«.5*PnL(«,
     JF  (PR1.LT. «»(!)) KH TO 85(1
     IF  (FR2.GT.UOO. > r.fl Tf) "54
     LFl/FLM ,!)=?
    6(1  Til  850
    BR1=  (0.8*Pril ( 1 , I)*.=S
    6(1  TO  S50
857 RH1= (0."S«BI.L(t.I )*0.an«PUL( ?, I ) ) / (POL ( 1 , I )»POL(3.I ))
    PPa=((0.0?*PHL(?, I )+0.50»DUL(a,I)>/(2*(f>VCSU )*   DVSS(I) )))*.!?
    IF  (PR1 .LT.Ri-d) )  GO TIJ 858
    IF  (PR?.GT.aOO.O)  GO TO 858
    LEVKL(1,I)=5
                   GO TU 850
               858  PRl = ((0.95«PuL( I ,I)*0.b*  PUI ( 3, I ) ) / (PHL ( 1 , I ) +PIIL C 3, T ) ) )
                   PH?=( f 0.0?«Pl'L(?,I ) + 0.3»Pn|_(U, I))/ (2«(t)VSS(I)+    OVCSCI))))*.!?
                   IF (PBl.LT.Hrtf 1) )  GO  Til 859
                   IF (H»?..GT.a00.01  GO  Til r59
nvCS(Il)ll*.l?
    GO TU 85u
    P«l = (0.a5.pn| (1 ,n*0.««PI)L(?,I)l/(PnLC 1 . I1+POI C
    PR?=CfO.O?*PnL(?, I)t0.1*PriUfu, Ill/(?*(OVSSCI)+
    IF(PR1 .LI .«R(I))  GU TH 8hO
    IF(PHP.GT,aOO.)  GO TU 860
                                                                                             ?50
                                                                                             ?53
                                                                                             ?5a
                                                                                             ?55
                                                                                             ?56
                                                                                             ?57
                                                                                             ?.66
                                                                                             ?67
                                                                                             ?fcfl
                                                                                             ?6«
                                                                                             ?70
                                                                                             ?7I
                                                                                             ?7?

-------
FlIPTHAN Iv G  LFVFL   .? I
                                         COST
                                                           DATE =  7636U
                                                                                 17/01/Sd
                                                                                                       PAGE  00(1}
!>09S
0096
0097
0098
0099







(MOO
0101
01 »?
0103
010"
0105
0106
0107
0108


0109







C
C
C
C
C
C
C














LEVFL (1,11=5
LEVFL(?,I1=U
SO Til 850
860 LEVELM.I1=5
LF.VFL(2,I)=S

THE FOLLOWING SEQUENCE CALCULATES THE CAPITAL AND OPERATION AND MAINTENANCE
COSTS FI1U EACH URBANIZE" ARFA

THE NEXT SEOUENCL rlLL CALCULATE THF CCISTS FllR CATEGORT SIX FOR VARIOUS
LEVELS 1^ EACH ilRMNllFl) AREA

85» IF (LFVFL(2,I).F0.1) GO FD 970
IF (LFVEL(P, 1 ).tl).2) Gil TO 971
IF (LE«EL(2,1 1.F.Q.3) GO TO 97?
IF (LEVFL(2,Il.Erj.U) GO (0 973
IF (LEVEL (2. n.FQ.S) KCl TO 07;
970 COST! (2,Il=rK(I)*B0.08*l 1.251
CflSfpf £ , O=CM(!1*2B 3.92+ (LANf02(I}*0.5 + BET*(6rIJ*bflO.)*16.
G't Til HOO
"71 COST1(2,I1=\.?S*(1SOOOO*TRSS(T)**0.602 +a31?0*TRSS(I)**0.8173+2176
.55*THSS(Il**u.SOS + 2l:'OSb*lRSS(T)**.698+3129*TkSS(Il**0.(IB((*15200*(.S
.P'PCIl)**0.7|b8+l77500*SPTP{I)«*0.5981*NSSTP(I)+CW(I)*80.0e*l1.?5l
C(IST2f2,Il= fLAND2(I l*.5*BETA{6,I)*bUO. )«lb.t ('00.*
,IRSS( I )*«n.«o?76*1 3 30 0*875. *TRSS(T)*«. 798 + 1000. *SPTP(I)**.(l7*1') 30*
.TRSS(T)**.UbBt£900*TPSS(p**.731S+179n«TRSS(I)*«.(l26t88?8.S*TPSS(I
?73
?729«TRSS(n**.?Ofi7*9?*TRSS(H**.6(l?*li|*SPTP(n**.51
                   .*'0«lPSS(T)**.i«h*6.««TWSS(Il«*.913)*NSSTP{n*'B'5.9?«CH(I)
29S
?96
?97
?9B
299
300
301
30?
303
301
30S
306
307
30fl
•109
T)0
311
31?
313
31"
MS
316
317
3IB
319
320

-------
                   FORTRAN  Iv  G  l.FV'L   ?|
                                                           COST
                                                                              OATF = 76368
                                                                                                   17/oi/ia
                                                                                                                         p»GF  oooa
                    01 16
                    0117
                    01 1«
                    01 1<>
                    ul ?.l
                    012?
NJ
                    ftt?1)
                    Ol?6
                    0127
                    012*
                    01?°
                    0130
                    01)1
      IFILtvELC?, D.EO.I)  GO Tl) 800
      CflSri(?,I)s  r(IST1(?,l)* 110U018«TRSS(I)««.73S7)*NSSTP(I1*1 ,
      Cl)sr?(?,l)=  Cnsr?(?,I>t (?<4*T«SS(I )t761*T"SS(l )*«.?56»S.
     .??7SO)«NSSTP(I)
C
C THE NEKT SEOUENCE  »ILt  CALCUL4TF. THE COSTS FOR CATEGflPY  FIVF  FOB  VARIOUS
C  LEVttS IN EACH  URBANIZED AK£»
C
  800 IFUtVEl II. I). EO. 1)  GO TO 8?0
      IFCLEVFLII ,I).EQ.?)  Gd TO H?1
      IF(LFVELI1,I).En.3)  GO TD K??
      IFClEVEl II, I l.fJ.1)  GO TU B?3
      rF(l f.VEl 11 ,11. EQ. 5)  GH TO -823
  8?0 COST I ( I ,1) = 1 .?S«tf">R8?r>.0«l?*STCS0*».1-SII»STCS(I))»«0.80?7
     .»1SOOOO«(.l'iu«TRCS(I))«».fl23 1 «NSP ( I ) + ( (5?80*0 . 3S* 1 .562S*HETA ( 3, 1 )
     .)••(?« «TuCS(I)»« 0. 3)) + (l3l 10«(n.15a-»CTRIT))»*0.<>SS»3129*(0.15ll»CTR(
                                       COS T2 (1.1)= (?00*f0.1SU*CTR(I))««O.II6?76t75*ln.15a«CTRIT)>«*0.«71»
                                      .10800»M75«(0.1SU«CTB|I))«»0.7l»8t57«(0.1Sa«CTR(I))*«0.e38H530«f0.1
                                                   0.1h6 + 67a*l.lSU«CTR(I))««0.?81)»NTP(I)  »(875«(0.158*T
                                                   «fi + S7«IO.IS«*TRrs'l))**0.838t67(>0+1930>(2*STCS(I)i*«0.
                                      .«68*2«0«(?*STr.SU))t2S7l»(?«STCS(I))«*o.?l«  *1000«(0.11>a«STC.S(I))
                                      .«»0.«7t«80»(0.1';M*STCS(I))««0.a»l««(0.1SU«STCS(I))*»O.S1*?UO*(0.1S
                                      .1«TRCSII))t1<»50«(0.1Sa«TRrSf I))«*0.a68)«NSP(I)
                                       GO TO 901
                                   8?)
   .CTR(I)«*0.6"«+31?''*CTD(I).«o.a8a)*NTP(I)t  (S?RO*.3S«l.'5fc2S«BETAI3.
   .l))«(?i<*TRCSII)»«.3)»U06SOO«STCS(I)««0.508*271'iOO«STCS(I)**0.8027
   .*1SOUOO«STCS(T)«*0.fl23 )«NSP(I))
   "CMSTif 1. I)s  ( 200»CTR 111 «»0. 86276 + 75*C Toll) «»9;a71-»l 0800 »875«CTR« I)
   .*»0.798tS7»CTR(I)*«0.83"+17l'0*CTH(I)»*0.a2fc»<»?*CTRtI)*«fl.6a2t<a7hS5*CTB|I)**O.S03+SOI 12«CTR{ I ) **0 .69R+31?9«CTR( I )**
                    01 3?
                    01 J3
                                                      .3S*1 .56?S*BETA(3,
   .p)»l?tl»TRCS(I)*». 3) + (106'iOO«STrsni«»0. 598 + 271 SOO*STCS( I> *»0.8027
   .«15COno«STCSlU*»0.602 >«NSP|I))
    CI1ST2(1,I)=  (200*CTR(I)*«0. 46276+ 7S*CTR(1)««0. 071+10800+8 75«CTR(I)
   .«*0.798+57*CTI*(t)»«0.838+1790»CTRII)**0.aP6+9?*CTP(I)*'0.6a?tR5a7.
   .5»CIRIl))«NTPf I)   +llOOO«STCS(I)**0.a7+a80*STCS(Il«»0.a+|a«STCS(I)
   ,**0.b1 +2500+ 1930* TRCSI I )«*0.a68+?aO»TRCS( I 1+875*TRCS(1)**0. 798+57
   .*TRtSm**0.f 3*)l*NSP(I)t
   .(8S.5*CTRII)«*0.8ea3+?5.6*CTR(l ) »*0.698+5a*CTR(l ) +3«65*CTP( I )**0. 3
   . i?+36*CTHf Il.»o.b6?+20«CII»(I)«*0.86)*NTP(I) +
   .(2700«CT»IIV»«o.hl8+!91S*C1l»(I)»*0.203+?2?0*CTR(I))«NTP(I)
    GO TO 901
11? J COST1 (1,1)=  1,i"itf(53a3«CTRtl)**0.7?a»«8000«CTR(I)»«0.61l +
                                                                             3J?
                                                                             333
                                                                             33"
                                                                                                                3afc
                                                                                                                3SS

-------
                    FOH1PAN  IV G LFVFL   21
                                                            COST
                                                                               DATE = 7636«
                                                                                                     17/01/54
                                                                                                                          PAGF  nons
U)
                     013«
                     CMS
                     0136
                     0137

                     013*
                     013<>
                     Olao
0142

0143
                     0145

                     0146
                     0147
                     ul«8
                     0|.J»
                     0150
                     01S1
                     01S?
                     01 S3
   .RU)»«0.<>116S*43l20<>CTR(I)**0.8t73*?47655«CTR(I)«»0-.503-»50l12*CTR(
   .U«*0.69»»SI29*CTR(I)**0.a84l2)*NTP(n»
   .                       •                    (5280*0. 35*1. Sfc?5«ReTA(3.
   .I))»(:>l<*THCS(n«*.3)t(106SOP«STCS(n«*O.S9t)«?71SOn.STCSU)**0.8027
   . *150000*STCS(T)**0.hO? )*NSPU))
    COST2(1,I)=  (?00«CTR(I)*«O.U6?7h+75«CTR(Il«*0.471t10800*875«CTRfl)
   .»*0.708+57*CTB{I)*«0.»38+l7'»0*CTW(I)**0.4?6+<>2*CTP(I)**0.b«?+a587.
   . 5«CTR(I) )«NTP( II   *<1000*SICS(I)««O.H7»480«STCS(1)««0.4*14«STCS(I>
   .*«O.S1
                                       .(S'»00«CTH(I)««0.731«-H2?»*CTR(I)«»0.?067+(>.<1«CTR(I)««0.I).FQ. GO  TO  <>01
                   Cnsri(.l.I)sC(iS11 tl,T)*1.2S*(10««>3e»  CTRf I)»«.73S7)*NTP(I)
                   COST2(1,I)EC(1SI2(1,D*  ( ?27bO + ?7.8» CTR(I)*761* CTR{ I >*«.2S6)«N1P
                  .CD
                       INUE
                                      rn fc7o
      IF  (NnPT.Eli.3)
      GO  Til  902
C
C THESE STEPS  CALCINATE ADDITIONAL COSTS FOR  RECREATIONAL CRITERIA
C
  670 IF(LEVEL(?.T).t0.1) GO TO »7l
      COSTl(?.I)=dlST1 (2,1)+   NSSTP(T)*(5343*TRSS(T)**.72«»63039*5190«T
     .RSS(I)  )»1.25
                           J*       (8V.'5*TRSSU)**.8843*1783«TRSS(1)«*.S
                           H+1134*TRSS(I)»».69+S««TRSS(I))*NSSTP(I)
C
C THE NF»T EOIJATIUNS  COMPHTF DISINFECTION  COSTS FOR CATEGORY FIVE
C
  671 IF  riEVEL(l,I).r,T.ll CO- TO 67?
                  ,9n«C2*STCS(T)D
                   COST.M 1,1 )=CiiS1Pt1 , I> + («5.5*(?*STrSCI))**.8*43-f1703*(STCS(I)«?>*«.
                  .S97«?S.(.«(STCS(I)«2)«*.698»113
-------
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                                                                                                                     no"
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-------
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 7? 00 71 K=1,S
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  7 IF (NilPT.F.Q.1 )  KC1 TO 5
    IF (NOPT.Fd.?)  C.M TO U
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-------
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-------
                                APPENDIX D


                       COMMENTS ON THE DRAFT REPORT
                         AND RESPONSES TO COMMENTS
          Copies of the draft report of October, 1976 were sent to each
 State Water Pollution Control Director, State Needs Survey Director, Inter-
 state Water Pollution Control Commission, and EPA regional office as well
 as numerous other individuals on October 22, 1976.  Written comments on
 the draft report were requested by December 1, 1976.

          A series of meetings was held in each EPA regional office
 November 8 through 23, 1976 to present the report and receive verbal
 comments.  Written comments received prior to January 1, 1977 were incor-
 porated in the final report.

          Comment letters  were received from 29  states,  1 territory,
3 interstate  commisions,  3 cities,  and 2 other organizations.   Numerous
other organizations  were  represented at the regional review meetings
and offered verbal comments.   The comment  letters  are reproduced on the
following pages and the EPA responses follow each  set of comments.  The
effort of those who read  and commented on  the draft  report are  appreciated.
It is hoped that the responses will be as  helpful  as the comments.
                                    D-l

-------
                                                            JAYS. HANHHOHO. GOV£RHOH
DEPT. OF ENVIRONMENTAL CONSERVATION
                                                      POUCH 0 ~ JUHEAU 99111
                                             November 9, 1976
    Mr. James Chamblee, Chief
    Needs Assessment Section
    Facility Requirements Branch (WH-547)
    U.S. Environmental Protection Agency
    401 M St. S.W.
    Washington, D.C.  20460

    Dear Mr. Chamblee:

    This agency has reviewed the draft "1976 Survey of Needs for Control of
    Pollution from Combined Sewer Overflows and Stormwater Discharges",
    and we have the two following comments for your consideration:

    1) Other than the introductory remark that the report is prepared to comply
    with the requirements of PL 92-500, there is no statement of purpose for
    the study.  In what manner will the report be used and of what importance
    is it to the states? It is our understanding that construction grants funded
    under sec. 201 of PL 92-500 are not available for construction of storm
    sewers and separation of combined sewers.

    2) The base data in Appendix B lists the EPA 1990 population forecast
    for Alaska as 408,000 (page B-8) .  This figure also appears elsewhere
    in EPA needs study data, and is far too low.  Existing State Department
    of Labor statistics lists Alaska's present population as 406,000.   A detailed
    reliable forecast of the State's population, was recently prepared by
    the University of Alaska Institute of Social, Economic, and Government
    Research. The  results  of this study are summarized on the attached sheet.
    These forecasts take into account the phasing of various oil and gas
    projects. We recommend adoption of the 1990 forecast of 676,081 which
    assumes a pattern of limited development of oil and gas reserves.

    Since this forecast has a bearing on our 201 grant allocations  and presumably
    reflects future sewerage needs, we would like to take this opportunity to
    have it corrected.

    Please call if you have questions regarding this review.
                                              Sincerely,
   cc: Regional Administrator, Region X

                                    D-2

-------
                              EXHIBIT 18
                    ALASKA POPULATION PROJECTIONS
      tj;v!J~%:"i"".si_"'_ i. ^fci&a^^a^.i^SiJi.-^.M
Southeast

Southcentral

Southwestern

Interior

Northwestern
  Statewide           406,000

rjo^sa^aEK^r-s;-' ^^r^^ss
1975*
61,000
226,500
28,500
77,500
12,500
1980**
66,000
279,000
30,000
74,000
17,000
1985**
85,000
366,000
33,000
83,000
18,000
                 1990**

                99,000

               483,000

                36,000

                95,000

                19,000
                                   466,000
585,000
/c r
     *Alaska Department  of  Labor

    **Institute of Social,  Economic,  and Government Research,
      University of Alaska.
                                 D-3

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                                   Table ' .   Projected  Population Changes for Alaska
                                        and  the Southeast Region. 1975 to 1990.
Y
E
A
R
1975
1980
1985
1990
Limited Development — '
Southeast
Alaska
51,527
63,093
75,448
83.358
All of
Alaska
376.601
457.291
571,434

\ 676.08ll
	 -, 	 ,
Accelerated Development *J
Southeast
Alaska
51,527
64.012
83,706
95.937
All of
Alaska
376,601
472.970
647.707
802.075
t)
                  I/  Projections based on regional economic model developed for Man-in-the-Arctic
                      Program by the Institute of Social, Economic and Government Research,
                      University of Alaska, Anchorage, Alaska, 1976.

                  2/  Assumptions underlying limited development projections are that the Beaufort  1,
                      Upper Cook Inlet/North Slope Uplands, Lower Cook Inlet, and Yukon-Klondike/
                      Copper River oil developments will start by 1980.  Also the North Slope Uplands  1
                      development will start by 1979; the Gulf of Alaska (East) by 1983 and the Gulf of
                      Alaska  (West) by 1984.
                  j}/~  Accelfirated development assumes  all the  starts  Incl.  under limited  development
                      1981 - Lower Cook Inlet II                                scenario  plus:
                             Gulf of Alaska  (on or near  shore)
                      1982 - West of Pet 4/NS Uplands
                      1983 - Beaufort II; West of Pet 4; Pet 4
                      1984 - Bering St. Geo/OBB
                      1985 - Beaufort/Chukchi

-------
                                                              19 NOV 1976

Mr. Ernst Mueller, Commissioner
Department of Environmental
 Conservation
Pouch "0"
Juneau, AK  99811

Dear Hr. Mueller:

      This 1s In reply to your letter of November 9,  1976,  concerning the draft
report "1976 Survey of ?feeds for Control of Pollution from  Combined  Sewer
Overflows and Storawater Discharges."

      The Heeds Survey is submitted to Congress in compliance  with Sections
516(b)(2) and 205(a) of the Federal Water Pollution Control  Act  (PL .52-500).
These provisions have the dual purpose of obtaining a comprehensive  estimate
of the total cost of meeting the yoals of the FWPCA,  and of estimating  these
costs State-by-State as a possible basis for the allocation of construction
grant funds.  As you may be aware, the Congress sets  tne allocation  formulae,
and in the past Category V has been partially included.

      For data collection purposes, the 1976 Needs Survey was  handled through
two separate contracts.  Categories V and VI were done using modeling tech-
niques on a State-by-state basis, resulting 1n the draft report.  Categories I
through IV were done on a f ad lity-by-facility basis, using data-of-record
from the 1974 Survey as a starting colnt.

      The 1976 Survey foras for Categories I-IV were  updated by  contractor
personnel based in each Regional Office.  These personnel had  complete  access
to all Regional files, and also worked closely with each State Needs Director.

      In a raemo to all State and Regional Needs Survey Directors, dated
March 25, 1976, we outlined the procedure to be used  by the States to rfiquest
a variance on the 1990 population projections.  The stated  April  15  deadline
was later extended to April  30.  We regret to inform  you that  since  the data
collection stage of the Survey 1s now completed and the 1990 population ,has
been adjusted on a facility-by-facility basis, it 1s  too late  for us to grant
a variance on Alaska's 1990 population ceiling.

      I hope that this has answered your questions.  If I can  be of  further
help, please let me know.

                                    Sincerely,
                                    James A. Chamblee, Chief
                                    Needs Assessment Section
                                            (WH-547)


                                  D-5

-------
DEPT. OF ENVIRONMENTAL CONSERVATION
                                                                   JAY S. HAMMOND, GOVERNOR

                                                                Pouch 0
                                                                Juneau   99811
                                                   December 23, 1976
                Mr. James A. Chamblee, Chief
                Needs Assessment Section (WH-547)
                U.S. Environmental Protection Agency
                401 M Street SW
                Washington, D .C .  20460

                Dear Mr. Chamblee:

                Need Survey Estimates - Catagory V and VI

                Thank you for your letter of December 16, 1976 which transmits
                a print-out of the final EPA estimates for Categories V and VI.

                At  this time we would like to submit for inclusion in your report
                to Congress, the State's estimate of needs  for these two categories.
                Since the EPA needs are based upon an erroneous 1990 state popu-
                lation forecast of 408,000, as mentioned in our letter of November 9,
                1976 to you,  we have pro-rated the estimated needs to reflect a more
                realistic population forecast of 676,000.  Accordingly, our estimate
                of needs for these categories is as  follows:
                   Category V
                   Category VI
$5.01 million
$25.24 million
               Thank you for your attention to this matter.
                                                   Sincerely ,
                                                   Jonathan W. Scribner
                                                   Director
                                                   Division of Water Programs
               cc:  EPA, Region X
                                         D-6

-------
      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C.  20460
                                                        ,
Mr. Johnathan W. Scribner
Director, Division of Water Programs
Department of Environmental Conservation
State of Alaska
Pouch 0
Juneau, Alaska  99811

RE:  Draft Report on 1976 Needs Survey for
     Conibined Sewer Overflows and Stonnwater

Dear Mr. Scribner:

     Thank you for your letter of December 23,  1976,  which transmits
your estimates of $5.01 million for Category V and $25.24  million for
Category VI.  We will include your estimates as well  as the EPA estimates
reported to you on December 16, 1976.

     The final report, including all conments received from the States,
will be forwarded to you in early February 1977.

     If I can be of further assistance, please let me know.

                                   Sincerely yours,
                                   James A. Chamblee, Chief
                                   Needs Assessment Section
                                           (WH-547)
cc:  Robert Coughlin, USEPA Region X
     Needs Survey Coordinator

-------
                  ARIZONA DEPARTMENT OF HEALTH SERVICES
                                                                      Office of the Director

                                                                         tov 3 0 1976
  RAUL H. CASTRO,  Governor
  SUZANNE DANDOY, M.D., M.P.H., Director
              Mr. James Chamblee
              Chief, Needs Assessment Section
              Facility Requirements Branch  (WH-547)
              401 M. Street,  S.W.
              Washington,  D.  C.   20460

              Dear Mr. Chamblee:

              RE:  1976 Needs Survey Categories V and VI

              This is to notify you that this Department has received the  draft
              report on needs for combined sewer overflows and storm sewers,
              categories V and VI respectively.

              We have reviewed the methodology, needs estimates,  and base  input
              data and have no changes or comments to offer you at  this  time.


                                              Sincerely,
                                              Ted Williams
                                              Deputy Director
              TW:JAWrcma

              cc: Bureau of Water Quality Control
                                           D-8
State Health Building             1740 West Adams Street           Phoenix, Arizona 85007

-------
*
s •J*""fc- -   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      ,0<^                     WASHINGTON, D.C. 20460
    Mr. Ted Williams
    Deputy Director
    Arizona Department of Health Services
    State Health Building
    1740 West Adams St.
    Phoenix, Arizona 85007
                                            RE:   Draft Report on 1976  Needs
                                                 Survey for Combined Sewer
                                                 Overflows and Stormwater
    Dear Mr. Williams:
         Thank you for your letter of November 30, 1976, on our draft report
    which estimated needs for combined sewer overflows and stormwater control
    (Categories V & VI).

         The final report, including all comments received from the states,  will
    be forwarded to you in early February, 1977.

                                        Sincerely yours,
                                        James A. Chamblee, Chief
                                        Needs Assessment Section
                                                (WH-547)
    cc:  Robert  Rock,  Region  IX.
                                      D-9

-------
STATE OF CALIFORNIA-TH6 RESOURCES AGENCY                                   EPMUND G. BROWN JR.. Governor

STATE WATER RESOURCES  CONTROL BOARD

P. O. BOX 100 • SACRAMENTO 95801
(916) 445-7971
       Mr. James Chamblee, Chief                      In Response  Refer
       Needs Assessment Section                         to:  560:JA
       Facility Requirements Branch (WH-547)
       U.S. Environmental Protection Agency
       401 M Street,  S.W-
       Washington,  D.C.  20460

       "1976 SURVEY OF NEEDS FOR CONTROL OF POLLUTION FROM COMBINED
       SEWER OVERFLOWS AND STORMWATER DISCHARGES"

       Requests for comments on the subject report, "1976 Survey of
       Needs for Control of Pollution from Combined Sewer Overflows
       and Stormwater Discharges" were received by this Agency
       through various channels, including the Resources Agency, the
       State-Federal Water Programs Advisory Committee and the
       Environmental Protection Agency (EPA), Region IX.  It is
       unfortunate that the opportunity to comment on the approach
       taken to assess needs in these areas was not offered at an
       earlier date.   Much information, particularly in the area of
       combined sewer overflows, is available in California as a
       result of completed Step 1 and Step 2 work.  Furthermore, the
       time that was allowed for review and comment was too short
       for a detailed review.

       As part of the review process,  a meeting with EPA was held  on
       November 8.   At that meeting,  our staff expressed concern over
       the methodology used and the resulting reduction in needs.
       Money and time constraints were used to explain the lack of a
       more in-depth study on this complex subject.  Far less effort
       has been expended to document  Category V (combined sewer
       overflows)  and Category VI (storm sewers) needs, than was used
       to develop needs for Categories I-IVB, though the former, in
       terms of cost,  are greater than the latter.  Comments have
       been solicited from the states; however, we are concerned that
       EPA may be locked into  the methodology presented in the draft
       report.  We  do not believe that resulted in an accurate estimate
       of California's needs.   The needs reported are much less than
       those documented by studies completed in California.

       Enclosed are specific comments  concerning the subject report.
       Also enclosed  are comments that were solicited from San Francisco,
       which has the  major portion of  Category V needs in California.
                                   D-10

-------
  Mr.  James Chamblee            -2-            DEC
  I  hope these observations will be used to assess the utility
  of the report.   Mr.  James Cornelius of our staff will be
  available to provide further comments on this report prior to
  final publication.
       E.  Bryson
t  Chairman

  Enclosures

  cc:   Environmental Protection-Agency,
         Region IX
       ATTN:  Mr.  Robert Rock
       100 California Street
       San Francisco, CA  94111
                             D-ll

-------
               CALIFORNIA  STATE  WATER  RESOURCES  CONTROL  BOARD
                          COMMENTS  ON  DRAFT  REPORT

            "1976 SURVEY OF  NEEDS FOR  CONTROL  OF POLLUTION FROM
             COMBINED SEWER  OVERFLOWS  AND  STORMWATER  DISCHARGES"
Although it was requested  that  our  review  focus  principally on  the base
data input, our greatest concern  is in  the methodology  used to  determine
needs.   As previously stated, we  do not concur in  the methodology used
in the  report.   The results  produced do not  represent a reasonable assess-
ment of national  needs.  The following  comments  were generated  from the
limited review of base data  input and methodology  (time constraints did
not allow a review of the  computer  program):

     Base Data

     1.  Streamflow data was not  verifiable  due  to the  lack of  specific
         information given.   The  USGS gaging station or the particular
         reference used to determine streamflow  should  be  identified.

     2.  The method used to  determine the  reaeration rate  (k2)  is rather
         arbitrary and certainly  is not validated  by data  obtained from
         the site studies.

     3.  Data from the 1967  APWA  report used to  obtain  the average
         drainage area per combined sewer  overflow is questionable
         and cannot be related  to the drainage areas used  from  the
         1975 APWA report.


     Methodology

     1.  The derivations of  numerous equations used in  the mathematical
         model  are questionable.  Most  equations were formulated  from  a
         limited  data base.  A  particular  example  of this  was acknowledged
         by the authors of the  report as follows:   "Unquestionably, the
         data base for estimating pollutant  loads  is very  weak  and the
         resulting estimating equations, supported by such a weak founda-
         tion should be used with extreme  caution".

     2.   The receiving water quality criteria and  the overall control
         levels are inconsistent  with those  addressed in NPDES/WDR
         permits,  the "Water Quality Control  Plan  for Ocean Waters
         of California" and  the "Water  Quality Control  Policy for the
         Enclosed  Bays and Estuaries of California".  It is particularly
         disturbing to identify 1990 needs without considering  control
         of such  pollutants  as  heavy metals,  pesticides, herbicides and
         asbestos.
                                    D-12

-------
                                 -2-
3.  The assimilative capacity of receiving waters was considered in
    the site studies; however, the resulting relationship to
    determine required level of treatment is very suspect when
    considering only the few data points used to develop it.

4.  The proposed treatment schemes cannot be uniformly applied
    to all areas.  The use of best management practices throughout
    the country is highly questionable.  Removal of pollutants at
    the source by street sweeping is dependent on local economics,
    operations and pollutant loads.   Utilization of existing
    facilities and optimization of treatment and storage can only
    be addressed for specific areas.

5.  The cost estimating methodology used results in very low costs
    when compared to costs from completed Step 1 and Step 2 work.
    It would be more meaningful to document needs for Category V in
    the same manner as Categories I-IVB.

6.  The site study attempted for San Francisco is another trouble-
    some area.  Although a receiving water impact evaluation could
    not be completed for San Francisco, the data derived from the
    other site studies was used to develop the model which ultimately
    did assess the impact and needs for San Francisco.  The report
    stated that it was not intended to predict needs for a specific
    area and that it was a best estimate of statewide needs; however,
    the majority of California's Category V needs are in the
    San Francisco Bay Area.  Attached are additional comments from
    the City and County of San Francisco.

7.  Mathematical modeling has become increasingly useful in attempts
    to predict or assess environmental impacts.  However, a mathematical
    model is useless if it cannot be validated.  The draft report
    states that $334 million of EPA funds has been spent on combined
    sewer overflow control.  It would be logical to assume that there
    is a wealth of information available to test the validity of the
    model.
                                D-13

-------
                 CiTY  AND COUNTY  Cf SAN  FRANCISCO

                       AENT   OF  PUBDC  \VORKS

                   BUREAU  OF  SANITARY gNGINggSiNG	

     770 GOLDEN GATE AVE. 3SD R.    SAN FRANCISCO,CAl. 94102     (415)353-2I3T
                         November 19, 1976
                                          1976 EPH
                                          Needs Survey:
                                             . 's V end VI
State Water Resources Control Board
P. 0. Box 100
Sacramento/ CA

Attention:  Mr. Ed Dito

Gentlemen:

This letter is in response to the request of Kr. Dito of your
staff and members of the EPA staff on the subject project to
Mr. Cockburn of my staff for comments on the draft 1576 needs
survey report for combined sewer overflow control and storm-
water control   (Categories V and VI respectively) .

As Mr. Cockbxim stated at the presentation meeting on Novsjnber 8,
1976 in the EPA offices, we are greatly dismayed at the lack of
coordination exhibited by the EPA in producing such a report
without any contact with local or State agencies who have been
intimately involved in the problem.  Further, if it had not be«n
for Mr, Dito's invitation, we would not have had any opportunity
to consaient on this report which might have severe impact upon the
City's present program (as well as the State's).  Tha time allowed
to review and comment on the report was also much too short for
any detailed review.
     attaching a list of the City's general comments with specific
examples where we have had time to develop them.  Basically, the
report estimates costs about ten times lower than our estimates
for the same facilities.  Also the basic methodology and control
levels selected are subject to severe question.  There appears
to be little in the report to recommend it without major revision.

In light of the short time for review and the possible importance
of such report in terras of funding, it is our request that the
adoption and publication of this survey be delayed pending detailed
review and revision.

-------
State Water Resources Control Board
November 19, 1976
Page two
He will be available to answer any questions which you might
hava concerning our comments and furthar to also aid and
support your staff in conveying our comaents to the EPA.

                             Very truly yours.
                                      fed land, Chief
                             Bureau of Sanitary Engineering
Attach:  As Noted
cc:  EPA
     Region IX  Attn:  Mr. Kobert Rock

     EPA
     Municipal Construction Division
     401 N St. S.I?. WH 547
     Washington  D.C.  20460    Attm  Mr. Wen H. Huang

     State of Ore.
     Dept. of Environmental Quality
     1234 S.W. Morrison St.
     Portland, Oregon   ,97205   Attn:  Mr. C. P. Hilbrick, Jr
                         D-15

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                    Comments on Draft 1976
                    Survey of Needs for Control
                    of Pollution from Combined Sewer
                    Overflows and Stonnwater Discharges


1.  The approach used of applying a uniform set of standards
    to all areas is not responsive to differing local needs
    a^d uses.  It would be much better to allow each state to
    define its own needs.  Each-independant entity with a com-
    bined sewer overflow problem is probably much better
    informed as to its needs and xrosts.  San Francisco is a good
    case in point.  We have a program under construction with
    fairly definite goals for protection which are consistent
    with SWRCB and RWQC3 goals as well as EPA approval for funding.
    Yet, the criteria used in the report are significantly different,
    with costs which are much lower than the City's program anti-
    cipates.

2.  The method of developing storage volumes and treatment rates
    is not a method which we can relate to reality.  The approach
    when applied to San Francisco results in a storage volume
    of 0.53 inches of rainfall and a treatment rate of abo'afc 70
    HGD.  This in turn would result in between 10 and 20 untreated
    overflows per year and a capture of less than one half of the
    rainfall runoff.  Thus, the sizes put forth do not roest the
    80 percent control criteria in the report even though they
    were developed following the methods used in the draft report,

3.  The water quality criteria levels used and the overall con-
    trol levels (80%) are inconsistant.  For example, fish and
    wildlife protection must necessarily include shell fishing
    coliform standards for those waters where this beneficial
    use exists.  This is not included in the criteria.  To provide
    recreational protection will require better than 80% control.
    Otherwise,the receiving waters will not meet the stated
    criteria for a significant period of time.  Control levels
    in the mid to high 90 *s are more appropriate*  Further,
    toxicity removal may be the roost significant benefit to
    category VI control yet it is totally ignored.  All of these
    problems result from the attempt at uniform criteria rather
    than evaluating area by area needs.

4.  No attempt was made to resolve the difference in costs between
    the 1973, 1974, NCWQ and 1976 estimates even though significant
    differences exist. This is an ommission which must be corrected.

5.  The costs as stated in the report are low by factors of upwards
    of 10 times.  For example the cost of San Francisco's present
    program  is about 1,437 million dollars (ENR2800).  Of this
    cost 962 million is for wet weather control.  Yet the total
    State need is estimated at 159 million in the report.  On
                             D-i

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Page 2


an areawide apportionment, San Francisco accounts for
about ,one half of that value.  Thus where we estimate
a need of $952 million, the report estimates a need of
about $80 million.  This type of difference indicates
that a detailed review of the cost bases is necessary.

A couple of examples of the inaccuracy of the estimating
formulas will earve to point to one area of concern.

A.  Pumping Station Costs:

    EPA Formula
    Cost « 98,826 (Peak Plow) ..expoiu  0.602
    for our Channel Street Station (P.P. = 100 KGO)
    'This results in a cost of $1.7 million.
    The bid cost this year was $13.3 million for construction
                                               •
B.  Cost of Pretrsatrmint and Primary Sedimentation

    EPA Formulas:
    Screens: 43,120 (Treatment Rate)  expon. 0.817,
    Sedimentation: 13,110 (Treatment Rate) expon/0.955
    Using the Southeast Expansion as an example
    (Peak Rate =142 HGD)
    Screens = $1.5 million
    Sedimentation Tanks = $2.5 million
    Sum » $4.0 million
    City 10% design estimate - $40 million
                        D-17

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460
Mr. John E. Bryson, Chairman
State Water Resources Control Board
Post Office Box 100
Sacramento, California  95801

Re:  Draft Report on 1976 Needs Survey for
     Combined Sewer Overflows and Stormwater

Dear Mr. Bryson:

     Thank you for your letter of December 1, 1976 offering comments on
our draft report which estimated needs for combined sewer overflow and
stormwater control (Categories V & VT).

     In response to your general comments, every attempt within budget
and time constraints was made to obtain comments from the states on the
draft report.  An early draft report was published and distributed to
the states prior to complete review within EPA.  It is unfortunate, if
the time constraints with this project allowed insufficient time for
your detailed review and comment.

     In regard to your specific Garments on base data, the stream flow
data was developed on an urbanized area basis and used USGS gaging
information to determine the three month average low streamflow for each
particular urbanized area.  We agree that the method used to determine
reaeration rates is rather arbitrary and we are requesting validation of
this data by the states.  Data from the 1967 APWA report was used only
when more recent data was unavailable for a particular parameter.  It is
unfortunate that a complete up to date inventory of combined sewered
area across the nation is not available.

     In regard to your specific questions on methodology, the derivation
of the equations used in the mathematical model were based on the avail-
able data base.  This data base is very weak and the resulting estimated
equations are difficult to verify and should be used only for general
estimation purposes.
                                D-18

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     Definition of receiving water quality criteria for wet weather
discharges is very difficult at the present time since state standards
are non-existent for these stream flow conditions.  Although the need
for control of such pollutants as heavy metals, pesticides, herbicides,
and asbestos have been identified, specific numerical state stream
standards for these pollutants have not been documented.

     The relationship developed to determine the required level of
treatment utilized the available information developed during the project.
Although it is unfortunate that more site studies could not be used to
verify the relationship, it does point out that many areas do not require
complete control of stormwater runoff to meet water quality standards.
Additional data.points have been added in the final report; the relation-
ship between the assimilative capacity and required treatment level was
not measurably affected.

     We agree that the proposed'treatment schemes cannot be uniformly
applied to all areas.  The schemes were identified to provide an in-
creasing cost for increasing levels of control.  Only by a detailed
evaluation of specific local problems and feasible solutions can an
applicable treatment scheme be defined for a specific area.

     After a detailed review of the cost estiitiated equations used in the
draft report, the equations were revised to predict more accurately
present construction costs for these unit processes.  These revisions in
part have result in an approximate doubling of the project needs estimates
for Categories V &VI.  In regard to verification of the mathematical
model, several approved facilities plans are being evaluated to assess
the accuracy of the methodologies used in estimating needs for combined
sewer overflow control.  This is somewhat difficult to do because of
differences in design parameters, facilities sizing, and other variables
in methodology.

     The final draft report, including all conments received from the
states, will be forwarded to you in early February 1977.

     I hope that this has answered your questions.  Enclosed is a copy
of our response to Mr. A.O. Friedland's letter of November 19, 1976, a
copy of which was included with your letter of December 1, 1976.  If I
can be of any further assistance, please let me know.

                              Sincerely yours,
                              'James A. Chamblee, Chief
                              Needs Assessment Section
                                        (WH-547)
Enclosure
cc:  Mr. Robert M. Rock, USEPA Region IX
     Needs Survey Coordinator      D-19

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON  D.C.  20460
                                                      1.1 JAM 1977
Mr. A.O. Friedland, Chief
Bureau of Sanitary Engineering
Department of Public Works
City and County of San Francisco
770 Golden Gate Avenue, 3rd Floor
San Francisco, California  94102
                                   RE:  Draft Report on 1976 Needs
                                        Survey for Combined Sewer
                                        Overflows and Stormwater
Dear Mr. Friedland:
     Thank you for your letter of November 19, 1976, offering comments
on our draft report which estimated needs for combined sewer overflows
and stormwater control (Categories V & VI).

     After reviewing Garments on the draft report, several changes have
been made which significantly affect the needs estimates for Categories
V and VI.  The final needs estimate for the State of California is
$385.115 million dollars, as compared with the draft report figure of
$159 million.

     In regard to your specific comments, the decision to apply a
uniform set of wet weather standards and a uniform methodology to
estimate state-by-state needs was developed based on the fact that
nationwide information on a facility-by-facility basis is not available
for either the combined sewer overflow problem or the stormwater problem.

     The method for developing storage volumes and treatment rates was
developed from existing literature and several simplifying assumptions.
The methodology was evaluated in detail in several cities and showed
that the 80th percentile storm event would result in between 10 and 20
overflows per year and capture approximately 80 percent of the rainfall
runoff.  In the final report the control levels for combined sewer will
be increased in response to comments which were received.  The cost of
achieving the aesthetics and the fish and wildlife criteria will be
evaluated for control of the 90th percentile storm period.  The cost of
achieving the recreation criteria will be evaluated for an 98th percentile
storm.  For Category VI,  all criteria will be evaluated for an 80th
percentile storm.  The final report will contain an expanded discussion
of toxic pollutants.
                                  D-20

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     Section 8.4 and 9.2 of the draft report discussed the differences
in cost estimates between the 1973, 1974 and 1976 estimates.  This
section will be expanded to include comparison of the NCWQ cost estimates
for the final report.

     After a review of the cost equations in the draft report, several
equations for unit processes were modified to represent more accurately
the cost of actual construction.  Significant adjustments were made to
the pumping equation and to the storage equation.  These changes, in
addition to increasing the size of the design storm, provided the major
reasons for the approximate doubling of the Category V cost estimate
that was mentioned earlier.

     Our Sanitary Engineer, Wen Huang, called Mr. R.T. Cockburn and
requested the bid tabulations for the pumping station in question.  As
soon as we receive the material from you and complete the analysis, we
will write to you further on this subject.

     The final report, including all comments received, will be forwarded
to you in early February 1977.

     I hope that this has answered your questions.  If I can be of
further assistance, please let me know.
                              Sincerely yours,
                                  Chamblee, Chief
                         Needs Assessment Section
                               (WH-547)
cc:  Mr. John E. Bryson, Chairman
     State Water Resources Control Board
     Post Office Box 100
     Sacramento, California  95801

     Robert Rock, USEPA Region IX
     Needs Survey Coordinator
                                 D-21

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.STAiE OF CALIFORNIA—THE RESOURCES AGENCY
                                  EDMUND O. BROWN JR., Govirnor
STATE WATER RESOURCES CONTROL BOARD
P. O. BOX 100 • SACRAMENTO 95801

                                               In  Reply Refer
                                               to:   560:RB
      ,! AN 5 ~1977

      Mr. James Chamblee, Chief
      Needs Assessment Section
      Facility Requirements Branch  (WH-547)
      U.S. Environmental Protection Agency
      401 M Street, S.W.
      Washington, B.C.  20460

      "1976 SURVEY OF NEEDS FOR CONTROL OF POLLUTION  FROM COMBINED
      SEWER OVERFLOWS AND STORMWATER DISCHARGES"

      The final EPA estimates for California's 1976 Needs Survey
      Categories V and VI, transmitted with your  letter of
      December 16, 1976, were received with a  certain amount of
      disappointment on our part.

      The State of California and some of our  local communities have
      spent a considerable amount of time and money studying various
      aspects of abating water pollution from  combined sewer overflows
      and stormwater discharges.

      In our December 1, 1976, letter to you, we  commented on various
      inadequacies in the draft copy of the "1976  Survey of Needs
      for Control of Pollution from Combined Sewer Overflows and
      Stormwater Discharges".  We also included a  letter from the
      City of San Francisco which pointed out  that San Francisco's
      wet weather control costs are currently  estimated to be
      $962 million (based on an EPA funded Step 1  study).   Yet your
      final estimate for California's Category V  needs, is only
      $385.115 million.  Your final estimate for  Category VI needs
      was $5,298.258 million which is considerably lower than our
      estimate of $9,761 million to $97,607 million.

      It is our understanding that we are permitted to have an inde-
      pendent State estimate included in your  report  which is to be
      submitted to Congress on February 10, 1977.

      California's estimate of needs in January 1976  dollars is:
          Category V
          Category VI
$1,261 million
$9,761 to $97,607 million
      These estimates are based on a July 1974 report  (enclosed)  to
      the California State Water Resources Control  Board which was
      done by Metcalf and Eddy, Incorporated.  The  range given for
      Category VI reflects the difference between a minimum compre-
      hensive program and a fully developed program.
                                    D-22

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Mr. James Charablee               -2-               JAN 5  1977
Due to the January 7, 1977, deadline for submittal of state
estimates, I understand that the estimates listed were
transmitted to your office on January 5, 1977, via telephone.

Mr. James Cornelius of our staff will be available to provide
further comments, if necessary, prior to your submittal to
Congress.
John E. Bryson
Chairman
Enclosure

cc:  Environmental Protection Agency,
       Region IX
     ATTN:  Mr. Robert Rock
     100 California Street
     San Francisco, CA  94111
                              D-23

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        I'NITED STASIS FMVIRi'NMLl'NTAL PRO F FO 'PM AGENCY

                         \VA'"^ :U-.!CTON. PC.  ?0-1f!0
John E. Bryson, Chairman
State Water Resources Control Board
Post Office Box 100
Sacramento, California  95801
                                        Your reference:  560:RB
                                        Re:   Draft Report on 1976 Needs
                                             Survey for Combined Sewer
                                             Overflows and Stormwater
Dear Mr. Bryson:
     Thank you for your letter of January 5, 1977 which transmits your
estimate of $1,261 million for Category V and $97,607 million for Category
VI.  We will include the State estimate for Category V estimates as well
as the EPA estimates reported to you on December 16, 1976.

     We understand from recent conversations with your staff that the
State estimate for Category VI should not be reported as an official
independent State estimate.  We will, however, discuss it in the text of
our report to Congress,

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     If I can be of further assistance, please let me know.

                              Sincerely yours,

                              !  (1   (*
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COLORADO  DEPARTMENT OF  HEALTH

 421O E. 11TH /VENUE        DENVER BO22O            PHONE 3SB-B111

                    ANTHONY ROBBINS. M.D..M.P.A. EXECUTIVE DIRECTOR
     November 23, 1976
     Mr. James Chamblee
     Chief, Needs Assessment Section
     Facility Requirements Branch  (WH-547)
     401 M. Street, S. W.
     Washington, D. C.  20460

     Re:  Needs for Catagories V and VI

     Dear Jim:

     Thank you for the opportunity to review and comment on the "Draft-
     1976 Survey of Needs for Control of Pollution From Combined Sewer
     Overflows and Stormwater Discharges".  I am sorry to say that we
     do not have enough background data at this time to verify or
     disprove the findings in the  report.  The Area 208 agencies are
     developing required data, but until the plans are completed, we
     will not have sufficient information.  Hopefully, sufficient in-
     formation will be available for the next needs survey.

     Sincerely yours,

     FOR DIRECTOR, WATER QUALITY CONTROL DIVISION
                    o •  "^/i Uti-/i(..i
     Ronald G. Schuyler, P.E.      /
     Technieal Services and Grants7 Section
     RGS/vg

     cc: Horriberg,
                                  D-25

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C. 20460
Mr. Ronald G.  Schuyler, P.P..
Technical Services and Grants Section
Colorado Department of Health
421u Last 11th Avenue
Denver, Colorado  P0220
                                        RE:   Draft Report on 1976 Needs
                                             Survey for Combined Sewer
                                             Overflows and Stormwater
Dear rlr. Schuyler:
     Thank you for your letter of November 23, 1975 offering comments on
our draft report which estimated needs for combined sewer overflows and
Stormwater control (Categories V 5 VI).

     As you state, the available data base developed through the 208
Agencies may provide a much more specific data base for the 1978 Needs
Survey.

     The final report, including all  comments received from the states,
will be forwarded to you in early February, 1977.

     If I can be of any further assistance, please let me know.

                                  Sincerely yours,
                                 xfames A.  Chamblee, Chief
                                  Needs Assessment Section
                                          (WH-547)
CC: William Hormberg, USEPA Region VIII
    Needs Survey Coordinator
                               D-26

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                               FILE  COPK
COLORADO DEPARTMENT  OF HEALTH
             4210 EAST 11TH AVENUE • DENVER, COLORADO 80220 • PHONE 388-6111
                                         Anthony Robbins, M.D., M.P.A. Executive Director
  December 28, 1976
  Mr. James A. Chamblee, Chief
  Needs Assessment Section
  U. S. Environmental Protection Agency
  Washington, D. C. 20460

  Re:  Cost Estimates for Catagories y g VI, 1976
       Needs Survey

  Dear Mr. Chamblee:

  We have received the computer printout of cost estimates
  for Catagories V and VI in Colorado.  As we have no addi-
  tional data with which to make independent estimates in these
  catagories, we feel that the EPA numbers are adequate.

  Our office is now also in the process of reviewing your com-
  puter printouts for Catagories I-IVB.  We have found numerous
  errors and omissions.  In several cases, neither Dames  & Moore's
  nor our numbers were used.  Instead, the unre vised 19 7 M- figures are
  shown.'  It will take several more days to complete our  review
  of this portion of the needs survey.  You can be assured, however,
  that our extensive comments will be submitted prior to  January 10,
  1977.

  Very truly yours,

  FOR DIRECTOR, WATER QUALITY CONTROL DIVISION
  Ronald G. Schuyler, P.E.' Chief
  Technical Services & Grants Section

  RGS/vg

  cc: William H. Hormberg
                                      D-27

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         (ii-.il |FD S'T '\ I t'S EfMN/'RONMENTAL, PROT'F.C'nON AGFNCY

                          WAP! UMGT'ON. C ".  "(MSO
Ronald G. Schuyler, P.E., Chief
Technical Services and Grants Section
Colorado Department of Health
4210 East llth Avenue
Denver, Colorado  80220
                                   Re:  Draft Report on  1976  Needs
                                        Survey for Combined Sewer
                                        Overflows and Stormwater
Dear Mr. Schuyler:
     Thank you for your letter of December 28, 1976, in which you concur
with the EPA Category V and VI cost estimates for the State of Colorado.

     We have received your review of the print-out for Categories I-IVB
and have made the required corrections.  We certainly appreciate your
efforts to make this an accurate survey.

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     If I can be of further assistance, please let me know.

                              Sincerely yours,
                          ' .   James A. Chamblee, Chief
                         Needs Assessment Section  (WH-547)
cc:  William Hormberg, USEPA, Region VIII
     Needs Survey Coordinator
                               D-28

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                     STATE  OF  CONNECTICUT

           DEPARTMENT OF ENVIRONMENTAL  PROTECTION
                  STATE OFFICE BUILDING     HARTFORD, CONNECTICUT 06115
                                    January 5, 1977


Mr. James Chamblee
Chief, Needs  Assessment  Section
Facility Requirements  Branch  (WH-547)
401 M. St. S.W.
Washington, D.  C.   20460

Dear Mr. Chamblee:

     Reference  .is made to  your letter of December 16, 1976 transmitting revised
cost estimates  for  Categories V  and VI of the 1976 Needs Survey.

     I would like to comment  first on the cost estimates for Category VI
(stormwater discharge  control).   You have provided estimates of $899,606,000
for needs existing  in  1976 and $1,480,345,000 for needs expected thru 1990.
These estimates compare  favorably with the total state estimate of $2,667,000,000
submitted for the 1974 Need Survey.

     Our 1974 needs estimate  in  Category VI was based on EPA quidance and we
claim no independent analysis of cost on which to base projected cost.  Therefore,
we have no reason to question your estimates at this time.  Further since we
sense no intention  on  the  part of EPA to request grant funding in this category
nor any inclination on the part  of the Congress to appropriate monies for this
need, the estimates are  probably best considered academic.

     Although we acknowledge  that we have made no concerted effort to make precise
estimates of need in Category VI intuitively we feel that the expenditure of
sums in the amounts projected cannot be justified on the basis of real water
quality improvement.  We feel that the voting local public would never support
the local expenditure  of 25%  of  the total cost or nearly $570,000,000 nor would
they support federal expenditures of about three times that total if they had a
real mechanism to separate their contributions toward that and from other federal
taxes.  Our admittedly intuitive attitude in this regard is not wholly arbitrary
as we feel we can achieve  the 1983 standards prescribed by the Congress without
major expenditure  in this  category based on our monitoring of chemical and
especially biological  indicators of water quality.

     In contrast to our  rather ambivalent attitude with respect to the Category
VI estimates, we take  extreme exception to the estimates of expenditure need in
Category V.  We feel that  the EPA estimate of $387,317,000 for Connecticut is
totally unrealistic.  As you  know that figure contrasts with our estimate of
more than $700,000,000 reported  in the 1974 Needs Survey which is also, in our
opinion, a low figure  since we were not allowed, in the 1974 survey, to report
expenditure estimates  not  derived from engineering reports on file.  We had intende
                               D-29

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Mr. James Chamblee                        - 2 -                    January 5,  1977
to submit more precise data than that used by your consultants to compute your
estimates but determined that by doing so we would provide a basis for further
reducing your estimates of cost making them even more unrealistic.  One of the
stated objectives emphasized by your consultants was to provide a uniform
estimate to make the relative needs projections in the category a more valid
basis of comparison among the states.  It was our conclusion that more detailed
base data would make your estimate of Connecticut needs in Category V less valid
as a basis of comparison among the states.

     We should reiterate our comments offered previously that we find little
cause for accepting the relativity of estimates in any one category as a basis
for accepting the methods used in the survey.  Since the needs in Category V
are the predominate needs in Connecticut, the cost estimates associated with
those needs must be related to all categories of need used by the Congress to
calculate dollar allocations especially since the fast approaching date of September
1977 is causing more and more states to divert expenditure to a category of need
(Category IV B - collector sewers) which will not reduce and will probably increase
their percentage of future allocation.  Connecticut has chosen not to divert
presently available monies from priority needs to support collector sewers in
part because we feel it will force potential applicants to defer needed collector
sewer construction normally financed by local appropriation to pursue federal
grants not supported by the allocation of Congressional appropriation.

     To further emphasize our comments offered previously, it would seem appropriate
to again enumerate our major criticism of the 1976 Needs Survey for Category V.
It appears that EPA has instructed the consultants to adopt criteria which
assumes a degree of control which (1) WILL NOT ACHIEVE THE 1983 GOAL established
in the Act by the Congress (2) WILL NOT ACHIEVE COMPLIANCE WITH STATE WATER QUALITY
STANDARDS administratively imposed by the EPA, and (3) WILL PRECLUDE THE RESTORATION
OF SHELLFISH AREAS FOR FOOD SUPPLY even if improved disinfection technology is
developed to assure virus inactivation.

     The above conclusions must be drawn from analysis of the criteria since they
dictate a level of control that will allow undisinfected raw sewage to discharge
without treatment.

     In addition, we find it almost incomprehensible that combined sewer separation
was not even considered an alternative control option.  In our experience, combined
sewer separation is the most cost effective control alternative for a majority of
Connecticut communities with-combined sewers.  This  is especially true in relative!
small communities with only a portion of the system being combined in the older
urban core.   Often these systems were built in the 1800's and are so deteriorated
physically that they are not economically salvagable or repairable for continued
use.   It is  not uncommon to find that the pipe inverts have been completely abraded
away.  In our larger cities, where full separation may not be economically practical
considerable separation will still, in our opinion, be necessary to insure that
separate sewage from satellite communities can be conveyed through the combined
system to treatment.
                                  D-30

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Mr. James Chamblee                      - 3 -                     January 5, 1977
     We also feel that the choice to assume overflows will  only occur to
the main stem of a river system draining an urban area is not valid and that
the assumption may have caused an unrealistic reduction in  computed needs.   We
are further concerned that reduced efficiency of treatment  plant receiving
combined sewage is being ignored.

     Our conclusions are (1) that the 1976 Category V Needs Survey is a completely
invalid basis for advising the Congress of the cost of achieving the goals  of
the Act, (2) that if the criteria on which the survey is based reflects EPA
policy, the goals of the Act will not be achieved, and (3)  that computing needs  in
a way that does not reflect achieving the goals of the Act  or the cost of
achieving those goals invalidates the concept of using needs as a basis for
allocation.  It would be tragic to ask the public to expend such vast sums  of
money as are projected for combined sewer overflow control  and not achieve  the
goals they have been advised will be achieved; and even more traqic if those
goals were virtually precluded from being achieved by the design of the control
options imposed.

                                         Very truly yours,

                                         o.
                                                   \ X-  \C.«-\-.
                                         Robert B. Taylor
                                         Director of Water Compliance
                                         and Hazardous Substances
RBT/am
                              D-31

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    ri
    **    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON. D.C. 20460
                                                                    l>/7
Mr. Robert B.  Taylor
Director of Water Compliance and Hazardous
  Substances
Connecticut Department of Environmental
  Protection
State Office Building
Hartford, Connecticut  06115
                                            RE:   Draft Report on 1976 Needs
                                                 Survey for Combined Sewer
                                                 Overflows and Stormwater
Dear Mr. Taylor:
     Thank you for your letter of January 5, 1977, offering comments on our
draft report which estimated needs for combined sewer overflows and storm-
water control (Categories V & VI).

     In regard to your comment regarding the wet weather water quality
criteria utilized, it is our feeling that the control levels selected will
enable the maintenance of the fishable, swimmable receiving waters a great
majority of the time and are based on the most recent thinking in the
field on what reasonable standards should be.  Additionally, the control
levels provide a cost effective approach to dealing with combined sewer
overflows.  Unfortunately, the time and budget constraints placed on the
project precluded consideration in detail of what could be cost effective
in view of specific local conditions and local standards for individual
communities in Connecticut.  We hope to be able to incorporate such infor-
mation in the 1978 Needs Survey.

     Sewer separation was not considered as a final alternative control
option because it has been shown in most cases across the nation not to
be cost effective.  This does not preclude the use of separation where
it is shown cost effective, but its general use in the 1976 Needs Survey
would have resulted in an overestimate of the cost of controlling pol-
lution from combined sewer overflows.
                                  D-32

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     There was no assumption that overflows would only occur to the main
stem of a river system.  However, the receiving water quality impact
analysis was only conducted on the main stem.   We feel this  assumption
is valid, because in the majority of cases, the overflow volumes are
quickly flushed from tributary streams due to  high velocities and the
major impact of the pollutants is on the larger river systems.

     The final report, including all comments  received from  the states,
will be forwarded to you in early February.

     I hope that this has answered your questions.  If I can be of further
assistance, please let me know.

                                   Sincerely yours,
                                   James A. Chamblee, Chief
                                   Needs Assessment Section
                                           (WH-547)
cc: Charles Pease, US EPA Region I
    Needs Survey Coordinator
                               D-33

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                       STATE OF DELAWARE

                DIVISION OF ENVIRONMENTAL CONTROL
                      EDWARD TATNALL BUILDING
                       DOVER, DELAWARE 19901
                       December 13, 1976
Mr. John T. Rhett
Deputy Assistant Administrator
Water Programs Operation
Environmental  Protection Agency
401 M Street,  S.W.
Washington, D.C.   20460

Dear Mr. Rhett:

     We are writing to you in response to the letter and draft
report of October 22, 1976, on needs to control  pollution from
combined sewer overflows and separate storm sewers.

     We think  the work performed is a commendable and necessary
effort.  We find it to be a very thorough effort incorporating
all the numerous variables bearing on the problem, and the task
has been approached, in our opinion, in a very objective manner.

     We have reviewed the base input data in Appendix B used in
the needs estimation model as it relates to Delaware and have no
serious issue  to take with the data developed.
     Again,
subject.
            we commend you on a very thorough effort on a complex
                                Sincerely yours,
                                John C.  Bryson
                                Secretary
JCB:RFA:jp

cc:   Mr.  John T.  Egan
     Mr.  Robert J .  Touhey
     Mr.  Richard  F.  Aurich
                 NATURAL RESOURCES AND
                                           DEPARTMENT OF
                                    ENVIRONMENTAL CONTROL
                                            JOHN C. BRYSON
                                                SECRETARY

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON  D C. 20460
Mr. John Bryson
Secretary
Delaware Department of Natural  Resources
   and Environmental Control
Edward Tatnall Building
Dover, Delaware 19901
                                          RE:   Draft Report on 1976  Needs
                                               Survey for Cobmined Sewer
                                               Overflows and Stormwater
Dear Mr. Bryson:
     Thank you for your letter of December 13, 1976, on our draft report
which estimated needs for combined sewer overflows and stormwater control
(Categories V and VI).

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

                                 Sincerely yours,
                                /James A. Chamblee, Chief
                                 Needs Assessment Section
                                         (WH-547)
cc: Ken Pantuck, USEPA Region III
    Needs Survey Coordinator
                                D-35

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                              STATE OF FLORIDA

            DEPARTMENT OF ENVIRONMENTAL REGULATION

                        2562 EXECUTIVE CENTER CIRCLE, EAST
                             MONTGOMERY BUILDING
                           TALLAHASSEE, FLORIDA 32301
oc, IBINI rm ACK-CIA/                                                JOSEPH W. LANDERS, JR.
  GOVERNOR                     November 24,  1976                SECRETARY

    Mr.  James Chamblee
    Chief,  Needs Assessment Section
    Facility Requirements  Branch  (WH-547)
    401 M.  Street,  S. W.
    Washington,  D.  C. 20460
    Dear Mr.  Chamblee:
                       Re:   Draft Report on Category V
                            and VI -  1976 Needs Survey
         This Department has reviewed the  draft report on cate-
    gory V and VI - 1976 Needs  Survey-   The criteria for the delinea-
    tion of urbanized areas  fails  to take  into consideration those
    areas which have a high  tourist or transient influx.  For example,
    there are several towns  within driving distance of Disney World
    which, though below the  50,000 permanent population cut-off, have
    well over that number when  tourists are considered.  Most travel
    is by auto and the consequent  increase in air and road contami-
    nation and impervious surfaces (additional parking lots, motels,
    restaurants, et cetera)  have a significant impact on both the
    amount of run-off and consequent storm water pollution.   This in
    turn will directly affect any  planning, size of construction and
    the resultant costs of stormwater pollution abatement facilities.
    It is therefore recommended that high  impact areas, be given
    special consideration for inclusion on your list of urbanized
    areas and in your NEMUR  methodology, and further that the con-
    tractor be directed to contact each individual state to determine
    if and where such areas  do  exist.   These areas may become an
    integral part of each category within  the report or maybe included
    as a special section.  In either instance this procedure would
    more accurately reflect  actual category VI needs.

         The Department thanks  you for the opportunity to review and
    comment on the draft report and would  be interested in your evalu-
    ation and decision on this  comment.

                            Sincerely,
                           Howard  L.  Rhodes,  P.E.,  Chief
                           Bureau  of  Wastewater Management
                                and Grants
   HLR/gwm

   GC: Mr. Jim Kutzman, EPA IV  Needs  Survey Director

                                 D-36

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                   BLACK, CROW 8c EIDSNESS, INC.
                           CONSULTING ENGINEERS                  PLCAXHEHY m
                                                                   GAINESVILLE, FLORIDA 32802
                                                                   POST OFFICE BOX 1647
                   PRINCIPAL OFFICE: 7201 N. W. ELEVENTH PLACE. GAINESVILLE, FLORIDA          7201 N.W. ELEVENTH PLACE

                    REGIONAL OFFICES: ATLANTA, GEORGIA /CLEARWATER, FLORIDA           cTsLE7AOORESS- BCEGNVFLA

                   BIRMINGHAM. ALABAMA / 80CA RATON, FLORIDA / NAPLES, FLORIDA

               SAN JOSE, COSTA RICA / PHILADELPHIA, PENNSYLVANIA / MONTGOMERY, ALABAMA
                                           November 29, 1976
Mr. Gordon  R.  Woodley
Environmental  Specialist
State of  Florida
Dept. of  Environmental  Regulation
2562 Executive Center Circle, East
Tallahassee,  Florida  32301

     Re:    1976 Survey  of Needs for
            Control of Pollution from
            Combined Sewer Overflow
            and Stormwater Discharge
            Project No.  573-7600-4

Dear Mr.  Woodley:

     On Monday, November  15,  1976, you attended a meeting  at  EPA Regional
Offices in  Atlanta concerning review of  the  draft Categories  V and VI,
1976 Needs  Survey.  At  that  time you expressed an interest in receiving
a copy of the notes prepared  for the site  study portion of our presen-
tation.   Enclosed for your information is  one copy of the  above notes.

     If you have any further  questions,  or need additional  information
regarding the site studies or design storm criteria, please let me know.

                                           Very truly yours,

                                           BLACK, CROW AND EIDSNESS, INC.
                                           Ronald L. Wycoff,  P.E.

RLW/mfl

Enclosure

xc:  Mr. R.  D.  G. Pyne
     Mr. Philip Graham
                                   D-37

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  _	 '   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

\.   ,0^                      WASHINGTON, D.C. 20460
   Mr.  Howard  L.  Rhodes, Chief, P.E.
   Bureau of Wastewater Management and Grants
   Florida Department of Environmental Regulation
   2562 Executive Circle,  East-Montgomery Building
   Tallahassee,  Florida  32301
                                            RE:  Draft Report on  1976  Needs
                                                 Survey for Combined Sewer
                                                 Overflows and Stormwater
   Dear Mr.  Rhodes:
        Thank you for your letter of November 24,  1976, offering comments  on
   our draft report which  estimated needs for combined overflows and Stormwater
   control  (Categories  V & VI).

        Your specific comment  requesting inclusion of non-urbanized areas  for
   Stormwater control needs was  voiced by several  states, although not  all
   were Interested in transient  influxes of population.  Regulations for the
   application of the ?!PDES Program to separate storm sewers were published
   1n the Federal Register of  March 18, 1976.  This document and the permit
   program it established  were utilized to determine the areas requiring needs
   in Category VI.

        The regulations defined  the term separate  storm sewer as "a conveyance
   or system of conveyances....located in an urbanized area and primarily
   operated for the purpose of collecting and conveying Stormwater runoff."
   The NPDES permit issuing authority may designate other storm sewers  as  being
   significant contributors of pollution and thus  subject to these regulations.
   In the absence of specific  designations, Stormwater needs are estimated for
   Census-defined urbanized areas only.

        The final report,  including all comments received from the states, will
   be forwarded to you  in  early  February, 1977.

        If I can be of  any further assistance, please let me know.

                                     Sincerely yours,
                                      James A. Chamblee,  Chief
                                      Needs Assessment  Section
                                              (WH-547)
   cc:  Jim Kutzman, USEPA Region  IV
       Needs  Survey Coordinator
                                   D-38

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3EORGE R. ARIYOSHI
GOVERNOR OF HAWAII
                                STATE OF HAWAII

                              DEPARTMENT OF HEALTH
                                    P O.Box 3378
                                 HONOLULU, HAWAII 96801
                              November 24,  1976
                                     GEORGE A. L YUEN
                                     DIRECTOR OF HEALTH

                                   Audrey W. Mertz, M.D., M.P.H.
                                     Deputy Director of Health

                                   James S. Kumagai, Ph.D., P.E.
                                     Deputy Director of Health

                                    Henry N. Thompson, M.A.
                                     Deputy Director of Health
                                     In reply, please refer to.

                                      File	
      Mr.  James Chamblee, Chief
      Needs  Assessment Section
      Facility Requirements Branch  (WH-547)
      HOI  M.  Street, SW
      Washington, B.C.  20460
      Dear Mr.  Chamblee:
                  Subject:
1976 Needs Survey  for
Categories V &  VI  Draft Report
           Thank you for the opportunity to review the subject document.
      The following comments are  offered for your consideration:

           1.   We recognize that  due to the lack of data many assumptions
               were required to develop the cost estimates  for Category VI
               needs.  However, it  is our opinion that the  exclusion of the
               hydro-geological uniqueness of the islands of  Hawaii in
               developing needs in  terms of time of concentration of storm
               runoff, slope and  distance to receiving waters, and the
               existence of numerous, small watershed basins  as well as
               the high cost of land represents an inequitable means of
               comparing needs with other states.

           2.   The EPA cost index of 1.0578 which was utilized in
               determining cost of  constructing facilities  in Hawaii
               should be changed  to 1.7.  Justification for cost index
               of 1.7 was reviewed  and approved by EPA in April,  1976.  The
               said cost index was  used in determining needs  for Categories I
               through IV in the  current 1976 Needs Survey.

           3.   According to the draft report, due to the lack of information,
               storage volume and treatment rates of storm  sewer discharges
               are based on treating runoff from the average  combined
               sewer overflow drainage area at each treatment plant.
               Since Hawaii has no  existing combined sewers,  it is apparent
               that Hawaii did not  receive any credit for cost of constructing
               treatment or detention facilities.  If the foregoing is correct,
               then the methodology used is obviously a great disadvantage
               on priority to states that have little or .no combined sewers.
                                 This Is Recycled Paper

                                      D-39

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Mr. James Chamblee
Page 2
November 24, 1976


     The above comments are what we  consider major factors which
should be seriously considered in determining needs for Categories V
and VI.
                                Sincerely,
                                'JAMES S. KUMAGAI,
                                Deputy Director  for
                                  Environmental  Health
DT/k:mt
                          This Is Recycled Paper

                             V^ ko

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   \
        UNITED STATES I
                         WASHINGTON, D.C. 20460
9    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Or. James S. Kumagai
Deputy Director for Environmental  Health
Hawaii Department of Health
Post Office Box 3378
Honolulu, Hawaii   96801
                                           RE:   Draft  Report on  1976 Meeds
                                                Survey for Combined Sewer
                                                Overflows  and  Stonnwater
Dear Dr. Kumagai:
     Thank you for your letter of November 24,  1976,  offering  consents on
our draft report which estimated needs for combined sewer overflows and
stonnwater control (Categories V & VI).

     The average drainage area for a storra sewer treateent plant  In the
State of Hawaii was estimated at 239 acres per  stormwater discharge
location.  As your letter so applicably put,  the small  drainage basins
make construction of storrowater facilities difficult  and  expensive.  This
factor has been taken into account in the draft report  due to  the relatively
small drainage area per stonnwater discharge  used for the State of Hawaii.
The high land costs in Hawaii ars not considered in our methodology as
land cost is ineligible for the purposes of the municipal facilities
grants program of EPA.

     The cost index of 1.7 will be utilized to  determine  the cost of
constructing facilities in Hawaii based on your April 1976 justification.

     The final report, Including all coinsnents received  from the states,
will be forwarded to you in early February, 1977.

     I hope that this has answered your questions. If  I  can be of
further assistance, please let me know.
                                    Sincerely yours,
                                     ames A.  Chawblee,  Chief
                                    Needs Assessment Section
                                            (W! 1-547)
cc: Robert Rock, USEPA RegionIX
    Needs Survey Coordinator
                                D-lU

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  STATE  OF
DEPARTMENT OIF  HEALTH AND  WELFARE
                                    Division of Environment
                                    Statehouse Mail
                                    Boise, Idaho 83720

                           November 9, 1976

  Mr, James Chamblee
  Chief, Needs Assessment Section
  Facilities Requirements Branch (WH-547)
  401 M Street S.W.
  Washington, D. C.   20460

  Dear Mr. Chamblee,

      We have reviewed the draft report of the "1976 Survey of Needs"
  for control of pollution from combined sewer overflows, Category V,
  and stormwater discharges, Category VI.

      The report is heavily biased in favor of those states with large
  urban populations  and it does not adequately address problems inherent
  to states with smaller populations and more diverse demographic and
  geological variability.  If the intent of this needs survey for
  Categories V and VI is for broad estimating purposes only, we would
  suggest that extreme caution be utilized in the application to indi-
  vidual states.  A  needs evaluation similar to that conducted in the
  1976 needs assessment for Categories I through IV would better reflect
  the individual state needs for Categories V and VI.

      The 1974 Idaho needs assessment for Categories V and VI show
  $36 million and $469 million respectively.  The 1976 draft assessment
  for Idaho shows no current or 1990 needs in Category V and only $841
  thousand in current and $8.86 million in needs for 1990 in Category VI.
  A  recently completed water management study completed for Boise, Idaho,
  shows that the current urban stormwater treatment cost needs alone,
  depending on the level of treatment, vary from $995 thousand for simple
  treatment and sedimentation to as high as $33 million for complex
  treatment.  The lowest cost in Category VI for a single Idaho urban area
  exceeds the total  1976 needs reported for the entire state.

      Combined sewer overflows have been identified in many of our
  northern Idaho communities and are presenting problems in treatment and
  receiving water quality.  The 36 million dollar 1974 needs estimate for
  Category V would not be realistic in light of current problems with
  combined sewer overflows.

      If the Congressional Committee should include Categories V and VI
  needs in the construction grants allocation formula for the individual
                   EQUAL OPPORTUNITY EMPLOYER

-------
Mr. James Chamblee
Nov. 9, 1976
Page two

states, it is evident that states such as Idaho would be seriously
penalized.

     The needs estimation model for urban runoff (NEMUR) methodology
may be satisfactory for broad estimating on a nationwide basis.  The
use of this model in states with a small population, such as Idaho,
should be done with caution since many inherent problems characteristic
of non-urban areas can be identified.

     We appreciate the opportunity to comment on the draft and trust
our comments will be taken into consideration.

                                    Sincerely,            ^
                                    Orlando M.  Dal^e., coordinato
                                    Municipal Programs
OMD/tlb
cc:  Bob Coughlin, MS 329

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C.  20460
Mr. Orlando M.  Balke,  Coordinator
Municipal Programs
Idaho Department of Health  & Welfare
Division of Environment
Statohouse Mail
Boise, Idaho   83720

                                         RE:   Draft Report  on  1976  Needs
                                               Survey  for  Combined Sewer
                                               Overflows and Stormwater

Dear Mr. Dalke:

     Thank you for your letter of November  9,  1976, offering coinments  on
our draft report which estimated needs for  combined sewer  overflows  and
Stormwater control (Categories V & VI).

     The report utilized to define the areas of each state served by
combined sewer overflows (APWA-University of Florida,  Report of EW\
Research and Development Group) did not identify any combined sewered
area in the State of Idaho. However,  based  on  Mr.  Philip Graham's
telephone conversation with Mr. Michael  HcMasters  on December 2S, 1976,
a combined sewer area  for non-urbanized area of 1315 acres and  associated
population of 31,248 parsons will be  used for  Category V of  this 1976
Needs Survey.

     Your comments relating to problems cnaracteristic of  r.on-urbanized
areas were voiced by several states.   Regulations  for  the  application
of the ilPDES program to separate storm sewers  were published in the
Federal Register of March 18, 1976.  This document and the permit
program it established were utilized  to determine  the  areas  requiring
needs in Category VI.

     In the regulations, the term "separate storm sewer" is  defined  as
"A conveyance or system of conveyances....located  in an urbanized area
and primarily operated for the purpose of collecting and conveying storm
water runoff.''  The permit issuing authority may designate other storm
sewers as being significant contributors of pollutlon'and  thus  subject
to these  regulations.  In  the absence of specific designations, storpi-
water needs are estimated for Census-defined urbanized areas only.
                                v-kk

-------
     The needs estimation model for urban runoff (Ht-JlUR) was developed to
provide relative estimates of state-by-state needs on a consistent
basis.  The iTiodel was not intended and should not he used to define
site-by-site estimates for combined sower or storrwater control.   Only
through a detailed engineering evaluation can these specific cost estimates
be developed.

     The final report, including all comments received from the states,
will be forwarded to you in early February. 1977-

     I hope that this has answered your questions.  If I can be of further
assistance, please let me know.

                                    Sincerely yours,
                                    •James A.  Chemblee, Chief
                                    Heeds Assessment Section
                                            (WK-547)
cc: Robert Cough!in} USEPA Region
    Needs Survey Coordinator
                                  D-45

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DEPARTMENT OF HEALTH                 DIVISION OF ENVIRONMENT
AND WELFARE                                     BoisOdahoU83720
                            December 29, 1976
   Mr- Phillip Graham
   Needs Assessment Section
   Facilities Requirements Branch  (WH-547)
   401 M Street S.W.
   Washington, D. C.

   Dear Mr. Graham,

        The following list of communities constitutes the identified
   Idaho needs for Category  V  (Combined Sewer Overflow Correction)  that
   were transmitted as per our telephone conversation of December 29,  1976.

        City                1976 Population         Acres Involved

   St. Anthony                   2877                    116
   Grace                          827                     78
   New Plymouth                   986                     34
   Rupert                        4563                    127
   Wallace                       6250                    160
   Sandpoint                     4144                    165
   Orofino                       3883                    240
   Grangeville                   3636                    267
   Bovill                         343                     25
   Troy                           541                     32
   Spirit Lake                    627                     52

   Total                       31,248                  1,315

        We appreciate  the opportunity to comment and trust this
   information will  be taken into consideration by EPA relative to
   Category V needs  for Idaho.

                                   Sincerely,


                                      ''•"';/<^c/^
                                   O. M.  Dalke, Coordinator
                                   Municipal Programs

   OMD/tlb
   cc:  James  Chamblee
                    EQUAL OPPORTUNITY EMPLOYER

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      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                       WASHINGTON, D.C.  20460
Mr. O.M. Dalke, Coordinator
Municipal Programs
Department of Health and Welfare
Division of Environment
State of Idaho
Statehouse
Boise, Idaho  83720

RE:  Draft Report on 1976 Needs Survey
     for Combined Sewer Overflows and Stormwater

Dear Mr. Dalke:

     Thank you for your letter of December 29,  1976, which reports
population and the associated acreage of combined sewer areas in Idaho.

     We have included these data in our final computer run.  The re-
sulting cost estimate for Idaho for Category V  is $8.569 million and for
Category VT is $8.855 million.

     The final report, including all comments received from the States,
will be forwarded to you in early February,  1977.

     If I can be of further assistance, please  let me knew.

                                   Sincerely yours,
                                     '  .''I /? ''"     •O'"'""
                                    i,f f. /'  n^-^_n <-«•..
                                   James A.  Chamblee,  Chief
                                   Needs Assessment Section
                                           (WH-547)
cc:  Robert Coughlin, USEPA Region X
     Needs Survey Coordinator

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                                  Richard H. Briceland, Director
     (2200 Churchill Road, Springfield, Illinois  62706

Telephone:  217/782-1696
                                                            November 29, 1976
    Mr. James Chamblee, Chief,
    Needs Assessment Section
    Facility Requirements Branch (WH-547)
    401 M. Street, S. W.
    Washington, D. C.   20460

    Dear Mr. Chamblee:

    This letter is in follow-up to our discussions at the meeting held in Chicago
    on November 16 for discussion of the "1976 Survey of Needs for Control of
    Pollution from Combined Sewer Overflows and Stormwater Discharges" draft
    report.  At that meeting, we expressed several comments concerning both the
    basic approach to the 1976 Needs Survey for Categories V and VI, and the draft
    report prepared by your agency's contractors.

    With regard to the latter set of comments, we have compiled readily available
    data primarily from Section 201 Facilities Plans, and have concluded that
    the estimate of Category V needs for Illinois is grossly understated.  Inasmuch
    as we were able to identify several significant errors in input data listed
    in the draft report, this difference in dollar estimates may not reflect
    serious problems with the contractors' methodology so much as it indicates
    easily correctible data source problems.  We have provided corrected data as
    well as the available 201 plan dollar estimates for Category V needs for
    Illinois in the attached report entitled "Combined Sewer Needs in Illinois
    Urban Areas".  We will withhold judgement on the adequacy of your contractors'
    methodology and on the validity of the state-by-state results for Category V
    until we have an opportunity to compare the revised results reflecting corrected
    data with the findings of the 201 Facilities Plans.

    One general comment regarding the methodology used by your contractors should
    be made now, however, because it does not pertain to the data problems mentioned
    above.  We recognize that the degree of combined sewer overflow control con-
    templated by the contractors is generally consistent with the recent policy
    direction taken by the U.S. Environmental Protection Agency in its administration
    of the construction grants program.  It is, for example, consistent with the
    thrust of Program Guidance Memorandum No. 61, which governs grant eligibility
    of combined sewer overflow control projects.  The point which we wish to make
    here is that the recent federal policy direction in the area of water quality
    standards has not been consistent with that taken in the construction grants
    area.   For example,  the recently released guidance under Section 304(a), "Quality
    Criteria for Water", suggests a water quality criterion for recreational waters
    of 200 fecal coliform organisms per 100 milliliters of water.  Such a level of
    quality will not be  generally attained in those Illinois waters affected by
    combined sewer overflows if only the controls contemplated in the contractors'
                                         D-l*8

-------
Mr. James Chamblee
November 29, 1976
Page 2
draft report are implemented.  In other words, while the degree of control
contemplated in the report may represent the maximum level that can be justified
pragmatically, it will not be adequate to achieve the "fishable/swimmable"
standards set forth in Section 101(a), as defined in detail in "Quality
Criteria for Water".  This serious inconsistency in policy on the part of the
USEPA must be reconciled if the overall program established under P.L. 92-500
is to retain integrity and credibility in the eyes of the public, and in
particular the affected municipal officials and their consulting engineers.

With respect to Category VI needs, we have no major objection to the methodology
or results described in the draft report prepared by your contractors.  Since
we have little solid information in the form of detailed studies with which
we can compare the Category VI results, we are unable to form any opinion as
to the validity of the findings.  The methodology seems reasonable if reliable
data are used.  We are reluctant to endorse total reliance on dissolved
oxygen and suspended solids as criteria for determining water quality impacts
of urban stormwater runoff, because of documented problems with heavy metals,
toxic materials, and other constituents of urban runoff.  Yet, we have no
practical methodology to suggest as an alternative; therefore, we simply urge
that your report note this weakness explicitly as one for which currently
available data and methodology offer no apparent solution, and consequently
the 1976 Needs Survey results for Category VI should be viewed as being
no more than a "best guess".  This problem should be largely corrected by
the studies currently under way or about to be started pursuant to Section 208.

An additional data item which was discussed during the meeting of November
16, 1976 is the data item of "Appendix B - Base Data for Needs Estimation
Model for Urban Runoff" of the contractors report.  On page B-12, Chicago
is shown as discharging to a large lake.  This item was discussed and we
understand has been corrected.  We wish to emphasize, however, that the Chicago
urban area discharges to the Illinois Waterway System which should be treated
as an impounded river because of the navigation controls and sluggish flows.
We feel a K2 (day ~^) of 0.08 should be used for the Chicago area.

We offer the above comments and attached report for your consideration in the
preparation of your final documents.  If you have any questions, please do
not hesitate to contact us.
                                         Very truly yours,
TGM/DJG/sf
Attachment
cc:  Philip H. Graham
     Robert F. Holbrook
     Michael Mauzy
     L. D. Hudson
     D. J. Goodwin
                                              is G. McSwiggin
                                         Illinois Needs Survey Director

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                         COMBINED SEWER CONTROL NEEDS IN

                               ILLINOIS URBAN AREAS
The Illinois Environmental Protection Agency has completed a study of Illinois
Urban Areas to determine the total present combined sewer acreage in each.  This
study was carried out to check the accuracy of the figures contained in the "Draft
1976 Survey of Needs for Control of Pollution from Combined Sewer Overflows and
Stormwater Discharges", relating to the acreage of combined sewers in Illinois
Urbanized Areas.

To arrive at these figures, Agency staff consulted existing 201 facilities
planning documents, or contacted consulting engineering firms engaged in the pre-
paration of 201 planning documents.  Findings of this study are presented in
Table 1, in comparison with the figures published on page B-4 of the draft
Needs Survey.

As indicated in Table 1, the actual present combined sewer acreage for Illinois
Urbanized Areas totals 295,000 acres, some 28% more acreage than indicated in
the Survey of Needs Report.

In conjunction with this study, the Illinois EPA compiled a list of dollar needs
from State approved 201 facilities plans for the above communities.  These data
are presented in Table 2.  The combined sewer dollar needs were determined by
this method for 89.4% of the total acreage, or 263,900 acres.  The total dollar
needs for this portion of the whole, as derived from facilities plans, came to
$1,871,200,000.  (These dollar figures were as reported at the time of 201 plan
approval.  It was not possible to adjust them to January, 1976 levels within
available information and time constraints.)

If it is assumed that the combined sewer needs in the remaining Urban Areas will
be proportional in cost to those which have already had needs identified by 201
facilities plans, then total combined sewer needs in Illinois Urbanized Areas
alone are projected to be $2,092,400,000.00.

The draft Survey of Needs Report indicates in Table 8.3 that the current capital
needs in Illinois Urbanized Areas stands at $774,571,000.  This amounts to only
41.4% of the total needs already arrived at in the existing 201 facilities plans
for 89% of the Urbanized Area combined sewers, and only 37% of the total predicted
needs for these Urbanized Areas assuming that unidentified needs will be proportional
to those already clearly identified in 201 planning.
                                      D-50

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                           TABLE 1.   Acreage of Combined
                      Sewer Areas in Illinois Urbanized Areas
Urbanized Area
Communities with
Combined Sewers
Actual Combined
Area in 1,000
Acres
Area Reported in
Needs Survey reported
in 1,000 Acres
Aurora
Bloomington
Champaign
Chicago
Davenport Metro
Decatur
Dubuque Metro
Joliet
Peoria
Rockford
Springfield
St. Louis Metro
Kankakee
Aurora
Bloomington
Normal
TOTAL
None
MSDGC
Addison
Villa Park
Lombard
Elgin
TOTAL
Rock Island
Decatur
None
Joliet
Peoria
None
Springfield
East St. Louis
Madison County
Belleville
Wood River
Alton
TOTAL
Kankakee
Bradley
TOTAL
4.3
3.0
1.0
4.0
0
240.0
.2
1.3
.9
1.3
243.7
1.0
7.2
0
9.0
2.9
0
8.1
3.8
2.7
2.3
1.0
3.3
13.1
1.4
.4
1.8
0
0
0
204.9
1.9
6.5
0
0
14.8
0
2.9
0
Not reported
                    TOTAL COMBINED
                    SEWER ACREAGES
                            295.1
                      231
                                    D-51

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                        TABLE 2.   Combined Sewer Needs for
                    Urbanized Areas,  derived from State Approved
                         201 Facilities Planning Documents
The dollar needs are expressed below for each Urbanized Area in millions of
dollars.  These dollar needs were extracted from facilities plans as presented,
and have not been converted to January,  1976 dollars.   Also, no adjustments have
been made to reflect construction grants awarded either prior to 201 plan pre-
paration or subsequent to January,  1976.
                    Urbanized Area
Needs in Millions of
Dollars for Combined
Sewer Areas
                    Aurora

                    Bloomington

                    Champaign

                    Chicago

                    Davenport Metro

                    Decatur

                    Dubuque Metro

                    Joliet

                    Peoria

                    Rockford


                    Springfield

                    East  St.  Louis

                    Kankakee
      9.2

      Not Available

      0

  1,804.1

      Not Available

      Not Available

      0

      Not Available

     23.5

      All combined
      sewers now separated

     15.3

     14.7

      4.4
                    TOTAL
  1,871.2
                                     D-52

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C.  20460
Mr. Thomas 6. HcSv/iggin
Illinois Meeds Survey Director
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois  62706

                                        RL:  Draft Rcj?ort on '197" iiecds
                                             Survey for Combined Sewer
                                             Overflows and Stomwater

Dear i'ir. McSwiqgin:

     Thank you for your letter of November 29, 1976, offering cofnments on
our draft report which estimated needs for combined sewer overflov/s and
sotrmwater control (Categories V & VI).

     In regard to your general comment ro'fating to control levels evaluate?
under the draft resort and watar quality standards promulgated by Section
304(a) of F.L. 92-500, the control levels to be evaluated In the final report
have been increased such that for the aesthetics and the fish and wildlife
criteria the design stonn for combined sewar systeins is the SO percent!la
storm and for the recreation criteria the design stonn is the 98 percent!le
storm.  It is our feeling that tin's higher level of control will have a high
liKali hood of maintaining of the fishable, swinwable standards in the
receiving waters.

    The corntineo sewered areas of the urbanized areas in the State of
Illinois vrcre changed to reflect the information provided in your letter.
Additionally, tha receiving water classification for Chicago has been chanced
to reflect discharge to an ii;Tf.ioundf>.d river.  For your information, although
fcmkakee is an SMSA, it is not an urbanized area and as such was not included
in the computer based methodology,  iieeds for Kankakee and other non-urbanized
areas in the State of Illinois are estimated for Cstenory V, however, and
are included 1n the total estimated needs for combined sev.'er control of each
state.

     These changes result in a total estimated Gstogory V need to ineet
the re-creation criteria in the State of Illinois of ^£35.508 mill Ion of
v/hich $2154.244 million is for urbanized area needs.  These numbers compare
very favorably with your state approved £01 Facilities Plans for the
urbanized conwunities of Illinois, that wero mentioned in your letter.

     The final report, including all consents received from the states
     be forwarded to you in early February, 1977.
                                  D-53

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     If I  can be of further assistance, please let mo know.

                                   Sincerely yours.
                                   James A. Charnblee, H)ief
                                   Meeds Assessment Section
                                           O'M-547)

cc: Ter* Horn, USilP/" Region V
    ,^eeds Survey Coordinator
                                    D-54

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           State of Kansas . . . ROBERT F. BENNETT, Governor
           DWIQHT F. METZLER, Secretary
Topeka, Kansas 66620
                                   November 29,  1976
Mr. John T. Rhett
Deputy Assistant Administrator
Water Program Operations (WH-546)
United States Environmental Protection Agency
401 M. Street, S.W.
Washington, D.C.  20460

Attention:  Mr. James Chamblee (WH-547)

Dear Mr.

I am writing in response to your request for comments on the draft
"1976 Survey of NEEDS" for categories V and VI.

At the recent review meeting in the Region  VII Office (11/22/76)
several points of a  general nature were offered for consideration.   e.g.-

    a) A 5 year 24  hour storm as a design  guide considers less poten-
       tial storm flow than standard practice has used, and  the 80%
       occurrence depth of rainfall further reduces design requirements.
       Might a 10 year 24 hour storm with  90% or 95% occurrence depth
       of rainfall be more representative of current design practice?

    b) Combined sewers that  were designed as such may have, since
       their initial installation,  come into use as transporters of
       sewage collected outside the area originally served.  Correction
       may incur either a category IVB cost to intercept present tribu-
       tary suburban collectors, or a larger construction  project than
       suggested by consideration of the  principal service area (for
       category V). We recommend that at least a telephone survey
       of study  sites with combined sewers  be made,  to develop a
       factor in the model to allow for this effect.

    c) The rather narrow definition of category IIIA in the 1976 Survey
       of NEEDS for categories I-IVB, and the similarly narrow defini-
       tion of category V in this  survey, may have defined some NEEDS
       out  of the overall survey. We believe this to be the case in
       Kansas.
                               D-55

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Page 2
November 29,  1976
    d)  The cost estimates in this review appear to have been mini-
       mized.  This cost cutting may not have been applied uniformly
       within the model.  Since an indication of relative NEEDS is
       the desired result, a more flexible cost estimation scheme
       may provide a better basis for the desired ratios.

    e)  Other specific comments addressing primarily typographical
       errors were offered to Philip Graham at the meeting.

We look forward to receiving a listing of the 1976 NEEDS Survey
results for categories I through IVB, which you indicated would be
sent soon.  The two  surveys may each (I-IVB and V,VI) have been
done on their own consistent basis, but we must assure ourselves
that they fit together.

Please address your  questions or comments in this regard to:

            Jon M. Rueck,  P.E.
            Water Quality Planning & Surveillance
            Division of Environment
            Kansas Department of Health & Environment
            Topeka,  Kansas 66620
                                    Sincerely yours,
                                    Melville W. Gray
                                    Director of Environment
JMR/hi
                           D-56

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                           WASHINGTON.  D.C.  20460
Mr. Jon M. Rueck, P.E.
Water Quality Planning  & Surveillance
Division of Environment
Kansas Department of Health and Environment
Topeka, Kansas  66620
                                            RE:   Draft  Report  on  1976 Needs
                                                 Survey for  Combined Sewer
                                                 Overflows and Stormwater
Dear Mr. Rueck:
     We appreciated receiving Mr.  Gray's letter of November  29,  1976,
offering comments on our draft report which estimated needs  for  combined
sewer overflows and stormwater control (Categories V  & VI),

     In regard to the comment regarding the use of a  10-year 24-hour design
storm, the design storm to be evaluated in the final  report  has  been increased.
For the aesthetics and the fish and wildlife criteria, the design  storm for
combined sewer systems is the 90th percentile storm,  and  for the recreation
criteria, the design storm is the 98th percentile storm.   It is  our feeling
that this higher level of control  will enable maintenance of the fishable,
swimmable standards in receiving waters.

     The area actually served by combined sewers was  used to determine
Category V needs.  Needs for transporting separate sanitary  flow which is
tributary to a combined sewer system should be included in Category  IVB.

     There was no intent to eliminate legitimate needs out of the  1976
Survey.  Required correction of overflows due to dry  weather infiltration
in combined systems is included in Category V.  Therefore, all  flow conditions
in combined systems are considered.

     Cost curves utilized in the draft report have been modified significantly
for the final report, as was discussed in the November 27,  1976 meeting  in
Kansas City.
                                   D-57

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     The resulting equations  increase  the  Kansas  needs  estimates  for
Category V from $43,522  million  to  $110.401  million.

     The final  report, including all comments  received  from the  states,
will be forwarded to you in early February.

     If I can be of further assistance,  please let  me know.

                                    Sincerely  yours,
                                      **         /•' •     /   /


                              S   James  A. Chamblee,  Chief
                                    Needs  Assessment Section
                                            (WH-547)

cc: Halter Robohn, USEPA Region  VII
    Needs Survey Coordinator
                              D-58

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           \. State of Kansas . . . ROBERT F. BENNETT, Governor
             DWIGHT F. METZLER, Secretary
Topeka, Kansas 66620
                                  January 1,  1977
Mr.  Philip H. Graham, P. E.
Project Officer, Needs Assessment Section
Facility Requirements Branch (WH-547)
U. S. Environmental Protection Agency
401 M. Street, S. W.
Washington, D. C.   20460

Re:  1976 Needs  Survey

Dear Mr.  Graham:

Thank you for returning my call of 111 111.  To confirm our conver-
sation, your telephone conversation notes of a contact of Bill Boggess
at Kansas City,  Kansas by Wen Huang indicate that a misinterpretation
was  initially made in the base data. The notes indicated 4000 acres of
combined sewers for Jersey Creek as being 50% of Kansas City's com-
bined sewer area.  The draft report showed 4000 acres as the total on
page B-6 rather than more properly indicating 8000 acres. I appreci-
ate your offer to make this small change in the last computer run prior
to presentation of the final report,  or  at least if  that is not possible,
to provide documentation  of the initial misinterpretation.

I look forward to your response to  a letter of 11/29/76 from M. W.
Gray, which we  also discussed.

Please inform Jim Chambleethat while we have not exhaustively
reviewed the EPA-1 forms for  the survey on the  other categories,
a spot check has shown them to resemble what we submitted.
Should the opportunity for it arise,  I would like to have a summary
of the Kansas EPA-1 forms,  at least on items 15 and 16.
                               D-59

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Mr.  Graham
January 1, 1977
Page 2
Since I will be involved in the 208 planning activities,  specifically
with model selection, I hope we can discuss the category V and VI
methodology in greater detail after you have made your report to
Congress.

                                  Sincerely,

                                  Division of Environment
                                  Jon M. Rueck,  P. E.
                                  Water Quality Planning and
                                    Surveillance Section
JMR:nb
cc: Walter Robohn,  Regional
      Needs Survey Director
                              D-60

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      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C.  20460
Mr. Jon M. Rueck, P.E.
Water Quality Planning and
Surveillance Section
Department of Health and Environment
State of Kansas
Topeka, Kansas  66620

RE:  Draft Report on 1976 Needs Survey
     for Combined Sewer Overflows and Stormwater

Dear Mr. Rueck:

     Thank you for your letter of January 7, 1977, reporting the 8000
acre combined sewer area for your State's portion of the Kansas City
urbanized area.  Our Region VII Office has stated that the population
figure of 76,000 persons used in our draft report for this area is
correct.

     We have included these data in our final computer run.  The re-
sulting cost estimates for Kansas are $107.961 million for Category V
and $124.876 million for Category VI.

     The total cost estimates for the Kansas City, Kansas combined sewer
area increased but the average cost of control per acre decreased due to
the reduced population density derived from the new estimate of area.
Because our methodology utilizes the urbanized area control costs per
acre to estimate the control costs for the combined sewer areas located
in the non-urbanized areas of the State, the non-urbanized area cost
estimates decreased.  The result was a small overall decrease in the
total EPA cost estimate for Category V.  The cost estimate for Category
VI also was reduced slightly because the area previously estimated to be
served by separate storm sewers was reduced by the 4000 acres you informed
us were actually served by combined sewers.
                               D-61

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     The final report, including all comments received from the States,
will be forwarded to you early in February, 1977.

     If I can be of further assistance, please let me know.

                                   Sincerely yours,

                                       .'•  /-/"       £/?
                                 "  James A. Chamblee, Chief
                                   Needs Assessment Section
                                           (WH-547)
cc:  Walter Robohn, USEPA
     Region VII, Needs Survey Coordinator
                               D-62

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NEIL SOLOMON, M.D., PH.D.
     SECRETARY
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
   ENVIRONMENTAL HEALTH ADMINISTRATION
                  P.O. BOX 13387
             201 WEST PRESTON STREET
           BALTIMORE, MARYLAND 21203
                PHONE • 301-383-2365
DONALD H. NOREN

   DIRECTOR
                                            November  30,  1976
        Mr. James Chamblee, Chief
        Needs Assessment  Section
        Facility Requirements  Branch  (WH-547)
        401 M Street,  S.W.
        Washington,  B.C.   20460

        Dear Jim:

              In line  with the discussions  held  in Environmental  Protection
        Agency  Region  III headquarters  in Philadelphia  on November 17,  1976
        with Mr. Philip Graham and  other members of your  staff,  I am hereby
        transmitting additions to your  base input data  for the State of Mary-
        land in Categories V and VI of  the  1976  Survey  of Needs.

              The first enclosure pertains  to  Category  V,  Combined Sewer Over-
        flows.  The  list  includes eight communities identified by their facility
        number  along with the  acreage involved and the  estimate of respective
        needs necessary for the correction  of  combined  sewer  overflows.  These
        communities  were  not included in the draft report on  needs in Category
        V and VI as  prepared by your  consultants.   It should  be noted that the
        listed  costs are  in June 1973 dollars  as reported in  the 1974 survey,
        and I request  that you adjust them  to  reflect appropriate 1976 dollars.

              As far as Category VI is  concerned,  the methodology employed and
        the assumptions made to estimate needs for the  nation does not accurately
        reflect the  needs of this area.  Specifically,  the draft estimate report
        grossly underestimates, and in  most cases,  neglects the needs associated
        with the requirement for the  protection  of shellfish  waters.  Your agency
        recognized the special problems affecting the Chesapeake Bay and the
        corresponding  stringent treatment requirements  necessary for the protection
        of shellfish waters, as indicated by the first  paragraph on page 9 of
        your final report to Congress of the 1974 "Needs" Survey.
                                         D-63

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Mr. James Chatnblee
Page Two
November 30, 1976
      For this reason, I am submitting a special report-for  Category  VI
needs (storm water treatment) and the accompanying  study by  Gannett Fleming
Corddry and Carpenter, Inc., prepared for the State of Maryland  for the
1974 submission for Category VI.  Again, the costs have  to be  adjusted to
1976 dollars.  The estimates are specific for Maryland and,  therefore, more
accurately reflect our needs as compared to the general  draft  report  prepared
for you by your consultants.

      Thank you for the opportunity of reviewing your draft  report  on needs
in Category V and VI, thereby enabling us to make the necessary  additions.

      Warmest personal regards,

                                    Sincerely yours,
                                    Max Eisenberg, Ph.D.
                                    State Needs Survey Director
ME:kn
cc:  Dr. Neil Solomon
     Mr. Donald H. Noren
     Dr. Benjamin D. White
     Mr. Kenneth Pantuck - EPA Region III

Enclosures
                                   D-64

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COUNTY
Allegany


FACILITY
31001
32001
97001
1976 UPDATE
CATEGORY V
CORRECTION OF
OVERFLOW
NUMBER NEEDS
ti
lii, 000, 000 Cumberland
6,781*, 000 Frostburg
1,600,000 Weeternport


ACRES
2160
lOljO
250
Anne Arundel
                    OliOOl
   10,000         City  of Annapolis
Baltimore City
                    01002
1,290,000         Patapsco
200
Dorchester
                    1*6001
2,U37,COO          Cambridge
330
Wicojnico
                    61*001
1,020,000          Salisbury
Worcester
                    69001
  300,000          Snow Hill
                                         D-65

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                           WASHINGTON, D.C. 20460
Dr. Max Lisenterci, I'h.;.)
State ;-;eeds Survey Pi rector
Maryland [Apartment of Health ?nd Cental  Hygiene
environmental Health Administration
r'ost Office Cox 13387
i> 1 tiiTiore-, i iaryl and  21203
                                             Draft Peport on 1S7C r:eads
                                             Survey for Combined Sewer
                                             Overflows and Stonviv/ator
     nax:
     Thank you for your  letter of  r!ovenber 303  1.97G, offerinq connients on
our draft report which ostimatsd naeJ.s  for corobined sev/er overflows and
stornavater control (Catc-yories V 5'  VI).

     In regard to your comm&nt or,  Category V,  the areas served by conihined
severs !i;antionof.; in the  attachiiiont to your lottor nave been included  in
t;ia fiscal report.  These inclusions provide a  total Category V need for
tno recreatioii criteria  of -t-47.460 mil lion.

     As far as Category  VI is conc^rpec!.,  your  corrr^ont reyardiriQ an inclusion
of non-urbanized areas for stomiwater corstrol  needs vfas voiced by several
states although not all  were intor^steu in the  shellfish standards.
iiet-uldtions for the application of the  iiPDES Prograra to separate storn
severs v;sre publisiied in ti;e F^Qsral  Register  of 'iarch !By 1975.  This
cocuinent ano the permit  procran it established  i«3re utilized to
deternine the areas requiring needs in  Category VI.  The term "separate
storm sewer" is defined  as ''A conveyance  or system of conveyances	
located in the urL-anizsci area and  primarily operated for the i/urpose  of
collcctiri'.i and conveyinq stor.n water runoff".   The permit issuing authority
:,iay uosi-nabe ot.'jsr ston.i severs as Leinq a significant contributor
of pollution and thus subject to these  regulations. In the; absence of specific
designations, storr^jatcr noGfis are estimated for Census-defined urbanized
areas only.

     The final report., irclucin-v; all  consents  received from the states, v/ill
i:>e fonardeci to yoi; in nsrly February,  1977,
                                D-66

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     I hope that this has answered your questions.   If I  can  be  of any  further
assistance, please let me know.
                                       Sincerely yours,
                                       James  A.  Chamblee,  Chief
                                       Needs  Assessment  Section
                                               (WH-547)
cc: Ken Pantuck, USEPA Region III
    Needs Survey Coordinator
                                 D-67

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                                       STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION

  CARL T. JOHNSON
  E. M. LAITALA
  DEAN PRIDGEON
  HILARY F. SNELL
  HARRY H. WHITELEY
  JOAN L. WOLFE
  CHARLES G. YOUNGLOVE
                     WILLIAM G. MILLIKEN, Governor

           DEPARTMENT OF NATURAL RESOURCES
               STEVENS T. MASON BUILDING, LANSING, MICHIGAN 48926
                        HOWARD A. TANNER, Director

                                December  14,  1976
 MIC
   R1026 1/75
           Mr.  James  Chamblee,  Chief
           Needs  Assessment Section
           Facility Requirements Branch (WH-547)
           401  M  Street,  S.W.
           Washington,  B.C.  20460
                                          Re:  Comments On "Draft,  1976  Survey
                                               of Needs for Control Of Pollution
                                               From Combined Sewer Overflows  And
                                               Stormwater Discharges"
           Dear Mr.  Chamblee:
           This  is in response to Mr.  Rhett's letter of October 22,  1976,  to  Dr.
           Howard Tanner,  Director, Michigan Department of Natural Resources, soliciting
           comments on the above referenced report.

           The Draft of the 1976 Needs Survey for the control of storm  and combined
           sewer discharges presents dollar figures which, in our view,  are extremely
           low.   We cannot argue with the relative percentages of the national
           total for each  state, however, the total dollars identified  as  necessary
           to meet the provisions of PL 92-500 do not appear realistic  and should
           not be represented to Congress as the total cost to solve all combined
           and storm sewer water quality related problems.

           We offer the following specific comments regarding the report:
           1,
There are limitations  in  the Draft  on assumptions, methodology,
data base and the relationship  to Categories I thru IV.

By limiting communities that need stormwater control to the census
definition of an urban area, a  substantial portion of the national
need is eliminated from Category VI.

There are areas of the country  where  the dissolved oxygen (DO)
levels used would be insufficient for maintenance of Water Quality
Standards.  The Recreation Criteria in the Draft uses a daily average
of 5.0 mg/1 and no less then 4.0 mg/1 at all times.  Michigan's
existing, and federally approved, Water Quality Standards call
for a minimum of 6 mg/1 DO in all Great Lakes and connecting waterways,
and in all inland streams designated  for coldwater fish.
                                              D-68

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Mr. Chamblee                        -2-             December 14, 1976


4.   The maximum allowance of 400 mg/1 suspended solids seems in our
     estimation to be extremely high.  At these levels there would most
     certainly be settlable solids which would result in sludge deposits
     contrary to Water Quality Standards and violations of the non-degradation
     provisions of the standards.

5.   Because the '76 Survey was done in two parts, by two contractors,
     there appears to be some confusion on what is needed to be included
     in Categories I thru IV, specifically the cost for storm and combined
     sewer interceptors.  This cost was not included in Categories I
     thru IV, because it related to Categories V and VI, and we find
     that in the Draft, Categories V and VI contained no transportation
     costs.  We believe all 6 Categories should be coordinated more
     closely.

6.   The water quality parameters considered for both combined sewer
     and storm sewer control include only suspended solids, dissolved
     oxygen, and bacteria.  As listed in the Draft, there are other
     parameters that affect water quality:  nutrients, dissolved solids,
     metals and pesticides.  These parameters can have a significant
     effect on water quality and should be included in the cost evaluation
     for storm/combined sewer controls.

7.   Operating costs were estimated on the basis of 0.03c per kilowatt
     hour for electric power.  We believe that future power costs
     will increase dramatically.  It seems reasonable to assume that
     this factor alone will increase operating costs, as well as other
     costs, significantly.

8.   It appears that only rarely was disinfection included in storm
     water control, even for the Recreation Category.  This was because
     disinfection was apparently only included in those few cases when
     DO problems would result in the need for a structural control system
     to remove biochemical oxygen demanding substances.  There could
     be gross violations of Water Quality Standards where disinfection
     is required to protect total body contact recreation.

9.   The Category I thru IV needs for '76 were determined by reviewing,
     within resource constraints, reports on cost.  This seems a fairly
     reasonable approach, although it also has some drawbacks.   Among
     others, in some categories, if no report were available, no need
     could be reported.  This, it must be recognized, does not mean
     that a need does not exist.

10.  Modeling is a valuable tool, however, the model should be flexible
     enough to take into account the different water quality requirements
     throughout the country.

11.  Additional parameters should be considered, as needed.  The influence
     of these parameters should be researched.
                                    D-69

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Mr. Chamblee                        -3-               December 14, 1976
We have cited the above to illustrate our concern that the assumptions,
and methodology used cannot reflect the total needs for the nation.
In looking at NPDES Permits, Water Quality Standards, and Construction
Grants Programs, it appears that these programs are not going in the
same direction.  To illustrate this, we cite the DO provisions of this
Survey (Grant Program) and the fact that we are in the process of upgrading
our Water Quality Standards.  We are considering a minimum DO of 7 mg/1
for streams supporting coldwater fish, a level that has been encouraged
and officially supported by EPA.  It seems reasonable that if Congress
is not willing to fund the programs necessary to meet the provisions
of 92-500 as presently written, that Congress should amend 92-500 to
reflect the realities of current achievability.

As far as basic data is concerned, we generally support the data included,
but believe that there were not enough communities indicated in the
determination.  We have attached a copy of the report done for Michigan's
1974 Survey for treatment and control of stormwater.  We also have included
the 1974 Survey form for Category V, for Detroit.  These reports are
included to illustrate our position that the needs for the "76 Survey
are too low.  It is our opinion that, at least for Michigan, the real
needs are reflected in this '74 Survey.

Michigan, in general, has flat topography and high groundwater tables.
These two factors increase construction costs for both retention structures
and transportation systems.  These factors are not reflected in cost
indices used in the cost calculation and, therefore, we question their
validity.

As indicated previously, stormwater control for communities in the urban
areas were not included as a need.  Further; although there was some
"area" included for control of combined sewers, it is not clear to what
extent, and what communities were included in this "area".

The next storm/combined needs survey should be directed at the results
of individual facility plans, which reflect the most realistic cost
data available.  Hopefully, there will be many more facility plans completed
when the next survey is necessary.

To reiterate our position, the Draft '76 Survey reflects costs for Categories
V and VI that are low as a national total.  It is our opinion that the
results of our '74 Survey for Categories V and VI are much closer to
the real costs, at least for Michigan, and probably for the nation.
Future surveys should address specific Water Quality Standards, and
input from the states should be solicited early in the process and more
time given for review of the draft report.
                                   D-70

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Mr. Chamblee                        -4-               December 14, 1976


We thank you for the opportunity to comment on the Draft 1976 Survey
of Needs For Control Of Pollution From Combined Sewer Overflows And
Stormwater Discharges.  We look forward to working with you in the future
in determining realistic estimate of needs.

                                    Very truly yours,

                                    ENVIRONMENTALPROTECTION BUREAU
                                    W. G.  Turney
                                    Bureau Chief  '
WGT:ss
                                   D-71

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON, O.C.  20460
Mr. W. G. Turney
Bureau Chief
Environmental Protection Bureau
Michigan Department of Natural  Resources
Stevens T. Mason Building
Lansing, Michigan  48926

                                      RE:   Draft Report on 1976 Needs
                                           Survey for Combined Sewer
                                           Overflows arid Stormwater

Dear Mr. Turney:

     Thank you for your letter of December 14, 1976, offering comments on
our draft report which estimated needs for combined sewer overflows and
stormwater control (Categories V & VI).

     Your comments regarding limitation of Category VI needs to urbanized
areas was voiced by several states.  Regulations for the application of the
NPDES program to separate storm sewers were published in the Federal Register
of March 18, 1976.  This document and the  permit program it established
were utilized to determine the areas requiring needs in Category VI.

     The regulations defined the term "separate storm sewer" as "a conveyance
or system of conveyances 	 located in an urbanized area and primarily
operated for the purpose of collecting and conveying stormwater runoff."
The permit issuing authority may designate other storm sewers as being sign-
ificant contributors of pollution and thus subject to these regulations.
In the absence of specific designations, stormwater needs are estimated for
urbanized areas only.

     The water quality criteria identified in the draft report were for wet
weather conditions.  Additionally, one nationwide set of criteria was required
due to budget limitations and the need for a nationally consistent estimate.
It is our feeling that, based on available information, the proposed criteria
will support the specific uses in and below urban areas and will not result in
sludge deposits.  Several of your comments request consideration of additional
parameters on a site specific basis, such as additional pollutants  (nutrients,
dissolved solids, metals, and pesticides), construction costs (high ground-
water conditions), power costs, and detailed information from facilitiy
plans.  Each of these parameters was considered in the early stages of the
needs survey development, but was rejected either because of lack of a national
data base or time and budget constraints on the project.
                                   D-72

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     In the assumptions for meeting the recreation water quality criteria,
all combined sewer overflows received disinfection and any stormwater dis-
charge which required structural control systems also received disinfection.
These considerations, plus increasing the design storm for combined sewer
control to the 98th percentile storm (as we have done for the final report
to Congress) should protect receiving waters for body contact recreation use.
Costs were included in the final Category V and VI estimates for intercepting
wet weather discharges and conveying them to centralized treatment facilities
where treatment was assumed necessary.

     A table will be included in the final report listing the combined sewered
acreage considered outside urbanized areas.  A total  of 33,300 acres of com-
bined sewered area was included for the State of Michigan outside of Census
defined urbanized area.

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     I hope that this has answered your questions.  If I can be of,any
further assistance, please let me know.

                                       Sincerely yours,
                                   /  /James A. Chamblee, Chief
                                    X Needs Assessment Section
                                               (WH-547)
cc: Ted Horn, US EPA Region V
    Needs Survey Coordinator
                                   D-73

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                Minnesota Pollution  Control  Agency
                              December 13,  1976
Mr. James Chamblee
Chief, Needs Assessment Section
Facility Requirements Branch (WH-547)
401 M. Street Southwest
Washington, D. C.  20406
                              Re:  Draft 1976 Needs Survey
                                   for correction of Combined
                                   Sewer Overflows and Storm
                                   Sewer Discharges
Dear Mr. Chamblee:
The Minnesota Pollution Control Agency  (MPCA) thanks you  for the
opportunity to review and comment on this report.

As you requested, we have focused our efforts on the "Base  Input
Data" located in Appendix B.  That data appears to be accurate,
as far as hydrologic and general population data is concerned.
The Twin Cities Metropolitan Waste Control Commission  (MWCC) has
been conducting studies on the combined sewer overflow areas and
associated populations.  They have indicated that they would like
to comment on that aspect of the data, if they find discernable
differences, and will do so by separate letter.

With regard to the methodology selected to prepare the needs
data, we generally agree that a nationwide effort would probably
result in a means to prorate funding without bias.  This  approach
has taken into account many assumptions which must be made  to come
up with a result.

While we are not necessarily in disagreement with these assump-
tions, we are concerned about several of the resulting implications.

Our first concern would be the assumption that results from
studies concerning discharges to lakes, rivers, and ocean estuaries
can be combined and standard parameters can be derived for  use
in all cities regardless of the type or use of the receiving water
to which they discharge.  It is a fact that treatment needs may
vary greatly with the type and use of the receiving water.
             1935 West County Road B2, Roseville, Minnesota 55113
      Regional Offices • Duluth/Bra inerd/Fergus Falls/Marshall/Rochester/Roseville
                       Equal Opportunity Employer
                             D-74

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Mr. James Chamblee
Page 2
December 13, 1976


The second area of concern would be the use of a design storm
to treat 80 percent of the rainfall caused overflows.  The method
at which this design storm was arrived appears to assume that
all precipitation nationwide occurs in the form of rainfall.  We
are concerned in Minnesota, especially in the Twin Cities areas, not
only about rainfall caused discharges, but the major volume of
runoff caused by spring melting of the snow accumulated through
the winter.  This is generally a mass loading at a time the
Mississippi River is at a very low flow and the discharge would
probably equal or exceed the existing river flow.  This, in fact,
may be the critical pollution time of the year.  The report, as
prepared, does not consider this aspect.  We would suggest that
the report should evaluate a summer rain design storm, as compared
to a spring runoff situation, as it actually occurs in most
no rthe rn s t ate s.

Other than these concerns, it would appear that the many assump-
tions made would probably affect most of the cities in a similar
manner.  We would ask that you remember that these are assumptions
which may or may not be true in every case and the Environmental
Protection Agency (EPA) consider funding on a basis of needs that
are shown in the actual studies to be prepared for the individual
areas concerned.

As a final note, we would like to point out that we have at least
six other cities (Mankato, Winona, Little Falls, New Ulm, Red
Wing, and Crookston) that did not meet the 50,000 population
criteria, as an urban area, but still may need to provide treat-
ment for combined sewer overflows.

Should you have any questions about these comments, please call
Mr. Gordon Wegwart at  (612) 296-7309.
                              Peter L. Gove
                              Executive Director

PLG:mlj
cc:  Mr. Richard Dougherty, Metropolitan Waste Control Commission,
     St. Paul
                            D-75

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           UNITED STATES ENVIRONMENTAL PROTECTION AOENCY

                            WASHINGTON.  D C. 20460
                                                       1 ft  i AM
                 A.M 1977
Mr. Peter L. Gove
Executive Director
Minnesota Pollution Control  Agency
1935 West County Road, B-2
Roseville, Minnesota  55113
RE:
                                                Draft Report on 1976 Needs
                                                Survey for Combined Sewer
                                                Overflows and Stormwater
D ear Mr. Gove:
     Thank you for your letter of December 13, 1976, offering comments on
our draft report which estimated needs for combined overflows and storm-
water control (Categories V & VI).

     We agree that the type of receiving water greatly influences the required
level of control of pollutants.  The use of the quality parameter to evaluate
requirements for pollution control was developed after reviewing many other
relationships.  The resulting quality parameter, which includes pollutant
levels from combined sewers, storm sewers and existing treatment facilities,
the receiving water discharge, and the reaeration coefficient (Kg), provided
the best correlation of the available information.  The methodology is not
intended to define the percentage of pollutant removal required for a specific
area, but to generally define areas which require higher levels of control
than other areas for a nationally consistent estimate of needs.

     The evaluation of snow melt runoff from urban areas was considered in the
early stages of the needs survey development.  However, no nationwide method-
ology could be developed to evaluate the volume and/or duration of snow melt
conditions. Therefore the resultant methodology utilizing runoff from rain-
storms was developed.

     The resultant needs survey numbers for urbanized areas should not be
utilized to consider funding for individuals areas.  The intent was to provide
relative state-by-state needs and a percentage of total national needs only.
                                   D-76

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     A total of 11,900 acres of non-urbanized combined  sewered  area  was
included in the draft and final report for the State of Minnesota.   This
acreage should be adequate to consider the six cities mentioned in your
comment letter.

     The final report, including all  comments received  from  the states, will
be forwarded to you in early February 1977.

     I hope that this has answered your questions.   If  I can be of any further
assistance, please let me know.
                                    Sincerely yours,
                                 f  '    '
                                 ( /James A.  Chamblee,  Chief
                                    Needs Assessment Section (WH-547)
cc:  Ted Horn, US EPA Region V
     Needs Survey Coordinator
                                  D-77

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                                STATE OF NEVADA

                      DEPARTMENT OF HUMAN RESOURCES          AOINS eERVICEa
                                  CAPITOL COMPLEX                     CHILD CARE SERVICES
                              ROOM 6OO, KlNKEAD BUILDING                 HEALTH

                                 505 E. KING STREET                    MEILTAL^p^n.
   O'CALLAGHAN                                                        MENTAL RETARDATI
   GOVERNOR                    CARSON CITY. NEVADA 897 1O               REHABILITATION
ROGER S. TROUNDAY                    TELEPHONE C7O2) 885-473O                   WELFARE
   DIRECTOR
November  17,  1976                 YOUTH 8ERVICBS AOENC*
        James Chamblee,  Chief
        Needs Assessment Section
        Facility  Requirements Branch   (WH-547)
        401 M Street,  S.W.
        Washington,  D.  C.    20460

        Dear Mr.  Chamblee:

                   Thank you for the opportunity  to comment on the
        Draft Report of the "1976 Survey of Needs  for Control of
        Pollution from Combined Sewer Overflows  and Stormwater Dis-
        charges."  I can appreciate the time  constraints under which
        the study was conducted and the necessity  to limit the num-
        ber of  quality parameters that could  be  'used for various
        reasons for modeling, but I feel the  report is not truly
        indicative of the needs in Nevada.

                   While only two streams were considered for Nevada,
        the quality of the water in the streams, the length of the
        reaches and receiving waters are of entirely different
        natures and will have to be considered independently with
        more stress on nutrient input before  the true needs can be
        determined.

                   I have no comments on the computer program method-
        ology presented in Appendix C, but the streamflow  (page B-15,
        no. 277)  for Las Vegas is 79 cubic feet  per second and not
        the 18  cfs indicated in Appendix B.

                   Again in Appendix B, using  the same stream classi-
        fication  for the two waters is unrealistic due to the quality
        of the  streams.
        RST/jr
                                      D-78

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          UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON, D.C.  20460
                                                £8  NOV 19>"o

Mr. Roger S. Trounday, Director
Department of Human Resources
Capital Complex, Room 600
Kinkead Building
505 East King Street
Carson City, NV  89710

Dear Mr. Trounday:

     Thank you for your comments on our draft report on needs for combined
sewer overflow and stormwater control (Categories V  and VI).

     Your comments are being studied carefully and will be taken into con-
sideration in our final report to the Congress.

     We are sorry that we cannot yet comment on the  issues your letter raised.
These are under study, along with comments from other states  and territories.

     As soon as possible, a complete explanation of our final cost estimates
will be forwarded.
                                  Sincerely,
                                  James A. Chamblee, Chief
                                  Needs Assessment Section
                                           (WH-547)
                                  D-79

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         UNITED STATES  ENVIRONMENTAL PROTECTION  AGENCY

                           WASHINGTON, D.C.  20460
h'r. Roger S. Trounday, Director
Nevada Department of Human Resources
Capitol Complex
Kinkead Building, Room 600
505 E. King Street
Carson City, Nevada  39710
                                            RE:  Draft Report on 1976 Needs
                                                 Survey for Combined Sewer
                                                 Overflows and Storrnwater
Dear l»r. Trounday:
     Thank you for your letter of November 17, 197C, offering comments
on our draft report which estimated needs for combined sewer overflows
and storniwater control (Categories V 4 VI).

     The input data for the Les Veqas urbanized area has bc;on changed
from the 18 cfs indicated in the draft report to the 79 cfs mentioned
in your letter.  MS you mentioned, the time and budcet constraints of
the contract limited the detail of the evaluations for each urbanized
area.  However, the methodology does provide a uniforn basis for
allocating needs to the states for storawater control problems.
iijoon completion of the 208 studies presently underway and other storr;'-
water water studies, a more detailed data base can be developed for use
in future needs surveys.

     The final report, including all consents received from the states,
will be forwarded to you in early February. 1977.

     I hope that this has ansv/ered your questions.  If ! can be of
further assistance, please let &e know.
                                   Sincerely yours.
                                     ir;es A. ChamMee, Chief
                                   Heeds Assessment Section
                                           (WH-547)
cc: Robert Rock, USF.PA Ren ion IX
    Heeds Survey Coordinator
                                  D-80

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                             STATE OF NEVADA
                     DEPARTMENT OF HUMAN RESOURCES
                    ENVIRONMENTAL. PROTECTION SERVICES
                              CAPITOL. COMPLEX
                        CARSON CITY. NEVADA  897IO
                           November 23, 1976
James Chamblee, Chief
Needs Assessment Section
Facility Requirements Branch (WH-547)
401 M Street, S.W.
Washington, D^C.  20460
                                   Re:  1976 Survey of Needs for the
                                        Control of Pollution From Combined
                                        Sewer Overflows and Stormwater
                                        Discharges (Draft)
Dear Mr. Chamblee:
          Nevada's Environmental Protection Services has reviewed the
subject document and has the following comments concerning it:

          1.  As is typical of federal studies of this nature, a "broad
              brush" technique was used in an effort to apply the
              assessment methodology uniformly to all states.  This
              approach frequently results in inequities because features
              which are unique to each state are not considered in the
              assessment. .Numbers developed in this manner frequently
              come back to haunt us when an accurate assessment is made.
              As an example, Nevada's needs are based on the needs of the
              Reno-Sparks and Las Vegas areas, but our most critical needs
              to control urban runoff are in the Lake Tahoe Basin.  Although
              the communities in the Basin are relatively small, the costs
              for stormwater control are relatively high, because of the
              terrain, climate, high quality of waters to be protected,
              and the stringent,controls placed on construction activities
              in the Basin.

          2.  I believe that input from the states is essential in order
              to produce a valid study.  As a minimum each state should
              have had an opportunity to review the data and methodology
                                  D-81
                     A section of the Bureau of Environmental Health

-------
James Chamblee
November 23, 1976
-2-
              used to evaluate their needs.   I  hereby request copies
              of the data and calculations used to assess our needs, so
              that we can adequately review the results of this study.

          3.   A table listing abbreviations  and symbols would be handy
              for quick reference.

                                   Yours  truly,
                                    'Lewv
                                   James  B.  Williams,  Jr.,  P.E.
                                   Construction  Grants Officer
gm
xc:  Wendell  D.  McCurry,  Environmental  Protection  Services
     John Wise,  EPA,  Region  IX
     Bob Rock,  EPA,  Region  IX

-------
   \
   9    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
  .0                       WASHINGTON, D.C. 20460
Hr. James 6.  Williams, Jr., P.E.
Construction  Grants Officer
Environmental Protection Services
Nevada Department of Human Resources
Capitol Complex
Carson City,  Nevada  89710

                                           RE:   Draft  Report on  1976 Needs
                                                Survey for Combined Sewer
                                                Overflows and Stormwater

Dear Mr. Williams:

     Thank you for your letter of November 23,  1976, offering comments on
our draft report which estimated needs for combined sewer overflows
and stormwater control (Categories V & VI).

     Your specific comment requesting inclusion of non-urbanized areas
for stormwater control needs was voiced by several states.  Regulations
for the application of the NPDES program to separate storra severs were
published in the Federal Register of March 18,  1976.   This document and
the permit program which it established were utilized  to determine
the areas requiring needs in Category VI.  In the regulations, the term
"separate storra sewer" is defined as "A conveyance or  system of  convey-
ances.... located in an urbanized area and primarily operated for the
purpose of collecting and conveying storm water runoff." The permit
issuing authority raay designate other storm sewers as  being significant
contributors  of pollution and thus subject to these regulations. In the
absence of specific designations, stormwater needs are estimated for
Census-defined urbanized areas only.

     Within the time constraints of the project, every effort was made
to allow state input and review of the 1976 Needs Survey.  An early draft
report documenting the methodology utilized to  the estimated needs and the
input data required by this methodology were sent to the states  for their
comments.  A listing of abbreviations and symbols is given on page x
through x11i  of the draft report.  It was unfortunate  hut unavoidable that
more ttrae was not available for state review of the draft report.


     The final report, including all comments received from the  states,
will be forwarded to you in early February, 1977-
                                   D-83

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     I hope that this  has  answered your questions.   If  I  can  be  of any
further assistance,  please let  me know.
                                   Sincerely yours,
                                        A. Chamblee, Chief
                                  Needs Assessment Section
                                           (WH-547)
cc: Robert Rock,  USEPA Region  IX
    Needs Survey  Coordinator
                                   D-84

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                                  Sty* &tatr of Jfout
      COMMISSIONERS
ROBERT J. HILL. Chairman                          Iwl                                WILLIAM A. HEALY, p. E.
HERBERT A. FINCHER, Vice Chairman                       ^                               Executive Director

DONALD C. CALDERWOOD, P. E.
                                             -^jgjg^"                         THOMAS A. LA CAVA, P. E.
BERNARD W. CORSON
      r\ u ci vn                                                                 Deputy Executive Director
RICHARD M. FLYNN            Water ftupnlu anb f fllhrtUm Otontral dnmmtaainn          and Chi8f Engineer
GEORGE T.HAMILTON
ELMER L. JOHNSON                            fUttHnitt flark                       LINDSAY M. COLLINS, P. E.

GEORGE M.McGEE.SR.                fl. ®. BflX 35 — 105  ftmifattt 210*21                   Director of
JAMES E. MINNOCH                                                                   Ml""C""»
MAYNARD H. MIRES. M. D., M. P. H.
WAYNE L. PATENAUDE
ROBERTM.SNOW                           November 30,  1976

JAMES VAROTSIS
          Mr.  James Chamblee
          Chief,  Needs Assessment Section
          Facilities Requirements Branch  (WH-547)
          401  M Street, Southwest
          Washington, D. C.  20460

          Subject:   Needs Survey, Categories  V and VI

          Dear Mr.  Chamblee:

                We have briefly reviewed the draft  report entitled, "1976  Survey
          of Needs  for Control of Pollution from Combined Sewer Overflows and
          Stormwater Discharges".  The following comments are offered:

                     1.  Separation of combined stormwater systems was
                         not evaluated in the  report.   However, it is our
                         opinion that, for many of  the older combined
                         systems, separation is, in fact, the most cost-
                         effective solution.   It should be noted that many
                         of our completed facilities plans recommend sepa-
                         ration as the most cost-effective alternative
                         (see attached summary).

                     2.  As a corollary to item (1) above, we would like
                         to call your attention to  the fact that category
                         IIIB costs were disallowed by Dames & Moore for
                         those combined systems which  had excessive flow
                         even during dry weather periods.  We were assured
                         by Dames & Moore that these costs would be included
                         under category V costs. We estimate that approxi-
                         mately 15 to 20 million dollars of documented
                         rehab needs have not  been  included in the overall
                         Needs Survey.

                     3.  On page B-l of subject report, the Manchester
                         SMSA is reported to have 5.1  thousand acres of
                         combined sewers, whereas,  the unpublished report
                         by the APWA (which was used by the Consultant as
                         the data base) shows  7.0 thousand acres of combined
                                           D-85

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Mr. James Chamblee
November 30, 1976
Page Two
              sewers.  Mr. Wen Huang of your office informed
              me that he had personally called the City of
              Manchester to verify the APWA data and that the
              City gave him the figure of 5.1 thousand acres.
              We called Mr. Ted McLeod, City Engineer for
              Manchester, and he informed us that he had
              offered to obtain the exact answer from Mr. Huang;
              however, when pressed for a quick answer, he
              took a guess and said 5,100 acres.  By scaling
              off the Manchester sewer map, we obtained a total
              of 7,460 acres of combined sewers.  We would
              suggest that the APWA figure of 7,000 acres be
              retained and that appendix B of the Consultant's
              report be changed to reflect the increased
              acreage of combined sewers.

          4.  The costs reported for category V .are based on
              treating a design storm of 1.6 times the mean
              rainfall event [Des. storm = 1.6 x MRF].  It is
              our opinion that the criteria is not consistent
              with State water quality standards and may, in
              fact, be inconsistent with PL 92-500.

     This Agency made no attempt to check or verify the numerous empirical
equations used in the Consultant's report.  In 1974, the Commission Staff
made a detailed estimate of category V costs which were directly related
to water quality standards.  We realize that New Hampshire's relative
percentage of total category V costs increased substantially from the 1974
Needs Survey, however, we are firm in our belief that this State's total
dollar needs for category V are closer to our 1974 estimate of 191 million
dollars than to the Consultant's estimate of 115 million dollars.

     We appreciate the opportunity to comment on the draft report, and
we trust that our comments will receive your attention.

                                 Very truly yours,
                                 William A. Healy, P.E,
                                 Executive Director
WAH:RAC:bml
CC:  Al Peloquin, NEIWPCC
                                D-86

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     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C.  20460
Mr. William A. Healy, P.E.
Executive Director
New Hampshire Water Supply and
Pollution Control Commission
Post Office Box 95
Concord, New Hampshire  03301

RE:  Draft Report on 1976 Needs Survey
     for Combined Sewer Overflows and
     Stormwater

Dear Mr. Healy:

     Thank you for your letter of November 30, 1976, offeringtcomments
on our draft report which estimated needs for combined sewer overflows
and stormwater control (Categories V & VI).

     In certain specific instances separation of combined stormwater
systems may be cost effective.  However, there was insufficient data to
determine all these instances and the related costs on a nationwide
basis.  Therefore, treatment and discharge systems were analyzed to
provide a cost estimate for control.  The control levels were identified
such that increased cost would be considered in the areas where higher
pollutant removal was required.

     Correction of dry weather infiltration in combined sewer systems
should be included in Category IIIB, if specific justification for these
costs are available.  However, we understand that, given the recent
revisions to needs estimates in Category V, you are satisfied with the
overall results of the 1976 Survey.

     In the final report, the combined sewered area of the Manchester
urbanized area will show the APWA figure of 7,000 acres and a combined
sewered population of 71,000.

     After receiving comments from the states, the design storm for
combined sewer control was changed to the 90 percentile storm for the
aesthetics and fish and wildlife criteria  (design storm equals 2.3 x
MRF) and the 98 percentile storm for the recreation criteria  (DS =3.91
x MFR).
                                  D-87

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       These and other changes raised the New Hampshire needs estimate for
  the recreation criteria for Category V to 307.960 million and for Category
  VI to 131.630 million.

       The final report, including all comments received from the states,
  will be forwarded to you in early February 1977.

       If I can be of any further assistance,  please let me know.

                                Sincerely yours,
                                James A. Chamblee, Chief
                                Needs Assessment Section
                                        (WH-547)
cc:  Charles Pease,  USEPA Region I
     Needs Survey Coordinator
                                 D-88

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                     OF  niwmixico
            ENVIRONMENTAL  IMPROVEMENT AGENCY
            Planning & Regs.  Dev.  Off.
CflLT-H
 OCIflL
                                                                        and
 November 5,  1976
                                                                  department
Mr. James Chamblee
Chief, Needs Assessment Section
Facility Requirements Branch  (WH-547)
401 M. St., S.W.
Washington, B.C.  20460

Dear Mr.  Chamblee:

I appreciate your sending the draft of the "1976 Survey of Needs for
Control of Pollution From Combined Sewer Overflows and Stormwater
Discharges" for our review.   In reviewing the base data for New Mexico,
I found only two points that  I would like to clarify.

The first point is that,  the  state population projected for 1990 by
EPA was changed in May 1976 from the old figure of 1,232,000 to
1,300,000.  This new projection was then used by EPA and Dames &
Moore for Categories I-IVB of the 1976 Needs Survey.

The second point is that since the 1970 Census, the SMSA containing
Albuquerque has been expanded to include all of Bernalillo and
Sandoval Counties.  In view of this, a change in your population pro-
jection for the SMSA in 1990  is also in order.

These then were the only points in your base data for New Mexico that
I have any question about.  I would, however, also like to mention that
there are no combined sewer systems in New Mexico.

Thank you once again for your consideration in sending us a copy of this
report.   This office will be  glad to supply you with any other infor-
mation that you may require in this regard.

Sincerely:
Cy Butner,
Needs Survey Chief

CB:opg
                              D-89

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C. 20460
Mr. Cyrus Birtner
Needs Survey Chief
New Mexico Environmental  Improvement
    Agency
P.O. Box 23489 W.Q. Division
Santa Fe, flew riexlco  87b03

                                           RE:   Draft Report on 1976 Needs
                                                Survey for Combined Sev/er
                                                Overflows and Stormwater

Dear ^r. Butner:

     Thank you for your letter of November 5, 1976, offering comments on
our draft report which estimated needs for combined sewer overflows and
stonnwater control (Categories V & VI).

     In regard to your specific comment, the state population projections
for 19:30 of 1,232,000, which was published in the Draft Report, was in
error and has been changed to 1,300,000.  The SMSA population projection
for Albuquerque was taken from the 1974 OCERS projections, and was only
used to define a growth rate for the urbanized  area of Albuquerque.
Considering this statement, the exact aerial designation of the SMSA is
not important to the needs estimation methodology.  The growth factor
utilized is the 1990 SMSA population divided by^the 1970 SMSA population.

     The final report, including all comments received from the states,
will be forwarded to you in early February, 1977.

     If I can be of any further assistance, please let me know.

                                   Sincerely yours,
                                     lies A.  Chatffalee, Chief
                                   Needs Assessment Section
                                           (WH-547)
cc. Richard 1-lcDermott, USEFA Region VI
    lieeds Survey Coordinator
                               D-90

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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
                                                                           Peter A.A. Berle
                                 November 26,  1976                           Commissioner
    Mr.  James Chamblee
    Chief, Needs Assessment Section
    Facility Requirements Branch (WH-5^-7)
    U01  M. St., S.W.
    Washington, D.C.   20U60

    Dear Mr.  Chamblee:

           This is in response to the October 22,  1976  letter  from Mr-  John  T.  Rhett
    transmitting the  draft report "1976 Survey of  Needs for Control  of  Pollution
    from Combined Sewer Overflows and Stormwater Discharges",  October 1976.

           Our comments on this report are as follows:
    1.  No rationale is provided for selecting the oO%  storm as  the  basis  of  design
        and analysis (Page U-10, 2nd full paragraph).

    2.  The observation "It is beyond the scope of this investigation  to undertake
        detailed .... analyses of the ten study sites  ..."  is definitely an unrea-
        sonable explanation for justifying the analysis (Page ^-10,  first  sentence
        in the 2nd full paragraph).   Since the ten study sites were  chosen, among
        other factors, for having site specific data, and since  the  relationship
        established between Organic  Removal Required and Quality Parameter (Figure
        6.3) for the ten sites was extrapolated to all  279  urbanized areas, a de-
        tailed analysis at these 10  sites was most certainly warranted, and in fact,
        a necessity.

    3.  The statement relating to the reaeration coefficient (K>>) to a receiving
        stream's capacity to accept  oxygen demanding material is very  questionable
        since K^  (deoxygenation coefficient) has been  observed  to not vary directly
        with K2  (Page 6-7, 3rd full paragraph).   The use of the relationship to
        calculate the "quality parameter" which is then applied  to all urbanized
        areas raises serious questions as to the credibility of  the  water  quality
        analysis for a specific site.

    U.  Although it is recognized that EPA is attempting to assess needs for  these
        categories on a nationwide basis, the criteria  for  the three levels of water
        quality which were used are  different from the  approved  water  quality stan-
        dards for specific receiving  waters in the urbanized areas.  As an  example,
       .toxic substances removal is  not considered in the analyses,  however,  stan-
        dards criteria do exist for  certain class of waters.  These  differences can
        result in a significant variation in control strategies, and their cost,
        on a site-by-site basis.
                                       D-91

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                                  -2-
5.  Most assumptions made by the  consultant  in the  methodology are "conservative",
    leading to an end result which minimizes treatment  requirements and costs.
    Examples of the conservative  assumptions are  use  of the Q0% design storm,
    criteria for the "water quality levels"  which are different than approved
    water quality standards, removal of toxic substances was not considered,
    monthly average stream flow and quality  data  rather than critical conditions
    (i.e., in New York State, Minimum Average 7 day - 10 year low flow),  no
    treatment required (except for street  sweeping  and  fine screening) unless
    the "water quality level" criteria were  violated, simplified stream model
    used for all areas.

       We strongly recommend that you fully  qualify the conservative element of
    the Category V and VI analysis in your report to  Congress.

6.  The statement "... costs estimated in  1976 are  slightly less than one-third
    of those reported in the 197^ Needs Survey and  less than one-half of  those
    in the 1973 Needs Survey" cannot be rationalized  with Table 8.U (Page 8-5,
    first full paragraph under Section 8.U).   We  recommend that this statement
    be clarified.

7-  We question the use of the words "eligible costs" in the 2nd line of  the
    paragraph at the top of Page  8-7.  In  lieu of our previous  comments regard-
    ing the methodology of analysis, the costs cannot be construed as being
    "reasonable" and therefore cannot  be used for the determination of eligibil-
    ity.  The suggested rewording is "Based  on these  considerations, ...  a more
    uniform nationwide estimate of the costs for  water  quality  control ...  ."

8.  We strongly recommend that the phrase  "  ... a reasonable program for  water
    quality control of combined sewer  overflows." be  deleted from the draft re-
    port and not be used in the report to  Congress  (Page 8-7, last line of para-
    graph in Section 8.5).  For the reasons  contained in this letter, the assess-
    ment does not constitute a "reasonable program".  We feel  it does, however,
    provide a relationship between state needs and  the  total national amount for
    equitable distribution of funds.

       To facilitate a more thorough review  of the  New  York State estimate for
both Categories V and VI, it is requested  that you  provide a copy of the  compu-
tations and the cost data for each urbanized area considered in New York  State,
including the data for any area which extended into an  adjacent state (i.e., the
New York Metropolitan area of New Jersey).

    Thank you for the opportunity to comment on the report.   If you have  any
questions, please call me at AC518—^57-2^62.
Sincerely yours,


                           i.-v^
                               r,
                             Albert W. Bromberg
                             1976 Needs  Survey Director
                                    D-92

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                   BLACK, CROW 8c EIDSNESS, INC.
                           CONSULTING ENGINEERS                  PLEASE KB-LY TO:
                                                                 GAINESVILLE. FLORIDA 32602
                                                                 POST OFFICE BOX IM7
                  PRINCIPAL OFFICE: 7201 N. W. ELEVENTH PLACE. GAINESVILLE. FLORIDA         7201 N.w. ELEVENTH PLACE

                    HeaiWML OFFMS: ATLANTA. GEORGIA / CLEARWATER. FLORIDA          ££")££«*: BCEGNVFLA

                  BIRMINGHAM, ALABAMA / BOCA RATON, FLORIDA / NAPLES, FLORIDA

              SAN JOSE, COSTA RICA / PHILADELPHIA, PENNSYLVANIA / MONTGOMERY, ALABAMA
                                          November 29, 1976
Mr. W. F. Esmond,  Jr., P.E.
Bureau of Sewage  Programs
Division of  Pure  Waters
New York State  Dept.  of
Environmental Conservation
50 Wolf Road
Albany, New  York   12201

     Re:  1976  Survey of Needs for
          Control  of  Pollution from
          Combined Sewer Overflow
          and Stormwater Discharge
          Project No. 573-7600-4

Dear Mr. Esmond:

     On Thursday,  November 18, 1976, you  attended a meeting at  EPA
Regional Offices  in New York City concerning  the Categories V and  VI
Needs Survey.   At  that time you requested additional information re-
garding the  source of urban runoff and  combined sewer overflow  data
listed in Table 4.1 of our draft report for New York, New York  and for
Brooklyn, New York.

     The data for  New York, New York are  found in the following
reference:

          Engineering Science, Inc., and  H. F. Ludwig and Associates.
          "Waste  Discharge Characterization Task Report."  City of New
          York, Department of Water Resources, Environmental Protection
          Administration.  May 1971.

The water quality  data reported in this reference were obtained from  a
storm sewered area sampled at the outfall  near 199th Street.  Runoff
from four rain  storms and one snow melt event were sampled.

     The data for  Brooklyn, New York are  reported in the following
reference:

          Mytelka, A. I., et al.  "Combined Sewer Overflow Study for  the
          Hudson  River Conference."  Environmental Protection Technology
          Series.   EPA-R2-73-152.  January 1973.
                                   D-93

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Mr. W. F. Esmond, Jr., P.E.          -2-               November 29, 1976
The water quality data reported in this reference were obtained from a
combined sewer outfall 1 coated at Johnson Avenue, east of Morgan Avenue
in Brooklyn.  Sampling was carried out for both dry weather and wet
weather conditions.  However, only one overflow event was sampled.

     The above references were the only sources containing runoff
quality information for New York City which we were able to find in the
short time allotted to the task.  I hope that this information will be
of some benefit to you.  If you have any additional questions, please
let me know.

                                        Very truly yours,

                                        BLACK, CROW AND EIDSNESS, INC.
                                        Ronald  L.  Wycoff,  P.E.

RLW/mfl

xc:  Mr. R.  D.  G.  Pyne
     Mr. Philip Graham
                                  D-94

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460
Mr. Albert W. Broriberg
1976 Needs Survey Director                          11 JAft  V'"'t
New York Department of Environmental
   Conservation
50 Wolf Road
Albany, New York  12233

                                   RE:  Draft Report on 1976 Needs
                                        Survey for Combined Sewer
                                        Overflows and Stormwater

Dear Mr. Bromberg:

     Thank you for your letter of November 26, 1976, offering comments
on our draft report which estimated needs for combined sewer overflows
and stormwater control (Categories V & VI).

     In regard to your specific coments, our responses are as follows:

          1.  After receiving comments from the states, the design storm
              for combined sewer control was changed to the 90th
              percentile storm for the aesthetics and fish and
              wildlife criteria (DS=2.3 x MRF) and 98 percentile
              storm for the recreation criteria (DS=3.91 x MRF).
              The rationale for this selection was to provide a cost-
              effective level of control and yet have a likelihood
              of meeting the water quality criteria identified in
              Section 2.2.

          2.  The statement quoted from page 4-10 relates to specific
              types of analyses of the ten study sites.  It is our
              opinion that the analyses which were conducted on the
              ten study sites were as detailed as could be accomplished
              within the time and budget constraints on the project.
              The minimum data base available also restricted the
              level of detail evaluated in the 1976 Needs Survey.
              Upon completion of 208 studies and other ongoing work,
              a more detailed data base nay be available for the future
              needs surveys.

          3.  The quality paramenter to evaluate the requirements
              for specific levels of pollution control was developed
              after reviewing many other relationships, including
              those utilizing the deoxygenation coefficient  (K-).
                                  D-95

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              The resulting quality paramenter, which includes pollutant
              loading from combined sewers, storm sewers and existing
              treatment facilities, the receiving water discharge,
              and the reaeration coefficient (K2) . provided the best
              correlation of the available information.  The methodology
              is not intended to define the percentage of pollutant
              removal required for a specific area, but to generally
              define areas which require higher levels of control than
              other areas.

          4.  We agree that on a site-by-site basis, toxic substances
              and other pollutants may require higher levels of control
              than identified in the draft report.  However, pollutant
              generation methodologies were not available from the
              literature for these pollutants and thus could not be
              used on this nationwide study.  Moreover, source control
              may be the most cost-effective way of controlling toxics.

     5,6,7&8. Your comments on specific recommended recordings of different
              sections of the report will be considered and required
              changes will be made in the final report.

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     I hope that this has answered your questions.   If I can be of any
further assistance, please let me know.
                              Sincerely yours,
                         Tames A.  Chamblee,  Chief
                         Needs Assessment Section
                               (WH-547)
cc:  Robert Olson,  USEPA Region II
     Needs Survey Coordinator
                                D-96

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NER
North Carolina Department of
Natural & Economic Resources
 JAMES E. HOLSHOUSER, JR., GOVERNOR  "  GEORGE W. LITTLE, SECRETARY

                             November 29,  1976
     DIVISION OF
  ENVIRONMENTAL
    MANAGEMENT

      W. E. KNIGHT
        Director

Box 27687, Raleigh 27511
 Telephone 919 829-4740
   Mr. James Chamblee
   Chief, Needs Assessment Section
   Facility Requirements Branch (WH-547)
   401 M Street, S.W.
   Washington, D.C.           20460

   Dear Mr. Chamblee:

        Reference is made to the letter from Mr. John T.  Rhett, Deputy
   Assistant Administrator for Water Program Operation, dated October 22,
   1976, requesting  review and comment on the draft report of the "1976
   Survey of Needs for Control of Pollution From Combined Sewer Overflows
   and Stormwater Discharges".  Our review was asked to focus principally
   on the base input data in Appendix B.

        The data supplied for the eleven  (11) urbanized areas selected for
   North Carolina appears to be adequate  for the purpose of determining
   needs for the treatment of stormwater  discharges and we, therefore, have
   no comments on the input data.

        However, it  is not clear if the needs in the urbanized areas, which
   show a percentage for the drainage area of the selected stream, is based
   only on the percentage of the urbanized area in the drainage area or if
   this particular stream and drainage area is used as a model to determine
   the needs of the  total area.  In any event, we recommend that the needs be
   shown for one-hundred percent of each  of the selected urbanized areas.

        If additional information is needed and we can be of assitance,
   please do not hesitate to contact us.

                                      Sincerely,
                                      W.E. Knight, Director
   TAW:daw
   cc:  Mr. L.P.  Benton, Jr.
        Mr. C.M.  Batten
                                   D-97

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        \
|^J27 I   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   , '  .
-------
                              Nottk Dakota State
  Environmental Control                                                    JONATHAN B. WEISBUCH, M.D.

DIVISION OF WATER SUPPLY                       —^^                          STATE
 AND  POLLUTION CONTROL
                                        / lOI-f* aiHL --V.V«\ \
                                                                       W. VAN HEUVELEN, CHIEF
 NORMAN L. PETERSON, P.E.                      l^PSSC"*^/                       ENVIRONMENTAL CONTROL
       DIRECTOR
     (701) 224-2354
                                   Missouri  Office Building
                                   120O  Missouri Avenue
                                Bismarck,  North  Dakota 58505            November 30, 1976
         Mr.  James Chamblee
         Chiefs  Needs Assessments Section
         Facility Requirements Branch(WH-547)
         401  M Street SW
         Washington,  D.C.    20460

         Dear Mr. Chamblee:

             Mr. Rhett's letter of October 223 1976, requested comments from this
         Department on the Draft 1976 Survey of Needs for Control of Pollution from
         Combined Sewer Overflows and Stormwater Discharges.  This Department feels
         a deep responsibility to comment on this 'draft although time and resources
         do not permit a complete check of all the references and methodology utilized
         in this study.

             The 1974 Needs Survey for the State of North Dakota was prepared for
         this Department by a consultant in accordance with the guidelines presented
         by the Environmental Protection Agency.  This was accomplished by direct
         contact with the communities involved in the Needs Survey.  This Department
         feels that this is more reliable than the computer program modeling used in
         the  1976 Needs Survey for categories V and VI.

             The needs for control of combined sever over flows(Category V) for the
         State of North Dakota in the 1974 Needs Survey was shown as $50,000,000.00.
         At the present time, the needs for the cities of Fargo and Grand Forks for
         this category are in excess of $25,000,000.00. This does not include the
         needs for all of the other cities in the State of North Dakota with combined
         sewers.  The 1976 draft indicates a range of needs from $344,000.00 to
         $399,000.00.  In addition, this Department cannot agree with the figure of
         $686,000.00 which is indicated as needs met before 1976.  The draft report
         indicated that for category V, the national needs are reduced to approximately
         22%  of the 1974 needs.  However, the needs for the State of North Dakota have
         been reduced to approximately 0.8% of the 1974 needs in this category.

             The needs for control of stormwater discharges(Category VI) for the State
         of North Dakota in the 1974 Needs Survey were shown as $344,000,000.00.
         The  1976 draft report indicates a maximum need of  $410,000.00.  The draft
         study indicates the national needs were reduced to approximately 14% of the
         1974 needs.   However, the needs for the State of North Dakota have been
         reduced to approximately 1.2% of the 1974 needs.
                                           D-99

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Mr. James Chamblee                 -2-                         November 30, 1976
    This Department objects to the methodology, best management practices,
assumptions, project-ions,, estimates of costs, and the complete  report.   It
appears that a great deal of time, effort, and resources  have been expended
to obliterate the pollution control needs for categories  V and  VI.   We  do
however, concur with Mr. Rhett 's statement in his letter  of October 22,  19763
which reads as follows: "It was not intended to predict accurately  the  needs
for any specific area. "  Therefore, this Department objects to  the  Draft 1976
Survey of Needs for Control of Pollution from Combined Sewer Overflows  and
Stormwater Discharges.


                                    Sincerely,
                                    Raymond Rolshoven3 P.E.
                                    Ass 't Director
RR/tj
CC:  Mr. John A. Green
                               D-100

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          WASHINGTON, D.C.  20460
Mr. Raymond Rolshoven, P.E.
Assistant Director
North Dakota Department of Health
Missouri Office Building
120tO Missouri Avenue
Bismarck, North Dakota  58505
                                        RE:  Draft Report on 1976 Needs
                                             Survey for Combined Sewer
                                             Overflows and Stormwater
Dear Mr. Rolshoven:
     Thank you for your letter of November 30, 1976, offering comments
on our draft report which estimated needs for combined sewer overflows
and stormwater control  (Categories V & VT).

     The Needs Survey estimates for combined sewer and stormwater control
were developed on a uniform nationwide basis to provide state-by-state
needs estimates on a comparable basis.  Several differences in the meth-
odology of your 1976 Needs Survey and the USEPA 1976 Needs Survey provide
an explanation for the significant differences in needs estimates for
the State of North Dakota.

     The 19,76 Needs Estimate for Category V considers the capability of
receiving waters to assimilate wastewater discharges from combined
sewered overflows.  This consideration generally leads to lower levels
of required combined sewer control than those which were utilized in
1974.  The 1976 Needs Estimates are based on treating all of a relatively
small design storm and the first flush of all larger storms.  This
assumption leads to smaller treatment facilities than those generally
identified in 1974.

     Data available to us identifies 1,300 acres of combined sewered
area in the Fargo urbanized area, and 800 combined sewered acres in
other areas of the state.

     We would appreciate receiving facilities plans or other documentation
for the 25 million dollars of needs in Fargo and Grand Forks, if this
information is available.
                                D-101

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     In regard to Category VI, the 1976 Needs Survey estimated the needs
for control in urbanized areas of the nation.  Regulations for the
application of the NPDES permit program to separate storm severed areas
were published in the Federal Register of March 18, 1976.  These regula-
tions require an NPDES permit for separate storm sewers located in
urbanized areas of the country.  In North Dakota, using this assumption,
the only area requiring control for Category VI is the Fargo urbanized
area, consisting of 15.3 sq. miles.  Although it is difficult to determine
the area which was considered in Category VI of your 1974 Needs Survey,
it apparently includes many smaller cities.  Additionally, the 1976
Needs Survey included no needs for construction of new storm sewers.

     North Dakota's final estimates after revisions to the draft report
will be 4.306 million for Category V and 2.112 million for Category VI.

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     I hope this has answered your questions.  If I can be of further
assistance, please let me know.
                              Sincerely yours,
                             'James A.  Chamblee,  Chief
                              Needs Assessment Section
                                      (WH-547)
cc:  William Hormberg,  USEPA,  Region VIII
     Needs Survey Coordinator
                               D-102

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  Environmental Control

DIVISION OF WATER SUPPLY
 AND POLLUTION CONTROL


 NORMAN L. PETERSON. P.E.
       DIRECTOR
     (7O1) 324-2354
                                                     State
                                   Missouri Office Building
                                    1200 Missouri Avenue
                                Bismarck, North Dakota 58505
                       JONATHAN B. WEISBUCH  M.[
                          STATE  HEALTH OFFICER
                        W. VAN  HEUVELEN, CHIEF
                          ENVIRONMENTAL CONTROL
                                                                     January 6, 1977
      Mr. James Chamblee
      Chief
      Needs Assessments Section
      Facility Requirements Branch  (WH-547)
      401 M Street Southwest
      Washington, DC   20460

      Dear Mr. Chamblee:

            This Department, in accordance with your  memorandum of December 16,
      1976, is enclosing a revised,  independent estimate for Category V Needs
      for the State of North Dakota, as well  as some general comments on the 1976
      Needs Survey Category V and VI updating procedures.

            The three levels of water quality used  to determine Category V and VI
      Needs do not adequately address the water quality effects of combined sewer
      overflows and storm water discharges.   Pollutants not considered, such as
      nitrogen, phosphorous, heavy metals and pesticides,  will, in many cases,
      have a greater impact upon the use of  a stream  for water supply, recreation
      or wildlife, than the pollutants considered  in  developing these Needs estimates.

            The cost estimating methodology  used  in this Survey is poorly defined
      and in some cases, contradictory.  An  example is the cost of storage, as il-
      lustrated below:

            Capital Cost  -  Storm water detention  basin   =   $.50/gal.

            Capital Cost  -  Combined sewer  overflow  for screening  -  swirl concentration

                 =   59,000 VR-598   +  43,200 VR-803

            Capital Cost  -  Combined sewer  overflow  for sedimentation

                 =   177,500 VR'598  +  193,900 VR'803

                         Where VR    =   volume of runoff to be stored.

            An example calculation  for 1.0 MG gives the following costs:
            Storm water detention:
            CSO-Screening-Concentration
            CS)-Sedimentation
$500,000
$102,200
$371,400
                                        D-103

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Mr. James Chamblee                       -2-                  January 6, 1977


      It is difficult to understand how the cost of a basic storage facility
can vary so much within one report where the methodology should be consistent.

      The attached calculations were used to formulate a State estimate for
Category V Needs using the same methodology as was used by EPA in developing
their estimates.  However, corrections were made in the assumptions and base
data when errors were found.

      The estimate submitted must be viewed as an absolute minimum need since
it is based on the assumption that adequate treatment facilities exist to
treat all combined sewer overflows once they have been collected and pumped
to treatment facilities.

      Due to a lack of time and the necessary data base, this Department was
unable to provide an estimate for Category VI Needs.   However, the $2.112
million dollars final EPA estimate is much too low to provide water quality
control measures necessary for storm water discharges.  The City of Fargo
shows 33 direct discharges to the Red River, ranging  in size from 15" to 66",
as well as 77 discharges to the Red River, via county drains, ranging in
size from 12" to 72".  An inventory of storm water discharges in' the City
of Grand Forks shows 12 direct discharges to the Red  River ranging in size
from 10" to 54", as well as 25 discharges to two tributaries of tire Red
River, ranging in size from 8" to 60".  This does not include private drains
and other unreported drains.  $2.112 million dollars  is not an adequate amount
of money to alleviate water quality problems from storm water discharges from
these two communities, much less the entire State of  North Dakota.

      We hope that these comments will be given full  consideration for inclusion
in the February 10, 1977, report to Congress.  If you should have any questions
in regard to this Department's comments or Needs calculations, please feel
free to contact our Office.
                                         Sincerely,
                                          aymemd Rolshoven, PE
                                         Assistant Director
RR:dmb
Enc.
cc:  EPA
                                  D-104

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HYDROLOGIC CALCULATIONS - FARGO, ND

     No. of storms/yr.   =   106
     Average yearly rainfall   =   18.73 inches
     Mean rainfall/storm (MRF)   =   18.73/106   =    .177 inches
     Design depth   =   1.61  (MRF)   =   .284 inches

DESIGN CALCULATIONS - FARGO, ND

     Population desnity of combined sewered areas  (PDCS), from p. B-7
     PCDS   =   2,000/200   =   10.0 people/acre
     % imperviousness  (CSI)
     CSI   =   9.6(10.0) ('573  -  -0391Logio 10.0)   =   ^^
     ROC   =   .15  +   ,75(.3282)   =   .40
     Design volume of combined sewer treatment  (DVCS):
          DVCS   =    (.284)(.40)(410)*(.027158)   =   1.26MG
*    The survey report indicates 200 acres served by combined sewers.  The
     Fargo Facility Plan (Project No. C 380374) and communications with the
     City of Fargo indicate there are 410 acres served by combined sewers.
     Therefore, 410 acres is used for design calculations.

     No. of storage facilities  (NSP)   =   2
     Storage per facility  (STCS)   =   1.26/2   =    .63 MG
     Discharge rate from storage facility  (TRCS)
     TRCS   =   .63/(183**/106)
            =   .36 mgd
**   Since rainfall occurs only in the period of April to September, the time
     between storms should be based on 183 days rather than 365 days for Fargo,
     or any other northern city.

     Interceptor length (IL)   =   2.8875(410)   =    1,184 ft.
Because of the topography of the Red River Valley  and the built-up nature of the
area, 1,184 feet would not be adequate to transport  flows to treatment facilities.

COST CALCULATIONS - FARGO, ND

     Storage basins:
     ($.50/gal)(630,000 gal.)(.9091)   =   $286,400/basin
     2 basins @$286,400   =   $572,800   =   Capital  Cost
                                  0-105

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                                      -2-
                                           on o
     Capital Cost of pumping:   48,000(.36)'   (.9091)    =   $18,800/station
     0 & M Cost   =   2,500  +  1,930(.36)'468  +  60(.36)   +  180(.36)
                      $3,800/yr./station
     Total Capital Cost of pumping   =   2($18,800)    =   $37,600
     Total O & M Cost for pumping   =   2 ($3,800)    =   $7,600/yr.
     Cost of interceptor sewer   =   (IL)(28.0 TRCS"  )(Cost Index)
     Interceptor cost   =   1,184(28).36"   (.9091)
                            $22,^00

Total Category V Needs for Fargo, ND:

     Detention basins                  =                       $572,800
     Pumping                           =                         37,600
     Interceptor                       =                         22,200
                                                               $632,600
     O & M Costs  =  $11,500  +  $7,600  =   $19,100/yr.
     Capital Cost/acre   =   $632,600/410   =   $l,543/acre
     O s M Cost/acre   =   $19,100/410   =    $46.60/acre

The 1967 AWPA Report indicates 6,366 acres  served by combined sewers in North
Dakota.  Since 1967, approximately 1,366 acres have been separated.  This leaves
a total combined sewered area of 5,000 acres.  Basing the total State Needs on
the cost/acre developed for the urbanized area,  as was done in the Survey Report,
the total Category V Needs for North Dakota are:
     (5,000 acres)($l,543/acre)        =              $7,715,000 Capital Costs
     (5,000 acres) ($46.60/acre)        =              $233,000/yr. O & M Cost.s
Of these 5,000 acres of combined sewered areas,  410 acres are located in Fargo
and 1,720 acres are located in Grand Forks.  These are the two most highly ur-
banized areas in the State.  The Category V Needs Estimate above assumes that
in all communities, the combined sewer overflows can be treated by the existing
waste treatment plants.  Therefore, this cost must be viewed as a low estimate
since expansion may be necessary at some plants.
                                D-106

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         L'NITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D C. 20460
                                                              TIJ V.V7
Raymond Polshoven, P.E.
Assistant Director
North Dakota Department of Health
Missouri Office Building
1200 Missouri Avenue
Bisraark, 'North Dakota  58505
                                   Re:  Draft Report on 1976 Needs
                                        Survey for Combined Sewer
                                        Overflows and Storrawater
Dear Mr. Rolshoven:
     Thank you for your letter of January 6, 1977, offering additional
Garments on our draft report which estimated needs for combined sewer
overflows and stormwater control  (Categories V & VI)-.

     We have included the data presented in your design calculations for
combined sewer areas:  410 acres for the urbanized area of Fargo, North
Dakota, and 4590 acres for the non-urbanized areas of North Dakota.  The
resulting needs for North Dakota for Category V is $12.837 million and
for Category VI is $2.032 million.  Based on Mr. Philip Graham's conver-
sation with Mr. Hormberg on January 21, 1977, I understand that you do
not now wish to submit separate state needs estimates for Category V &
VI.

     Each of the pollutants, nitrogen, phosphorus, heavy metals and
pesticides, was considered in the early stages of the needs survey
development, but was rejected either because of a lack of a national
data base or time and budget constraints on the project.  Pollutant
generation methodologies were not available from the literature for
these pollutants.  Moreover, "end-of-pipe" control may not be the most
cost-effective way of controlling toxics.

     You were correct in pointing out the variation in costs of storage.
Both combined sewer overflow storage cost equations have been modified
since the draft report.  In addition, the combined sewer overflow cost
equation for screening - swirl concentration was not accurately reported,
                                D-107

-------
although it was properly used in the computer program.  Estimates of
stormwater detention costs vary widely.  The estimate of $0.50/gallon
for stormwater detention is thought to be on the higher side.  The con-
sulting firms performing this needs survey were specifically requested
to use cost equations based on available literature.

     The final report, including all conments received from the states,
will be forwarded to you early in February 1977.

     If I can be of further assistance, please let me know.

                              Sincerely yours,
                                 (1
                                "I !  x
                         (     James A.  Chamblee,  Chief
                         Needs Assessment Section (WH-547)
cc:  William Hormberg, USEPA,  Region VTII
     Needs Survey Coordinator
                             D-108

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State of Ohio Environmental Protection Agency, Box 1049, 361 East Broad Street, Columbus, Ohio 43216  (614) 466-8565

                December 28,  1976


                RE:  1976 Needs Survey Catagories V and VI, Draft
                                                       CERTIFIED MAIL
                Mr. James Chamblee, Chief
                Needs Assessment Section
                Facility Requirements Branch  (WH-547)
                United States Environmental Protection
                  Agency
                401 M Street, S.W.
                Washington, D.C.  20460
James A. Rhodes
Governor          Attention:  Mr. Philip Graham
Ned E. Williams, P.E.
Director
                Dear Mr. Chamblee:
                Attached is more detailed information on Catagories V and VI
                as discussed with Mr. Graham on or about November 28, 1976.

                The  comments and suggested changes should not be construed as
                criticism of the Consultants.  I feel that, with the three
                month limit, the Consultants did a very good job.  In the time
                allotted, they could not have covered the entire country in
                the  detail that the "Survey" deserves.

                The  following are comments on some of the disagreements we have
                with the "Survey":

                   1.  The three month, 5 year low flow does not relate to
                       Ohio Water Quality Standards  (WQS);

                   2.  NPDES Permits are designed to require facilities that
                       will produce an effluent which will meet WQS or BACTEA
                       based on a seven day, 10 year low flow;

                   3.  We feel that the 50,000 population cut-off is too high.
                       The number of "Major" municipalities, as originally
                       defined for the NPDES Permit Program was 10,000 or more
                       population.  Ohio has 155 cities with more than 10,000
                       population, 20 of these have populations over 50,000.
                       Some of the remaining 135 are included in the Urban
                       Areas covered by the "Survey".  Many others are not,
                       and are major problems, especially those located near
                       the headwaters along the St. Lawerence-Ohio River Divide
                       and other headwaters;
                                             D-109

-------
 Mr.  James Chamblee
 December  28, 1976
 Page 2
    4.   A City in Ohio is  defined  as  an incorporated entity
        having 5,000 or more  population.   We have 109 cities
        with 5,000 to 10,000  population that are problems as
        cited in 3,  above;  and,

    5.   Due to the above and  the attachments that follow,
        we feel that U.S.  EPA would be  misleading Congress
        if the cost  figures,  as given in the "Draft  Survey",
        are used.
 There are two  errors  in  the  Tables  on pages  B-4  and  B-5.   On
 page B-4, last line,  No.  160, Akron has  186  miles  of Combined
 Sewers serving 13,000 acres, and  585 miles of  Storm  Sewers
 serving 21,560 acres.  On page B-5, first line,  No.  161,  Canton
 has no (0.0) Combined Sewers, area  served by Storm Sewers is not
 known.

 We are not requesting an "independent state  cost estimate" as
 mentioned in your memo to State and Regional Needs Coordinators,
 dated December 16,  1976.

 We do request  that  the comments and suggestions  contained in
 this letter and the Attachments be  seriously considered in de-
 termining cost figures for Ohio.

 I regret  that,  due  to  lack of time, I have not been  able  to
 submit  a  more  detailed report.  If  you have  any  questions,  please
 contact me at  (614) 466-8945.

 Happy New Year!

 Yours very truly,
L.T. Hagerty, P.E.
Director
I976jfeeds Survey
               >, P.E.

Ohio Environmental Protection Agency

LTH/NEW/jan
Enclosure

cc:  Philip Graham                 cc:  Ted Horn, Region V
cc:  Robert Holbrook               cc:  Ronald L. Wycoff

cc:  Ernie Rotering                cc:  Jim Greener
                             D-110

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                      ATTACHMENTS
Summary, Maps and Comments concerning the "Draft 1976 Survey
of Needs for Control of Pollution from Combined Sewer Over-
flows and Stormwater Discharges".
Attachment 1 - A.  Summary
               B.  Urban Areas

Attachment 2A - State Map
           2B - Urban Area Maps

Attachment 3 - Comments and Suggested
                 Changes                         14 - 16
                           D-lll

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                           ATTACHMENT NUMBER I
Summary
     A.   It is our understanding that the purpose of the Needs Survey, Catagories
         V and VI, was to determine the impact of Combined Sewer Overflows
         (CSO) and Storm Sewer Discharges (SSD) on streams in and below Urban
         Areas.  If this determination is to be made properly, it is necessary
         to gage the low flow in the stream(s) up stream of the Urban Area(s).
         When this is done,  CSO's and SSD's for various rainfalls can be
         plugged into an equation,  the WWTP effluent added and the net effect
         on the stream evaluated.

         The above procedure is relatively simple if the Water Supply for an
         Urban Area is taken from a large river, a natural lake or from wells.
         However,  if the Water Supply is taken from an impounded stream or a
         stream that is pumped for Off Stream Storage, the problem becomes
         more difficult.  The Gaging Station(s) must be downstream of the im-
         poundment (s) and upstream of any CSO's and SSD's in order to obtain
         correct data.

         The following tabulations of Water Supplies includes the 17 Urban
         Areas, plus Cities  (>5,000 population) and Villages, in Ohio:

                  Number                      Description

             1.     76                        Impounded Stream
             2.     23                        Off-Stream Storage*
             3.     16                        Ground** and On-Stream***
             4.      8                        Ground and Off-Stream
             5.     18                        On-Stream and Off-Stream
             6.      6                        Ground and "On" and "Off" Stream

             *Pumped to Upground Reservoirs
             **Well Supplies
             ***Impounded Stream
     B.   Urban Area -  Controlled  Streams

         None of the ten "study"  cities cited  in the "Draft 1976 Survey of
         Needs for Control  of  Pollution from Combined Sewer Overflows and Storm
         Water Discharges," including  any areas  tributary to Controlled Rivers.

         Ohio has many controlled streams.   Those areas included in the seventeen
         areas,  covered in  the "Draft" are:  Akron;  Columbus;  Lima; and Youngstown,

         Akron has reservoirs  on  the Cuyahoga  River  which impound water during
         wet  weather and release  it for water  supply during dry weather.  Ravenna
         has  a similar operation  on a  tributary  to the Cuyahoga River.

         Columbus  has  reservoirs  on the Scioto River,  Big Walnut Creek and Alum
         Creek.   The Scioto River and  Big Walnut reservoirs are controlled for
         water supply  only.  The  Delaware reservoir  on the Olentangy River is
         used  for  Flood Control only with a  guarantted dry weather flow of five
         to forty  cfs.   The Alum  Creek reservoir is  a  combination water supply

                                      D-112

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Attachment Number
Page 2
         and flood control facility for the cities of Westerville and Columbus.
         This is a new reservoir.  At present we do not know the plan of
         operation.  Water used by Westerville is discharged to the Columbus
         Sewer System.

         Lima pumps water from the Ottowa River to upground storage reservoirs
         during high flows.  The flow in the River, below Lima, during dry
         weather is essentially all sewage plant and industrial waste discharges.

         Youngstown and other cities are located on the Mahoning River or its
         tributaries.  Mosquito Creek and Meander Creek reservoirs are used
         for Warren and Youngstown - Niles respectively.  Milton, West Fork and
         Berlin reservoirs were designed and are used for low flow augmentation
         during summer months.  Their main purpose is to supply enough water
         to lower the high temperatures due to steel mill discharges to the
         Mahoning River.  As a result, low Dissolved Oxygen problems,  in the
         River, have been experienced in the months of November, March and April
         while the reservoirs are being filled.
                                    D-H3

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                                                                    ATTACHMENT NUMBER 3
NO.
      Urban Area
                             Attachment  92
                                Map No.
                     USGS
                  Station No.
               Data Code (7-6)
            Present      Proposed
                                                    Comments
 1.    Akron
 2.    Canton
 3.    Cincinnati
                                37-59
                                37-59
                                37-62
                                                    2060
                                                    1185
                    N/A*
                                                     Evaluation
                                                 of Gage Station
                                      This Gaging Station is downstream of all com-       1.  Not Good
                                      bined sewer overflows and storm water discharges.
                                      Stations should reflect flow from Lake Rock-
                                      well and Little Cuyahoga River.

                                      Flow in the Nimishillen Creek above Canton WWTF     2.  Not Good
                                      is from Industrial discharges and Louisville
                                      WWTP effluent.   Canton WWTP should be subtracted.

                                      Markland Dam is miles below the Cincinnati U.A.     3.  Not Good
                                      All discharges, Municipal and Industrial,  from
                                      Ohio and Kentucky and stream flows should be
                                      subtracted from the Markland readings.
 4.    Cleveland
                                37-60
 5.    Columbus
                                37-63
                    N/A'
                    2275
 6.   Dayton


 7.   Hamilton
37-64


37-62
2695
                                                    2740
                                                                                          Major WWTP's with combined sewer systems shown.
                                                                                          (See maps 4 and 4.a)
Plant effluent discharges to a river pool.  The
Gaging Station, in this pool, is upstream of the
effluent and is greatly influenced by the effluent.
The extent of the influence is dependent on wind
direction.  Gage also records all combined sewer
and storm discharges in the U.A.

Gage Stations should be on the three Rivers and
Wolf Creek to cover flows to the Urban Area.

Flow above this station is controlled by storing
River Flow in the Canal and discharging through
the City Hydroelectric Plant.
                                                                                          4. Cleveland
                                                                                             Southerly &
                                                                                             Bedford are
                                                                                             not direct t>
                                                                                             to Lake Erie

                                                                                          5. Not Good
                                                                                          6. Not Good
                                                                                                                                              7. Questionable

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 Attachmeat No. 3

 NO.   Urban Area
Attachment #2
   Map No.
   USGS
Station No.
   Data Code (7-6)
Present	Proposed
Comments
                                                                                                                                                 Evaluation
                                                                                                                                              of Gage Station
  8.   Huntington-lronton,
         Ohio
   N/A
   N/A
  9.    Lima
   37-62
   1875
•"10.    Lorain-Elyria
 11.    Mansfield
 12.    Springfield
 13.    Steubenville
 14.    Toledo
 15.    Wheeling-Belraont
         County, Ohio
   37-65


   37-65


   37-65


   37-65


   37-66



   N/A
   N/A


   1305


   2695


   N/A


   N/A



   N/A
                          Gaging Station is below Huntington effluent and
                          above Ironton effluent.  Reading appears to be
                          too high,  44,000 cfs,  at this station with only
                          36,000 cfs at Markland Dam.  ORSANCO thinks
                          24,000 cfs would be more nearly correct.  Kentucky
                          Office of USGS told me that no flows below 50,000
                          cfs have been recorded since 1968.

                          This Gaging Station is downstream of the Lima
                          WWTP effluent plus three Industrial Waste dis-
                          charges.  These discharges plus dry weather
                          storm flows are all of the low flow.  Higher
                          flows in the Ottawa River are impounded and
                          used for water supply for the City.  Low flow
                          above Lima occurs when the River is too low to
                          pump to storage.  The Ottawa River is the west
                          stream as corrected on map.

                          Lorain discharges to Lake Erie, 0 cfs.   Elyria
                          Station 042005.

                          Probably USGS Station 1305, Touby Run is the
                          same as Rocky Fork Creek.

                          WWTP effluent and combined sewer and storm water
                          discharges should be subtracted.

                          Gaging Station is above the mouths of the Beaver
                          and Little Beaver Rivers.  May be low.

                          WWTP discharges to Maumee Bay, which is difficult
                          to distinguish from Lake Erie.  It does not dis-
                          charge to the Maumee River.  Cfs should be 0.

                          Same Gaging Station as Steubenville (See 13).
                          Belmont County S.A. No. 1 currently serves
                          Martins Ferry, Bridgeport and Bellaire.  In
                          the near future the Authority will serve the
                          County Sewer District No. 1.  Tributary pop-
                          ulation will increase by 3,000 to 4,000.
                                                                                                                 8. Questionable
                                                                                                                 9. Not Good
                               10.
                                   Lorair.,  7 . E.
                                   Elyria 2005;
                                                                                                                                              11. O.K.
                               12. Not Good
                               13. Not Good
                                                                                                                                              14.
                                   Should be
                                   0 cfs
                               15. Questionable

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  VO
  Attachment No.  3

  NO.   Urban Area
                                Attachment #2          USGS           Data Code (7-6)
                                   Map Ho.	Station No.   Present	Proposed
                                                                             Comments
                                                                                                              Evaluation
                                                                                                           of Gage Station
  16.   Youngstown
37-66
                                                      0980
  17.   Paricersburg-Marietta,      N/A
          Ohio
                  N/A
Gaging Station is just upstream of the
Youngstown WWTP.  The Warren, Niles, McDonald,
Girard and the Trumbull County Mosquito Creek
Treatment Plants plust many Industries (mainly
steel mills) are upstream of this station.
Probably station 040940 should be used.

Point Pleasant Gaging Station is about 60 to
70 river miles downstream from Parkersburg.
It is possible that the intended Station was at
Willow Island Dam in Pleasant Township, W.V.
This station is 15 to 20 miles upstream from
Parkersburg.  44,000 cfs is to high for either
of these stations.  (See //8)
16. Should be
    0940
17. Questionable
J_, *N/A means  not  available in our office for Ohio River Urban Areas and not applicable in the Cleveland Urban Area.

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                           WASHINGTON, D.C.  20460
                                                     z e
Mr. Ned E. Williams, P.E.
Director
Ohio Environmental Protection Agency
Box 1049
361 East Broad Street
Columbus, Ohio  43216
                                            RE:   Draft Report on 1976  Needs
                                                 Survey for Combined Sewer
                                                 Overflows and Stormwater
Dear Mr. Williams:
     Thank you for your letter of December 28, 1976, offering comments  on  our
draft report which estimated needs for combined sewer overflows  and  Stormwater
control (Categories V & VI).

     The water quality criteria identified in the draft report were  for wet
weather conditions.  Existing standards are mainly written for dry weather
flow conditions and, therefore, are based on a 7-day, 10-year low flow.   It
is our feeling that wet weather conditions normally require different water
quality criteria and receiving water flow constraints.   Additionally, nation-
wide wet weather criteria were required for consistency throughout the
assessment.

     Your comments requesting inclusion of communities  other than urbanized
areas for Stormwater control needs was voiced by several states.  Regulations
for the application of the NPDES program to separate storm sewers were
published in the Federal Register of March 18, 1976.  This document  and the
permit program it established were utilized to determine the areas requiring
needs in Category VI.

     The regulations defined the term "separate storm sewer" as  "a conveyance
or a system of conveyances  .... located in an urbanized area and primarily
operated for the purpose of collecting and conveying Stormwater  runoff."
The permit issuing authority may designate other storm sewers as being
significant contributors of pollution and thus subject to these  regulations.
In the absence of specific designations, storrnwater needs are estimated for
Census-defined urbanized, areas only.
                                 D-117

-------
     Thank you for your specific  input  on  combined  sewered  areas  and receiving
water classifications for Ohio.   All  of your  recommended  changes  were made in
our final  computer run-off on  Jan 21, 1977.   The  1990  Category  V  Needs for
Ohio were  increased to $1765.612  million.  The  1990 Category  VI Needs for
Ohio are $4752.180 million.

     The final report, including  all  comments received from the states,  will
be forwarded to you in early February 1977.

     I hope that this has answered your questions.   If I  can  be of any
further assistance, please let me know.
                                  Sincerely yours,
                                  -'James A. Chamblee, Chief
                                  Needs Assessment Section
                                           (WH-547)
cc: Ted Horn, US EPA Region V
    Needs Survey Coordinator
                                  D-118

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              DEPARTMENT OF ENVIRONMENTAL RESOURCES
                           POST OFFICE BOX 2063
                      HARRISBURG, PENNSYLVANIA  17120

                          December  3, 1976         in reply refer to:
                                                       16-4.111
                                                        4-3.8

 Mr.  James  Chamblee
 Chief, Needs Assessment Section
 Facility Requirements Branch  (WH-547)
 U. S. Environmental Protection Agency
 401  M Street, S. W.
 Washington, D. C.  20460

               Re:  Sewerage, 1976 Municipal Needs Survey

 Dear Mr. Chamblee:

     Pursuant to Mr. Rhett's  letter of October 22, 1976, we are taking
 this opportunity to submit comments and recommendations concerning the
 preliminary results of the 1976 Municipal Needs Survey for Categories V
 and  VI.

     We  realize that previous Category V and Category VI needs estimates
 which were compiled by the individual states in 1974 suffered from lack
 of uniform guidelines and methodologies, and we would like to commend
 EPA  in its attempts to rectify this situation.  As with the survey for
 Categories I-IVa, the use of an impartial, outside contractor should
 prove worthwhile.

     In view of the following comments and observations, we would urge
 you  to reevaluate the underlying assumptions and methodologies used in
 1976 in order to avoid what may be a severe underestimate of needs in
 both categories for the nation as a whole.

A.   General Observations

     1.    It appears that the survey methodology follows a logical
pattern and utilizes reasonable assumptions regarding factors such as
pollutant removal efficiencies for various control or treatment schemes,
and minimum degrees of treatment required for the three basic levels of
receiving water quality to be protected.  We must, however, question
 several of the other basic assumptions concerning design precipitation
                               D-119

-------
 Mr.  James  Chamblee                 2                   December  3,  1976
 magnitudes,  runoff coefficients, drainage areas, and mathematical models
 chosen for this  survey since the estimated 1976 needs, both for  the
 nation and for Pennsylvania, have been seriously reduced from the 1974
 estimates.

           For example, a tabular summary of Pennsylvania's 1973, 1974
 and 1976 Needs Survey results for Categories V and VI is presented as
 follows:

 Year                    Category v               Category VI

 1973               *  $1,589,000,000        (This information not in-
                           (12.51%)           eluded in the 1973  survey.)

 1974               *  $2,439,000,000             *$3,743,000,000
                           ( 7.85%)                     (1.59%)

 1976               ** $  217,315,000            **$  582,906,000
                           ( 3.22%)                     (1.73%)

 *July,  1973  Dollars
 **January, 1976 Dollars
 Number in  parentheses indicates percent of national totals

           If the applicable inflation factor (1.41) is used to convert
 July,  1973 dollars to January, 1976 dollars, it is obvious that the 1976
 Needs  Survey has resulted in a 16-fold decrease in Category V needs and
 a 9-fold decrease in Category VI needs from those needs reported during
 the 1974 Needs Survey.  We cannot, however, accept the implication that
 our previous needs estimates were so far off the mark.

     2.   A  review of Appendix B indicates that the survey concentrated
 upon the needs for Pennsylvania's 13 SMSA areas and one additional urban
 area (Williamsport) .   We would agree that the majority of the Category V
 and Category VI needs occur in these major urban areas, and this was our
 basic  approach for estimating the Category VI needs during the 1974
 Needs  Survey.  Enclosed is a copy of the broad rationale and the method-
 ology which  we used for Category VI at that time.

          As far as Category V is concerned, in 1974 we reported the
 total needs which were identified for 29 authority/facilities (repre-
 senting 26 authorities) .   The methodologies used to estimate these needs
 varied from case to case.

     3.   Prom a review of Sections 8.4 and 9.2 of this report,  "rela-
 tively small  design storms" were used as part of the survey methodology
to determine  Category V and Category VI needs.   We understood from a
recent telephone conversation with you that a "relatively small  design
storm" consists  of 80% of  the applicable five-year storm for a particular
                                D-120

-------
Mr.  James Chamblee                 3                   December 3, 1976
urban area.  Actually, as indicated on pages 4-10, the average rainfall
which occurs 80% of the time was used for this survey.  As the enclosed
consultant's comments state, this would account for some of the differences
in reported needs.  You also indicated that the total needs for Categories
V and VI were estimated on the basis of having to meet the highest of
the three basic levels of water quality criteria which are listed in
Tables 21 through 23.

          Although it is not specifically shown in the attached method-
ology for the 1974 Category VI estimates, we used an average rainfall
intensity ranging from 0.9 to 1.2 inches per hour.  (This is roughly a
two-year storm of one-hour duration.)   We then calculated the average
runoff using the Rational formula, O = CAi, using an average runoff
coefficient of 0.5 for all urban areas.   We then used 10% of the calcu-
lated runoff in each case to size the storm water storage and treatment
facilities and to estimate their costs.   Granted, the use of the Rational
method has its limitations; however, from this brief discussion, it
would appear that we were more conservative in our approach during 1974
for Category VI than the contractor was in 1976, yet the 1976 results do
not support this assumption.

     4.   Finally, to the best of our knowledge, this Department was not
consulted at any point before or during the Category V and Category VI
survey to discuss general study procedures and assumptions to be used.
Although we understand the need for a uniform nationwide methodology, we
fail to understand the need for a complete lack of communication regarding
this portion of the 1976 Municipal Needs Survey.

B.   Specific Comments

     1.   Page 2-2, Section 2.1.1, next to the last paragraph - Although
this would have no apparent bearing on the outcome of the survey, there
are some erroneous statements included here.

          According to the U.S.P.H.S.  1962 Drinking Water Standards, a
water supply source containing more than 500 mg/1 total dissolved solids
should generally not be used when other more acceptable sources are
available (i.e., it is not an absolute limit).  Also,  there is no
maximum turbidity limit for raw water supplies in the U.S.P.H.S. 1962
Standards.  A limit of five turbidity units (not mg/1)  would apply to
finished waters served to the public.   EPA has promulgated interim
primary drinking water standards which closely parallel to the Public
Health Service Standards and we suggest that you coordinate this portion
of the survey report with EPA's Water Supply Program staff.

     2.   Section 3 - In order to further assist our own program efforts
in the area of treatment and/or control of combined sewer overflows and
storm water, we would appreciate your sending us copies of references 6-
8 and 10 which were indicated in Part I of the Survey Report, if possible.
                                 D-121

-------
Mr. James Chamblee                 4                   December 3, 1976
     3.   Section 7, Table 7.1, pages 7-21 - We would be extremely
interested to know what specific treatment and/or control combinations
were chosen for the 14 urban areas identified for Pennsylvania in Appendix
B.  We feel that this will shed some light on the reasons for the decreases
in the reported needs for Categories V and VI from the 1974 results.
This type of information, as well as information on design storms,
rainfall intensities, runoff coefficients, etc. , should be included in
tabular form for each area in this Survey Report.

C.   Other Comments

     In conjunction with our on-going Comprehensive Water Quality Management
Program (COWAMP),  we requested one of our COWAMP consultants  to  review
this report.  These comments are enclosed.

                              Sincerely yours,
yvii  M\
•ij W. Garg,
                                            G
                              Brij IK Garg, Chief J
                              Facilities Section
                              Division of Water Supply and Sewerage
                              Bueau of Water Quality Management
Enclosure
                            D-122

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       CHESTER-BETZ   ENGINEERS
       One Plymouth Meeting Mall
       Suite 413
                      Plymouth Meeting, Pa. 19462
                       Telephone; 215 S2B-O4OO
TO:
FROM:

SUBJECT:




DATE:
Mr. F. Rab
Dept. of Environmental
 Resources
Fulton Bank Bldg.
3rd & Locust Sts.
Harrisburg, PA 17101
T. May
REVIEW OF EPA REP/
COMBINED AND STOI
SEWER SURVEY OF NEEDS

November 29, 1976
     CBE Memo No. 303

Mr. Tom Walton
Delaware Valley Regional
 Planning Commission
Penn Towers Building
1819 J.F.K. Boulevard
Philadelphia, PA 19103

Cc:  K. O'Day
     W. Bellaman
I have reviewed the 1976 Survey of Need for control of
pollution and combined sewer overflows in storm water dis-
charges (draft October 1976).  The following summarizes my
comments on the report.  I have forwarded the report to
Wayne Bellaman of TCE and he will probably also be com-
menting in the near future.

1.   The approach described in the Need Survey appears
     reasonable.  The assumption of an 80 percent storm as
     the design storm, consideration of assimilative capa-
     city, consistent definition of urban area, etc. are all
     in the right direction.

2.   The approach is based on many assumptions but this is
     probably necessary due to the scope of the undertaking.

3.   The assimilative capacity assumptions presented in the
     report are especially crude; however, these crude
     assumptions are probably better than no consideration
     of the assimilative capacity that was used in previous
     Needs Surveys.

4.   Taken in total, I believe the Needs survey is reason-
     able and is especially welcome in comparison to what it
     replaces (ie., much better than the techniques used in
     previous surveys).
                             D-123

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CHESTER-BETZ  ENGINEERS


     Mr. F. Rab               -2-            November 29, 1976


     5.   The description of the Philadelphia case study  (p. 5-5)
          is very interesting.  The report concludes that water
          quality standards will not be met even after all points
          source allocations are complied with.  The report also
          indicates that approximately an 80% reduction in non-
          point source and combined sewer loads will be required
          in order for the Delaware to meet water quality stan-
          dards.  It will be interesting to see if these conclu-
          sions are verified during our COWAMP/208 work.

     6.   The analysis of design storm selection (p. 4-10) was
          very interesting.  The report showed that previous
          surveys may have used a design storm of, say, a 5-year,
          24-hour storm.  This type of storm would deliver ap-
          proximately 5" of rain.  It can be shown that this
          rainfall is in the 99.83 percentile.  The October 1976
          draft assumes an 80 percent storm rather than a 5-year
          24-hour storm.  This 80 percent storm turns out to be
          .74" or only 15% of the 5-year value.  Assuming that
          storm water and combined sewer costs are a function of
          the volume of storm water, it is obvious that assuming
          an 80 percent storm will drastically reduce the cost
          for storm water/combined sewer overall treatment.


     /ll
                                  D-124

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                                      rr (SURVEY;

                        COMMONWEALTH OF PENNSYLVANIA

            Special Report on Assessment  of Needs of Category VI:
                   Treatment and/or Control of Storm Water
     The needs for this category have been developed on a state-wide basis
approach.

     (1)  Broad rationale:  Based upon the information available
          in the Department only those areas of the state were
          selected for assessing needs of Category VI which are
          known to have significant water quality problems as a
          result of storm water discharges into the surface waters.
          Most of the areas considered are the Standard Metropolitan
          Statistical Areas (SMSA) and areas which are adjacent thereto.

          Most of these population concentration areas have combined
          and/or separate sewer systems.  The financial needs for
          separating the combined sewer systems have already been
          considered under Category V.  The needs assessed in
          Category VI are for:

          (i)   new storm sewers which are considered necessary
                to abate water pollution.  It should be emphasized
                that no new storm sewers which are for flood control
                functions, and for the treatment of wastes from non-
                point sources, or from non-publicly owned sources
                are included in this assessment.

          (ii)  storage and treatment facilities.  The treatment
                facilities are expected to provide the level of
                treatment which is necessary to meet the estab-
                lished water quality standards for the waters of
                the Commonwealth.

     (2)  Methodology:  It is known that in the areas included in this
          survey for Category VI, the majority of them either have
          storm sewers or have combined sewer systems.  Therefore, it
          is estimated that only 10% of total storm water volumes would
          need to be conveyed by new storm sewers to serve year 1990
          population.

          For calculating the cost of facilities to control and treat
          storm waters, it is estimated that only 10% of the total
          runoff would need to be treated because of high pollution
          load.  This 10% would essentially be the flow resulting
          from first flush.  The remainder 90% of the storm flow will
          either be carried by combined sewer systems or would not
          have high pollution load to justify storage and treatment.

     (3)  Total State-wide cost assessment for Category VI:  As a
          result of systematic analysis based on reasonable assumptions,
          it is estimated that an estimate of eligible cost for Category VI
          is 3.743 billion dollars.
                                    D-125

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       Sub-area and/or Authority COUCH Tor Category VI:
Total Area
Name of SMSA or to be served
Municipality Sq . Miles
Philadelphia SMSA
Pittsburgh SMSA
Allentown-Bethlehem-
Easton SMSA
Johnstown SMSA
Erie SMSA
Harrisburg SMSA
Altoona SMSA
Lancaster SMSA
Reading SMSA
Scranton SMSA
Wilkes-Barre SMSA
York SMSA
Williamsport (Lycoming)
Hazleton (Luzerne)
Honesdale (Wayne)
Wellsboro (Tioga)
Monongahela (Washington)
Jeannette Area
(Westmoreland)
1000
528

112
36
40
150
22.5
45
40
90
68
39
9.5
5.85
4.2
4.0
1.8

36.0
New Storm Sewers Storage and Treatment
Total Storm To Carry *Elig. Cost Facilities
Runoff for **Elig, Cost
MGD MGD Billion $ MGD Billion $
249,000
98,000

25,600
7,460
7,450
34,200
4,660
10,210
9,120
18,650
14,100
8,900
2,000
1,210
870
830
375

7,460
24,900
9,800

2,560
746
745
3,420
466
1,021
912
1,865
1,410
890
490
500
705
250
210

1,720
SUB-TOTAL
0.210
0.112

0.024
0.008
0.008
0.032
0.005
0.010
0.009
0.019
0.014
0.008
0.0049
0.0051
0.0072
0.0025
0.0021

0.0175
0.499
24,900
9,800

2,560
746
745
3,420
466
1,021
912
1,865
1,410
890
200
121
87
83
38

746

1.610
0.640

0.166
0.048
0.048
0.222
0.030
0.066
0.059
0.121
0.092
0.058
0.013
0.0078
0.0057
0.0053
0.0025

0.0485
3.244
              TOTAL ESTIMATED ELIGIBLE NEEDS FOR CATEGORY VI - $3,743,000,000
 * Average size of new storm sewer 24" dia.  costing $40 per lineal foot

** Storage cost estimated @5c per gallon^   Per EPA publication, "Urban Stormwater
   Treatment cost estimated @1.5c/gallon  £    Management and Technology: An Assessmer,
                                         J   of May 1974
                                 D-126

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\&tf /    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                             WASHINGTON, D.C.  20460
                                                    Z 6  JAM 1977
 Mr.  Brij  M.  Garg,  Chief
 Facilities Section
 Division  of Hater  Supply  arid  Sewerage
 Bureau of Water Quality Management
 Pennsylvania Department of Environmental
    Resources
 Post Office Box 2063
 Harrisburg, Pennsylvania    17120
                                           RE:   Draft Report on 1976 Needs
                                                Survey  for Combined Sewer
                                                Overflows and Stormwater
 Dear Mr.  Garg:
      Thank you for your letters  of December  3,  1976 and January 3, 1977,
 offering comments on our draft report which  estimated^needs for combined
 sewer overflows and stormwater control  (Categories V  & VI).

      In regard to your first general  observation, several methodology
 changes have been made for the final  report.  These changes include:
 (1) increasing the design storm for combined sewer control to the 90th
 percentile storm for the aesthetics and fish and wildlife criteria and
 the 98th percentile storm for the recreation criteria, (2) several
 changes to the cost functions, and (3)  a keypunch error correction in the
 stream classification for Philadelphia from  11  to 12.

      These changes increase the  needs results for the-State of Pennsylvania
 to $820,505,000 (4.516 percent)  for Category V  and $3,097,523,000 (5.874
 percent) for Category VI.  Although these needs are lower than those reported
 in 1974, it is our opinion that they provide a  consistent basis of comparison
 for relative needs among the states.   Upon completion of ongoing 208 studies
 and other storm water studies, a more specific  data base will be available
 for estimation of needs in the future.

      The design storm utilized in the needs  assessment, as mentioned above,
 was the 80th percentile storm for Category VI and the 90th or 98th percentile
 storm for Category V.  This is a smaller storm  than was utilized by most
 states in the 1974 needs assessment and is a significant reason for the
 reduced total national needs estimate.   Our  opinion is that this conservative
 approach will provide the most cost effective blend of pollutant capture
 for all storm sizes while it is likely to meet  the wet weather water quality
 criteria identified.
                                  D-127

-------
     In regard to your general  comment on communications between EPA and
the states relating to the  Categories  V & VI,  we have utilized every
possible method of developing  state  input within the time and budget
constraints placed on the project.   An early draft report was submitted
for your comments on the methodology and the resulting cost estimates.
The report was explained in detail at  a meeting  in Philadelphia on
November 17, 1976.  We regret  that more time was not available for your
review and comment.

     In regard to your specific comments on  solids criteria for water
supplies, the material listed  in the draft report was summarized from
"Quality Criteria for Water" published by EPA  in July, 1976.   There appear
to be some discrepancies between this  document and the EPA interim primary
drinking water standards.   These discrepancies will  be clarified in the
final report.

     References 6 and 10 are published and are available from the U.S.   -
Department of Commerce, National  Technical Information Service, Spring-
field, Virginia 22161.  References 7 and 8 are draft reports  to the EPA
Research and Development Group  and will  be available within several
months.  Your name can be placed on  the mailing  list for these Vatter two
references by contacting Mr. Richard Field,  Chief Storm & Combined Sewer
Overflow Branch, U.S. Environmental  Protection Agency, Edison, New Jersey
08817 (Telephone 201-548-3347).

     Information such as specific design storms, runoff coefficients ,and
other intermediate results  from the  computer documentation was not
included in the draft report to keep it as concise as possible.  These
numbers are available and can  be provided upon specific request.

     The final report, including all comments  received from the states,
will be forwarded to you in early February,  1977.

     I hope that this has answered your questions.   If I can  be of any
further assistance, please  let  me know.

                                 Sincerely  yours,    ,  ,

                                         "  '    >^< '*" •  <* *
                                  James  A.  Chamblee,  Chief
                                  Needs  Assessment  Section
                                          (WH-547)
cc: Ken Pantuck,  USEPA Region  III
    Needs Survey  Coordinator
                                 D-128

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 - _*'<*
A
?JS£-\
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             WASHINGTON, D.C. 20460
     Mr. T. May,
     Chester-Betz Engineers
     One Plymouth Meeting Mall
     Suite 413
     Plymouth Meeting, Pennsylvania   19462
                                           RE:  Draft Report on 1976 Ueeds
                                                Survey for Copbined Scv;ar
                                                Overflows and Ston:iwater
     Dear Mr. Hay:
          Thank you for your letter of November  29, 1975, offering comments
     on our draft report which estimated needs for combined sewer overflows
     and stormwater control  (Categories V S. VI).

          As you know well,  the approach of the  1975 >!eeds Survey was to
     provide a reasonable and consistent needs estimate for these tv,-o categories
     based on the minimal amount of information  available.  The on-noinn 208
     Studies and other studies, such as the COWAMP/208 work, will provide
     more specific data for estimation of needs,  in the future.

          The final report,  including all coiiwents received, will ba forwarded
     to the states in early February 1977.

          If I can be of further assistance,  please let :ne know.

                                      Sincerely  yours,
                                        If,
                                            A. Char-blee, Chief
                                         ds  Assf»ssniont Section
                                              (WH-547)
     cc: Ken Pantuck, 'JStPA Renion III
         Needs Survey Coordinator
                                     D-129

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                                                                       BOARD MEMBERS

                                                                 Lachlan L  Hyatt. Chairman
                                                            William M. Wilson. Vice-Chairman
                                                             I DeOumcey Newman, Secretary
                                                                       W. A. Barnette, Jr.
                                                                 Leonard W. Douglas, M.D.
                                                                  J Lorin Mason, Jr., M.D.
                                                               William C.  Moore, Jr., D.M.D.
SOUTH CAROLINA DEPARTMENT OF HEALTH  AND ENVIRONMENTAL  CONTROL
 November 9,  1976
E. KENNETH AYCOCK, M.D., M.P.H., COMMISSIONER
   J. MARION SIMS BUILDING — 2600 BULL STREET
         COLUMBIA, SOUTH CAROLINA  29201
 Mr. John T.  Rhett
 Deputy Assistant Administrator  for
   Water Programs Operations  (WH-546)
 U.S. Environmental Protection Agency
 401 M Street,  S.W.
 Washington,  B.C.  20460

                                              Re:   Draft  Report on 1976 Needs
                                                   Survey for Combined Sewer
                                                   Overflows and Stormwater

 Dear Mr. Rhett:

          The South Carolina  Department  of  Health  and  Environmental Control is
 in receipt of  your letter  of October  22,  1976,  concerning the draft report on
 the 1976 Survey  of Needs for Control  of Pollution From Combined Sewer Overflows
 and Stormwater Discharges.   The staff of  this Department has reviewed the
 draft report,  and it's proposed methodology,  and  offers  the following comments
 for your review.

          1.   Section 2.1 of  the text  indicates  that the  Stormwater pollutants
 selected for control and to  be  utilized as a  measure,  include suspended solids,
 dissolved oxygen and fecal coliform.  This Department  does not agree that control
 of these few pollutant constituents will be sufficient to achieve the desired
 water quality  goals  in the State of South  Carolina.   If  feasible, therefore,
 we suggest that  pollutants selected for control include,  in addition to those
 identified in  the report,  BOD,  total-P, TKN,  N02  and  pH.   We feel that the
 addition of  these control  factors would help  identify  potential nutrient and
 organic loading  problems in  receiving streams,  thus making the survey a more
 accurate reflection  of the needs of this  State  and of  the Nation.

          2.  We  suggest that alternative disinfection techniques to chlorination
 should  be considered  (i.e.,  ozone, bromine chloride,  dechlorination, etc.) due
 to the  adverse effects of residual chlorine upon  the  aquatic ecosystem.

          3.  Section  4.11 of the draft  report indicates  that the treatment
 of Stormwater  and/or  combined sewer discharges  will not  be required if the DO
 level in  the receiving stream is 5.0  mg/1  or  greater.  We do not feel that this
 statement  is accurate.  Rather,  we suggest that the teatment of stormwaters
 should  not be  discounted unless water quality impact  analysis (modelling) indicates
 that  the  resultant pollutant loading  will  not be  sufficient to depress instream DO
 below acceptable  levels.
                                     D-130

-------
Letter to Mr. Rhett:
Category VI Needs Report
November 9, 1976
Page 2


         4.  The NEMUR General Composition Schematic (Figure 7.1) is not clear
in its present format.  The utilization of flow directors and/or other clarifying
remarks would facilitate model review.

         5.  The methodology utilized for determining a State's Category VI
needs is too restrictive.  For example, in South Carolina, the technique of
basing stormwater runoff needs upon urban areas of 50,000 plus population will
totally discount such critical (or potential) problems areas as the Myrtle Beach
(Grand Strand) area, already involved in an Environmental Impact Statement and
the Beaufort area (a potential problem area).  We would suggest that EPA require
the contractor to contact each State to determine if there are any such problem
areas of less than 50,000 population, that should be surveyed.  This procedure
would probably lead to a more accurate survey and report on Category VI needs.

         This Department would like to express our appreciation to the Environmental
Protection Agency for the opportunity to review and comment on the draft report.
A representative of this Department will attend the meeting with EPA and the
contractors in Atlanta, on November 15, 1976, to further voice and discuss our
comments and suggestions on the draft report.

                                             Very truly yours,
                                                    r       c'
                                             James G: Zack, Jr.
                                             Manager, Budgets and Grants
                                             Administration Section
cc:  Mr. James Chamblee, Chief
     Needs Assessment Section
     Facility Requirements Branch (WH-547)
     U.S. Environmental Protection Agency
     401 M Street, S.W.
     Washington, D.C.  20460

     Mr. James Dutzman, Director
     Needs Survey
     U.S. Environmental Protection Agency
     345 Courtland Street, N.E.
     Atlanta, Georgia  30308
                                    D-131

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C  20460
                                                  16  NOV 1976

Mr. James G.  Zack,  Jr.,  Manager
Budgets and Grants  Administration  Section
Environmental Quality Control
South Carolina Department of Health  and
 Environmental Control
2600 Bull Street
Columbia, SC  29201

Dear Mr. Zack:

     Thank you for your comments on  our  draft report on needs  for combined
sewer overflow and stormwater control  (Categories  V  and VI).

     Your comments are being studied carefully and will be taken into con-,
sideration in our final  report to the  Congress.

     We are sorry that we cannot yet comment on the  issues your letter raised.
These are under study, along with comments from other states  and territories.

     As soon as possible, a complete explanation of  our final  cost estimates
will be forwarded.

                                  Sincerely,
                                  James A.  Chamblee, Chief
                                  Needs Assessment Section
                                           (WH-547)
                                  D-132

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                   BLACK,  CROW & EIDSNESS, INC.
                           CONSULTING ENGINEERS
                                                                  GAINESVILLE. FLORIDA 32602
                                                                  POST OFFICE BOX 1647
                  PRINCIPAL Off ICE: 7201 N. W. ELEVENTH PLACE, GAINESVILLE, FLORIDA         7201 N.W. ELEVENTH PLACE

                    HESIOHAL Office* ATLANTA. GEORGIA / CLEARWATER, FLORIDA          SIS'iSSlESS: BCEGNVFLA

                  BIRMINGHAM. ALABAMA / BOCA RATON, FLORIDA / NAPLES, FLORIDA

               SAN JOSE, COSTA RICA / PHILADELPHIA. PENNSYLVANIA / MONTGOMERY, ALABAMA
                                          November 29, 1976
Mr. James  G.  lack, Jr.
South Carolina Department  of
Health and Environemntal Control
2600 Bull  Street
Columbia,  South Carolina   29201

     Re:   1976 Survey of Needs  for
           Control of Pollution  from
           Combined Sewer Overflow and
           Stormwater Discharge
           Project No. 573-7600-4

Dear Mr. Zack:

     On Monday, November 15,  1976, you attended  a  meeting at EPA  Regional
Offices in Atlanta concerning review of the draft  Categories V and  VI,
1976 Needs Survey.  At that time you expressed an  interest in receiving
a copy of  the notes prepared  for the site study  portion of our presen-
tation.  Enclosed for your information is one copy of the above notes.

     If you have any further  questions, or need  additional information
regarding  the site studies or design storm criteria, please let me  know.

                                          Very truly yours,

                                          BLACK, CROW AND EIDSNESS,  INC.
                                          Ronald  L.  Wycoff, P.E

RLW/mfl

Enclosure

xc:  Mr. R.  D.  G.  Pyne
     Mr. Philip Graham
                               D.133

-------
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
t ^^^PfM^V* ^
 \ipR0^                      WASHINGTON.  D.C. 20460
    Mr.  Janes G.  Zack,  Jr.
    Manager,  Budget and Grants
     Administration Section
    South Carolina Department of
     Health and Environmental Control
    J. Marion Sims Building
    260  Bull Street
    Columbia, South Carolina  29201
                                       RE:   Draft Report on 1976 Needs
                                            Survey for Combined Sewer
                                            Overflows and Stormwater Control
    Dear Mr. Zack:
         Thank you for your letter of November 9,  1976,  offering comments on
    our draft report which estimated needs for combined  sewer overflows and
    Stormwater control (Categories V and VI).

         In regard to your specific comment on inclusion of other pollutants
    in the determination of control levels, we would agree that in specific
    cases other pollutants such as toxic materials and nutrients may control
    the treatment level required to meet receiving streams standards.  How-
    ever, pollutant generation methodologies were  not available on a nationwide
    basis such that inclusion of the required  control for these pollutants
    could be accomplished within the time  and  budget restraints of the
    project. As more specific information  is developed through the 208
    planning program and other sources,  a  more detailed  methodology for the
    Category VI needs estimation methodology can be developed for future
    needs surveys.

         The draft report does not recommend a nationwide program of chlori-
    nation, but merely uses published cost estimated equations for choirination
    to develop a cost estimate for disinfection.  Where  receiving water
    conditions dictate, alternative disinfection techniques to chlorination
    should be considered for each individual case.

         The water quality impact analysis conducted in  the needs survey for
    the ten specific site studies was utilized to  indicate where combined
                                   D-134

-------
sewer and stormwater pollutant loading would be sufficient to depress
instream D.O. levels below the identified wet weather criteria.  The
D.O. level of 5.0 mg/1 was identified as an acceptable wet weather water
quality level for this nationwide study.  In areas where receiving water
standards are higher than this level, the resulting treatment levels for
stormwater nay be in excess of those evaluated in the draft report.

     The NEMUR general computational schematic (Figure 7.1) is only a
simplified presentation of the "building blocks" for the computation
inodel.  The exact conputational steps are described in Sections 7.5
through 7.11.

     Your specific comment requesting inclusion of non-urbanized areas
for stormwater control needs was voiced by several states.  Regulations
for the application of the NEDES program to separate storm sewers were
published in the Federal Register of March 18, 1976.  This document and
the permit program it established were utilized to determine the areas
requiring needs in Category VI.

     In the regulations, the term "separate storm sewer" is defined as
"A conveyance or system of conveyances...located in.an urbanized area
and primarily operated for the purpose of collecting and conveying
stormwater runoff".  The permit issuing authority may designate other
storm sewers as being significant contributors of pollutants and, thus,
subject to these regulations.  In the absence of specific designations,
stormwater needs are estimated for Census-defined urbanized areas only.

     The final report, including all comments received from the states,
will be forwarded to you in early February 1977.

     I hope that this has answered your questions, and if I can be of
any further assistance, please let me know.

                                   Sincerely yours,
                             (_^X James A. Chamblee, Chief
                                   Needs Assessment Section
                                            (WH-547)
cc:  Jim Kutzman, USEPA Region 3V
     Needs Survey Coordinator
                                D-135

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     RAY BLANTON
       GOVERNOR
Eugene W. Fowinkle, M.D., M.P.H.
       Commissioner
       STATE OF TENNESSEE
DEPARTMENT OF PUBLIC HEALTH
        NASHVILLE 3721 9


  621 Cordell Hull Building
       November 30,1976
       Mr. James Chamblee
       Chief, Needs Assessment Section
       Facility Requirements Branch (WH-547)
       401 Main Street, S.W.
       Washington, D.C.

       Re:  Category V and VI
            1976 Needs Survey

       Dear Mr. Chamblee:

       This is written in reply to Mr. Rhett's letter to Mr. Church dated October 22,1976.

       In general the  Category V and VI Study for 1976 appears well done and is in a form
       that will be useful in future stormwater  treatment studies.  I agree that methods
       for  computing treatment requirements should be standardized.   The referenced
       study can be the basis for this standardization and formulates data in a  manner that
       is readily understood.

       I would  differ  with the study on one or two aspects.  In the "Survey of Needs for
       Treatment and/or Control of Stormwaters in Tennessee" prepared for Tennessee in
       1974 by  Consoer, Townsend and Associates, interceptor lines, storage facilities and
       treatment facilities were plotted on maps.  I believe this gave a more accurate, yet
       not too  complicated, method for figuring lengths of interceptors than the empirical
       approach proposed in the present study on page 7-27.

       The present study includes only 6 urban areas in Tennessee. The Consoer-Townsend
       Study selected 78 urban areas all  of which were located on water quality limited
       stream segments.

       I agree generally with the differences in the 1974 study and the 1976 study as stated
       on page 9-5, but do  not agree that the definition of urbanized areas should  have
       been as restrictive  as  it was in the  current study,  resulting in  Tennessee's
       statement of needs being cut from  4.207 billion to 0.467 billion. As a minimum, the
       study should include urban areas having a population of 10,000 or more.  Otherwise
       states  with few or  no  urban centers  having 50,000 population or  greater are
       severely penalized and their needs  are not fairly represented.
                                          D-136

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November 30,1976
Mr. James Chamblee
Page 2
Thank you for the opportunity to comment on the study. In preparing for the 1978
Needs Survey, I offer the following suggestions:

     lr     Begin preparation  now and  get  information  to the States well in
            advance of the Survey.

     2.     Return control of the Survey to the States, with appropriate guidelines
            to insure uniform data collection.

     3.     Allow  the   States  to comment on  proposed  guidelines,  boundary
            conditions, assumptions and preliminary data  well in advance of the
            Survey, commencing in early calendar year 1977.

Sincerely,
                 ..--"•>
 ..'i
Quentin C. LaPrad, P.E.
State Director
1976 Needs Survey

QCL/slh 2-3

cc:   Mr. J. L. Church, Jr.
      Mr. Jim Kutzman
      Mr. Ellis Cokes
                                     D-137

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      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C.  20460
Mr. Quetin C. Laprad, P.E.
State Director, 1976 Needs  Survey
Tennessee Department of Public Health
621 Cordell Hull Building
Nashville, Tennessee   37219
                                                  Draft Report on T>76  Nf»eds
                                                  Survey for Combined Sewer
                                                  Overflows  and Stormwatcr
Dear Mr. LaPrad:
     Thank you for your letter of November 30,  197S,  offering consents  on
our draft report which estimated needs for combined sewer overflow and
stormwater control (Categories V & VI).

     Your proposed alternate methodology for defining interceptor lines,
storage facilities, and treatment facilities by plotting these locations
on maps was beyond the time and budget constraints  allowable on the 1976
Heeds Survey for these categories.  Upon completion of the ongoing 208
studies and other storm water evaluations, a more detailed data base may
be available for use in the future.

     Your comments requesting inclusion of non-urbanized areas for storm
water control needs was voiced by several states, although not all discussed
the specific population floor of 10,000 or noro. Regulations for the appli-
cation of the NPDES program to separate storm sewer w&re published in the
Federal Register of March 18, 1S76.  This document  was utilized to determine
the areas requiring needs in Category VI.

     In the regulations the tern "separate storm sewer  is defined as 'A
conveyance or system of conveyances....located  in a urbanized area and
primarily operated for the purpose of collecting and conveying storwater
runoff."  The permit issuing authority nay designate other storrri ssv/ers as
being significant contributors of pollution and thus subject to these re-
gulations.  In the absence of specific designations, stonnwater needs ara
estimated for Census-designated urbanized areas only.

      Your suggestions for the conduct of the 1978  Needs Survey are
appreciated and will be considered in developing the guidance for that
survey.
                             D-138

-------
     The final report, including all comments received from the states,
will be forwarded to you in early February, 1977.

     I hope that tin's has answered your questions.  If I can be of any
further assistance, please let mo know.
                                   Sincerely yours,
                                   lames A. Chamblce, Chief
                                   Needs Assessment Section
                                           (WH-547)
cc: James Kutzman, USEPA Region IV
    Needs Survey Coordinator
                                 D-139

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LVMAN
    Di
J. OLSEN, M.D..M.P.H.
rector of Health
                STATE OF UTAH-DEPARTMENT OF SOCIAL SERVICES
 DIVISION OF HEALTH
    44 MEDICAL DRIVE
SALT LAKE CITY, UTAH 84113
     AREA CODE 801
      533-6146
  November 29, 1976
                                                                         CALVIN L.
                                                                             Governor

                                                                           PAUL S. ROSE
                                                                           Executive Director
                                                                             Board of Health
                                                                             Air Conservation Committee
                                                                             Health Facilities Council
                                                                             Medical Examiner Committee
                                                                             Nursing Home Advisory Council
                                                                             Water Pollution Committee
Environmental Health Services Branch
      72 East 4th South
     Salt Lake City, Utah
      Mr. James Chamblee
      Chief, Needs Assessment Section
      Facility Requirements  Branch  (WH-547)
      401 Main Street,  S.W.
      Washington, D.C.  20460
      Dear Mr. Chamblee:

           We have completed  our review of the draft report entitled "1976 Survey
      of Needs for Control  of Pollution from Combined Sewer Overflows and Stormwater
      Discharges" and would like to offer the following comments  regarding the contents
      of this report.

           Although  it  appears that the methodology described  in  the report will provide
      a uniform and  consistent means of calculating the national  needs for Categories
      V and VI, we feel  there are shortcomings in the methodology which ignore certain
      State requirements.   For instance, the criteria used for calculating the needs
      for Category VI,  Treatment and/or Control of Stormwater  are based on uniform
      water quality  criteria  and the assimilative capacity of  the receiving water rather
      than individual States'  water quality standards.  The water quality criteria used
      are generally  less  stringent than Utah water quality standards; therefore, the
      costs to meet  Utah  standards would be somewhat greater than those costs shown
      in the report.  Dissolved oxygen (D.O.) in lieu of BOD5  is  used extensively to
      define water quality  in the report and the minimum of 4.0 and 5.0 mg/1 as
      discussed is lower  than the minimum p.O. acceptable limit of 5.5 mg/1 established
      by the State of Utah  for Class "C" waters.

           In Appendix  B, the stream classifications for Ogden, Provo, and Salt Lake City
      are designated as  2,  8  and 2 respectively.  It is unclear as to how these
      designations were  determined, but it appears that they should be more consistent
      inasmuch as they  all  have the same State water quality classification.  We
      would like to  know  how  the Appendix B classifications were  arrived at.

           If you have  any  questions, please feel free to call  on us.

                                             Very truly yours,

                                             UTAH WATER POLLUTION  COMMITTEE
                                             Calvin K.7 Sudweeks
                                             Executive Secretary
      FCP:mc
                                            D-140

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Jffij
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                 WASHINGTON, D.C.  20460
   "•r.  Calvin K.  Sudweaks
   Executive Secretary
   Utah Udtar Pollution Ccnnn'ttoo
   44 iiodlcal ;;rive
   Salt Lake City,  Utah ii^m
                                              RE:   Draft keport  on  1976  Heeds
                                                   .Survey for  Combined Sewer
                                                   Overflows and Stormwater
        Mr.  Sudwesks:
        Thank you for your letter of novsmcer 29,  1976,  offering  comments on
   our draft report which estimated needs  for combined  sewer overflows and
   stoniwater control (Catonories V £ VI).

        In regard to your consent on water quality standards,  time and budget
   constraints required th« use of uniform water quality criteria.   The
   needs were analyzed to taeet a receiving water dissolved  oxygen concentration
   of ;5.U ing/1, which was utilized to define the required level of treatment.
   However, treatment of the Stormwater runoff to  meet  D.O.  standards was
   seldom required in areas without combined sewer overflows,  due to low
   concentrations of SOD in the separate storm-water discharges.

        The stream classifications shown in Appendix D of the  Draft  Report
   were determined by review of USGS naginq station information and  review of
   USGS topographic isiaps.  Og-Jen, Prove and Salt Lake City  were designated as
   2, 3 and 2, respectively.  Provo was designated as 8, or lake, because it
   was determined that a significant portion of the urban runoff  from the
   Provo urbanized area discharged directly to Utah Lake, while the  discharges
   from Ogden and Salt Lake City are to individual  stream systems.

        The final report, including all comments received from the states,
   will be forwarded to you in early February, 1977.

        If I can be of any further assistance, please let me know.

                                        Sincerely yours,
                                         James  A.  Chanblee,  Chief
                                         Needs  Assessment Section
                                                 (WH-547)
   cc:  William Hormberg,  USEPA  Region  VIII
       Needs  Survey Coordinator
                                     D-141

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            State of Vermovt!
Department of Fish and Game
Department of Forest, Parks, and Recreation
Department of Water Resources
Environmental Board
Division of Environmental Engineering
Division of Environmental Protection
Natural Resources CoTservation Council
   AGENCY OF ENVIRONMENTAL CONSERVATION


                        Montpelier, Vermont 05602
               Division of Environmental Engineering



December 1, 1976
          Mr. James Chamblee
          Chief, Needs Assessment Section
          Facility Requirements Branch  (WH-547)
          401 M. St., S.W.
          Washington, D.C.  20460
                                             Re:
     Category V and  VI  Needs
     State of Vermont
          Dear Mr. Chamblee:
               This office has reviewed  the  draft report on needs in Category
          V (combined sewer overflows) and Category VI (storm sewers) prepared
          by Jordan, Jones and Goulding,  Inc.  and Black, Crow and Eidsness,  Inc.

               In conjunction with  this  review,  members of our staff recently
          attended the meeting held in Boston  concerning the above.  Of major
          concern to this Agency was  the  methodology and base data utilized  in
          computing the needs in Category V  and  VI for the State of Vermont.

               Category V;  The total needs  in this category are based on  an
          APWA survey which was intended  to  generate a realistic estimate  of  the
          total number of acres of  combined  sewers within Vermont.  It is  our
          profound belief that response  to this  survey was inadequate to formulate
          an accurate assessment of the  total  acreage invo-lved.  The needs for the
          State of Vermont were based on  7,900 acres of combined sewers.   Members
          of our staff utilizing infiltration/inflow analysis reports (which
          clearly define the limits of combined  systems) have re-evaluated this
          figure and submit that the  following is more representative of the  actual
          conditions that prevail:
                                 Rutland
                                 Newport
                                 St. Johnsbury
                                 Barton
                                 Bennington
                                 Springfield
                                 Lyndon
                                 Montpelier
                                 Windsor
                                 Bellows  Falls
                                 Burlington
         4,300  acres
           948  acres
         4,775  acres
            72  acres
            40  acres
           575  acres
           231  acres
         1,900  acres
           212  acres
           400  acres
         2,525  acres
                                       D-142

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Mr. James Chamblee
Page 2
December 1, 1976
     The above yields a total acreage in the magnitude of 15,978 acres
not 7,900 acres.  Therefore, utilizing the dollars per acre cost for
New Hampshire, the Category V needs for the State of Vermont are $69.19
million.  We wish also to note that our 15,978 figure is low as we did
not assess acreage in towns where maps weren't immediately available.

     Category VI;  The needs in this category were based on "Census de-
fined urbanized areas".   Due to the lack of urbanized areas, the State
needs in the category have been calculated as being zero.   We submit
that, to use this criteria for a State such as Vermont, is totally in-
accurate.  The Water Quality needs do not disappear when an urbanized
area does not exist.  It is the State's opinion that there are several
large communities where storm water discharges can degrade water quality
and, under present laws, corrective action will have to be accompli shed -
under this category at some future time.  The following is a list of the
communities with their respective (low side) control costs.
Community
Burlington
St. Johnsbury
Newport City
Rutland City
Bennington
St. Albans
Windsor
Springfield
Hartford
Brattleboro
Winooski
Colchester F.D.#1
Shelburne F.D.#1&2
So. Burlington
  (Bartletts Bay)
Feet of Connecting
Storm Sewer  @
$70.00/1.f.

  31,680
  15,840
  15,840
  23,760
  21,120
  21,120
  13,200
  13,200
  21,120
  10,560
  10,560
  26,400
  21,120

  10,560
Sedimentation      Total
   basins(s)        Costs
4 @ 350,000
2 @ 350,000
1 plus pump sta.
4 @ 350,000
3 @ 350,000
2 @ 350,000
1 @ 350,000
1 plus pump sta.
2 @ 350,000
2 @ 350,000
1 @ 350,000
1 @ 200,000
1 (<> 200,000
1 @ 350,000
3,617,600.
1,808,800.
1,608,800.
3,063,200.
2,528,400.
2,178,400.
1,274,000.
1,424,000.
2,178,400.
1,439,200.
1,089,200.
2,048,000.
1,678,400.
1,089,200.
                                                TOTAL
                                          27,025,600.
     These figures are generated based on a map determination of inter-
ceptor footage required and a determination of the number of treatment
facilities necessary to reasonably treat the discharges.

     In conclusion, we wish to submit the previous estimates of needs in
Category V and VI as being clearly more representative of the actual  needs
for the State of Vermont.  We expect these figures to be reported to
Congress.
                            D-143

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Mr. James Chamblee
Page 3
December 1, 1976
     Should you have any questions,  please contact this office at
828-3345 (802).

                                  Sincerely,
                                  Reginald A.  LaRosa,  Director
                                  Environmental  Engineering Division
RAL/lg
cc:   Alfred Pelequin,  N.E.  Interstate Water  Pollution  Control  Commission
     Secretary Martin  Johnson
                       D-144

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    \
     |    UNITED STATES ENVIRONMENTAL  PROTECTION AGENCY
                          WASHINGTON, D.C.  20460
                                                       JAN  W7
Mr. Reginald A. LaRosa, Director
Environmental Engineering Division
Agency of Environmental Conservation
Montpelier, Vermont   05602
                                           RE:   Draft Report  on  1976  Needs
                                                Survey for Combined Sewer
                                                Overflows  and Stormwater
Dear Mr. LaRosa:
     Thank you for your letter of December 1,  1976,  offering  comments on
our draft report which estimated needs for combined  sewer  overflows and
Stormwater control (Categories V & VI).

     In response to your specific comment on Category V, the  combined
sewered acreage for the State of Vermont was changed from  the 7,900
acres, reported in the draft report, to  the 15,978 listed  in  your  letter.
Utilizing the dollars per acre cost for  urbanized  area control  in  the
State of New Hampshire, and considering  the changes  from the  draft to the
final report, the Vermont final  Category needs are $161.722 million.

     Your specific comment on Category VI  requesting inclusion of non-
urbanized areas for storm water control  needs  was  voiced by several
states.  Regulations for the application of the NPDES program to separate
storm sewers were published in a Federal Register  of March 18,  1976.
This document and the permit program it  established  were utilized  to
determine the areas requiring needs in Category VI.   The term "Separate
storm sewers" is defined as "a conveyance or system  of conveyances	
located in an urbanized area and primarily operated  for the purpose of
collecting and conveying storm water runoff."   The permit  issuing
authority may designate other storm sewers as  being  significant contri-
butors of pollution and thus subject to  these  regulations.  In  the
absence of such designations, only urbanized areas can be  included.
                                 D-145

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     The final  report, including all  comments received from the states,
will be forwarded to you in early February, 1977.

     I hope this has answered your questions.  If  I  can be of any
further assistance, please let me know.
                                    Sincerely your
                                     ames  A.  Chamblee,  Chief
                                    Needs  Assessment  Section
                                            (WH-547)
 cc:  Charles Pease, Region I
                                 D-146

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            State of Vermont
                                                AGENCY OF ENVIRONMENTAL CONSERVATK
Department of Fish and Game
Department of Forest, Parks, and Recreation
Department of Water Resources
Envnonmental Board
Division of Environmental Engineering
Division of Environmental Protection
Natural Resources Conservation Council
        Monlpelier, Vermont 056<
Division of Environmental Engineer!


       January 3, 1977
   Mr.  James A. Chamblee, Chief
   Needs Assessment Section
   U.S. Environmental Protection  Agency (WH-547)
   401 M St. S.W.
   Washington, D.C.  20460
                                           Re:   1976 Needs Survey
                                                Category V and VI
                                                State of-Vermont
   Dear Mr. Chamblee:
        This office has reviewed your recent transmittal dated December  16,  1976
   of the Final EPA Estimates  for the 1976 Needs Survey for Categories V and VI
   and is in agreement with  the  revised figure of 161.722 million as presented for
   Category V.

        With respect to Category VI,  we wish to reference the information for-
   warded in our letter of December 1,  1976 (copy of same enclosed) .  Although
   there are no "census-defined  urbanized areas" within the State of Vermont, we
   feel that a real need  still exists requiring corrective measures be undertaken
   at some future time to prevent further degradation of the water quality of
   those bodies of water  adjacent to our larger -communities.  The State  of Vermont
   does not accept a zero need for Category VI as projected by EPA and respect-
   fully requests that a  figure  of $27,025,600 be reported to Congress for this
   category as a separate State  estimate.

        Should you require any further information on this matter, please contact
   this office at (802)828-3345.
                                           Sincerely.
                                                                              L-
                                           Reginald A. LaRosd/ P.S.,  Director
                                           Environmental Engineering Division
   RAL/DB/cc
   Enclosure
   cc:  Alfred Peloquin,  N.E.  Interstate Water Pollution  Control Commission
        Charles Bishop, Environmental Protection Agency,  Region I (w/enclosures)
                                      D-147

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                                                            r,  JAN in/7
    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     WASHINGTON, D.C. 20460
Mr. Reginal A. LaRosa, Director
Environmental Engineering Division
Agency of Environmental Conservation
Montpelier, Vermont  05602

RE:  1976 Needs Survey for Combined Sewer
     Overflows and Stormwater

Dear Mr. LaRosa:

     Thank you for your letter of January 3, 1977, which transmits your
estimate of $27,025,600 for Category VI and which concurs with the EPA
cost estimate for Category V.  We will include your estimate* as well as
the EPA cost estimates in our final report.

     The final report, including all comments received from the States,
will be forwarded to you in early February 1977.

     If I can be of further assistance, please let me know.

                                   Sincerely yours,
                                    I
                                    f.
                                   james A. Chamblee, Chief
                                   Needs Assessment Section
                                          (WH-547)
cc:  Charles Pease, USEPA Region I
     Needs Survey Coordinator
                            D-148

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    R. V. Davis
  Executive Secretary

 Post Office Box 11143
Richmond, Virginia 23230
   (804)786-1411
                                 STATE WATER CONTROL U04RD
                                       2111 Hamilton Street
November  23,  1976
BOARD MEMBERS
Col. J. Leo Bourassa
   Chairman
 Warren L. Braun
  Vice-Chairman
George M. Cornell
Roy B. Martin, Jr.
Millard B. Rice, Jr.
Kenneth B. Rollins
 R. Alton Wright
          Mr. Wen Huang
          Sanitary Engineer
          Facility Requirements Branch
          Environmental  Protection Agency
          Waterside Mall Building
          4th § M Streets,  S.W.
          Washington,  DC  20460

          Dear Wen:

          I was glad to  see you again in Philadelphia on November  17,  1976.
          I thought it was  a useful meeting.

          The tables contained in the copy  of your November 3,  1976 memorandum
          "Review of Draft  Report	by J  J  § G,  Inc. and B C  § E,  Inc." which
          was furnished  me  were truncated in  copying.  I would  appreciate having
          full copies  of these important tables.

          I've seen various references to the EPA sewerage cost index,  eg., on
          page 3-3 of  the above-cited report  and  in your memorandum.   Is there a
          tabulation of  historical data on  this cost index, and is it  an overall
          national average  or do separate regional indices also exist?   I would
          appreciate any quantitative information you can supply,  for  if such
          exists in this office, I have not been  able to find it.

                                               Yours truly,
                                               R.  L.  Hill
                                               Regional Operations  Coordinator
          RLHrzmh
                                         D-149

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                                                  0 N0\
Dr. R.L.  Hill
Regional  Operations Coordinator
Commonwealth of Virginia
State Water Control Soard
2111 Hani!ton Street
P.O. Box 11143
Richmond, Virginia 23230

Dear Dick:

It was nice to see you again in Philadelphia on November 17, 1976.

In response to your letter dated November 23, 1976,  I enclose the
following materials:

    1.  A table (t pages) attached to the memorandum "Review of
Draft Report --- by JJ & G, Inc. and 3C & E, Inc."
    2.  Engineering Hews Record Construction Cost Index Table
    3.  EPA Sewage Treatment Plant Construction Cest Index
    4.  EPA Sewer Construction Cost Index
    5.  City Multipliers for Treatment Plant Construction
    6.  City Multipliers for Sewer Construction

For the 1376 NEED Survey of Categories I through IV, we used EPA
STP and Sewer Construction Cost indices.  The city multipliers were
used for regional consideration.

For the NEED Survey of Categories V and VI, construction cost index for
Engineering itews Record was primarily used.  In order to include the
regional  factors in Categories V and VI, v/a also used the city multipliers
for treatment plant and sewer construction.

If I can be of any further assistance, please do not hesitate to call.

                                      Very truly yours,
                                      Wen H.  Huang, Ph.D, P.E.
                                      Sanitary Engineer
                                      Facility Requirement Branch
                                  D-150

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    R. V. Davis
  Executive Secretary

 Post Office Box 11143
Richmond, Virginia 23230
   (.04,7.6-1411        98
STATE WATER CONTROL BOARD
       2111 Hamilton Street

       3 December 1976
BOARD MEMBERS
Col. J. Leo Bourassa
   Chairman
 Warren L. Braun
  Vice-Chairman
 George M. Cornell
 Roy B. Martin, Jr.
 Millard B. Rice, Jr.
 Kenneth B. Rollins
 R. Alton Wright
             Mr.  James  Chamblee
             Chief,  Needs Assessment Section
             Facility Requirements Branch (WH-547)
             Environmental Protection Agency
             401  M Street, S.W.
             Washington,  D.C.  20460

             Dear Mr. Chamblee:

             We are responding to Mr. Rhett's letter of 22 October  1976  with our
             comments on  the Jordan/Jones/Goulding and Black/Crow/Eidsness  draft
             report "1976 Survey of Needs for Control of Pollution  from  Combined
             Sewer Overflows and Stormwater Discharges" which was prepared  under
             EPA  contract to delineate Category V and VI needs nationwide and by
             individual States.
             We will  make a distinction between the technical  quality  of the report
             and  the  larger issue of how the results are going to  be used.

             We understand that the two consultant firms which authored the report
             had  five to six months to develop it in toto.  We feel that they did
             a reasonable job in the limited time available, in this field  where
             firm detailed knowledge and experience are sparse.  But we seriously
             question the advisability of using the State-by-State dollar figures,
             as set forth in the draft, for the purpose of allocating  Federal con-
             struction grant funds among the States, although  the  national  totals
             may  provide an approximate indication of national needs undifferentiated
             by State.   It seems clear that the methodology described  in the draft
             could not possibly consider individual facility costs, or local/regional
             peculiarities, in the same detail as done by the  localities and their
             consultants, the individual States, Dames & Moore,  and EPA itself for
             Categories I through IVB needs in course of the 1976  Survey.

             The  draft report concedes that the individual-area estimates should be
             viewed with caution but claims that the State totals  are  sufficiently
             reliable to permit an equitable allocation of grant funds among the States.
             The  320  urbanized areas listed in the report represent an average of
             only about six per jurisdiction, which is a rather small  number to rely
             on for "averaging out" of individual-area errors  within a jurisdiction.
             Virginia will have roughly three times 320, rather than 6 or 8, individual
             facility needs to total for Categories I - IVB, which does provide real
             scope for countervailing errors to balance out.
                                              D-151

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Mr. James Chamblee                     - 2 -                  3 December 1976

The fundamental decisions to design for the "80% storm" and  to grant  full
allowance for the assimilative capacity of the receiving waters  appear  to be
quite sound, at least for "average" streams.  Even with these concessions to
economic reality, the aggregate 1990 capital costs for Categories V and VI
needs to meet your Fish and Wildlife or Recreation protection goals run to
$1.06 billion for Virginia and $40 billion for the nation, which we suspect
are roughly half the corresponding Categories I through IVB  needs.  Consider-
ing the backlog for I through IVB, a major funding effort for VI at present
seems out of the question unless you wish to make a major diversion of  avail-
able funds to the detriment of the I through IVB program, which  we would view
as most unwise.

It is noted that the current capital requirements for Category VI are only
about half the 1990 capital requirements.  If VI needs must  be funded soon,
it would appear most reasonable to allocate on the basis of  current, not
1990 needs for this category.

Considering that the major portion of the total cost of stormwater management/
control, whether for combined sewers (Category V) or not (Category VI),  will
lie in collection and transmission facilities, it seems appropriate to  provide
treatment capability at least sufficient to meet your Recreation criteria,
even in "average" waters not characterized by special uses for which a  higher
level of treatment might be desirable.   (It is realized that  EPA may never
fund general stormwater collection and transmission, but our  contention is
independent of who funds the construction work.)  Furthermore, the cost dif-
ferential between Recreation and Fish and Wildlife protection is negligible,
and the disinfection step provided in the former appears to  us to be well
worth its small incremental cost if it can be made effective.  To skimp on
treatment quality will be poor economy.

However, we do not believe that stormwater effluent containing 80 mg suspended
solids per liter can be reliably or effectively disinfected.  This issue is
crucial in swimming areas like Virginia Beach, Buckroe Beach, and Colonial
Beach, and even more crucial in shellfish waters, of which Virginia has
500,000 acres.  If the full benefit of controlling stormwater runoff to
shellfish and swimming waters is to be realized, it will be necessary to re-
duce the average suspended solids load to 30 mg/1 or at worst 40, during all
save peak periods, then to disinfect.

In further reference to shellfish protection,  an additional  defect of the
draft report in our view is the heavy emphasis placed on "urbanized" areas,
which are substantially equivalent to SMSAs, having population greater  than
50,000.  Aside from Hampton Roads area, there are no such major  urban areas
adjacent to shellfish waters in Virginia.   Yet,  of the 500,000 acreas total
of such waters, 100,000 acres of productive non-marginal waters  are condemned.
We have attempted to unambiguously identify the causes of these  condemnations
on an individual basis, but without much success.  We do know that we have
made substantial progress in controlling animal wastes and municipal/indus-
trial point sources, as attested by rescission of prior condemnations on some
80,000 acres.   It is becoming increasingly evident that, even with all  point
sources controlled,  a task by no means yet completed, sizeable acreages will
remain condemned in waters abutting populated areas including small towns
having a population far below 50,000.   The condemned Lynnhaven Bay oyster
ground on Virginia Beach's north shore, although not exemplary of the smaller-
town non-urbanized category,  is a prime example of the need to control  non-
point sources  including stormwater for shellfish protection.  We believe that
the same control need exists in most of the towns adjacent to shellfish waters.
                                  D-152

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Mr. James Chamblee                     - 3 -            3 December 1976
EPA has already devoted considerable effort to shellfish protection; witness
your Technical Bulletins 430-99-74-001 and 430/9-74-010 to name but two.
Consistency demands that stormwater facilities discharging into shellfish
waters be of a character akin to Reliability Class I.  While we are unable
to cite a rule-of-thumb for the incremental cost which such reliability
entails, we believe it will be significant.  Yet the draft report makes no
allowance for it.  The defect applies to both Category V and VI.  However,
it will not be major for Category V in Virginia because we have only one
combined sewer area in the shellfish water territory, and that one is small.

The draft report took no cognizance of and made no allowance for combined-
sewer non-urbanized areas in Virginia, of which there are seven.  Additionally,
we have six urbanized areas with combined sewers, of which only five were
identified in the draft report.  It grieves us to advise that the acreages
of three of these five are overestimated in the draft, to the extent that
the corrected total combined-sewer acreage for Virginia (see enclosure) is
less than that reported in the draft, notwithstanding your consultants'
omissions.  Correction of these omissions might be to Virginia's detriment
(that is not entirely clear), but we suspect that a similar review of other
States' data might well result in similar downward adjustments thereof.

We have not been privileged to review the December 1975 APWA/U. of Florida
draft report to EPA (reference 2, Part III), but the JJG/BCE report now at
issue places heavy reliance on this one, and on a much earlier one (1967)
by APWA the currency of which is dubious.  In short, it appears that your
consultants' data base may have been inferior to that which could have been
used given more time to conduct the study.

It would have been helpful if the draft had shown dollar needs estimates
for each of the 320 urbanized areas, at minimum, for the separate Categories
V and VI.

Presumably Mr. Wen Huang's cost equations will be incorporated in the revised
final report and the facility costs will be recomputed accordingly.  We would
expect the dollar needs to rise appreciably if this is done.

This agency sent a representative to the November 1976 EPA Regional meeting
on the draft report, at which spokesmen for the authors made explanatory
presentations aided by slides.  We think that many of those slides not now
present in the draft would be helpful in the final report.  In particular,
inclusion of the five process schematic diagrams would add strength.  The
control strategies used to satisfy the Aesthetics, Fish and Wildlife, and
Recreation goals respectively, though mentioned in the text, could be set
forth in tabular form for clarification and emphasis.

The term "construction practices" should be clearly defined as erosion/sedi-
mentation control practices implemented in course of ground-disturbing
construction (and other?) activities, or whatever is intended.

We would have liked to see a closer analysis of (a) the fraction of total
stormwater volume which actually receives treatment, and  (b) the fraction
of total pollutant poundage in stormwater which actually receives treatment
and  also  (a different matter!) which actually gets removed, as a function
of (c) the design storm depth variable. An analysis of the dependence of
                                D-153

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Mr. James Chamblee                      - 4 -               3 December 1976


overall control costs on the volume and degree of treatment provided would
also be useful.  We realize that such analyses could probably only be
conducted for a few representative geographic/climatic/urban development
situations.

We appreciate having had the opportunity to review the draft report.  Not-
withstanding our reservations, the report is a significant addition to the
literature of stormwater management.

                                           Sincerely yours,
                                           R. V. Davis
                                           Executive Secretary
/ap

cc:  Mr. Kenneth Pantuck, EPA III
                                  D-154

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                    Combined Sewer Areas in Virginia
              November 1976 State Water Control Board Update
Area Name
"Urbanized" Areas (SMSAs) c)

    Lynchburg
    Newport News
    Norfolk
    Petersburg
    Richmond
    Roanoke
    Va. portion B.C. Metro
       (Alexandria)
    Va. portion Kingsport Metro
       (Bristol)
               Subtotal
        CSO Area Acreage
Draft report a)SWCB update
                                                                          b)
 10,400
    0
    0
    0
 15,900
    300
  1,500

    0

 28,100
10,425
   268
   0
   0
11,500
   300

   885

   805
24,183
"Non-urbanized" Areas

    Radford, City
    Clifton Forge, City
    Dayton, Town
    Waynesboro, City
    Ashland, Town
    Hopewell, City
    Pocahontas, Town
               Subtotal

               Grand Total
    0
    0
    0
    0
    0
    0
    0
 28,100
   321.5
   480
   (0) e)
   175
   211
   450
   486
 2,124

26,307
a)  Jordan et al. and Black et al. , October 1976 draft report to EPA
b)  from agency files and locality contacts
c)  all eight Virginia SMSAs are listed
d)  Greeley & Hansen Engineers' 1970 study says 10,361 acres
e)  minor CSO needs are being handled by the Town and State
                                  D-155

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C.  20460
Mr. R. V. Davis, Executive Secretary
Virginia Hater Control Board
2111 Hamilton Street
Post Office Box 11143
Richmond, Virginia   23230
                                                   Draft Report on 1576 Needs
                                                   Survey for Combined Sewer
                                                            and Stonmvater
Dear Hr. Davis;

     Thank you for your letter of December 3, 1976, offering consents on our
draft report which estimated needs for combined sewer overflows and stormv/ater
control (Categories V & VI).

     Your comment discussing inclusion of smaller communities for storrnwater
control needs was voiced by several states,  Regulations for the application
of the :;PDES program to separate storm sewers v;ere puMished in the Federal
Register of March 18, 1976.  This document and the permitting program it
established were utilized to define the areas requiring needs in Category VI.
In the regulations the terr:> ''separate storm se<,«>er!' is defined as :'a conveyance
or system of conveyances ..... located in urbanized area and primarily operated
for the purpose of collecting and conveying stormwatsr runoff.1'  The permit
issuing authority way designate other storm sewers as being significant
contributors of pollution and thus subject to these regulations.  In the
absence of such specific designations, storrnwater needs are estimated for
Census-defined urbanized areas only.

     It is unfortunate that time and budget constraints would not allow as
detailed an evaluation of Category V and VI needs as was accomplished in
Categories I through IVC.

     Several of your cor.jnents related to changes which were discussed in the
regional Meeting in Philadelphia.  After making these changes (which included
Or. Wen Huang's cost equations) and increasing the design storn volume  (OS)
for combined sewers to the SOth percent! le storm for the aesthetics and fish
and wildlife criteria (DS=2.3 x f;RF, uhf-re MRF = means rainfall depth per
stprm) and the C'Sth percentile storm for the recreation crieria  (L",'S=3.t)l x
MP.F), the final Virginia needs estimates for the recreation criteria are
$244,947,000 for Category V and $1,550,490,000 for Category VI.  The increase
in design storm between the fish and wildlife criteria and the recreation
criteria will provide nreater assurance of meeting the water quality criteria
in the shellfish areas near your urbanized areas.
                                   D-156

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     The suspended solids criteria defined in the water quality criteria
were obtained in research conducted by the European Inlands Fishery Commission.
Unquestionably, more research needs to be done on the impact of suspended
solids from stormwater runoff and the implications of suspended solids concen-
trations on disinfection.

     The changes in the input data base enclosed in your letter were included
in the final report and were used to develop the final  estimate.  As you
mentioned, several portions of the available data base were minimal  at best.
Completion of ongoing 208 studies and other storm water studies may provide
a more detailed data base for future needs surveys.

     In an attempt to write a concise report that would be reviewed by the
states and other reviewers, certain specific data such as individual  urbanized
area needs, process schematic diagrams, and tabulations of design  storm size
treatment rates, and other incremental pieces of data were deleted from the
draft report.  This information is available upon request.

     We agree that analysis of specific relationships in the cost  function
and treatment rate assumptions would be interesting.  Although  not possible
within current time constraints, the computer program of our model  could be
modified to produce such information.
     The final report, including all comments received from the states, will
be forwarded to you in early February, 1977.

     I hope that this has answered your questions.  If I can be of any
further assistance, please let me know.
                                       Sincerely yours,
                                        i
                                   C-XJan
   /
 ames A. Chamblee, Chief
Needs Assessment Section
        (WH-547)
cc: Ken Pantuck, USEPA Region III
    Needs Survey Coordinator
                                 D-157

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    R. V. Davis
  Executive Secretary

 Post Office Box 11143
Richmond, Virginia 23230
   (804)786-1411
STATE WATER CONTROL HOARD
       2111 Hamilton Street

       January  5,  1977
BOARD MEMB
Col. J. Leo Bon
   Chairman
 Warren L. Br.r
  Vice-Chairm.'
 George M. Coi
 Roy B. Martin.
 Millard B. Rice
 Kenneth B. Ro
 R. Alton Wrio
           Mr.  James A. Chamblee,  Chief
           Needs  Assessment Section  WH-547
           U.S. Environmental Protection Agency
           401  M  Street S.W.
           Washington, B.C. 20460

           Dear Mr. Chamblee:
           We  have your 16 December letter concerning the 1976 Needs  Suavey Categories V
           and VI Final EPA Estimates.

           We  have no technical  basis on which to  challenge the  figures for Virginia
           and we take no exception to them.

           We  do feel that in upcoming formulae for  allocation of  construction grant
           funds among the States,  Categories V and  VI should be weighted considerably
           lower than Categories I  through IVB, if indeed Categories  V and VI are
           included at all.

                                                          Sincerely yours,
            /ap

            cc:  Mr. Kenneth C.  Pantuck
                 Dr. Richard L.  Hill
                                                          R. V. Davis
                                                          Executive  Secretary
                                              D-158

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V*-
LIMITED STAIES ENVIRONMENTAL PROTECTION AGENCY
                 WASHINGTON, D.C. 20.160
    Mr.  R. 'V.  Davis
    Executive  Secretary
    State Water Control Board
    Commonwealth of Virginia
    2111 Hamilton Street
    Post Office Box 11143
    Richmond,  Virginia  23230
                                       Re:  Draft Report on 1976 Needs
                                            Survey for Combined Sewer
                                            Overflows and Stormwater
    Dear Mr.  Davis:
         Thank you for your letter of January 5,  1977 in which you concur
    with the EPA Category V and VI cost estimates for the Commonwealth of
    Virginia.

         The final report, including all comments received from the States,
    will be forwarded to you in early February 1977.

         If I can be of further assistance,  please let me know.

                                  Sincerely yours,
                                  James A. Chamblee, Chief
                             Needs Assessment Section (WH-547)
    cc:   Ken Pantuck,  USEPA, Region III
         Needs Survey Coordinator
                                     D-159

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                                                                          State of
     .    ,n  1Q7fi                                                       Washington
November 30, 19/6                                                             /°
                                                                        Deeartrnent
                                                                         of
Mr. James Chamblee
Chief, "Needs" Assessment Section
Facility Requirements Branch  (WH-547)
401 M. Street, S.W.
Washington, D.C.  20460

Dear Mr. Chamblee:

Considering the existing time and monetary restraints,  the quality of
the report entitled 1976 Survey of Needs  for  Control  of Pollution From
Combined Sewer Overflows and  Storm Water  Discharges could be described,
at best, as barely adequate.

In general, the Environmental Protection  Agency  (EPA),  in gathering data
for the report, has chosen an approach  that:  1)  does  not conform with
their existing guidance for the construction  grants program; 2)  does not
take into account a significant percentage of the needs in combined
sewer and storm sewer discharge correction; and  3) does not properly
utilize existing data.

The EPA's program guidance memorandum 61  requires combined sewer correc-
tion programs to be justified on the  basis of impairment of a beneficial
use; therefore, the time of the year  at which the overflows occur becomes
the deciding factor.  This time-of-year factor should be a major element
in EPA's approach to the problem.

EPA guidance stipulates that  facility planning decisions are to be for
the 20-year planning period,  so it seems  reasonable  that estimates of
"needs" should be based on the same ground rules as  these 20-year deci-
sions; however, the "needs" estimates are not.

The "needs" survey estimates  cover only the major metropolitan areas,
leaving out many of the communities in  the State with combined sewer
problems, e.g., Bremerton, Aberdeen,  Everett, Bellingham, Mount Vernon,
Anacortes, Olympia, Hoquiam,  Raymond, Vancouver, Walla  Walla, etc.
These cities represent 30 percent or  more of  our "needs" in Category V.
In the past, states have developed their  own  estimates  because national
surveys fail to take into account the uniqueness of  each state.  For a
state such as Washington, which has frequent  rainfall events and many
combined systems, the approach used to  determine this year's "needs"
estimates for Category V is grossly inadequate.
   Daniel J. Evans, Governor John A. Biggs, Director  Olympia, Washington 98504  Telephone (206) 753-2800
                                 D-160

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Mr. James Chamblee
November 30, 1976
Page two
The use of existing data was an approach ignored by EPA in arriving at
their estimates.  The $5.3 million worth of facilities planning data on
the Seattle, Tacoma, Everett, and Spokane areas were not utilized, and
an additional $1 million worth of facilities planning data for other
areas were not used.  The $4.4 million "RIBCO" study, funded by grants
from HUD, EPA, COE, City of Seattle, and the State of Washington was
totally ignored.  A major goal of the RIBCO study was to define storm
water problems in the Seattle metropolitan area and recommend solutions
to these problems.  Two years ago, the Department of Ecology funded an
$8,000 study which included development of an empirical methodology for
estimating storm water "needs,"and DOE contributed an additional 200
man-hours to this study, but no use was made of this effort by EPA.  We
have not, by any means, mentioned all the available work, but it seems
clear that EPA chose a $90,000 theoretical model approach rather than to
utilize the millions of dollars worth of specific studies already com-
pleted in Washington State under local, state, and federal grants.

In addition to the overall approach, the methodology used also has some
areas which could be improved.  First of all, the mathematical model
does not consider whether or not the sewers are flowing full or near
full prior to a rain event.  If either of these situations exist, the
sewer may overflow with only 0.01-0.02 inches of rainfall.  A high
ground-water table in early spring or summer may cause infiltration not
correlated with a storm, and may cause overflows to occur with minimal
precipitation during a time when use of the receiving water is high.

The model does not take into account that I/I rehabilitation of the
system cannot take place upstream of the overflow unless the overflow is
eliminated, so the cost effective solution in many instances may be
treatment at the plant or separation of the system.  The costs in these
instances may be higher than predicted.

The model is based on fish and wildlife criteria that are adequate for
minimal fisheries production, but would by no means be acceptable in
this state where fisheries is one of our major industries.  D.O. levels
of 5 mg/1 could significantly effect salmon reproduction and rearing;
and sedimentation, even at 80 mg/1 Suspended Solids, could destroy
valuable spawning beds.

The criteria for recreation does not take into consideration nutrient
impacts on freshwater lakes.  This is a severe problem both in Seattle
and Spokane, e.g., Long Lake in Spokane was closed this summer due to a
toxic anabaena bloom.
                              D-161

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   Mr. James  Chamblee
   November 30,  1976
   Page three


   In order for  this survey to reflect "the true cost of correction of our
   State's storm water related problems,  at least the problems with the
   methodology must be addressed;  and more than likely, a complete reversal
   in the approach should be considered.
   Sincerely,
   John Spencer
   Assistant Director
   Office of Water Programs

   JS:FM:pam
   112920
cc:Russell  Train,  EPA Headquarters
   Donald DuBois,  EPA, Region X
                                   D-162

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                                                       T| ty '<•'->•••
                                                       vt L .,-i,/ s

     Mr. John F. Spencer,
     Assistant Director
     Office of Water Programs
     Department of Ecology
     State of Washington
     Olympia, Washington  98504

     Dear Mr. Spencer:

          Thank you for your letter of Hbveaiber 30, 1976, on the draft report,
     "1976 Survey of Needs for Control of Pollution from Combined Sewer
     Overflows and Stormwater Discharges."

          This is to confirm that we would like very much to see a copy of
     the facility plans and the "RIBCO" study as well as your Department's
     report on an empirical methodology for estimating stormv-Tater "needs",
     which Mr. Philip Graham requested by phone.  They will help us to deter-
     mine the reasons for differences between our estimates and those in the
     studies.

          I would note that we did consider the time-of-year factor in the
     methodology.  The parameter used to take the time-of-year into con-
     sideration, is the coverage annual, sunmer flow shown  for the State of
     Washington on Page 13-16 of our draft report.  The data were obtained
     from five years of record.  The lowest three months flows for each year
     were averaged.  If summer flows and winter flows were approximately
     equal, the summer flow data were used to determine  the three month
     period with 3xw oxygen resource.  Needs in the Survey are, as you noticed,
     based on 1990 population. The decision to use 1990  population was made
     by the Stata and EPA Wefads Survey Storking Group to rainiird.se the changes
     between 1974 and 1976 Needs Surveys.

          Category V needs for Washington were based on  an estimate of 57,300
     acres in Seattle and Spokane, and an additional area of 21,800 acres for
     non-urbanized areas.  This additional area represents 27% of your
     states' combined sewer area.

          The variation in number of rainfall events per year for each urbanized
     area is considered in the model as the number of storms per year and
     average yearly depth of rainfall.  For example, compare data for Seattle
I320~'         '    '                                               OFFICIAL FILE COPY
                                        Drl63

-------
on page B-16, which shows 34.10 indies precipitation occurring as  164
storms per year, with data for Spokane, which shows an annual precipi-
tation of 17.19 inches distributed over 118 storm events per year.  The
use of this data is described in the computer program on Page C~4  lines
16-18, and in the report on page 7-11, and in more detail on pages 6-1
to 6-5.

     You caimented that, at certain times, dua to groundwater causing
infiltration not correlated with a storm, only one to tii^o-huniredtl-is of
an inch, of rainfall can cause an overflow event from a combined sewer
overflow, and that our methodology does not consider whether combined
sewers are full prior to a rain event.  Our methodology provides for
storage at each cverf low point and transmission to- regionalized cctTibinod
sewer overflow treatment plants.  In the model, all stormwater collected
in the combined sewer area is assumed to overflow (at conbined sewer
overflow concentrations) to the ccrobined sewer overflow storage-trans-
mission-treatrreant system.  Thus our methodology doos wt rely on the
capacity of the existing ca-nbined sewer system and, to the extent  this
existing capacity may be used, our dollar estimates are high.

     You cccmented tlvat the cost-effective solution in many instances
may ba treatment at the plant or separation of the systan.  You also
carrnented in a subsequent paragraph tliat sedimentation even at 80 ng/1
suspended solids could destroy valuable spawning beds.  Under the  sewer
separation alternative, unless treatment is provided for the separated
storm sewer system, the -suspended sediment load from urban stormwater
runoff would be delivered to the receiving water with likelihood of
higher suspended solids concentrations in the receiving water than with
cotibined sewer overflow treatment alternatives.  If it is more cost-
effective to separate combined sewer systems, tiie costs sliould include
the cost of treating stormwater runoff from tl*a separate storm sewer
systan and the resulting total cost of separation of the combined  sewer
system stoald also be lower than the cost determined using the coribined
sewer overflow storage-transmission-treatriient alternative of our 1976
needs survey.

     We would be interested to know if the spawning bads you discussed
are located in streams which receive combined sewer overf lows or storm-
water runoff from urbanised areas (which is the current scope of Category
V and VI of the Weeds Survey).

     You commented that the recreation criteria do not tate into con-
sideration nutrient Impacts on freshwater lakes.  There is seme nutrient
removal associated with the processes listed in on pages 3-4 through 3-
13 of the draft report, though we would be very interested in your
analysis of the extent to which nutrient removal fran combined sewer
overflows and stormwater flows is required in your State.
                               D-164

-------
     Vio. are looldng forward to receiving the studies mention©:!  in your
letter.

                                    Yours sincerely,
                                    James Ctiamblee
                                        Chief
                                     Weeds Survey
                          Facility Requirernenta Branch  (VSI-547)
                          D-165

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IRAS. LATIMER, Jr.
    Director
                                    STATE OF WEST VIRGINIA
                             DEPARTMENT OF NATURAL RESOURCES
                                     CHARLESTON 25305
                                    December 7, 1976
       Mr. James Chamblee
       Chief, Needs Assessment Section
       Facility Requirements Branch  (WH 547)
       401  'M' Street, SW
       Washington, D. C. 20460

       Re:  Draft 1976 Survey Of Needs For Control Of Pollution From Combined
            Sewer Overflows and Stormwater Discharges

       Dear Mr. Chamblee:

            We have received the subject draft report and appreciate the opportun-
       ity afforded to us  to comment on this important document.

            In keeping with the instructions included in the  transmittal letter to
       this agency from the Deputy Administrator, our comment on  this draft  con-
       cerns the base input data contained in Appendix  'B1.   In our  opinion,  those
       areas in West Virginia chosen for and included in this appendix cannot be
       considered as representative cases for analysis.  As a state  with small and
       rural communities the rule and the metropolitan  (SMSA) area the exception,
       the chance of having our needs in categories V and VI  accurately represented
       is extremely slight.  We feel that the selection of those  communities with
       populations greater than or equal to 50,000 presents an exceedingly good
       likelihood for a distortion of true needs.  The selected communities,  four
       in number,occur in only two of our seven river basins.  Both of these  streams,
       the Ohio River and  the Kanawha River, maintain relatively  large flow  volumes,
       even in periods of  lowest flow.

            Additionally,  if only by virtue of their proximity to one-another, these
       communities present a similarity in topographic features and  geographic set-
       ting.  Beyond that, existing facilities are remarkably similar in the select-
       ed communities, as  are their needs for modifications and improvements to
       those systems.

            Our point is that utilization of the communities  selected as input data
       will not clearly reflect the image of in-state needs,  as we see it, since
       only a small percentage of the total state population  will have been  included
       and the communities selected are not representative of the type found in
                                         D-166

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Page 2
Mr. James Chamblee
                                                   December 7, 1976
other areas of the state which do contain the largest percentage of total
population.  Further, in that the communities selected as data points for
the survey all occur on high average flow streams, even the magnitude of
the impact that this percentage of the storm flow and combined sewer over-
flow which will be addressed may well be of lesser significance in compari-
son to the serious impacts upon stream quality that the present unrestricted
flows from the typical small community would have upon its similarly small
volume receiving stream.  We offer the suggestion that the impact of these
flows may well be of greater significance in terms of water quality degrad-
ation in the smaller stream than those in the sample group.

     To simplify our position, it is that as state administering agency, we
are deeply concerned about state needs, not those needs of four SMSA's to
the exclusion of all else.

     While it was clearly stated in the letter of transmittal that the me-
thodology "is not intended to predict accurately the needs for any specific
area", the application of this methodology to this state appears to con-
sider the needs only of a specific area.  If future allocations of funds to
states may be determined in part by estimated needs in categories V and VI,
we would be particularly interested in seeing that these estimated needs
approach closely the actual needs of our state.

     We hope that you will consider our viewpoint in the time available be-
fore adoption of the methodology and can adjust or factor results accord-
ingly so that you will deliver an output from the survey which will pro-
vide a consistent basis for comparison of needs among the states, rather
than a comparison of their populations alone.

                                           Sincerely,

                                           WATER RESOURCES DIVISION
                                           Steven J. Knopp, Planner
                                           Construction Grants Section
                                           Municipal Branch
SJK/lt
c:  John Hall, Chief,
    Div. of Water Resources

    Warren Means, Ass't. Chief
    Municipal Grants Branch
                                D-167

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  \
   ?    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C. 20460
Sir. Stephen >3. Knopf
Planner Construction Grant Section
Municipal Branch
Hcst Virginia Department of Natural Resources
Charleston, L^st Virginia   iOSOG
                                            HE:  Draft Report on  1976  heeds
                                                 Survey for Combined Sev/er
                                                 Overflows and Stortnwater
Oear : the regulations, the tern) "separate storm sev/er" is 
-------
     I hope that this has answered your questions.   If I can be of further
assistance, please let me know.

                                    Sincerely yours,
                                    femes A.  Chanhlee,  Chief
                                   'Heeds Assessment Section
                                            (WH-.347)
cc: Ken Pantuck, USLPA Region III
    Needs Survey Coordinator
                                  D-169

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IRA S. LATIMER, Jr.
    Director
       STATE OF WEST VIRGINIA
DEPARTMENT OF NATURAL RESOURCES
         CHARLESTON 25305

        January 5,  1977
         Mr.  James Chamblee
         Chief,  Needs Assessment  Section
         Facilities Requirements  Branch
         Environmental Protection Agency
         401  M.  Street,  S.W.
         Washington, D.C.  20460

                                                  Re:   1976 Needs Survey Categories
                                                       V and VI Final Estimates

         Dear Mr.  Chamblee:

              We have received and  reviewed the final  estimates for categories V and
         VI attached to your  16 December memorandum.   From these estimates, we have
         determined  that  our comments concerning the  inapplicability of the category
         V and VI  methodology to  the general or specific case in West Virginia have
         been ignored.  We strongly feel that the unrepresentative nature of the base
         data has  yielded  a product which neglects the needs, not only our predomi-
         nantly small, rural  communities, but also the significant impacts which com-
         bined sewer overflows and  storm flows have upon our smaller streams with con-
         siderable existing water quality problems.

              Evaluation of this  problem by our staff  members has produced the con-
         clusion that the  final estimates which have been presented to us are highly
         suspect.   We are  also disturbed that the printing schedule for your final
         report allows us  less than thirty calendar days over a holiday period to
         complete  estimates to rebut estimates generated by EPA consulting engineers
         over a period of  several months.  The only course left to us is to register
         our  dissatisfaction  with the estimates which  you have presented, and enter
         as the independent state cost estimate for category VI those final figures
         generated in the  1974 needs survey adjusted by inflation modifiers to re-
         flect needs in January 1976 dollars.  Our calculation of category VI needs
         is $2,454,010,530.00 (or $1,740,433 thousands of 1973 dollars x 1.41 in-
         flation modifier).
                                      D-170

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Page 2                                        January 5, 1977
Mr. James Chambl ee
Chief, Needs Assessment Section
Environmental Protection Agency
     Those figures were generated by our large 1974 needs survey staff who
utilized not only considerable personal expertise in the estimation process,
but also the staff resources of private consulting engineers who are most
familiar with the needs of their individual clients, those smaller communi-
ties totally neglected by your statistical approach.  We feel these figures
to be most representative of the true needs of our state and will greatly
appreciate your attention to the interests of the remaining 1.62 million
people which they and we represent.

                                            Very truly yours,

                                            WATER RESOURCES DIVISION
                                            John H. Hall
                                                Chief
JHH/skt
Honorable Robert   C. Byrd,  U. S. Senator
Honorable Jennings Randolph, U. S. Senator
Honorable Arch A.  Moore,  Jr., Governor
Governor-Elect Jay Rockefeller
                             D-171

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X08**
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, D.C.  20460

                                                                     ;: ". JAN
      Mr. John H. Hall, Chief
      Water Resources Division
      West Virginia Department of Natural Resources
      Charleston, West Virginia  25305

      RE:  1976 Needs Survey for Combined Sewer Overflows
           and Stormwater

      Dear Mr. Hall:

           Thank you for your letter of January 5, 1977, which transmits your
      estimate of $2,454,010,530 for Category VI.  We will include your estimate
      as well as the EPA estimates reported to you on December 16, 1976.

           The final report, including all comments received from the States,
      will be forwarded to you in early February 1977.

           If I can be of further assistance, please let me know.

                                         Sincerely yours,
                                               A. Chamblee, Chief
                                         Needs Assessment Section
                                                  (WH-547)
       cc:  Ken Pantuck, USEPA Region III
           Needs Survey Coordinator
                                  D-172

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    State  of Wisconsin  \  DEPARTMENT OF NATURAL RESOURCES

                                                                       Anthony S. Earl
                                                                            Secretary

January ?H, 1977                                              MADISON, WISCONSIN 53707
                                                                        3^30
                                                      IN REPLY REFER TO:	
Mr. James A. Chamblee, Chief
Needs Assessment Section WH-5'i7
Environmental Protection Agency
HOI M Street S.W.
Washington, D. C.   20U60
RE:  Estimate of Wisconsin Category V Needs
Dear Mr. Chamblee:

We have reviewed the draft document, "1.916 Survey of Needs for Control
of Pollution from Combined Sewer Overflows and Stormwater Discharges."
We consider the costs of Category V (Combined Sewers) to be too low.  The
following are our comments regarding the combined sewer overflow problems
in the State of Wisconsin.

The given task of the contractors was to estimate costs for treatment of
combined sewer overflows only.  No consideration is given to costs of land
and relocation assistance as required by Ho CFP Part U, the need for
combined sewer system separation to eliminate basement backups, or treatment
plant expansion to provide at least secondary treatment to the I/I from storm
water that reaches the treatment plant, as required by Ho CFP Part 133.

The cosis are based on removing pollution from combined sewer overflows by
building holding ponds and treatment facilities at the holding ponds.  The
following assumptions were made:

1.  The holding ponds and facilities would collect and treat the overflow
from 80$ of the five-year Btorms.  Any additional overflow would not be
treated.

2.  Suspended solids in the effluent from the treatment facilities would
be less than Uob mg/1 for Fish and Wildlife Criteria and Recreation Criteria.

3.  BOD would be removed to a level that would provide a minimum of 5.0 mg/1
of dissolved oxygen in the receiving stream for criteria other than
Aesthetics.  Only under exceptional pollution loads where the  dissolved
oxygen in the receiving water would be less than 5.0 mg/1 were additional
point source treatment plant costs considered.
                              D-173

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H.  Costs for chlorination were estimated to limit fecal coliform only vhere
the receiving water quality is to meet the Pecrention Criteria.

The estimated costs for Category V, Combined. Sewer Overflow Correction or
Control, are too low for the following reasons:

1.  To meet the recommendations of international compacts, Wisconsin has
agreed to require phosphorus removal from effluent from wastewater treatment
plants of all communities over 2,500 population discharging in the Great
Lakes Basin .  No costs are included for this removal .

2.  Federal Regulation kO CFP Part 133 indicates that all municipal treat-
ment facilities are to provide an effluent not to exceed a monthly average of
30 mg/1 of BOD5 and suspended solids, nor a weekly average of 1*5 mg/1 of
BOD5 and suspended solids.  These limits also apnly to combined sewer over-
flow treatment . facilities .

3.  Apparently no consideration was given to separation of combined sewers
to eliminate basements being partially filled with wastewater from surcharged
combined sewers.

14 .  The City of Racine has combined sewers in 1.5 square miles' of its municipal
area.

From data available to us, we estimate the costs for correction of combined
sewer overflow problems of five municipalities as of January 1, 1976 as
follows :

                                                  Estimated Cost
             Name                               millions of dollars
     Milwaukee Metropolitan Sewerage District
     City of Racine                                     15
     City of Kenosha                                    30
     City of Wisconsin Rapids                            8
     City of Superior                                   11
     Total                                             JT6IT

It is requested that calculated costs of combined sewer overflow control for
the urbanized areas of Appleton, Green Bay and 'La Crosse and the non-urbanized
areas of the state other than Wisconsin Ranids and Superior, as determined by
the 1976 Needs Survey, be added to the estimated cost of $U6H million.  It is
our belief that this revised, total cost will more accurately present the
Category V needs of the State of Wisconsin .

Sincerely,
Department of Natural Resources
Paul Guthrie, Jr., Directoi
Office of Intergovernmental Programs

cc:  Edwin Home, Jr., EPA-Region V
                                 D-174

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f  «m \
s
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                             WASHINGTON, D.C.  20460
    Mr. Paul Guthrie, Jr., Director
    Office of Intergovernmental Programs
    Wisconsin Department of Natural Resources
    Box 7921
    Madison, Wisconsin  53707

    RE:  Draft Report on 1976 Needs
         Survey for Combined" Sewer
         Overflows and Stormwater Control

    Dear Mr. Guthrie:

         Thank you for your letter of January 24, 1977, offering comments on
    our draft report which estimated needs for combined "sewer overflows and
    Stormwater control (Categories V and VT).

         In regard to your comment that no consideration is given to land
    cost, land costs are considered ineligible for the purposes of the
    municipal facilities grants program of EPA except for land treatment of
    wastewater or for sludge disposal.  I have enclosed copies of PGM's 49
    and 67 which state these policies in more detail.

         In regard to your comment that no consideration is given to relocation
    costs, costs amounting to 25% of the costs determined from the cost
    equations are included in our cost estimates; relocation costs are
    included in this additional amount.

         In regard to your conment that no consideration is given to the
    cost of the separation of combined sewers to eliminate basements being
    partially filled with wastewater from surcharged combined sewers, the
    cost estimates of the 1976 Needs Survey are for single purpose projects
    only to protect receiving water quality.  Sewer separation was not
    considered as an alternative control option because it has been shown in
    most cases across the nation not to be a cost-effective means of reducing
    pollutant discharges to receiving waters.  I have enclosed a copy of PGM
    61 and PRM 77-4 which summarize EPA's policies on the control of combined
    sewer overflows and on cost allocations for multiple purpose projects.

         In regard to your comment that treatment plant expansion costs
    should be included to provide at least secondary treatment to the non-
    excessive infiltration/inflow from storm water that reaches the treatment
                              n-175

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plant, the guidance for Categories I-IV states that these costs should
belong in Category I or II where a separate sanitary sewer is involved.
Where a combined sewer is involved, treatment costs of infiltration and
inflow are included in Category V.

     In regard to your comments on the combined sewer overflow cost
estimation methodology, the costs in the final report are based on (1)
storage at each overflow site sized for a 98th percentile storm, and  (2)
treatment of the stored volume at consolidated treatment facilities
during the average interstorm period.  The Category V and VI cost estimates
reported to Congress are for the recreational water quality criteria and
thus disinfection costs are included for all combined sewer overflow
areas.

     In regard to your Garment on phosphorus removed, costs for treatment
of wastewater to a level higher than secondary should be included in
Category II.

     In regard to your comment that combined sewer overflows require
secondary treatment, EPA does not interpret secondary treatment require-
ments of the 1972 FWPCAA to apply to combined sewer overflows.  The
policy is to provide that degree of pollution control which is cost-
effective and needed to protect beneficial uses (please refer to PG-
61).

     Our final cost estimates were prepared January 21, 1977; we are
sorry that we did not receive your data about the Racine, Wisconsin
combined sewer area in time for the 1976 Needs Survey.

     Per the telephone conversation between Mr. Philip Graham and Mr.
John Hario on February 1, 1977, I will include your separate State
estimate for Category V of $495 million and note that you do not wish to
submit a separate State estimate for Category VI for Wisconsin.

     The final report, including all comments, will be forwarded to .you
in early February 1977.

     If I can be of further assistance, please let me know.

                              Sincerely yours,
                              James A. Chamblee
                                 Survey Director  (WH-547)
Fjiclosures

cc:  Ted Horn, USEPA Region V
     Needs Survey Coordinator
                              n-ur

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   OFFICE CF
Natural Resources Management
             GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES
                                    _____ Q ______

                   Department oj Conservation and Cultural Affairs
                                    p. o. BOX JTOX 4340
                              CHARLOTTE AMALIE, ST. THOMAS


                                 November 5, 1976
     Mr. James Chamblee
     Chief, Needs Assessment Section
     Facility Requirements Branch (WH-547)
     401 M. St., S.W.
     Washington, D.C.  20460

     Dear Mr. Chamblee:

           I have received the Draft Report entitled, "1976 Survey of Needs
     for Control of Pollution from Combined Sewer Overflows and Stormwater
     Discharges" and was disappointed to see that the Virgin Islands, Guam,
     American Samoa, and the Pacific Trust Territories were listed as having
     no Capital Costs for State Category VI, (Stormwater) Needs.

           The Virgin Islands were excluded, I believe, on the basis that
     there is no urbanized city with 50,000 or more population.  The survey
     implies that we have no Stormwater run-off problem.  This is not so,
     and I am sure the same thing applies to the other small islands.

           I believe a fairer analysis would be to consider the percentage
     of land area urbanized in relation to the total  land area available.
     For in reality the Virgin Islands with the exception of St. John, are
     almost totally urbanized.
                                         Pedrito Francois, Director
                                         Natural Resources Management
     cc:   Commissioner Brown
                                    D-177

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   \
    *    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON. D.C  20460
                                               16 TO


Mr. Pedrito Francois, Director
Natural Resources Management Division
Department of Conservation and Cultural
 Affairs, P.O. Box 4340
Charlotte Amalie, St. Thomas, VI  00801

Dear Mr. Francois:

     Thank you for your comments on our  draft report on needs for combined
sewer overflow and stormwater control (Categories V and VI).

     Your comments are being studied carefully and will be taken into con-
sideration in our final report to the Congress.

     We are sorry that we cannot yet comment on the issues your letter raised,
These are under study, along with comments from other states  and territories.

     As soon as possible, a complete explanation of our final cost estimates
will be forwarded.

                                  Sincerely,
                                  James A. Chamblee, Chief
                                  Needs Assessment Section
                                           (WH-547)
                                  D-178

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                          WASHINGTON, D.C.  20460
                                                                     CT*
S JAN IS?/
 Mr.  Pedrito Francois,  Director
 Natural  Resources  Management
 Department of Conservation and Cultural  Affairs
 Government of the  Virgin  Islands  of the  United States
 Post Office Box  4340
 Charlotte Amalie,  Saint Thomas
                                         RE:   Draft  Report on 1976 Needs
                                              Survey for Combined Sewer
                                              Overflows and Stormwater
 Dear Mr.  Francois:
      Thank you  for your letter of November  5,  1976, offering comments on
 our draft report which estimated  needs  for  combined sewer overflows and
 Stormwater control  (Categories V  and  VI).

      Your specific comment requesting an  inclusion of non-urbanized areas
 for Stormwater  control  needs  was  voiced by  several States as well.
 Regulations for the application of NPDES  program to separate storm sewers
 were published  in the  Federal  Register  of March 18, 1976.  This document
 and the  permit  program it  established were  utilized to determine the areas
 requiring needs in Category VI.

      In  the regulations, the  term "separate storm sewer" is defined as
 "a  system or system of conveyances ..... located in an urbanized area and
 primarily operated for the purposed of  collecting and conveying Stormwater
 runoff."   The permit issuing  authority  may  designate other storm sewers
 as  being  significant contributors of  pollution and thus subject to these
 regulations. In the absence of specific designations, Stormwater needs
 are estimated for Census defined  urbanized  areas only.

      The  final  report, including  all  comments  received from the states,
 will  be  forwarded to you in early February, 1977.

      I hope that this  has  answered questions.  If I can be of any further
 assistance, please let me  know.
                                    Sincerely you^s,
                                    James A.  Chamblee, Chief
                                    Needs Assessment  Section
                                            (WH-547)
cc: Robert Olson, Region II



                                  D-179

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 NICHOLAS J. MELAS

    PRESIDENT
  Bart T. Lynam
General Superintendent
    751-5722
BOARD OF TRUSTEES


  JOANNE H. ALTER

  JOAN G. ANDERSON

  JEROME A. COSENTINO

  VALENTINE JANICKI

  WILLIAM A. JASKULA

  JAMES C. KIRIE

  CHESTER P. MAJEWSKI

  NICHOLAS J. MELAS

  JOHN W. ROGERS


       445
                                        November  22,  1976
         Mr.  James Chamblee
         Chief, Needs Assessment Section
         Facility Requirements  Branch (WH-547)
         401  M. Street, S.W.
         Washington, D. C.    20460

         Dear Jim:

         In response to Hal's  October 27 request  to review the  Draft
         on the 1976 Survey  of Needs for Combined Sewer Overflows,  the
         following comments  are made:

              1.  It appears  that the sequence  of storm events
                  has not been given due consideration and could
                  result in  a  gross underestimation of the total
                  needs.

              2.  Utilization  of a design rainfall of only 1.6
                  times the  average rainfall may  not achieve the
                  objective  of having a design  rainfall greater
                  than  80% of  the annual rainfall.

              3.  The combined sewer overflow area indicated in
                  Appendix B  for the Chicago Area is approximately
                  320 square miles.  The District's Facilities
                  Planning Study indicates the  combined sewer area
                  of approximately 375 square miles.

         If you require any  additional information, please feel free
         to contact me.
                                        Very truly  yours,


                                                    7.
                                         \art T. "Lynam
                                        General Superintendent
        BTL:HM:kl
        cc:  Mr.  McMillan
                                      D-180

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   0                      WASHINGTON, D.C.  20460              .., „ ,,
Mr. Bart T. Lynam
General Superintendent
Metropolitan Sanitary District of Greater Chicaoo
100 t. Erie Street
Chicago, Illinois   60611
                                        RE:  Draft Report on 1976 Heeds
                                             Survey for Combined Sewer
                                             Overflows and Storm's ter
Dear Mr. Lynam:
     Thank you for your letter of November 22, 1976, offering comments  on
our draft report which estimated needs for combined sewer overflows and
storrcwater control (Categories V & VI).
      v
     The following is in response to your specific contents :

        1.  The sequencing of storm events has significant impact on
            the percentage of total runoff treated and the percentage
            of annual runoff captured.  However, when storm events
            are separated by short time durations, the concentration
            of pollutants in the latter storm events are lower than
            those of earlier stortr, events.  A sensitivity analysis
            of the results from the computer model show that  there
            is only a ten percent increase in the total cost  for
            combined sewer control by increasing treatment rates and
            decreasing storage volumes such that the captured volune
            is treated over one day as opposed to treating over the
            average tifiie between storms, which is assumed in  the draft
            report .

        2.  After receiving comments from the states, the design storm
            for combined sewer control was changed to the 90th percentile
            starrn for the aesthetics and fish and wildlife criteria
            (DS=2.3 x MRF, where OS = design storm volume and HRF =
            rflean rainfall depth per stonn) and the 96th percentile
            storm for the recreation criteria (f)S=3.91 x tfRF).  We
            feel that this design parameter will more likely  meet the
            water quality cirteria set in Section 3.2.
                                   D-181

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        3.  The combined sewered overflow area for the Chicago urbanized
            area was changed for the final  report to 243,700 acres as
            opposed to the 240,000 acres utilized draft report.   This
            243,700 acres includes the 375  square miles of combined
            sewered area in the district and additional areas outside
            the sanitary district boundaries.

     The final  report, including all comments  received from the  states,
will be forwarded to you in early February,  1977.

     I hope that this has answered your questions,  and if  I  can  be of
further assistance, please let me know.
                                   Sincerely yours,
                                   James  A.  Chamblee,  Chief
                                   Needs  Assessment  Section
                                           (WH-547)
cc: Ted Horn, USEPA Region V
    Needs Survey Coordinatory
                               D-182

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                                               OF THE COUNTY OF MILWAUKEE
                                               P.O. BOX 2079 MILWAUKEE, WISCONSIN 53201
                                               PHONE 271-2403
Sewerage Commission of the City of Milwaukee • Metropolitan Sewerage Commission of the County of Milwaukee


      December 1,  1976
      Mr.  Harold P.  Cahill,  Director
      Municipal  Construction Division
      WH-547
      U.S.  Environmental  Protection Agency
      401  M Street,  S.  W.
      Washington,  D.  C.  20460

      Dear Hal :

      I  have reviewed the draft of the 1976 survey of needs for CSO and feel  that
      more work  needs to be  done to refine this information.

      For  example,  in the ongoing CSO study now being conducted by the Milwaukee
      Sewerage Commission, we are beginning to distill  concepts to a point where we
      can  estimate more closely what needs to be done and the associated capital
      investment.  One of the points that has been established is that along  with
      dealing with the overflows themselves, it will  be necessary to consider a
      program of dredging the Milwaukee River.   There is an accumulation of organic
      solids deposited  at the bottom of the Milwaukee River.  To achieve the
      dissolved  oxygen  level of 5 mg/1 will not only  require the removal of untreated
      overflows,  but  also will  require the removal of the deposited solids in the
      bottom of  the  river.  This combination should restore the Milwaukee RliVer to
      meet  the water  quality requirements imposed by  the State of Wisconsin.'   Further,
      a  technology needs  to  be developed on optimizing the collection and treatment
      systems as  a community or District package.  It is not enough to optimize the
      individual  treatment plants in a district, or to optimize independently the
      solids handling and  disposal  strategies,  or to  optimize independently a system
      of handling  combined sewer overflows.  All of the decision making in these
      three major  areas needs to be done with regard  to an overal1, system basis to
      minimize undesirable impacts  on the water quality, and to minimize the  undesir-
      able  impacts on the  environment by the disposal of the waste sludges.

      I  am  looking forward to seeing you at the meeting in January.

      Best  regards,
     William J.  Katz
     Director of Planning,  Development
      & Consultant  Coordination
Arner. Soc. of Civil Engrs. Landmark Award
                                        1974 Amer. Soc. of Civil Engrs. Wisconsin Engr. Achievement
                                         D-183

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'*•*wen^                       WASHINGTON, D.C.  20460
  <-ir.   dilliorn J.  Katz
  Director of Manninc, i^evelonnsnt  anrf
     Consultant Coordis-ation
  :,oLropolita;i SGWf-:ra}^ know.
   cc:  Tf;d Horn, USE PA iior;ion V
             Survey Coordinator
                                        Sincerely your?,
                                                           Chief
                                                          ection
                                     D-184

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                  CITY  AND COUNTY  OF SAN  FRANCISCO

               DEPARTMENT   OF  PUBLIC   WORKS

                   BUREAU OF SANITARY ENGINEERING
      770 GOLDEN GATE AVE. 3RD FL.    SAN FRANCISCO,CAL. 94102     (415)558-2131

                         November 19,  1976
                                           1976 EPH
                                           Needs Survey:
                                           Cat.'s V and VI
 State Water  Resources  Control  Board
 P- 0. Box  100
 Sacramento,  CA

 Attention:   Mr. Ed  Dito

 Gentlemen:
This letter  is  in  response  to  the  request  of Mr. Dito of your
staff and members  of  the  EPA staff on  the  subject project  to
Mr. Cockburn of my staff  for comments  on the draft  1976 needs
survey report for  combined  sewer overflow  control and storm-
water control    (Categories V  and  VI respectively).

As Mr. Cockburn stated at the  presentation meeting  on November 8,
1976 in the EPA offices,  we are greatly dismayed at the lack of
coordination exhibited by the  EPA  in producing such a report
without any contact with  local or  State agencies who have  been
intimately involved in the  problem.  Further, if it had not been
for Mr. Dito's  invitation,  we  would not have had any opportunity
to comment on this report which might  have severe impact upon the
City's present  program  (as  well as the State's).  The time allowed
to review and comment on  the report was also much too short for
any detailed review.

I am attaching  a list of  the City's general comments with  specific
examples where  we  have had  time to develop them.  Basically, the
report estimates costs about ten times lower than our estimates
for the same facilities.  Also the basic methodology and control
levels selected are subject to severe  question.  There appears
to be little in the report  to  recommend it without  major revision.

In light of the short time  for review  a-id  the possible importance
of such report  in  terms of  funding, it ; <;  our request that the
adoption and publication  of this survey be delayed  pending detailed
review and revision.
                               D-135

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State Water Resources Control Board
November 19.- 1976
Page two
We will be available to answer any questions which you might
have concerning our comments and further to also aid and
support your staff in conveying our comments to the EPA.

                             Very truly yours,
                             A. 0. Friedland, Chief
                             Bureau of Sanitary Engineering
Attach:  As Noted
cc:  EPA
     Region IX  Attn:  Mr. Robert Rock

     EPA
     Municipal Construction Division
     401 M St. S.W. WH 547
   ^ Washington  D.C.  20460    Attn:  Mr. Wen H. Huang

     State of Ore.
     Dept. of Environmental Quality
     1234 S.W. Morrison St.
     Portland, Oregon   97205   Attn:  Mr. C. P. Hilbrick, Jr.
                              D-186

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         LIMITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, D.C.  20460


                                                      1.1  JAM-1977
Mr. A.O. Friedland, Chief
Bureau of Sanitary Engineering
Department of Public Works
City and County of San Francisco
770 Golden Gate Avenue, 3rd Floor
San Francisco, California  94102

                                   RE:  Draft Report on 1976 Needs
                                        Survey for Combined Sewer
                                        Overflows and Stormwater

Dear Mr. Friedland:

     Thank you for your letter of November 19, 1976, offering comments
on our draft report which estimated needs for combined sewer overflows
and stormwater control  (Categories V & VI).

     After reviewing comments on the draft report, several changes have
been made which significantly affect the needs estimates for Categories
V and VI.  The final needs estimate for the State of California is
$385.115 million dollars, as compared with the draft report figure of
$159 million.

     In regard to your specific comments, the decision to apply a
uniform set of wet weather standards and a uniform methodology to
estimate state-by-state needs was developed based on the fact that
nationwide information on a facility-by-facility basis is not available
for either the combined sewer overflow problem or the stormwater problem.

     The method for developing storage volumes and treatment rates was
developed from existing literature and several simplifying assumptions.
The methodology was evaluated in detail in several cities and showed
that the 80th percentile storm event would result in between 10 and 20
overflows per year and capture approximately 80 percent of the rainfall
runoff.  In the final report the control levels for combined sewer will
be increased in response to comments which were received.  The cost of
achieving the aesthetics and the fish and wildlife criteria will be
evaluated for control of the 90th percentile storm period.  The cost of
achieving the recreation criteria will be evaluated for an 98th percentile
storm.  For Category VI, all criteria will be evaluated for an 80th
percentile storm.  The final report will contain an expanded discussion
of toxic pollutants.
                                D-187

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     Section 8.4 and 9.2 of the draft report discussed the differences
in cost estimates between the 1973, 1974 and 1976 estimates.  This
section will be expanded to include comparison of the NCWQ cost estimates
for the final report.

     After a review of the cost equations in the draft report, several
equations for unit processes were modified to represent more accurately
the cost of actual construction.  Significant adjustments were made to
the pumping equation and to the storage equation.  These changes, in
addition to increasing the size of the design storm, provided the major
reasons for the approximate doubling of the Category V cost estimate
that was mentioned earlier.

     Our Sanitary Engineer, Wen Huang, called Mr. R.T. Cockburn and
requested the bid tabulations for the pumping station in question.  As
soon as we receive the material from you and complete the analysis, we
will write to you further on this subject.

     The final report, including all comments received, will be forwarded
to you in early February 1977.

     I hope that this has answered your questions.  If I can be of
further assistance, please let me know.
                              Sincerely yours,
                         James A. Chamblee, Chief
                         Needs Assessment Section
                               (WH-547)
cc:  Mr. John E. Bryson, Chairman
     State Water Resources Control Board
     Post Office Box 100
     Sacramento, California  95801

     Robert Rock, USEPA Region IX
     Needs Survey Coordinator
                              D-188

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         UNITED STATE? FNV'RONME^'T \L. PROTFCTION A1I-.NCV

                          WASHINGTON  O.C.  ?0'18C
Mr. Robert T. Ccckburn
Sanitary Engineer
Bureau of Sanitary Engineering
Department of Public ilorks
City end County of 5?,n Francisco
770 Golden Gate Ave,
3rd F loot-
San Francisco, California   94102
                                             RE:  Draft  Report  on  1-976  Needs
                                                 Survey for  Combined Sewer
                                                 Overflows and Stonrovater
Dear Mr. Cockburn:
     Th^nk you for  your  iattsv  of January  7.  1977,  providing  us^with  three
sets of cost data in  r'3.n  Francisco related  to combined  sawer  overflows  and
stomater control  ('"'.'fegorips  V  ?* VI),

     !.'e have thorouahly gone  over these  cost  data  but were  unable  to
breakdown the cost  items  detailed enough to provide i.'s  vn'th meaningful
?ti«'iy?i s .
     '•'e vvoi'id apt'1' relate you*"  farther  providing  us  of the  cost  breakdown
>f the fol loving  i ,-'jii!S which were  indicated  in your oosv, data:

     1,  Preliminary  pnd Primary Treatment,  (i.e.  the items  included  in
         the Fretreat'>i>ent  Building).
     2.  All work  to  be done under Specification Mo.  22568;  but excluding
         the work  set forth under  bid  items  2,  3,  4 and  ?.

     It will be he'pfu'i if you provide us  with  engineering data along with
 cost data.

     We very much  appreciate your  interest and  assistance.

                                     Siricerel y yours,
                                           ,i  />  '
                                     dames A.  Chainb'lee,  Chief
                                     Needs Assessment. Section
                                             (UH-547)
cc: Robert Rock, US  EPA  Heg.ion IX
    Needs Survey Coordinator
                               D-189

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                  DEPARTMENT OF ENVIRONMENTAL RESOURCES

                              POST OFFICE BOX 2357
                          HARRISBURG, PENNSYLVANIA  17120
                                                  December 1, 1976
James Chamblee, Chief
Needs Assessment Section
Facility Requirements Branch (WH-547)
401 M Street, S. W.
Washington,  D.  C.   20460

Dear Mr. Chamblee:

        In response to Mr. Cahill's letter of October 22, 1976 concerning
the draft report of Needs for Combined Sewer Overflows and Storm Water
Discharges,  I am transmitting the following comments on behalf of the
Region III group of states, which met on November 30,  1976:

        (1)  While we are unable to comment in detail on the techniques
used to compute the needs,  we noted with approval that the procedure avoids
the use of a "broad-brush"  rigid technology requirement for estimation of
treatment levels.

       (2)  We note that  the assimilation capacity of the receiving water is
used.  We agree with this concept.

        (3)  We wish to raise a question as to whether the application of this
concept would require a legislative amendment or some administrative adjust-
ment in view of  the "secondary" treatment requirement.

                                         Sincerely yours,
                                         WESLEY E. GILBERTSON
                                         Special Assistant for Planning
WEG/ch
cc: Region III Group
    Committee of Ten
                                  D-190

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**fc
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460
Mr. Wesley E. Gilbertson
Special Assistant for Planning
Pennsylvania Department of Environmental Resources
Post Office Box 2357
Harrisburg, Pennsylvania  17120
                                   RE:  Draft Report on 1976 Needs
                                        Survey for Combined Sewer
                                        Overflows and Stormwater
Dear Mr. Gilbertson:
     Thank you for your letter of December 1, 1976, offering the Garments
of the Region III group of states on our draft report which estimated
needs for combined sewered overflows and Stormwater control (Categories
V & VT).

     We appreciate your comment on the use of the assimilative capacity
of the receiving water.  It is our interpretation that the secondary
treatment requirement applies to dry weather pollution control works and
does not apply to combined sewer overflows.  In this latter case both a
cost-effectiveness and a cost-benefit analysis is required to determine
the amount and degree of treatment of wet weather flows which are eligible
for Federal grant funding (see PGM 61/PRM 75-34, "Grants for Treatment
and Control of Combined Sewer Overflows and Stormwater Discharges").

     The final report, including all Garments received from the state,
will be forwarded to you in early February 1977.

     If I can be of further assistance, please let me know.

                              Sincerely yours.
                          James A. Chamblee, Chief
                         Needs Assessment Section
                                (WH-547)
cc:  Ken Pantuck, USEPA Region III
     Needs Survey Coordinator
                                 D-191

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                          DELAWARE  RIVER BA5IN COMMISSION
                                        P. D. BOX 73BD
                             WEST TRENTON,NEW JERSEY OBESE
                                       (BD3)  BBB-aSOO
JAMES F. WRIGHT
EXECUTIVE DIRECTOR
HEADQUARTERS LOCATION

 25 STATE POLICE DRIVE

  WEST TRENTON, N. J.
                                              December 1,  1976
        Mr. James Chamblee
        Chief, Needs Assessment Section
        Facility Requirements Branch (WH-547)
        401 M. Street  S.W.
        Washington,  D.C.   20460

        Dear Mr.  Chamblee:

               This is in response to your October 22, 1976 request for comments on your
        1976 Needs Survey Category V, combined sewer overflows, and category VI,
        storm sewers.  We are interested in this report since the  Delaware River at Philadelphia
        was used as an illustration.  The Commission, as part of  a program being carried out
        under Section 208 of PL 92-500, along with EPA Region  III,  Delaware Valley Regional
        Planning Commission, and the States of New Jersey, Pennsylvania and Delaware are
        involved in a storm water survey for the Delaware Estuary to assess the effects of non-
        point pollutants.

                In addition,  under EPA Grant #P003106-01-0 and Section 208 of PL 92-500
        we are developing a two dimensional link-node mathematical model of the Delaware
        Estuary which will be used for establishing waste discharge allocations for point
        source and gross allotments for non-point sources.  The model will evaluate loads
        for current standards and also be used to consider the practicality or revision in standards.
        This program  is scheduled for completion  in 1977.

               We are including a copy of our Water Quality Standards for the Delaware River
        Basin and a copy of the allocated discharges and their River Mileages.  These may help
        your evaluation  of costs or at least complete your data base.

               Thank you for the opportunity to comment on this report.

                                               Sincerely,
                                               Seymour D. Selzer
                                               Head, Planning Branch
        Enclosures
                                          D-192

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            WASHINGTON, D.C. 20460
 Mr.  Seymour D.  Selzer
 Head,  Planning  Branch
 Delaware River  Basin Commission
 Post Office Box 7360
 West Trenton, New Jersey   08628
                                         RE:   Draft Report on 1976 Needs
                                              Survey for Combined Sewer
                                              Overflows and Stormwater
 Dear Mr.  Selzer:
      Thank you for your letter of December  1,  1976, offering comments on
 our draft report which estimated needs  for  combined sewer overflows and
 Stormwater control (Categories V & VI).

      We also appreciate receiving a copy  of the water quality standards
 and allocated discharges for the Delaware River Basin.  This information
 will  be of help in refining the water quality  criteria to be used in the
 final  report.  We are also pleased to hear  of  detailed studies being
 conducted on the Delaware River Basin in  relation to the Section 208
 planning studies.  The mathematical  modeling of the Delaware Estuary and
 resulting waste discharge allocations for all  waste sources will provide
 a much more specific data base for future needs estimates.

      The final report, including all comments  received from the states,
 will  be forwarded to you in early February, 1977.

      If I can be of further assistance, please let me know.
                                    Sincerely,
                                    James  A.  Chamblee, Chief
                                    Needs  Assessment  Section
                                            (WH-547)
cc: Ken Pantuck, Region III
                                D-193

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         INTERSTATE  SANITATION  COMMISSION
 COMMISSIONERS

   NEW YORK

NATAUE COLOSI, PH.D.
   CHAIRMAN
PETER A.A. BERLE
CHESTER SCHWIMMER
   NEW JERSEY
DAVID J. BARDIN
JOSEPH J. BRENNAN
JOANNE E. FINL6Y, M.D.
LOUIS J. FONTENELLI
SAMUEL P. OWEN
                      10 COLUMBUS CIRCLE  •  NEW YORK, N. Y. 10019
                                AREA CODE 212-582-0380
December 1, 1976
                           COMMISSIONERS

                            CONNECTICUT

                         CARL R. AJELLO
                         JOHN P. CLARK
                         JOSEPH N.GILL
                         DOUGLAS S. LLOYD, M.D.
                         JOSEPH ZANDRI
                          THOMAS R. GLENN, JR.
                        DIRECTOR-CHIEF ENGINEER
       Mr.  James  Chamblee,  Chief
       Needs Assessment  Section
       Facility Requirements  Branch  (WH-547)
       U.S. Environmental  Protection Agency
       401  M Street,  S.W.
       Washington,  D.  C.  20460

       Dear Mr. Chamblee:

            At the request of Mr.  Cahill,  we have reviewed and here-
       with offer comments on the  draft report "1976  Survey of Needs
       for  Control of Pollution  from Combined Sewer Overflows and
       Stormwater Discharges" prepared for the U.S. EPA.

       (1)   Within the New York-New  Jersey Metropolitan Area, most
            of the sewers are combined and many are very  large in
            diameter.   These large diameter sewers act as settling
            basins in many cases during dry weather flow.  When it
            rains, therefore, the  combined sewers not only overflow
            the sewage flowing  during  the rainfall but also much of
            the solids and contaminants absorbed on the solids that
            occurred during the  dry  weather.  In reviewing the draft
            report, we are unable to see that this point has been
            realized and it is  an important one since in this region
            possibly as much as 50% or more of the solids in the
            sewers never reach  the treatment plants and thus the
            combined sewer overflow loadings on the receiving
            waters caused by rainfall are considerable.
                                  D-194

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Mr. J. Chaniblee                     -2-  December 1, 1976
 (2)  With the foregoing in mind, it makes little sense to
     commit the limited resources available to achieve
     wastewater treatment levels greater than secondary
     treatment until the combined sewer overflow problem
     can be meaningfully addressed.

     We hope these comments prove useful.  If we may be of
 further assistance, please do not hesitate to contact us.
                              Very truly your
                              Thomas R. Glenn
                              Director & Chief Engineer
TRGtrym
                           D-195

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        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C.  20460
fir. ij'ioinas R. Glenn
Director £, Chief Engineer
Interstate Sanitation Cefnrrission
10 Columbus Circle
itew York, New York  10019
                                         RE:  Draft Renort for 1'376 Heed
                                              Survey for Combined Sev/er
                                              Ovorflov/s and Stonrwatar
uear /*r. Glenn:
     Thank you for your 1 otter of December ls li;76, offering comments on
our draft report which estimated needs for combined sewer nverflovis and
stcrmwater control (Categories V « VI).

     vie agree that tha accumulation of solids in large combined sev/ers
during dry weather periods is a significant portion of the combined
sewer problem.  This was considered In the developepint of the -draft report
and all facilities were- sized such that ths 'first flush11 or heavily
contaminated oortior: of run-off in the earlier stares of the storm avcnt
would be captured and treated to the degree required by the receiving water
analysis.  Only after capture ard treatment of the design storm would any
overflows of combined sewage reach the receiving v/nter.

     The final report, including all comments received from the states,
will be forwarded to you in oarly February, 1977.

     I hope that this has answered your questions.  If ! can be of any
further assistance, please lot me know.

                                       Sincerely yours.
                                             A. Chan;bleas Chief
                                       Needs Assessment Section
                                               (v;H-547)

cc: Robert Olson, USEPA Region II
    Needs Survey Coordinator
                                D-196

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       tyH   SUSQUEHANNA  RIVER  BASIN  COMMISSION
        f/J   5012 Lenker  Street     •     Mechanics burg,  Pennsylvania  17055
  •-o^-iss^r^"
  ^r^'tWHHL-i**^.
                            December  8,  1976
From the Office of the
 Executive Director
  Mr. Harold P. Cahill,  Director
  Municipal Construction Division
    (WH-547)
  U.S. Environmental Protection Agency
  Washington,  DC   20460
  Dear Mr. Cahill:

       This  is  in reply  to your  letter of October 27, 1976 re-
  questing review and  comment on the draft report, "1976 Survey
  of Needs For  Control of Pollution From Combined Sewer Overflows
  and Stormwater Discharges."  We have reviewed the report and
  believe, that as  a national assessment, it provides a good cost
  estimate for  removing  oxygen demanding materials from combined
  sewer overflows.

       Of major significance; however, is the need for control
  of toxic contaminants  associated with urban runoff.  Although
  it was recognized in the subject draft report, costs for the
  removal of toxic  materials are not included in the assessment.
  I believe  this should  be addressed in the future needs survey.

                                   Sincerely yours,
                                   Robert J". Bielo
                                   Executive Director
                                  D-197

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          \
           §    UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
          ^                      WASHINGTON, D.C.  20460
      Mr. Robert J. Bielo,
      Executive Director
      Susquehanna River Basin Commission
      5012 Lenker Street
      Mechanicsburg, Pennsylvania   17055

                                               RE:  Draft Report  on  1976  Needs
                                                    Survey for Combined Sewer
                                                    Overflows and Stormwater

      Dear Mr. Bielo:

           Thank you for your letter of December 8, 1976, commenting on our
      draft  report which estimated  needs for combined  sewer  overflows and
      Stormwater control (Categories V & VI).

           Your comment on  the  need for control of toxic contaminants is
      appreciated and  understood.   However, there was  no nationwide  data  base
      on  the generation rates of these pollutants from Stormwater runoff,
      the removal efficiences by the unit processes for these toxic  materials,
      or  the potential cost-effectiveness of source controls.  Therefore, the
      control of toxic pollutants could not be analyzed in the current needs
      survey.  Completion of on-going 208 studies and  other  Stormwater studies
      will provide a much more  specific data base for  use in the  future needs
      surveys.

           The final report, including all comments received from the states,
      will be forwarded to  you  in early February, 1977.

           I hope that this has answered your questions.  If I can be of  further
      assistance, please let me know.
                                              Sincerely yours,
                                                   A. Chamblee,  Chief
                                              Needs Assessment  Section
                                                      (WH-547)
      cc:   Ken  Pantuck,  Region  III
           Robert  Olson,  Region  II
                                         D-198

U.S. Government Printing Office: 1977-778-573/127 Region 8

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BIBLIOGRAPHIC DATA
SHEET
1. Report No.
EPA-430/9-76-012
                                       MCD-4%C
3. Recipient's Accession No.
4. Title and Subtitle
  1976 Survey of  Needs for Control  of Pollution from
  Combined Sewer  Overflows and Stormwater Discharges
                                                5. Report Date
                                                  February 10,  1977
                                                6.
7. Amhor(s)  Turner,  B.C., Holbrook, R.F.,  Corbitt, R.A. ,  and
	Wycoff,  R.  L.	
                                                8. Performing Organization Rept.
                                                  No.
9. Performing Organization Name and Address
  Jordan, Jones  &  Goulding, Inc.
  2000 Clearview Ave/Suite 200
  Atlanta, Georgia  30340
                                                10. Project/Task/Work Unit No.
                  Black,  Crow & Eidsness,  Inc
                  7201 N.W.  Eleventh Place
                  Gainesville,  Florida 36201
11. Contract/Grant No.
      68-01-1984
12. Sponsoring Organization Name and Address
  U.S. Environmental Protection Agency
  Municipal Construction Division
  Office of Water  Program Operations
  Washington, D.C.    2046Q
                                               13. Type of Report & Period
                                                  Covered
                                                        Final
                                               14.
 15. Supplementary Notes

 Project  Officer: Philip  H.  Graham
16. Abstracts  xhe  1976  Needs Survey  for Category V  (Combined  Sewer Overflows) and  Category
VI (Urban Stormwater Discharges)  developed current and  1990 capital and annual operatioi
and maintenance  cost estimates to attain three water  quality criteria using  a  well
defined consistent  nationwide methodology.  A computer  model was developed from inten-
sive work with the  literature and a detailed analysis of  ten specific urbanized areas.
The model calculates the combined sewer and Stormwater  control needs for each  urbanized
area.  These estimates are then  sumed on a state and  territory basis to provide the
national estimated  needs for Categories V & VI.  The  estimated needs are lower than
those developed  by  earlier Needs  Surveys due to the consideration of receiving water
assimilative capacity, a relatively small design storm, a well defined area  for
Stormwater control, and a nationwide consistent methodology.  The methodology  provides
a reasonable and well defined estimate of the eligible  costs for water quality control
required by combined sewer overflows and Stormwater runoff.  They also provide a
consistent basis for comparison  of relative needs among states.	
17. Key Words and Document Analysis.  17a. Descriptors

   Construction  Grants
   Combined Sewers
   Rainfall
   Storm Sewers
   Wastewater Treatment
   Water Pollution
   Water Quality
   Runoff

17b. Identifiers/Open-Ended Terms

   Needs Survey;  Stormwater, U.S.E.P.A.,  Urban Runoff,  Urbanized Areas, Water  Quality
   Criteria
17c. COSATI Field/Group    8H, 13B
18. Availability Statement

     Release to Public
                                    19. Security Class (This
                                       Report)
                                         UNCLASSIFIED
                                    20. Security Class (This
                                       Page
                                    	UNCLASSIFIED
          21. No. of Pages
            400
          22. Price
FORM NTis-35 (REV. 10-73)  ENDORSED BY ANSI AND UNESCO.
                                                   THIS FORM MAY BE REPRODUCED
                                                                              USCOMM-DC 826S-P74

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