United States Region 4 EPA 904/9^ 1-076
Environmental Protection 345 Courtland Street, NE August 1981
Agency Atlanta, GA 30365
&EPA Environmental Final
Impact Statement
Mammoth Cave Area,
Kentucky
Wastewater Facilities
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA. GEORGIA 3O365
AUG 2 o W\
TO: All Interested Agencies, Public Groups and Citizens
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for proposed wastewater facilities for
the Mammoth Cave Area cities of Munfordville, Horse Cave, Cave
City and Park City, Kentucky and the Mammoth Cave National Park.
This EIS was prepared in compliance with the National
Environmental Policy Act and implementing Agency regulations
(40 CFR Part 6, November 6, 1979). In accordance with these
regulations, the Final EIS will be filed with EPA's Office of
Federal Activities. Availability of the EIS will then be
announced in the Federal Register, beginning a 30-day comment
period. This Agency will take no administrative action on this
project until the close of the comment period.
We will appreciate your review of this document and any
comments you may have. Please send all comments to John E.
Hagan III, P.E., Chief, EIS Branch at the above address.
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Final
Environmental Impact Statement
for
Mammoth Cave Area, Kentucky
Wastewater Facilities
Prepared by
U.S. Environmental Protection Agency
Region IV, Atlanta, Georgia 30365
This Final EIS addresses proposed wastewater facilities for the
Mammoth Cave Area cities of Horse Cave, Cave City, Park City
and Munfordville, Kentucky and the Mammoth Cave National Park..
Eight wastewater management alternatives have been evaluated
with particular attention to the sensitivity of the cave
environment to wastewater discharges, the resource value and
importance of the caves, the complexity of the area's
subsurface hydrology and the financial impacts of the
alternatives on the communities.
Comments or inquiries should be forwarded to:
John E. Hagan III, P.E., Chief
EIS Branch
EPA, Region IV
345 Courtland St, N.E.
Atlanta Georgia 30365
404-881-7458
Approved by
-f0< Ctfsfles R. Jeter
Regional Administrator
Date
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EXECOTXVE SOHMAHf FOB ENVIRONMENTAL IMPACT STATEBE&T
HAHHOTH CAVE AHEA iASTBiATBB FACILITIES
HAHHOTH CAVE AfiEA, KEMfOCKT
Draft ( ) Final
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this practice has been replaced by the use of septic tanks. However*
because of soils, geologic formations and improper septic tank instal-
lation, much of the septic tank effluent drains directly into the
sub-surface streams without proper treatment.
There are five ma-jor population centers in the study area. These
include the municipalities ot Munfordville (1980 population of 1,788),
Horse Cave (1980 population of 2,019), Cave City (1980 population of
1,997), and Park City (1980 population of 603), and the proposed Stag-
ing Area at Mainmoth Cave Park.* With the exception of Park City, these
population centers maintain and operate wastewater treatment facili-
ties. The disposal technique practiced by auntordville and Mammoth
Cave National Park is surface water discharge to the Gre«n River,
Treated effluent is disposed of in Horse Cave and City City, however,
by direct discharge to adjacent sinkholes. The centralized collection
and treatment systems of Cave City and Horse Cave in many ways com-
pounded the problem by discharging larga guantities of wastewater
directly into the subsurface streams without any awareness of the
eventual impacts. Once again it was an expedient solution to a diffi-
cult problem, which resulted in more far ranging problems. To
compound this problem, plant performance at both Cave City and Horse
Cave has been unsatisfactory. This has resulted in discharges of
wastewater with poor treatment and is the reason for many of the prob-
lems which presently occur in the subsurface receiving stream, Hidden
River. \
Much of the problem at the Horse Cave treatment plant has been
caused by industrial flows, which have seriously inhibited treatment
capability at that facility. The treatment olant was designed as a
biological treatment plant to provide secondary levels of treatment.
However, heavy inflows of industrial wastes have hindered the biolog-
ical treatment processes of the plant and has affected the quality of
wastewatec being discharged into the subsurfaca streaas. These events
have had significant impacts upon Hidden River,
Hidden River, which flows through Horse Cave has for many years
caused significant odor problems in downtown Horse Cave. This is in
contrast to the period from 1916-1944 when Hidden River Cave was a
source ot both recreation and water supply. Now, Hidden River is
severely degraded, and the source of serious odor problems.
Problems in the area are further compounded by the proliferation
of tourist related facilities, especially those along Kentucky, Route
70, which is a major entrance to Mammoth Cave National Park. Many of
these facilities rely upon on-lot disposal systems. Additionally,
Park City is served primarily by on-lot systems with approximately 80%
of the residences and businesses discharging untreated wastewater
directly to the subsurface. The remaining 20% have septic tanks which
result in a direct discharge to the subsurface streams.
The major concern with the tourist facilities along Kentucky
Eoute 70 and Park City is that they are in sub-surface drainage basins
which flow into Mammoth Cave National Park and wastawater from improp-
*These are 1980 Preliminary Census population figures.
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erly installed, operated, and maintained on-lot systeas aay affect
subsurface water quality in and around the Park. Furthermore, the
boundaries o£ the sub-basins are not fixed. They move in unknown ways
depending on qroundwater levels in the aquifer and on the flood stage
ot the surface rivers, This is caused by the filling of normally dry
cave passages which may spill over into adjacent basins. This effect
is particularly important with respect to Echo River Springs which is
located in Mammoth Cave National Park, Under low flow conditions Echo
River spring derives its water almost entirely from the region of Maa-
moth Cave Bidqe and much of its catchment is within the National Park.
Under high flow conditions, a spillover occurs at an unknown point and
water from the Park City-Cave City area of the Sinkhole Plain flows
und^r the ridges to greatly augment the flow of Echo River spring.
This implies that pollutants introduced in the more highly populated
part of the Central Kentucky Karst could be carried into the National
Park, affecting aquatic life in the low level passages and even reach-
ing portions of the cave close to those used by visitors.
Efforts to develop wastewater management systems that are compat-
ible with the area's sensitive natural resources must also consider
the local economic climate and the ability of the community to suc-
cessfully support a wastewater manaqemeat system, In this regard the
financial impact of the wastewater management alternative on the com-
munities in the study area is an additional concern that is critical
to this EIS.
B. DESCRIPTIOM OF <EBH&TIYES
This EIS was initiated in October, 1977. The focus of the EIS
was to develop aad evaluate wastewater management systems in the study
area which would ensure tue integration of environmental and economic
considerations. During the development of the EIS certain issues were
identified as more significant in developing and selecting a vaste-
water management alternative. These included:
I- The sensitivity of the cave environment to wastewater
discharges,
2, Resource value/importance of the caves.
3. Complexity of the area's subsurface hydrology.
U. Financial impacts of wastewater management systems and
funding options.
To address these issues eight wastewater management alternatives
were generated in. the 2IS. These eight alternatives range froi a
regional management concept involving local treatment and -foiat dis-
posal by all population centers (except for lunfordville) to local
treatment and local disposal of wastewater at each population center.
Each alternative was evaluated with respect to cost, impacts on
the natural environment and man-made environment and operabilitv.
4
111
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From this evaluation three alternatives exhibited the greatest
promise. A cost comparison of these three alternatives is presented
below:
Alternative #
2
5
8
Project
cost
$10,574,000
6,546,000
5,876,000
Annual
0 5 «
$261,000
230,000
249,000
Net Present
Worth
$1 1 ,620,000
7,975,000
7,630,000
Ot additional concern in the evaluation of alternatives is the esti-
mated user costs of the alternatives, and the local implications of
these costs. These costs for alternatives 2, 5, and 8 for three of
the communities are presented below-
Alternative
2
5
8
Horse Cave
$39/yr/EDU*
$40
$44
Cave t
$68
79
71
:ity
Park City
$425-495
145-165
145-157
•Equivalent Dwelling Unit
NOTE* Horse Cave and Cave City existinq user costs are not
included.
Alternative^
JJL Descriptign_of _Alternatife_25.
This alternative involves the following components of a
regional system:
• Local treatment facilities at. each population center,
» Joint disposal of all effluent (except Kuntordville) via
surface water discharge (secondary treatment) to the
Green River.
• Existing facilities at Cave City and Horse Cave would
require upgrading.
• New facilities would be reguired at Park City and the
Staging Area,
* Additional on-lot systems would be reguired at Munford-
ville.
IV
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An inter-city conveyance and disposal line would be
required.
a. Provides greatest amount of protection for free
flowing groundwater, groundwater supplies, sensitive
cave systems and rare and endangered species by
removing all wastewater discharges from the subsur-
face water network,
b. Corrects existing water guality problems in the Hid-
den River groundwater sub-basin,
c. Corrects existing odor problems in Horse Cave. i
d. Exhibits greatest overall system operability (reli-
ability, flexibility and maintainability),
e. Has received the support of the communities, envi-
ronmental/conservation groups and the National Park
Service,
t. Provides service to existing development along Route
70 (between Cave City and the National Park) and
affords protection of sensitive areas froa saste-
water discharges,
g. Received a high rating with regard to natural and
man-made environmental itapact.
a. Has the highest net present *orth cost,
b. The cost to Park City would be prohibitive unless
other funding sources could be tapped,
c. The potential exists for development to be encour-
aged along Route 70. In this instance, non-point
source problems could adversely impact area cave
systems.
d. There is currently no multi-city or county sewer
authority to implement this option, Local communi-
ties are, however, in the process of developing one.
e« Considerable construction activity is associated
with the inter-city conveyance and disposal line
(114,000 feet, of gravity lines and force sains),
v
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This alternative involves the following components:
Local treatment facilities at each population center.
Joint disposal of Horse Cave's and Cave City's effluent
via surface water discharge (secondary treatment) to the
Green River.
Existing facilities at Horse Cave and Cave City would
require upgrading.
Additional conventional and alternative on-lot systems
would be required at Park City,
Additional on-lot systems would be required at Hanford-
ville.
The Park's proposed Staqinq Area would employ on-lot
systems.
£ros_of_41tergatii:e_.5i
a. Has the next to lowest net present worth cost,
b. Corrects the obvious water quality and odor problems
in the Hidden River qroundwatec sub-basin by remov-
inq Horse Cave's and Cave City's sub-surface dis-
charges.
c. As with #2 provides the qreatest degree of pro-
tection of the qrouudwater system and cave environ-
ment for the Hidden River sub-basin.
d» Involves less than half of Alternative 2*s con-
struction activity for the inter-city conveyance
system (approxiaately 51,000 feet of gravity lines
and force mains),
e. tfhen compared to #2, the local cost is significantly
less for Park City, slightly more for Cave City and
the same for Horse Cave,
VI
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f. If the force mains from Cave City to Horse Cave to
the Green River were desiqned to include flows frora
the Staging Area and Park City, this alternative
could be the initial phase of »hat could eventually
be a regional system to include Park City and the
Park Service.
a. Existing residential and commercial developments now
using on-lot systems in Park City and along Kentucky
Route 70 would not be served* According to the Park
Service's dye tracing studies these areas are
drained by qroundwater basins that clow through the
Park. Although no problems have yet been detected,
the potential does exist for the continued use of
these on-lot systems to adversely impact these sen-
sitive areas and the proposed critical habitat of
the Kentucky Cave Shrimp within the boundaries of
the Park,
b. Tue local cost to Cave City is slightly higher than
c. System operabilitv (reliability, flexibility and
maintainability) is less than #2.
d. Although this alternative does address the water
quality problems in Horse Cave and Cave City, it
does not receive the support of the Park Service and
other interests as does #2 because all sab-surface
wastewater discharges are not removed*.
B§scriBtioa_gf_Alte£aat4f§_85.
This alternative involves the following components;
Local treatment facilities at each population center.
Additional conventional and alternative on-lot systems
at Park City.
On-lot systems at the Park's proposed Staging Area.
vii
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Cave City's existing facility would require upgrading
tor sub-surface discharge (advanced secondary
treatment).
Horse Cave's existing facility would require upgrading
tor surface water discharge (secondary treatment) to the
Green River.
Additional on-lot systems would be required at Munford-
ville.
2«. £ro§_of_Alter native _8
a. Has the lowest net present worth cost
b« Lowest local costs for Cave City and same local cost
for Park City as in Alternative 5,
c, Bemoves Horse Cave's discharge from the Hidden River
Sub-basin-
d. Least amount of construction activity for inter-city
conveyance and disposal system (approximately 36,000
feet of gravity lines and force mains).
3*. Cgns_of_Alte£natiie_8
a. Existing residential and commercial deveiopaents now
using on-lot systems in Park City and along Boute 70
would not be served. According to the Park Ser-
vice's dye tracing studies, these areas are drained
by groundwater basins that flow through the Park.
Although no problems have yet been detected, the
potential does exist for the continued use of these
on-lot. systems to adversely impact these sensitive
areas and the proposed critical habitat of the Ken-
tucky Cave Shrimp within the boundaries of the Park.
b. Cave City's sub-surface discharge would not be
removed. The potential for the Hidden River
sub-basin to be adversely impacted by wastewater
discharges does exist.
c. This option is rated lowest concerning inpacts to
the natural and roan-made environment*
d. This option is rated lowest concerning systems oper-
ability (flexibility, reliability, and maintainabil-
ity).
Vlll
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e. This option has received the least amount of support
from the ParK Service, study area communities and
interested groups and individuals.
f. Although wasteload allocations for sub-surface dis-
charges have been developed, a lesser degree of con-
fidence is attached to these allocations than to
surface water discharges.
g. This option would preclude the possibility of Park
City or the Park Service being served by a regional
system.
C. PREFERRED ALTEHiATI¥E
The underlying theme of the EIS is that the provision of waste-
water services should be compatible with efforts to preserve and pro-
tect tne Mammoth Cave Area's nationally significant cave systems and
their unigue physical, biological and historical resources. It is
therefore incumbent upon EPA to explore all available mechanisms to
achieve an environmentally sound alternative that is sensitive to eco-
nomic realities. The selection of the least costly alternative is not
EPA's only aim, but rather the selection of an environmentally protec-
tive alternative that is locally affordable. In this regard, a
regional system is viewed as the environmentally preferred option.
However, local economic constraints dictate that other environmentally
acceptable options de pursued.
In light of the concerns regarding cost and the protection of the
cave resources, the approach selected by EPA is a phased approach
whica, depending on local decisions, will ultimately result in a
regional (Alternative 2) or semi-regional (Alternative 5) wastewater
management system.
1. The initiation of Phase I of the pro-ject which would
provide for design for upgrading the treatment facili-
ties at Cave City (0.37 mgd) and Horse Cave (0.53 aigd)
and for conveyance facilities to the Green Biver. The
conveyance facilities would be evaluated with and with-
out future flows from Park City, (0.08 mgd) the proposed
Mammoth Cave National Park Staging Area (0. 105 mgd), and
the Route 70 area.
2. The establishment of a critical decision date to coin-
cide with completion of the preliminary design for Horse
Cave and Cave City for the NPS's decision regarding the
development of the proposed Staging Area or the local
communities* commitment to obtain additional non-EPA
funding sources.
3. Ttie initiation of Phase II of the project which would
provide for final design for facilities based on the
above decisions. At that point, EPA and the Common-
wealth of Kentucky will also have to define the extent
IX
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ot EPA eligibility for remaining design and
construction.
• If the NFS does develop the Staging Area and is
able to provide significant funding assistance for
Park City or additional non-FPA funds are
available, the remaining components ot" the regional
alternative could be constructed. These con-
struction elements would involve treatment
facilities at Park City and the Mammoth Cave
National Parfc Staging Area, conveyance facilities
from Park City to the Staging Area along Eoute 70
to Cave City and expand Cave City's facility to
0.58 mgd. This would, in essence, be Alternative
2.
• If the NFS does not develop the proposed Staging
Area or additional non-EPA funds are not available,
the remaining components of a semi-regional alter-
native would be constructed. This construction
element would involve on-lot systems for Park
City's residential areas and a comaunity
sub-surface absorption field for the Park City
business district. Presently available funding
mechanisms would allow for EPA participation in the
cost of these activities but would he contingent on
congressional continuation of these sechanisras,
Also, funding would have to be in accordance with
the State priority list. This would, in essence,
be Alternative 5.
The regional alternative is most responsive to local and the NPS
desires regarding protection of the groundwater and the cave systems.
However, because of high cost and the resultant financial burden to be
seen locally, the regional alternative may not be viable at this tiae.
Local funding decisions to be made in the near future are critical to
the ultimate wastewater management system for this area, Additional
non-EPA funds must he available for a regional system to be affordable
to Park City, Until the appropriate decisions related to SPS funding
or other non-EPA financial assistance are made, EPA is moving to
resolve existing wastewater management and water guality problems. In
essence, the proposed phase approach allows foe resolving the current
more serious problems waiile remaining flexible to future local funding
decisions. Figure 3-1 presents the preferred approach to wastewater
management in the Mammoth Cave study area, as recommended in this EIS,
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FIGURE S-l
MAMMOTH CAVE AREA
PREFERRED STRATEGY FOR WASTEWATER MANAGEMENT
PHASE I
MUNFORDVILLE
MAMMOTH
CAVE
NATIONAL
PARK
HORSE CAVE
STAGING AREA
CAVE CITY
PARK CITY
YES
NPS OR ADDITIONAL NON-EPA
FUNDING AVAILABLE ?
NO
PHASE H
o
o
ALTERNATIVE 2
ALTERNATIVE 5
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D. DRAFT EIS COHMESTS
Comments on the Draft Statement were received from the following;
_ Agencies
U.S. Array Corps of Engineers
Department of Health and
Human Service's
Environmental Health
Services Division
U.S. Department of the Interior
- Office of the Secretary
- National Park Service
- Fish and Wildlife Service
State_Ggvernieftt
Kentucky Department for Natural Resources and
Environmental Protection
- Division of Water
- Office of the Secretary
Kentucky Heritage Commission
Ohio fiiver Basin Commission
Kentucky Department of Fish and Wildlife Resources
Office of State Archaeology
Kentucky Department of Transportation
Cave City Council (Leo E. Esters)
Interest ed_Grougs
Club
XI
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Jack L. Abn?y, Environmental Planner
Tom Chaney
Campbell Wallace
Tom Aley
XII
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TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
*
A. Existing Problem
B. Description of Alternatives lx
C. Preferred Alternative
I. Introduction 1-1
II. EPA Decision II-l
A. Description of the Proposed Action II-l
B. Purpose of and Need for Action II-4
C. Cost Evaluation Summary I I -6
D. Environmental Evaluation Summary I 1-7
E. Implementability Summary 11-11
F. EIS Requirements 11-12
III. Draft EIS Summary III-l
A. Background of the Study III-l
B. Alternatives Development and Evaluation III-l
C. Description of the Preferred Alternative III-3
D. Description of the Study Area III -7
1. Existing Natural Environment III-7
2. Existing Man-made Environment III-ll
E. Environmental Impacts of the Preferred Alternative 111-14
F. Mitigative Measures, Recommendations and Requirements 111-13
G. EIS Coordination III -18
IV. Revisions to the Draft EIS and Additional Information IV-1
V. EPA Responses to Comments Received on the Draft EIS V-l
A. Index of Written Comments V-2
B. Index of Oral Comments Received at the Public Hearing V-4
C. Responses to Written Comments V-5
D. Responses to Oral Comments V-1S
VI. Transcript of Public Hearing Held on June 8, 1981 on Draft EIS VI-1
VII. Comments Received on Draft EIS VI I -1
VIT1. List of Preparers VIII-1
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LIST OF TABLES
Table Page
II-l Preferred Alternative Cost Summary 11-8,9,10
III-l Present Worth Analysis Update 111-4,5
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LIST OF FIGURES
Following
Figure Page
S-l Mammoth Cave Area Preferred Strategy x
for Wastewater Management
II-1 Wastewater Management Alternative 2 11-4
11-2 Wastewater Management Alternative 5 11-4
III-l Mammoth Cave Area EIS Alternatives III-3
(Schematic Illustration)
III-2 Mammoth Cave Area Preferred Strategy II1-7
for Wastewater Management
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I. INTRODUCTION
This Final Environmental Impact Statement (FEI.S) foe the Mammoth
Cave Acea Wastewater Facilities, Mammoth Cave, Kentucky supplements
the Draft EIS issued in April 1381. The EIS has been prepared in
accordance with the Council on Environmental Quality (CEQ) Guidelines
and EPA Guidelines for the preparation of Environmental Impact State-
ments. This EIS is also in response to the requirements of Public Law
91-190, the National Environmental Policy Act of 1969, which requires
the preparation of an EIS for any major Federal action that will sig-
nificantly affect the quality of the environment. While this summary
document is intended to be comprehensive, the supporting information
furnished with the Draft EIS should be reviewed and is incorporated
here by reference. It is to be noted that this Final BIS supercedes
the Draft EIS wherever conflicts between the two exist,
I
The Final EIS contains eiqht major sections. Section II, EPA
Decision, describes in detail the preferred alternative and the evalu-
ation process that led to the selection of this alternative. Section
III presents a summary of the Draft EIS, including a review of each
Chapter in the Draft EIS and major findings and recommendations. Sec-
tion IV presents any revisions and additional information gathered
after issuance of the Draft EIS in April 1981. EPA*s responses to
comments received on the Draft EIS are tabulated is Section V, The
written comments, and the oral comments received at the Public Hearing
are indexed in this section. Section ¥1 contains the transcript of
the Draft EIS Public Hearing held on June 8, 1981. Additional com-
ments received on the Draft EIS are presented in Section 711. A list
of EIS preparers is presented in Section VIII,
1-1
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II. EPA DECISION
&. DESCRIPTIOH OF THE PROPOSED &CTIOB
The underlying theme of the BIS is that the provision of waste-
water services should be compatible with efforts to preserve and pro-
tect tne ^Mammoth Cave Area's nationally significant cave systems and
their unique pnysical, biological and historical resources. It is
therefore incumbent upon EPA to explore all available mechanisms to
achieve an environmentally sound alternative that is sensitive to eco-
nomic realities. The selection of the least costly alternative is not
EPA *s only aim, but rather the selection of an environmentally protec-
tive alternative that is locally affordable. In this regard, a
regional system is viewed as the environmentally preferred option,
However, local economic constraints dictate that other environffleatally
acceptable options i>e pursued.
In light of the concerns regarding cost and the protection of the
cave resources, the approach selected by EPA is a phased approach
whicu, depending on local decisions, will ultimately result in a
regional (Alternative 2} or semi-regional (Alternative 5) wastewater
management system,
This approach would involve the following components:
U Initiate Phase I of the project which would provide for
design for upgrading the treatment facilities at Cave
City (0.37 ragd) and Horse Cave (0-53 mcjd) and for con-
veyance facilities to the Green River. The conveyance
facilities would be evaluated with and without future
flows trorn Park City (0.08 ragd), the proposed Mammoth
Cave National Park Staging Area (0.105 mqd) r and the
Route 70 area.
2. The establishment, of a critical decision date to coin-
cide with completion of the preliminary design for Horse
Cave and Cave City tor the NPS's decision regarding the
development of the proposed Staging Area or the local
communities* commitment to obtain additional non-SPA
funding sources.
3. Initiate Puase II of the project which would provide for
final design for facilities based on the above
decisions. At that point, EPA and the Commonwealth of
Kentucky will also have to define the extent of EP&
eligibility for remaining design and construction,
• If the NPS does develop the Staging Area and is
able to provide significant funding assistance for
Park City or additional non-EPA funds are
available, tha remaining components of the regional
alternative could be constructed. These con-
struction elements would involve treatment
II-l
-------
facilities at Park City and the Mamaoth Cave
National Park Staqinq Area, conveyance facilities
from Park City to the Staqinq Are* alonq Route 70
to Cave City and expand Cave City's facility to
0.58 ragd. This would, in essence, be Alternative
2.
• It the NP3 does not develop the proposed Staging
Area or additional non-EPA funds are not available,
the remaining components of a semi-regional alter-
native Mould be constructed, This construction
element would involve on-lot systems for Park
City's residential areas ind a coniaunity
sub-surface absorption field tor the Park City
business district. Presently available funding
mechanisms would allow for EPA participation in the
cost of these activities but. would be contingent on
Congressional continuation of these mechanisms,
Also, funding would have to be in accocdaace with
the Stata Priority list, This would, in essence,
be Alternative 5,
The regional alternative is most responsive to local and NFS
desires regarding protection of the groundwater and the cave systems.
However, because of the high cost and the resultant financial burden
to be seen locally, the regional alternative may not be viable at this
time. Local funding decisions to be made in the rear future are crit-
ical to the ultimate wastewater management systems for this area.
Additional non-EPA funds must be available for a regional systen to be
affordable to Park City. Until the appropriate decisions related to
NPS funding or other non-EPA financial assistance are made, EPA is
moving to resolve existing wastewater management and water quality
problems. In essence, the proposed phased approach allows for resolv-
ing the current more serious problems while remaining flexible to
future local funding decisions. Figure S-1 in the Executive Summary
describes the proposed strategy for wastewater management in the study
area.
Bf fluent.. Li fits
Under the preferred action, all treated wastewater from Horse
Cave and Cave City would be conveyed to the Green River for disposal.
Because of the large 7 day, 10 year low flow, approximately 160 cfs,
effluent limitations tor the Green Siver are secondary treatment lev-
els. This would mean a discharge of 30 rag/1 of suspended solids and
30 mg/1 of 8005 .
11-2
-------
?escriBtion_of_ Proposed _f agilities
Horse __ Cave : The Horse Cave wastewater treatment facility is a
hicjh-rate trickling filter plant designed for a hydraulic loading
of 0.4 niga and a RODs loading of approximately 870 Ibs/day, Major
wastewater treatment processes include grit removal, comminution, pri-
mary sedimentation, trickling filtration, secondary sedimentation and
chlorinatiou. According to the 201 W'astewater Facilities Plan the
Horse Cave plant is capable of producing an effluent BOD 5 of approxi-
mately 50 isg/1 if operated at optimum efficiency. (This is contingent
on adequate pre- treatment of industrial wastewater.)
Sinc« the existing facility is capable of providing substantial
BOD5 removal, it appears that a second stage biological treatment step
in series with existing trickling filter process is the most appropri-
ate method of treatment for upgrading plant effluent- Therefore it is
recommended that an activated sludge second stage biological treatment
step be added to the process train* In addition, a new secondary
claritier is also recommended, A flow egualizatiom basin is also
recommended to handle industrial flow eminating from Ken Dec,
Cave __ City.: The Cave City treatment plant provides biological waste-
water treatment by means of a high-rate trickling filter with a design
capacity of 0,37 mgd. The Cave City treatment plant would also be
upgraded to provide secondary level treatment through the addition of
activated sludge and a new secondary clarifier to the existing
process. Should the National Park Service develop the Staging Area,
then the regional system option {Alternative 2) would involve con-
struction of treatment facilities at Park City and the Staging Area,
conveyance facilities from Park City to the Staging Area along Route
70 to Cave City and expansion of Cave City's facility to 0.58 mgd,
£sLE.!L_Citl" Under this preferred alternative. Park City would have two
options. If the National Park Service develops the Staging Area and
provides funding assistance or, if additional non-SPA funding assist-
ance is available thwn a centralized collection and treatment system
would be constructed at Park City, However, if there is no partic-
ipation, then Park City could utilize the option of a community low
pressure sewer system for collection and a community soil absorption
field for the downtown area. Outlying areas would utilize on-lot sys-
tems.
6-7 This facility would continue to serve the existing ser-
vTce area. Homes and businesses outside the existing service area
would be served by on-lot systems (septic tanks) .
tfa§moth __ Cave __ National __ Park.l§_P£op.os-ed_Staging_Area: Under the pre-
ferred alternative, the proposed Staging Area would~have two options.
I." the Staging Area is part of tue regional system option under Phase
2f then a wastewater treatment facility would be constructed to sertre
the Staging Area. Treated wastewater from Park City would be pu raped
to the Staging Area, mixed with the Staging Area wastewater and pumped
II-3
-------
ultimately to the Green Fiver for surface water discharge. If the
Staging Area is part of the serai-regional system option under Phase 2,
then composting waterless toilets - septic taak/soil absorption sys-
tems are recommended. It snould be noted that facilities for the Park
Service are rot EPA grant eligible and these costs would be borne
solely by the Park Service,
Route 70 area: Under the preferred alternative, the Route 70 ar«a
7between~~the~~Park
-------
N
i MAMMOTH
NATIONAL
(PARK /
/
LEGEND
MAMMOTH CAVE NATIONAL PARK
FORCE MAIN
GRAVITY INTERCEPTOR
EXISTING TREATMENT FACILITY
UPGRADED EXISTING FACILITY
NEW WASTEWVTER TREATMENT FACILITY
PUMPING STATION
ON-LOT SYSTEMS
LAND APPLICATION SITE
FIGURE H-l
MAMMOTH CAVE AREA
201 FACILITIES PLAN
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER MANAGEMENT
ALTERNATIVE 2
(PC-SA-CC-HO2 PLUS MN-I
12.000 6000 0 I2.0OO 24,000
Scale In Feet
U.S. Environmental Protection Agency
Region TV Atlanta,Georgia
-------
LEGEND
MAMMOTH CAVE NATIONAL PARK
FORCE MAIN
GRAVITY INTERCEPTOR
EXISTING TREATMENT FACILITY
UPGRADED EXISTING FACILITY
PUMPING STATION
ON-LOT SYSTEMS
LAND APPLICATION SITE
FIGURE H-2
MAMMOTH CAVE AREA
201 FACILITIES PLAN
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER MANAGEMENT
ALTERNATIVE 5
SA PLUS PC-2 PLUS(CC-HC)8 PLUS MN-
12,000 6000
12,000
24,000
Scole In Feet
U.S. Environmental Protection Agency
Region TV Atlanta,Georgia
-------
ticed by Munfordville aud Mammoth Cave National Park is surface water
discharge to the Green River. Treated effluent is disposed of in
Horse Cave and Cave City, however, by direct discharge to adjacent
sinkholes. This practice has the potential to adversely impact the
unique underground cave systems of the study area, primarily because
of the quality of the effluent discharged. Recent sampling data indi-
cates unsatisfactory performance dt the Horse Cave plant principally
due to industrial wastewaters discharged to the plant, Slightly over
50 percent of the daily average flow is untreated industrial waste-
water from the Hart County Creamery and Ken Dec's electroplating
plant, resulting in influent high in SOD and heavy aetals concen-
trations. Also, the Cave City plant is not providing the level of
treatment reguired by its NPDES permit, according to plant performance
data.
Already plagued with severe subsurface water pollution problems
is the Hidden River Cave cotaplex situated in downtown Horse Cave.
Once a tourist attraction and a water supply source, the Hidden River
is now the recipient of inadeguately treated wastesater discharges
from the Horse Cave and Cave City treatment plants. This has
resulted in severe odor problems and the degradation of the entire
Hidden River Cave environment.
Problems in the area are further compounded by the proliferation
of tourist related facilities, especially those along Kentucky Eoute
70, which is a major entrance to the Park, Many of these facilities
rely upon on-lot disposal systems. Additionally, Park City is served
primarily by on-lot systems with approximately 80% of the residences
and businesses discharging untreated wastewater directly to the sub-
surface, The remaining 20% have septic tanks which result in a direct
discharge to the subsurface streams.
The major concern with, the tourist facilities along Kentucky
Route 70 and Park City is that they are in sub-surface drainage basins
which flow into Mammoth Cave National Park and wastewater from improp-
erly installed, operated, and maintained on~lot systems aay affect
subsurface water guality in and around the Park, Furthermore, the
boundaries of the sub-basins are not fixed, They move in unknown ways
depending on groundwater levels in the aquifer and on the flood! stage
of the surface rivers. This is caused by the filling of noraally dry
cave passages which may spill over into adjacent basins. This effect
is particularly important with respect to Echo River Springs which is
located in Mammoth Cave National Park, Under low flow conditions Echo
River Spring derives its water almost entirely froia the region of Mam-
moth Cave Ridge and much of its catchment is within the National Park.
Under high flow conditions, a spillover occurs at an unknown point and
water from the Park City-Cave City area of the Sinkhole Plain flows
under ttie ridges to greatly augment the flow of Echo River spring.
This implies that pollutants introduced in the more highly populated
pact of the Central Kentucky Karst could be carried into the National
Park, affecting aguatic life in the low level passages and even reach-
ing portions of the cave close to those used by visitors.
II-5
-------
C. COST EVALUATION SOflHART
A detailed evaluation of all significant cost components of the
alternative wastewater management systems is required in order to per-
form the comparative cost analysis. Construction, project, and opera-
tion and maintenance costs are developed for each management systea
for incorporation into a net present worth cost analysis. The present
worth cost analysis establishes a basis for comparison of total costs
(capital and annual operations costs) for each of the wastewater man-
agement alternatives. Tuese total costs include the federal share of
the costs associated with construction grants. Comparative cost anal-
ysis (eithet present worth or equivalent annual cost) is an EPA
requirement in performing the cost effectiveness analysis and serves
as the primary cost evaluation criterion according to EPA guidelines.
Cost_Defelopaent
Construction, project and operation and maintenance costs are
developed for all wastewater facilities in each management system.*
Available local cost, data from recent similar projects, standard
costing sources and detailed engineering estimates are used in cost
development. All costs are trended to mid-1979 price levels project-
ed for the Mammoth Cave area.
As previously noted, the alternative wastewater management sys-
tems have been compared on the basis of their relative net present
worth in accordance with EPA regulations. The present worth analysis
establishes an estimated total cost value of the capital expenditures
(project costs) and operating cost of each alternative over the dura-
tion of the planning period. For the purposes of this net present
worth evaluation, construction of the wastewater facilities in the
wastewater management alternatives is assumed to take place in 1983
resulting in a 17-year planning period ending with the year 2000, The
discount rate use in the net present worth analysis is 7,125 percent.
In accordance with EPA guidelines, allowances are made for salvage
*Cost estimates tor wastewater management are developed readily
from detailed estimates prepared for the cost evaluation of local and
joint wastewater treatment/disposal options. Since each of the waste-
water management alternatives is composed of two or more recommended
options, the estimated cost tor any management alternative is the sum
of the costs of wastewater facilities (collection, conveyance, treat-
ment and disposal) associated with the recommended treatment/disposal
options incorporated into that management alternative.
II-6
-------
value at tbe end ot the planning period. Also, phasing of con-
struction is included in the analysis where applicable.
The present worth analysis of the preferred strategy (showing
both future options available to Park City and the proposed Staging
Area) is shown in Table T.I-1. The present worth costs of the eight
EIS Alternatives are presented in Table III-1 in Section III.B.'of
this document.
0. ENVIRONMENTAL Bf&LO&TIOH SOHH&RT
An evaluation was conducted to assess and compare the impacts of
alternative wastewater management plans on the natural and nan-nade
environment. A parameter-checklist evaluation methodology was used to
analyze the impacts tor the eight wastewater management alternatives.
This methodology presented a specific list ot" environmental parameters
to be investigated for possible impacts but did not reguire the estab-
lishment of direct cause-effect links to project activities.
A scaliug-weighting checklist was used in this project for the
evaluation or potential impacts to the environment. Scaling factors
were used to estimate the relative magnitude of impacts while weight-
ing factors were assigned to each environmental parameter and were
constant tor all alternatives. Scaling factors varied according to
the magnitude of the impact for each alternative.
The impact scaling factors could be beneficial (*) or adverse
(-) . The score for an environmental parameter wastewater management
alternative combination, is the product of the weight and the scale,
The summation of the parameter alternative scores for an individxial
alternative yields a cumulative comparative score for that.
alternative,
The natural environment evaluation for the preferred strategy
indicates that Alternative 5 received the highest, rating and Alterna-
tive 2 was tied for fourth. Both 5 and 2 were shown to positively
impact odor, subsurface water guality, surface water guantity, cave
ecology and rare and endangered species; while negatively impacting
air guality, topography, geology, noise, surface water quality and
surface ecosystems*
The man-made environment evaluation for the preferred strategy
indicates that Alternative 2 was given the highest, rating and Alterna-
tive 5 was rated second. Both 2 and 5 were shown to positively impact
population, land use, economic conditions, historical/cultural/archae-
ological, resources, recreational resources, wastewater programs, water
supply and community services; while negatively impacting transporta-
tion facilities. The overall environmental evaluation resulted in
Alternative 5 achieving the highest rating, while Alternative 2 tied
for the second highest rating.
The environmental impacts ot the preferred alternative are dis-
cussed in more detail in Section III.E.
II-7
-------
TABLE II-l
PREFERRED ALTERNATIVE COST SUMMARY
Present Worth Analysis
t-l
f-H
1
OO
Wastewater
Management
Alternative
Alternative 2
(PC-SA-CC-HC)2
plus MN-1
Alternative 5
SA plus PC- 2
plus (CC-HC)8
plus MN-1
Wastewater
Management
Alternative
1981
Pro j ect
Cost
10,574,000
6,546,000
Construction
Costs
Present
Annual Worth
Of|M Annual
Costs 0£M Costs
261,000 2,527,000
230,000 2,226,000
Estimated
Assumed
Grant
Project Eligible
Costs Project Costs
Total
Present
Worth
13,101,000
8,772,000
Local Annual
Anticipated
Grants
Year 2000
Salvage
Value
4,770,000
2,568,000
Costs
Local
Share
Project
Costs
Present
Worth
Salvage
Value
1,481,000
797,000
Annual
Debt •"-•"
Service
Net
Present
Worth
11,620,000
7,975,000
Annual
OSM
Costs
Local
Annual
Costs
Alternative 2
(PC-SA-CC-HC)2
plus MN-1
Alternative 5
SA plus PC-2
plus (CC-HC)8
plus MN-1
8,333,000 10,574,000 8,615,000 6,518,000 2,756,000 417,000
5,110,000 6,546,000 5,769,000 4,502,000 1,758,000 210,000
261,000 678,000
226,000 436,000
-------
Alternative 2
(PC-SA-CC-HC)2
plus MN-1
Alternative 5
SA plus PC-2
plus (CC-HC)8
plus MN-1
TABLE II-l (Cont'd.)
Estimated Annual User Costs
Wastewater
Management
Alternative
1981
Project
Costs
Park City
Annual Total Annual
0£jM Local Costs Annual
Costs (with grant) User Costs
1981
Project
Costs
Cave City
Annual Total Annual
0§M Local Costs
Costs (with grant)
Annual
User Costs
3,652,000
1,249,000
40,000
26,000
149,000
50,000
$425-495
$145-165
1,835,000
2,340,000
68,000
73,000
123,000
143,000
$68
$79
Alternative 2
(PC-SA-CC-HC)2
plus MN-1
Alternative 5
SA plus PC-2
plus (CC-HC)8
plus MN-1
Horse Cave
Munfordville
Wastewater
Management
Alternative
1981
Project
Costs
Annual
0§M
Costs
Total
Local
(with
Annual
Costs
grant)
Annual
User Costs
1981
Project
Costs
Annual
O^M
Costs
Total
Local
(with
Annual
Costs
grant)
Annual
User Costs
1,752,000
1,895,000
87,000
88,000
139,000
145,000
$39
$40
570,000
776,000
26,000
26,000
56,000
56,000
-------
TABLE II-l (Cont'd.)
Estimated Annual User Costs1 (Cont'd.)
Wastewater
Management
Alternative
Alternative 2
(PC-SA-CC-HC)2
plus MN-1
Alternative 5
SA plus PC-2
plus (CC-HC)8
plus MN-1
Staging Area
1981
Project
Costs
297,000
Annual
Costs
28,000
Total Annual
Local Costs
(with grant)
162,000
Annual
User Costs
**
285,000
13,000
42,000
1981
Project
Costs
259,000
Route
Annual
Costs
12,000
70
Total
Local
(with
50
Annual
Costs
grant)
,000
Annual
User Costs
** *
NOTES:
I—I
l-i
o
Estimated annual user costs do not include existing user charges for Cave City and Horse Cave.
2
Assumes 75% funding for conventional collection systems. However, conventional collection systems are generally
not funded. If low pressure systems are 85% funded, user charges are increased by approximately 5%.
*No user charge estimation due to lack of water service records, combined wastewater service facilities (community
on-lot and conventional) in the Munfordville area (refer to Alternative MN-1), and the uncertainty of the
number of customers to be connected during the planning period.
**Same as local annual cost since the Park Service would be the only customer at the Staging Area.
***No user charge estimation due to the uncertainty of the number of connections to be on line, and lack of water
service records.
-------
B« IMPLEMENT-ABILITY SOHHARf
The practicalities of implementing a specific wastewater manage"
ment plan must be considered, together with cost, environmental impact
and operability evaluations, as an important part of the
cost-etfectiveness anal/sis. The purpose of the implementability rat-
ing is to assess the prospects for successful implementation of an
alternative based on its potential tor general public acceptance and
political realities in the study area.
Unlike the other evaluation in the cost-effectiveness analysis
(costs, environmental impacts 8 operability), the implementability
rating is not independent, but is somewhat dependent on the results of
the other evaluations. This is especially the case with public
acceptance since costs and environmental impacts evaluations probably
have toe greatest influence on public acceptability, For example, if
an environmentally favorable plan is significantly more costly, the
public must decide how much it is willing to pay (in terms of monetary
costs) for environmental benefits.
An important factor in public acceptance is the local annual cost
associated with a wast.ewater management alternative. The local annual
cost includes annual operation and maintenance costs plus the annual-
ized local share of the cost of constructing the wastewater
facilities* This is a measure of annual revenue requirements, and
therefore, the actual cost to the users. Since construction costs ar®
75 percent federally funded and local operation and maintenance costs
are not subsidized, projects with high construction and low operation
and maintenance costs sometimes have lover local annual costs even
though they are higher on a net present worth basis than other plans
with greater operation and maintenance costs and lower construction
costs.
Local annual costs including estimated annual user costs for the
preferred alternative are listed in Table II-1.
Through the series of Citizen Review Committee meetings held in
the study area it has become clear that environmental protection of
the local natural resources such as the complex cave systems and sub-
surface streams are of paramount concern. There is considerable sea-
tiraent from the local community, the National Park Service and care
research and exploration groups that the area must be protected from
further intrusions of wastewater. This clearly Beans utilizing a
regional alternative to remove all wastewater from the area.
This solution is more expensive since it means conveying all
treated wastewater to the Green River, However, based upon local
reaction and input, cost considerations do not appear to be an impor-
t.«ut barrier. The only exception is Park City where sewer rental
rat^s would clearly be beyond the ability of many local residents to
pay based upon cost estimates.
The local communities and the National Park Service are aware
that the natural resources of the area need protection. Furthermore
their protection is important to the area since most of the area's
11-11
-------
economy is dependent upon the continuing viability of cave resources
as a source of tourism.
Another aspect of implementability is the ownership and operation
of the new wastewater facilities. Several options are being consid-
ered by the local communities. However, it appears that a local ser-
vice authority will be formed, by the communities of Horse Cave and
Cave City. This authority would have responsibility for ownership and
operation of the new conveyance facilities recommended in the pre-
ferred alternative. They would generate revenues from centals charged
to Horse Cave and Cave City for the use of the conveyance systems.
F. EIS 8EQOIHEHEHTS
The following SIS Requirements are included to mitigate adverse
or potential adverse affects of the preferred alternative. These
requirements will be incorporated into the project as special Grant 2
conditions.
The potential exists for sewer line leaks or breaks to adversely
impact the area's subsurface <*ater and cave resources. To ensure
expeditious identification and correction of leaks or breaks and to
monitor the flow between population centers, flow monitoring instru-
mention will be required at reasonable intervals along the inter-city
conveyance line. The type of instrumentation and the interval between
instrumentation placement should be decided during Step 2»
2» Endangered_Sjsecies
The Fisti and Wildlife Service has noted that 3 endangered mussels
and their habitats are known in the Green River and could potentially
be affected by the construction and/or operation of the proposed Green
River discharge. In order to satisfy the requirements of the Endan-
gered Species Act and the concerns of the Fish and Wildlife Service,
the appropriate measures must be taken early during Step 2 preliminary
design to identify areas of concern regarding these 3 protected aussel
species. Additionally, measures to avoid or mitigate identified
adverse impacts must be developed during this stage of preliminary
design. If necessary. Section 7 consultation involving the Fish and
Wildlife Service, EPA and the applicant will be undertaken.
11-12
-------
Since the exact routings of interceptor lines are not known at
this time, detailed surveys could not be performed. Surveys of the
interceptor corridors will be performed during Step 2 design. These
surveys will be reviewed by EPA prior to granting funds for con-
struction*
There is a potential that archaeological resources are present in
or near proposed interceptor corridors. No construction will take
place until surveys are completed to the satisfaction of the State
Archaeologist and the State Historic Preservation Officer. Should
resources be discovered, the appropriate state office should be con-
tacted for appropriate preservation, avoidance or other nitigative
measures. No construction will take place until the appropriate state
offices have been satisfied with the selected mitigativa measures.
The study area is located in the Central Kentucky Karst region
and as such the area's geology may contain formations that pose a haz-
ard to conventional interceptor design and construction, Prior to
initiation of final design, proposed interceptor corridors shall be
surveyed to determine the existence of subsurface formations and, if
necessary, appropriate measures (design modifications or interceptor
rerouting) shall be taken.
Section III.F of this document provides additional information on
other available rnitigative measures that could be applied daring
design and construction of the preferred alternative.
11-13
-------
III. DBAFT EIS SDHHA1I
A« BACKGROUND OP THE STUDY
The Mammoth Cave Area Environmental Impact Statement has been
prepared in response to the legal requirements of the National Envi-
ronmental Policy Act of 1969, P.L» 91-900. This Act requires the pre-
paration of an EIS for any major Federal action that will
significantly affect the quality of the huaan environnent. This SIS
was prepared by the U.S. Environmental Protection Agency, Begion IV
and addresses the issues and concerns for potential environnental
impacts resulting from a major federal action in the Mammoth Cave area
of Kentucky,
The major Federal action regarding wastewater facilities for the
Mammoth Cave area is represented by the Section 201 Facilities Plan
for the same araa. This plan was prepared in response to P»L. 92-500,
the Federal Water Pollution Control Act Amendment. Under this Act, a
20! Facilities Plan is required as the first step toward the design
and construction of wastewater facilities. In the Mammoth Cave study,
the 201 Facilities Plan was prepared in conjunction with the EIS, due
to the environmental complexities in the cave area and the financial
and management constraints of the applicant cities.
In J977, EPA granted Step I funding tor preparation of the Ham-
moth Cave Area 20? Facilities Plan, The project area developed by the
Kentucky Division of Water Quality includes the cities of Munfordville
and Horse Cave in Hart County, and Cave City and Park City in Barren
County. In addition, consideration was given to the flanmoth Cave
National Park, These cities are represented by the Barren River Area
Development District (3BADD) in Bowling Green, Kentucky, BRADD, a
regional planning and development agency, has been coordinating the
201 Facilities Plan for the study area. In 1977, BHADD hired Campbell
Wallace Consulting Engineers of Knoxville, Tennessee to prepare the
201 Facilities Plan.
The BIS was initiated in September, 1977. The focus of the study
was on the development and evaluation of alternative wastewater man-
agement systems in the cave area and to ensure the integration of
environmental and economic considerations at the earliest stage of
facilities planning. Subsequently, a Notice of Intent was issued by
the EPA Regional Administrator on October 5, 1977*
B. ALTERNATIVES DEVELOPMENT AMD EfALOATXOM
The process of developing alternative wastewater management
schemes for the Mammoth Cave area involved a presentation of a range
of structural engineering alternatives and nonstructural consider-
ations for the solution of wastewater management problens.
III-l
-------
The first of two phases in the development of alternatives was
the development of alternative wastewater service configurations. A
service configuration is a distinct plan for providing wastewater
treatment and disposal services to each major population center in the
study area, either by local treatment/disposal, or joint
treatment/disposal by two or more population centers,
The second phase of alternatives development involves screening
various wastewater treatment/disposal techniques for applicability in
the Mammoth Cave study area and generating treatment/disposal options
for local treatment disposal at each population center as well as for
each joint treatment combination which appears in the service config-
uration alternative,
Following completion of the phased approach to alternatives
development, eight wastewater management alternatives were developed.
The following is a description of the ma-jor components of each alter-
native,
AiiS£aiLyjt§ __ 1: Kastawater collection system and extended aeration
treatment facility at Park City; construction of a gravity sewer froi
the proposed Staging Area to the Park City treatment plant and convey-
ance facilities to transport treated wastewater from Park City to Cave
City; conveyance facilities to transport treated wastewater from Cave
City to Horse Cave; upgraded existing Cave City and Horse Cave treat-
ment facilities; additional on-lot treatment systems at Bunfordville;
and pump station and force main to convey commonly treated wastewater
to the Green Biver discharge point,
Alternative __ 2: Wastewater collection system and extended aeration
facility at Park City; construction of a pump station and force Bain
to convey treated wastewater from Park City to the proposed Staging
Area's pump station; gravity line to convey raw wastewater from the
proposed Staging Area to the treatment plant site; gravity interceptor
to convey raw wastewater from Rt, 70 development to the proposed Stag-
ing Area's plant site; extended aeration wastewater facility for Stag-
ing Area and Rt. 70 wastewater,; purap station and force asain at
proposed Staging Area to convey combined treated wastewaters to gravi-
ty interceptor tor gravity flow to Cave City along Rt. 70; gravity
interceptor to convey treated wastewater and additional raw wastewater
to Cave City; conveyance facilities to transport treated wastewaters
to Horse Cave pulping station; upgraded existing Cave City and Horse
Cave treatment facility; additional on-lot treatment systems at Mun-
fordville; and puffip station and force main to convey treated
wastewaters to the Green River discharge point,
3: Wastewater collection system and extended aeration
wastewater treatment facility at Park City; conveyance facilities to
transport treated wastewater from Park City to Cave City; upgraded
existing Cave City treatment plant; composting waterless toilets -
septic tank/soil absorption system for greywater at the proposed Stag-
ing Area.
Alternative. __ U: same as Alternative 2f except that conventional and
alternative on-lot treatment systems would be used at Park City, in
addition to development of a small community low pressure sewer systea
III-2
-------
and community soil absorption field.
5: Composting waterless toilets - septic tank/soil
absorption system for greywater at the proposed Staging Area; conven-
tional and alternative on-lot systems, and small community low pres-
sure sewec system and community soil absorption field at Park City;
upgraded existinq Horse Cave and Cave City treatment plants; convey-
ance facilities to transport treated vastewater from Cave City plant
to Horse Cave; additional on-lot treatment systems at Muufordville;
and pump station and torce main to convey treated wastewater to Green
River discharge point
iiternative_6: Same as Altarnative 5, except for the development of a
wastewater collection system and an extended aeration treatment facil-
ity at Park City; also. Park City treated wastewater would be conveyed
to Cave City, where both Parfc City and Cave City wastes would be dis-
posed of through subsurface discharge.
Z- Sam« as Alternative 4, except that Cave City wastes
would not be transported to Horse Cave but would be disposed of
through a spray irrigation land application system during the dry sea-
son and subsurface discharge during the wet season.
... &: Same as Alternative 5, except that Cave City effluent
would be disposed of through subsurface discharge.
Figure III-! provides a schematic illustration of the eight EIS
alternatives. Table III-l provides the results ot the present worth
analysis for these alternatives,.
The no-action alternative was developed and compared with the
most cost-effective structural alternative with respect to cost, oper-
ability, and impleiBentabil.it y,
C. DESCRIPTION OF THE PREFERRED ALTKRHATIfE
The underlying tuerae of the EIS is that the provision of waste-
water services should be compatible with efforts to preserve and pro-
tect this area*s nationally significant cave systems and their unique
physical, biological and historical resources. It is, therefore,
incumbent upon EPA to explore all available mechanisms to achieve an
environmentally sound alternative that is sensitive to economic reali-
ties. The selection of the least costly alternative is not EPA's only
aim, but rather the selection of an environmentally protective alter-
native that is locally affordable. In this regard, a regional system
j.s viewed as the environmentally preferred option. However, local
economic constraints dictate that other environmentally acceptable
options be pursued.
In light of the concerns regarding cost and the protection of the
cave resources, the approach recommended by EPA is a phased approach
which, depending on local decisions, will ultimately result in a
III-3
-------
MAMMOTH CAVE AREA ELS. ALTERNATIVES
MUNFOROVIU.E
CAVE
CITY
WWK CITY
-d
NO. I
O
NO. 5
o
r-
NO. 2
r-
O
"Cf
NO. 3
O
NO. 4
o
NO. 6
O
-d-—o
o
NO. 7
O
o
NO. 8
O
FIGURE m-i
-------
TABLE III-l
PRESENT WORTH ANALYSIS
UPDATE
Wastewater
Management
Alternative
Alternative 1
(SA-PC-CC-HC)2
plus MN-1*
Alternative 2^
(PC-SA-CC-HC)
plus MN-1*
Alternative 3
SA plus (PC-CC-
HC)3, plus MN-1*
Alternative 4
PC-2 plus (SA-
CC-HC)3 plus
MN-1*
Alternative 5
SA plus PC-2
plus (CC-HQ8
plus MN-1*
Alternative 6
SA plus (PC-CC)2
HC-4 plus MN-1*
plus filters**
Alternative 7
1981
Project
Cost
9,985,000
10,574,000
8,804,000
9,030,000
6,546,000
7,834,000
338,000
8,172,000
8,675,000
Annual
O&M
Costs
233,000
261,000
237,000
252,000
230,000
235,000
22,000
257,000
252,000
Present
Worth
Annual
O&M
Costs
2,255,000
2,527,000
2,294,000
2,439,000
2,226,000
2,275,000
213,000
2,488,000
2,439,000
Total
Present
Worth
12,240,000
13,101,000
11,098,000
11,469,000
8,772,000
10,109,000
551,000
10,660,000
11,114,000
Year 2000
Salvage
Value
4,494,000
4,770,000
4,007,000
3,626,000
2,568,000
3,467,000
9,400
3,561,000
3,412,000
Present
Worth
Salvage
Value
1,395,000
1,481,000
1,244,000
1,126,000
797,000
1,076,000
29,000
1,105,000
1,059,000
Net Present
Worth
10,845,000
11,620,000
9,854,000
10,343,000
7,975,000
9,033,000
522,000
9,555,000
9,704,000!
Cost
Ranking
7
8
5
6
2
3
4
PC-2 plus (SA-
CC) plus-HC-4
plus MN-1*
-------
Alternative 8
SA plus PC-2
plus CC-3 plus
HC-4 plus MN-1*
plus filters**
TABLE III-l (continued)
PRESENT WORTH ANALYSIS
UPDATE
Waste water
Management
Alternative
1981
Pro j ect
Cost
Annual
0§M
Costs
Present
Worth
Annual
0§M
Costs
Total
Present
Worth
Year 2000
Salvage
Value
Present
Worth
Salvage
Value
Net Present
Worth
Cost
Ranking
5,576,000
300,000
5,876,000
228,000 2,207,000 7,783,000 2,031,000
21,000
205,000
503,000
84,000
249,000 2,410,000 8,286,000 2,125,000
630,000
26,000
656,000
7,153,000
477,000
7,630,000
i—i
en
1 This net present worth is adjusted for 15 % cost preference for (SA-CC) spray irrigation
and pretreatment facilities.
*MN-1 Cost estimates do not provide for upgrading of the Munfordville wastewater facility.
** Filters are only considered for Cave City.
NOTE: All costs have been developed to accommodate flows from Park City and National Park Service Staging Area.
-------
regional (Alternative 2) or serai-regional (Alternative 5) wastewater
management system.
This approach would involve the following components:
I. Initiate Phase I of the project which would provide for
desiqn for upgrading the treatment facilities at Cave
City (0.37 mgd) and Horse Cave (0.53 mgd} and for con-
veyance facilities to the Green River. The conveyance
facilities would be evaluated with and without future
flows from Park City (0.08 mgd), the proposed Mammoth
Cave National Park Staqinq Area (0. 105 mgd), and the
Route 70 area.
2. The establishment of a critical decision date to coin-
cide with completion of the preliminary design for Horse
Cave and Cave City for the NPS*s decision regarding the
development of the proposed Staqinq Area or the local
communities* commitment to obtain additional non-BPA
funding sources,
3, Provide final desiqn for facilities based on the above
decisions. At that point, EPA and the Commonwealth of
Kentucky will also have to define the extent of EPA
eligibility for remaining desiqn and construction,
• If the NFS does develop the Staging Area and is
able to provide significant funding assistance for
Park City or additional non-EPA funds are
available, the remaining components of the regional
alternative could be constructed. These con-
struction elements would involve treatment
facilities at Park City and the Mammoth Cave
National Park Staging Area, conveyance facilities
from Park City to the Staging Area along Route 70
to Cave City and expand Cave City's facility to
0,58 mgd. This would, in essence, be Alternative
2,
» If the NPS does not develop the proposed Staging
Area or additional non-EPA funds are not available,
the remaining components of a semi-regional alter-
native would be constructed. This construction
element would involve on-lot systems for Park
City's residential areas and a community
sub-surface absorption field for the Pack City
business district. Presently available funding
mechanisms would allow for EPA participation in the
cost of these activities but would be contingent on
Congressional continuation of these mechanisms.
Also, funding would have to be in accordance with
the State Priority list. This would, in essence,
be Alternative 5.
The regional alternative is most responsive to local and the NPS
desires regarding protection of the qroundwater and the cave systems,
III-6
-------
However, because of high cost and the resultant financial burden to be
seen locally, the regional alternative may not be viable at this time,
Local funding decisions to be made in the near future are critical to
the ultimate wastewater management system tor this area. Additional
non-SPA funds must be available for a regional system to be affordable
to Park City. Until the appropriate decisions related to NPS funding
or other non-EPA financial assistance are made, EPA should move to
resolve existing wastewater management and water quality problems. In
essence, the proposed phased approach would allow for resolving the
current more serious problems while remaining flexible to future local
funding decisions. Figure III-2 describes the proposed strategy for
wastewater management in the study area. A summary of the costs of
the preferred wastewater management alternative is presented in Table
II-1 in Sectio'n II.C. of this document.
D. DESCRIPTION OF THE STUDY AREA
The Mammoth Cave study area is located in south central Kentucky,
about 100 miles southwest of Louisville, Kentucky and fOO miles north-
east of Nashville, Tennessee, The 20t Planning Area is partially sit-
uated, in Barren, Hart and Edmonson Counties, and includes the
municipalities o± flunfordville. Horse Cave, Cave City and Park City as
well as portions of Mammoth Cave National Park.
As is characteristic of the Central Kentucky karst, in which the
study area is situated, the terrain of the study area is gently roll-
ing and pitted with sinkholes while the subsurface contains a complex
structure ot limestone caves and free flowing groundwaters. The
area's unigue geological features are of national interest and provide
the area with a strong tourist attraction. Other than the tourist
industry, the study area and surrounding region is primarily
rural/agricultural.
Is Ilistiaa_»ataral_lB»i£o§i§at
The study area has a variable continental climate with wide
extremes in both temperature and precipitation. Bowling Green, 30
miles southwest of Mammoth Cave, has the closest weather stations with
complete records. The average annual temperature is about 59° F, with
100 year extremes of -2t°F and 1?3°F. Precipitation is well distrib-
uted throughout the year and averages about 49 inches per year- The
average daily wind speed for the entire year is between 6 and 7 m.p.h.
Because the area is primarily rural, severe air pollution prob-
lems do not occur. Portions of the study area do, however, suffer
odor problems. The major odor problem is associated with the
sub-surface discharge of the Horse Cave Treatment Plant. The combina-
tion of metal laden effluent from the Ken-Dec Metal Plating Plant,
creamery waste from the Hart County Creamery, and ineffective treat-
ment from the treatment plant have produced ma-jor odor problems in the
III-7
-------
FIGURE 3H-2
MAMMOTH CAVE AREA
PREFERRED STRATEGY FOR WASTEWATER MANAGEMENT
PHASE I
MUNFORDVILLE
MAMMOTH
O
NATIONAL
PARK
/
STAGING AREA
HORSE CAVE
O
CAVE CITY
PARK CITY
YES
NPS OR ADDITIONAL NON-EPA
FUNDING AVAILABLE ?
NO
PHASE n
1
o
o
ALTERNATIVE 2
ALTERNATIVE 5
-------
Hidden River system in downtown Horse Cave. Overall, the study area
has relatively low ambient noise levels, The ma-for noise generators
are the highways and railroad.
On a very general level, the structural setting of the study area
is that of a monocline with beds dipping gently to the northwest
toward the Illinois Basin (or alternatively off the western flank of
the Cincinnati Arch). Two karst formations are visible in the Maraaoth
Cave Study Area - karst valleys and the Sinkhole Plain. Solutional
Karst valleys, a half mile or more in width and several miles long,
with sinkhole-pitted floors, extend in a dendritic pattern from the
Green Biver into the Chester Caesta (sometimes called the Haamoth Cave
Plateau). The Sinkhole Plain consists of a rolling topography pocked
with thousands of sinkholes. There are no surface streams and little
evidence for channels or distinguishable valley development-
Hundreds of caves abound under the study area and in the region
surrounding the study area, Thase caves range in size from tiny frag-
ments to the longest cave in the world- the Flint-Mammoth System,
There are presently six private show caves open to the public in the
Mammoth Cave study area,
The Cave systems of the Central Kentucky Karst are very sensitive
to intrusion of pollutants from the surface through either direct
infiltration of surface water or by pollutants traveling laterally
through low level stream passages. There are three potential threats
to the caves as the result of intrusion of pollutants: (?) Loss of
scenic value due to contamination of the cave air or streams by pollu-
tants, and subseguent threats to the tourist industry, (2) Damage to
aquatic and terrestrial life forms, (3) Damage to mineral deposits and
other special features, some of which are stable only within a narrow
range of temperature and relative humidity.
During the EIS process, four major issue areas were defined.
Three of these issues revolved around the protection of these cave
systems and the subsurface hydrology of the study area. They are:
• the sensitivity of the cave environment to wastewater
discharges
• resource value/importance of the caves
• the complexity of the area's subsurface hydrology.
The nine soil associations present in the study area have severe
limitations for on-lot disposal systems. These soils should, however,
be examined on a more site specific basis to determine if outlying
areas can be left on conventional on-lot systems or if alternative
systems may be appropriate.
The Green River, which serves as both a wastewater receiving
stream and a water supply source for the study area, is the major sur-
face water body in the study area, Water guality of the river is gen-
erally good. There have, in the past, been a fair violations of the
lead and fecal coliform state water guality standards. These,
however, are not considered to present a serious threat to water gual-
III-8
-------
ity. There are few additional surface streams in the study area other
than the Green River because of the hydrologic conditions associated
with the Karat geology.
The Green River is the hydrological base level for the region and
receives most groundwater discharqe from th
-------
polluted waters in the Hidden River Cave System and areas of local
chloride pollution in the Turnhole Spring Basin, the water quality of
the sinking streams and subsurface waters in the study area is gener-
ally good to excellent, sufficient for maintaining aquatic life (the
aquatic life water quality criteria are defined by the EPA Quality
criteria tor water, EPA, Washington, D..C. July 1976). There are
undoubtedly several areas of undetected local subsurface pollution
problems in the study area, though they do not significantly affect
overall water quality,
The cave systems of the Kamsaoth Cave area contain extremely
diverse cave biota. Approximately 200 different animal species have
been collected in Mammoth Cave. The cave biota of the area is
extremely sensitive to surface and subsurface pollution activity. The
pollution effects on cave biota can be generalized into two
categories: direct toxic effects and habitat modifications. Several
pollutants have generally been shown to be directly toxic to cave spe-
cies, including heavy metals and chlorine. Specific impacts on cave
biota, however, are seldom observed and are difficult to estimate.
However, the study area is distinctive in that it has comparatively
extensive biotic survey work both in terms of nuaber of sites
attracted and length of observations* per site, The long term observa-
tion of Hidden fiiver Cave has permitted the documentation of pollution
impacts to this cave system, The documented causes {and potential
causes) of cave pollution ia the study area (subsurface discharges,
septic systems, urban runoff, pipeline leaks, transportation
accidents, storage facility leaks and dumping activities) have demon-
strated severe impacts to cave systeras.
The predominance of subsurface drainage in the study area has a
tremendous influence on the aquatic community. Generally, the aquatic
invertebrate connunities in the sinking streams and springs of the
area have a low density, but often contain pollution intolerant spe-
cies. An overall assessment of invertebrate samples collected for
this study indicates that pollution impacts to roajor streams is mini-
mal. There were no fish kills reported in the study area from 1975 to
1977, and there is no indication of the fish community being iapacted
by the current pollution loads,
The terrestrial environment of the study ar^a has been modified
by the clear cutting of forests and farming. Currently, total fars
areas account for approximately 57 percent ot the study area with over
36 percent of that land under cultivation. Forest area calculations
account for alatost 43 percent. The complex plant communities of the
study area and the projection afforded by Maroffioth Cave National Park
support a diverse animal community,
The U.S. ?isn and Wildlife Service (PWS) currently list 15 rare
and endangered species which may be found within the four counties of
the study area (Hart, Barren, Edaonson, and Barren). The FWS refers
to these as "species of concern",
111-10
-------
2,8.
There are five population centers within the Mammoth Cave Stud?
Area, They are the towns of Munfordvi lie (1980 population, 1,788),
Horse Cave (1980 population, 2,019), Cave City (1980 population,
1,997), and Park City (1980 population, 603), The Mammoth Cave
National Park may also be considered a population center during the
summer months because of the large number of tourists visiting the
park, "Cava Country" visitation also significantly increases the susi-
mer populations in the towns of Horse Cave, Cave City and Park City as
they provide tourist accommodations. The study area outside the towns
is sparsely populated, with only about 30-40 people per square mile.
Population projections for the study area developed by BRADD and
GFC&C, Inc, indicate insignificant increases in population for the
tour communities. fear 2000 projections by 8BADD ares Munfordville
(1,61<0, Horse Cave (3,093), Cave City (2,470), and Park City (723).
Land use in the study area generally falls within one of three
categories - agricultural, forested or vacant land use. The four
small communities of Jlunf ordville. Horse Cave, Cave City, and Park
City serve as centers of residential, commercial and industrial land
use in the study area*
One of the greatest influences on land use in the study area is
the Hammoth Cave National Park, The major impact of the park and
increasing visitation has been the proliferation of tourist related
activities in the area such as motels, restaurants, service stations,
and campgrounds. Most of this activity has focused around the 1-65
interchange at Cave City where a variety of commercial activities
related to the parks tourism have been developed. Other ainor commer-
cial activity has developed at the 1-65 interchanges at Park City and
Horse Cave,
Future land use is expected to reflect the influence of Mammoth
Cave National Park. One major impact on future land ase would be the
park*s plan to construct a new staging area at Chaumont on the periph-
ery of the park. Location of this staging site could have a signif-
icant influence on the 1-65 interchange at Park City since this exit
would be the closest to the proposed terminal and staging area» This
could result in a proliferation of tourist services in the area
between Park City and the park entrance. Overall, however, no dramat-
ic changes in land use in the study area are expected to occur
regardless of the influence of the National Park.
The two largest employers in the study area are agriculture and
manufacturing. Data indicate overall increases in manufacturing
employment for each county between 1971 and 1976, and an increase in
agricultural employment for the same tirae period in Barren County and
decreases in both Hart and Edmonson Counties,
In addition to containing one of the nation's leading natural
resources (the Flint-Mammoth Cave System), the Mammoth Cave National
Park is also the most important recreational resource in the area.
The study area itself also has the potential for increased recreation-
al facilities. There are many caves on private property that would
III-ll
-------
provide spelunkers with a variety of caves. The large amounts of mar-
ginal agricultural land and forested areas could be used for
campgrounds. In 1952, 217,015 persons visited study area caves. By
1975, this figure had increased to 650,000. During those same years
the park experienced a 400 percent increase in visitation from 400,000
to 2,000,000 visitors.
The majority of the land area in the study area is in agricul-
tural and silvicultural use. Agricultural lands are used for both
crops and pasture, The forested areas are primarily eastern red
cedar, scrub oak and hickory hardwood, A section of the study area
contains high calcium limestone reserves that are heavily mined. Oil
and natural gas resources within the study area are located around and
north of Glasgow, the eastern tip of Warren County, west of Kunford-
ville, near Cave City, east of Hiseville, in northeastern Barren
County and southeastern Hart County,
The Horse Cave wastewater treatment facility is a high rate
trickling filter plant designed for a hydraulic loading of 0.4 mgd and
a BOD5 loading of approximately 870 Ibs/day, Treated effluent is dis-
charged to the subsurface where it flows to the South Branch of Hidden
Biver Cave. The Horsa Cave wastewater collection and treatment system
serves about 90 percent, of the water customers within the city's cor-
porate limits, including two industrial customers, the Hart County
Creamery and Ken-Dec, Inc. An additional interceptor to service the
commercial establishments at the Horse Cave 1-65 interchange was
recently constructed. Results of sampling performed at different
times during the past three years at the Horse Cave plant, indicated
unsatisfactory performance. Slightly over 50 percent of the daily
average flow is untreated industrial wastewater from the Hart County
Creaaery and Ken Dec's electroplating plant, resulting in influent
high in BOD and heavy metals concentrations, Visual inspection of the
facility (in September 1977 and March 1978) revealed that there is
little biological growth on the trickling filter media and that the
anaerobic digester is no longer operational, conditions apparently the
result of toxic effects of chromium, copper and nickel.
The Horse Cave treatment plant cannot provide secondary treatment
under these conditions. Improved operations are expected with the
installation of pre-treatment facilities at the Ken-Dec electroplating
plant which should reduce heavy metals concentrations to levels
acceptable to permit biological treatment activities. However, unless
pre-treatment of the Hart County Creamery's wastewater is provided to
reduce influent BOD, the Horse Cave treatment plant cannot be expected
to produce the secondary treatment effluent for which it is designed.
The Kunfordville wastewater treatment plant is a 0.15 ngd
extended aeration facility which discharges to the Green aiver about
200 feet downstream from the Highway 31W bridge in Kunfordville, The
System serves approximately 50 percent (250 customers) of the popula-
tion of the community. Latest NPDES self-monitoring data and Kentucky
Compliance Monitoring Analyses indicate that the plant is performing
well, providing BODs reductions of about 95 percent and suspended sol-
ids reductions of about 90 percent. However, because there are no
disinfection facilities, the plant effluent is in constant vioiation
ot NPDES fecal coliform limits. Some improvements are reguired imme-
111-12
-------
diately at the plant to meet Federal and State regulations, including
continuous flow monitoring, disinfection facilities, and post aeration
to meet NPDES dissolved oxyqen requirements. Plant performance and
flow monitoring data indicate that there is capacity to expand the
present sewerage service area. However, flows should be carefully
monitored durinq wet-weather periods to confirm this conclusion and to
determine the amount, if any, of additional capacity.
The Cave City treatment, plant provides biological wastewatet
treatment by means of a high-rate trickling filter with a design
capacity of 0,32 mqd. The system is maintained within tne corporate
limits of Cava City and serves about 600 customers (about 90 percent
of the population) including commercial establishments, The treatment
plant is located near the L & N Railroad tracks and is surrounded by
open fields. Therefore, there appears to be ample space at the site
for expanding and upgrading the treatment facilities. Data indicates
that the Cave City treatment plant is not providing the level of
treatment required by its NPDES permit. However, even with ideal
operating conditions the treatment facility cannot be expected to meet
these stringent discharge limits since the high rate trickling filter
is designed to provide only secondary treatment (85 percent BOD
removal). Durinq the summer months, when efficiency should be at a
peak, plant BODs removals are only 76 percent even when loaded below
design capacity.
The Mammoth Cave National Park wastewater facilities consist of a
high rate trickling filter plant with a design capacity of 120,000
gpd. Should the need arise, there is adequate space at the treatment
plant site to accommodate additional treatment units. Visual
inspection of the plant has revealed that the plant is well operated
and maintained. Data indicate that the plant consistently provides
secondary (or better) treatment in compliance with its NPDES regu-
lations. High flow during wet weather periods indicates the existence
of an infiltration/inflow (I/I) problem in the Mamsoth Cave system.
Assuming the I/I problem can be eliminated, there appears to be suffi-
cient capacity to accomaodate greater wastewater flows due to the
increased park visitation anticipated in the National Park Haster
Plan. Based on these prelections, the plant appears to have adequate
capacity to continue to provide secondary treatment until the mid
!980«s.
Wastewater generated from activities at the Job Corp's Great Onyx
Civilian Conservation Center is treated in three waste stabilisation
Lagoons, The desiqu capacity of the system is approximately 20,000
gpd to provide for a population of 200 at the center. Monitoring data
indicate that the lagoon system is consistently providing secondary
(or better) treatment, meeting the conditions of its NPDES permit.
Tftere are eleven small wastewater treatment plants located in the
s,.udy area, most of them near the municipalities of Park City, Cave
City and funfordville. Nine of these plants have either direct or
indirect discharges to qroundwater, Five discharge directly to the
sub-surface via sinkholes. Four discharge to lagooas with no outlet,
but the water percolates into the ground. Because of the nature of
the wastewater, the relatively small flows and because there are no
111-13
-------
known water quality problems associated with such plants, it is pres-
ently assumed that impacts are minimal,
Other study area practices which may be contributing to ground-
water pollution problems are direct discharqe of wastewater to rock
openings and the use of septic tanks with absorption fields. The mun-
icipality of Park City, in particular, constitutes a large source of
untreated wastewater entering the qroandwater system. Approximately
80 percent of the residences and businesses in Park City discharge
untreated wastewater directly to the subsurface, while the remaining
20 percent have septic tanks followed by direct discharge. Although
the overall effect of these discharges is undetermined since little is
known about the assimilative capacity of underground streams, several
instances of fecal contamination of individual domestic water supplies
have been reported,
Two additional potential qroundwater pollution sources are
non-point sources (use of fertilizers and pesticides or large scale
livestock production) and contamination from oil wells.
There are three major sources of water supply in the study area:
groundwater, groundwater springs, and the Green River. Groundwater
wells are used extensively for home water supplies in areas unserved
by public supplies. In addition, qroundwater is used for semi-public
supplies such as campgrounds and motels. Groundwater springs present-
ly provide a source of water supply in Mammoth Cave National Park and
the source of water supply for the Green Hiver Valley Water District.
Because of the extensive use of the groundwater as a water supply
source, it is important that qroundwater quality goals be determined
and met through the resolution of local groundwater pollution
problems.
There are several, projects or programs in the study area which
are relevant to sastewater facilities planning and water quality man-
agement including: Green River Basin 303(e) Plan, Comprehensive Water
and Sewer Plan tor the Barren River Area Development District, Mammoth
Cave National Park Master Plan, and the Mammoth Cave National Park
Transportation Study.
E. EMVIROMMEHTAL IMPACTS OF THE PREFERRED ALTESIATIVE
Major impacts to the existing natural environment with implemen-
tation of the preferred alternative are not expected. As a matter of
fact, in the case of, for example, Subsurface Hater Resources and Cave
Ecology, major impacts are expected to be beneficial. These impacts
are basically the result of removal of wastewater front the subsurface
and reduced dependence on faulty septic systems, aiding in the cor-
rection of groundwater pollution problems.
Generally, impacts associated with the natural environment are
the result of construction of pipeline or facilities. The basic
assumption is that impact is generally proportional to distance of
pipeline. This holds true when considering short-term impacts to air
111-14
-------
quality, impacts to qeoloqy, topography, noise, surface (in teras of
sediment load) and subsurface water resources, cave.ecology, and sur-
face ecosystems, Each of these parameters is expected to be impacted
to some degree by construction activities. This potential iapact
would be greater with implementation of the regional alternative
option of Phase 2 because of the extent of proposed construction. The
serai-regional option of Phase 2 on the other hand, requires the next
to the least amount of construction and, therefore, the potential for
construction-related impact is liaited. In addition to pipeline con-
struction, leakage from pipelines could also have maior adverse
impacts. This is particularly true when considering inpacts to sub-
surface water resources. Again, impact is assumed to be proportional
to pipeline distance.
Several other impacts to the natural environtaent are expected in
addition to the effects of construction. A long-term impact to air
quality could be the result of operation of newly constructed facili-
ties in the regional system option of Phase 2. The removal of waste-
water fro» Hidden River Cave will correct the worst odor problea in
the area, however, the composting waterless toilets reconsiaended for
the proposed Staging Area in the semi-regional option of Phase 2 have
the potential to cause odor problems if the wastes are not composted
properly. An additional odor problem could result from improperly
maintained treatment facilities constructed in the preferred alterna-
tive.
In addition to construction impacts, the geology of the study
area could be adversely affected should ponding occur with application
of the community soil absorption field proposed in the semi-regional
option of Phase 2 of the preferred approach. Subsurface water
resources and cave ecology also could be negatively impacted by the
use of improperly installed, operated or maintained soil absorption
fields*
Impacts to soils in the area are not expected to be highly sig-
nificant. There is the potential for soils to become clogged should
on-iot systems be improperly designed, installed or constructed in
those areas not served by a central collecrion and treatment systea.
Potential degradation of the Green River aquatic conmunity could
occur with complete failure of pretreatment for heavy metals or aal-
tunction of the treatment plant at Horse Cave or Cave City. The
extent of the impact would depend upon the guality of effluent. Short
term and long terra impacts resulting from construction are expected.
Impacts include increased siltation from pipeline construction on the
floodplain and removal of vegetation during construction and from
changing land use. These impacts have the potential to affect aquatic
and terrestrial species and their habitat.
The habitats of several protected or formerly proposed species
could be influenced by activities in the study area. For instance,
three mussels found in the area could be impacted in two ways by
placement of the discharge pipe to the Green aiver. First, possible
mussel and mussel habitat destruction could occur by excessive sedi-
mentation during construction, and secondly, possible toxic substances
in the effluent could harm the mussels. Some beneficial impacts could
111-15
-------
also be realized, particularly in the case of the Kentucky cave
shrimp. Removal of all subsurface wastewater discharges of the
regional systen option of Phase 2 in the preferred alternative afford
the greatest amount of protection to the cave shrimp from the influ-
ence of wastewater.
In the Mammoth Cave area, it. is not expected that extensive popu-
lation growth will result from any new wastewater facilities, first
because population projections for the area are conservative, and sec-
ondly because the proposed wastewater facilities will include only
limited new service area and, therefore, will not act as a direct
stimulus to population growth. Sewering of the Route 70 area and con-
struction of collection and treatment facilities at Park City in the
regional system option of Phase 2 of the preferred alternative may
stimulate some additional population growth, but it is not expected to
be significant.
Some impacts upon land use may occur in the study area as the
result or upgrading treatment facilities at Horse Cave and Cave City,
development of a community sub-surface absorption field (the
seai-regional system option of Phase 2 of the preferred alternative),
and construction of new facilities {the regional system option of
Phase 2 of the preferred alternative)- Sewering of th« Route 70 area
may also act as a stimulus to additional growth in the study area. In
addition, the right-of-way areas for interceptors and force mains in
the preferred alternative will be permanent changes in land use.
The impact upon the local economy will come from both the short
term construction impacts and the long term investment from the
improvement of wastewater treatment in the study area. It is likely
that the project would create construction employment and would also
pump additional money into the local economy for the purchase of hous-
ing, eguipment, and materials. The long terra impacts of the preferred
action and the resultant improved wastewater management include:
* Potential stimulus of industrial growth
» Potential increase in visitors due to improvement of
water guality in the Hidden River Cave system
• Removal or improvement in guality of subsurface waste-
water discharges that drain through and could potential-
ly impact Mammoth Cave National Park's resources.
During the EIS process, a major concern was the ability of the
local communities to pay for an environmentally sound management sys-
tem. Taking into consideration the relatively high unemployment rate
and low per capita income of the study area, a semi-regional system
having the next to the lowest net present worth cost of all the alter-
natives was selected (the seai-regional system option of Phase 2 of
the preferred alternative), with eventual region*lization of the sys-
tem if the National Park Service constructs the Staging Area. The
regional system option of Phase 2 (Alternative 2) has the highest net
present worth cost of all alternatives. This phase, if implemented,
has the potential to place somewhat of a greater financial burden on
the local communities than the semi-regional approach.
111-16
-------
It is expected that some iaterruption of normal highway traffic
could be caused by construction of conveyance facilities, Under the
preferred alternative, a force main would be constructed to the Green
River to convey treated wastewater from Horse Cave and Cave City.
Although a specific corridor for the force main has not been selected,
the torce main would cross 1-65, which would require tunneling under
the interstate highway. This however, is not expected to disrupt
traffic on 1-65.
F. HITIGiTIVE HEASBRSS, RBCOHHBHD&f£OMS &HD BEQUIREHEIfS
For the roost part, mitigation of adverse impacts to the natural
environment would entail implementation of controls during con-
struction activities. Methods used to avoid adverse impacts to air
quality, odor, noise, qeology, soils, surface water quality, and aqua-
tic ecology involve:
* utilization of best management practices (sludge cianage-
ment techniques to reduce odor, erosion and sedimenta-
tion control plans, bank stabilization and iroaediate
reveqetation plans, controls to reduce non-point source
run-off from construction sites, dust containment prac-
tices)
* effective construction equipment (including sound
devices) and maintenance of equipment (meeting current
emission standards)
* minimize amount of land under construction at one tine
and limitations on time construction takes place
• effective land use control to prevent residential devel-
opment adjacent to treatment sites
In order to mitigate impacts to water resources, cave ecology,
and rare and endangered species as a result of pipeline leakage and
sedimentation, detailed design and construction of pipeline should be
required with a series of flow meters to facilitate the detection of
leaks. Effective land use control (local land use and zoning
restrictions) will be needed in order to protect the cave systems of
the area frow degradation. A final survey of the pipeline con-
struction site should be made prior to construction to determine the
presence of the Sjrnandra plant species in the area (it, as yet, has
not been detected in the tentative pipeline sites). If any species of
special concern is located in an area of possible impact from the
pipeline then such species should be transplanted to other areas.
Effective management ot land use through the use of planning and
regulatory tools can lessen aay undesirable aspects of population
growth and increased residential, commercial and industrial develop-
ment. These tools include comprehensive plans, zoning ordinances,
easements, fee simple aquisition of land, conservation zoning
district, and floodplain ordinances.
111-17
-------
In order to avoid adverse impacts to historic and archaeological
resources, a standard archaeological and historic sites survey should
be completed prior to construction. Consultation with the Kentucky
Heritage Commission or other agencies would determine the significance
of unlisted sites, their eligibility foe inclusion on the list of his-
toric places and appropriate mltigat.ive measures.
Any adverse impacts to recreational resources, transportation
facilities, resource use, and community services and facilities, also
may be mitigated through the implementation of planning tools.
Section II.F of this document details those EIS requirements to
mitigate adverse or potential adverse affects of the preferred alter-
native. Those reguirements listed will be incorporated into the pro-
ject as special Grant 2 conditions.
G. EIS COOHDIHATION
At the outset of the Mammoth Cave EIS, a public participation
program was established to provide opportunities for interested
groups, individuals, and governmental agencies to participate in the
development of the SIS, The focal point of this program was the
establishment of a Citizen Review Committee (CHC) . This committee
included a variety of persons representing local/regional government,
state government, industry, and interested citizens. Six meetings
with the CRC were held during the development of the EIS.
In addition, throughout the development of the EIS, there has
been considerable coordination with a variety of public and private
agencies at the federal, state, regional, and local levels* This
coordination has largely been in the form of data collection, dis-
cussions, and meetings in order to provide the necessary data for the
preparation of the EIS.
The following is a list of the members of the CRC and the organ-
izations they represent:
Name Representing
Mayor Robert L. Bybee Horse Cave, KY
Mayor Chester Fryer Hunfordville, Ky
Mayor Clyde Hubbard Cave City, KY
Alt: Charles Lohden
Chairman, Board of Trustees Park City, KY
Robert L. King
Elaore Lariaore Green Fiver Valley
Water District
111-18
-------
Ken Smith
Robert Deskins, Park
Superintendent
Fran?. Donin
Joe Thornton
Kentucky Division of
Water Quality, Dept.
for Natural Resources
and Environmental
Protection
Barren aiver Area
Development District
National Park Service
Industry
DNSEP
Tom Aley
Kick Gunn
Otis Caqle
H. f. Austin
Charles Neville
Tom Cfaaaey
Joseph Kulesza
Industry
Industry
Citizen
Citizen
Citizen
Cave Research Foundation
In addition to the development of the CEC, was the establishment
of a Groundwater Technical Advisory Committee (GTAC). The GTAC was
formed witn the purpose of supplementing the input of the Citizen's
Beview Committee. The qroup consists of scientists and technical per-
sonnel who are highly familiar with the unique hydrologic and geologic
conditions of the area, A raaior role of the group was to aid in
understanding the underground environment and the flow of water in the
sinkhole plain, and the impact sewage effluent would have on this
natural resource. The group provided technical assistance in the
development of the water quality sampling program. The five members
of the group are:
Name
Hr. Mike McCann
Geologist
B,;8 William B. White
Professor of Geochemistry
Kr. Thomas Aley
Director
ilr. John Thrailkiil
Bepresentiaq
Kentucky Division of Water
Quality
College of Earth; Mineral Sciences
The Pennsylvania State University
Ozark Underground Laboratory
Geology Department
111-19
-------
University of Kentucky
Dr. James F. Quinlin Uplands Research Laboratory
111-20
-------
I?. BE7ISIONS TO THE DRAFT EIS AND ADDITIOHAL IHFOHfUTIOi
Comments received concerning the Draft EIS revealed some cor-
rections which were needed to rectify errors in the report, Below,
the correction/ location in text, and person or agency making the com-
ment are given.
Page II-3, third
line form bottom
Page 11-34, first
full block
Page 11-46
The term "cost-effective"
should be changed to
read "cost-effectiveness"
Phrase, "conveyance of
Park City treatment plant,"
should be deleted.
Sentence "Conveyance of
combined Cave City - Park
City effluents from Cave
City pumping station
to Horse Cave discharge
pumping station" should
be added after fifth
item; sixth itera should
be moved to end of list;
eighth item should be
deleted.
Department of the
Array, Louisville
District Corps of
Engineers
Department of the
Artay, Louisville
District Corps
of Engineers
Department of the
Army, Louisville
District Corps
of Engineers
Page III-6
Page 111-13, para-
graph 3
Last sentence of the second
paragraph beginning with
"Because of the nature,.,"
should be deleted.
First sentence should
read "No surface run-oft
froa the EIS study area
reaches the Green Siver,"
Department of the
Army, Louisville
District Corps
of Engineers
Department of the
Interior
(Hoffman)
Page II1-41, Item 12,
paragraph 1, line 1
Line 1 should read
"Most rare and
endangered flora and
fauna of the Commonwealth
of Kentucky.,."; the
following sentences
should be added
following sentence 2,
"Plant species which are
candidates for Federal
Department of the
Interior
(Hoffman)
IV-1
-------
Page 111-41, Paragraph
2, line 10
Page III-15 and
111-16
listing have no Federal
protection at present.
There are several species
within the state wnich
may never be proposed
for Federal protection
although they are rare,"
The following sentence
should be added
following line 10,
"These three categories
refer specifically to the
Smithsonian Institutions
list of threatened plants,
not endangered species in
general,"
The sentence, "The Kentucky
Division of Hater Quality
and EPA apply Kentucky
Water Quality Standards,
as established in 40
CFF 120,21, which provide
in Section 1,{2) of the
Regulation WP-6-2..."
should reference 401 KAR
5:031 5, Aguatic Life,
and not 40 CFR 120,21.
Department
Interior
(Hoffman)
of the
Kentucky Depart-
ment for Natural
Resources and
Snvironraental
Protection,
Division of
Water Quality
(T, James Fries)
Page III-2, Table
III-5
The following are corrected
water guality criteria
according to Kentucky's
current water guality
standards as found in
401 KAR 5:031. Under
use classification
Aguatic Life, the
Ammonia criteria should
be changed from ,02 mg/1
to ,05 mg/1; the Copper
criteria should be
changed from ,1 times
96-hr to .01 times 96-hr;
the pH standard should be
changed from 6,5-9,0 to
6,0-9,0;and the Sulfidas
criteria should be changed
from 2 mg/1 to 2 ug/1.
Under use classification Saw
Drinking Water, the Iron
and pH standards should
be omitted; and the Total
Dissolved Solids standard
should be changed from
250 mg/1 to 750 ag/1.
Kentucky Depart-
ment for Natural
Resources and
Environmental
Protection,
Division of
Mater Quality
(T. James Fries)
IV-2
-------
Page III-106 last
full paragraph
Page III-106 and
III-107; last
paragraph under
#3,
Under use classification
Secondary Contact, the
Chromium standard should
be changed from 200/100 rcl
to 5000/100 ml; and the
pH standard, 6.0-9.0,
should be added.
Beginning with the
second sentence, the
paragraph should
read, "the most
desirable alternative is
WKA-5 which is five points
above the second best
alternative, The second
through sixth ranked
alternatives (WMA-3, WMA-4,
WMA-1, WMA-2, HMA-7) are separated
by nine points (Alternatives I
and 2 tied). The final two
alternatives (WMA-8 and WHA-6)
are clearly the least desirable
with total natural environmental
evaluation scores of 11 and 10,
respectively."
Second sentence should read,
"the most desirable alter-
natives are WMA-1 and HMA-2
(tied) while the least
desirable is «f»A-8.
IV-3
-------
V. EPA RESPONSES TO COMMENTS BECEIVED OH THE DRAFT EIS
This section of the Final EIS contains the responses that have
been made to comments in writing to SPA and oral comments made at the
Public Hearing held in Cave City on June 8, 1981, Because of the lim-
ited number of comments, the responses are categorized according to
the person or aqency making the comment.
The first part of this section indexes written comments received
on the Draft report. The second part lists those oral comments
received at the Public Hearing. A detailed listing of all comments
and responses is then included. Section VII includes actual letters
received commenting on the Draft report.
V-l
-------
A. INDEX OF HBITTEM COMHEMTS RECEIVED OH THE D8AFT BIS
Same/Association
1) Frank Kudrna
Ohio River Basin
Commission
2) Carl E. Kays
Kentucky Department
of Fish and Wildlif
Resources
3) Robert L. Brooks
Office of State
Archaeology
William L, S
3 i err a Cloh
5) FranK. Liselia, Ph,P.
D *H>a r t n' en t o f H <;M 1 1 h
y, Human .Services
6) Anne Arffi-sttonq Thompson
Kentucky
Commission
7} C. E. East.burn
Department ot tiie Ar;'ty
Louisville District
Corps ot; Engine ?rs
8) Hobort D» Pacific
U.S. Dop.ii. tra-ent of
the Interior, Fish
and Wildlife Service
9) Thomas A. Scott
Kentucky Dopartm^nt
of Transportation
Date Received
May 5, 1981
May 18, 1981
June 3, !981
June ti f i9«1
June 8, »931
June 8,
June
1981
Jim* 11, 1981
^ II,
Concerninq
Finds EIS to be
consistent with the
Commission* s Comprehen-
sive Coordinated
Joint Plan.
Supports EIS preferred
alternative.
Agrees with the need
tor surveys before
construction.
Tn support of EIS
preferred alternative,
Aqrees with major issue
oi: HIS; is supportive
of efforts to eliminate
untreated discharqas to
sub-surface water
resources and the
en v ironment.
Fi nds K1S to be in
compliance with tne
Advisory Council's
f. ?uir«ments.
Indicates the need for
construction permits in
state's rights-of-way.
V-2
-------
10) Jack L, Abney
Environmental Planner
June 22, 1981
II) Cecil S. Hoffmann
U..S, Department of
the Interior
12) T. James Fries
Kentucky Department
tor Natural Resources
and Environmental
Protection, Division
of Hater
13) U.S. Environmental
Protection Aqency,
Hegion iv
Atlanta, Georgia
June 29, 1981
July 2, 1981
Inadequate consideration
ot alternatives and
impacts of severs in
EIS; Does not agree with
preferred alternative.
Comments on various
aspects of the EIS.
Comments on various
aspects of the EIS*
Comments on various
aspects of the SIS,
V-3
-------
B. INDEX OF ORAL COHBESTS RECEIVED AT THE PUBLIC HB&RZIG
Rame/Association
Concerning
1) Leo Esters,
Cave City Council
2) Or, Janes Quinlin,
Uplands Research
Laboratory
3) Tom Chaney,
Citizen, Horse Cave
Thomas Aley, Director
Ozark Underground
Laboratory
5) Robert Deskins, Park
Superintendent, National
Park Service
Does not oppose 201 Plan, but
would like to deter it until they
have a definite commitment from the
National Park Service on the 201
study. Feels that, at least for
citizens of Cave City, cost is
prohibitive.
Did not see anywhere in the DEIS,
a discussion of monitoring the amount
of sewage flow through the pipes,
Suggests monitoring instrumentation
installed at various intervals.
Concerned with preservation of unique
underground system of the area;
elimination of odor in Horse Cave;
that since 40 percent of BOD in
Hidden River at Horse Cave is
unaccounted for, problems will still
exist and money will have been wasted;
protection of the known and unknown
cave environmental state within the
parks and that the wastewater capacity
in the region is sufficient to sustain
future tourist and industrial growth.
Feels that entire region, and in a
sensa, entire country should be
involved in preservation of natural
resources of the study area.
Concerned with any alternative which
allows for groundwater discharge
to flow through the Park; apparent
reluctance of the Park Service to be
involved to a greater extent,
Feels that solution to problems of
the area is at hand, and it should
be kept in mind that the money is
available now to solve problems and
may not be in the future.
Park Service feals that the regional
system is the best system; have not
participated as fully as he would
like because of lack of money.
Willing to share costs for design
of project, if they can come up
with the money.
V-4
-------
C. RESPONSES TO MRITfEH COHlEMfS
No questions or comments requirinq a response.
No questions or comments requirinq a response.
Ho questions or comments requirinq a response
No questions or comments requirinq a response,
No questions or comments requiriuq a response.
No questions or comments requirinq a response.
C. _ E*_ East bur B)L
Comment.: Define "on-lot systems" and the number of systems to be uti-
lized. Additional Mon-lot systems" may contribute to further problems
(Page iv, item 1e) . If. so, add to Subsection 3, Page v,
V-5
-------
£esgonse: The term "on- lot" system generally retars to any wastewater
treatment and disposal system which is capable of properly treating
and disposing or effluent on individual sites (such as parcels relat-
ing to single-family dwellings). * wide variety of on-site systems
exist, with the type chosen tor a given area generally being site
dependent. Population projections for the town of Muntordville indi-
cate very little growth expected to the year 2000 (see Table III-7,
Page 111-45 in the Draft E1S) . Although it is impossible to predict
the number of new on-lot systems in the Munfordville area, it is safe
to assume that tae number will bo fairly consistent with the future
population growth expected in the area. Thus far, with approximately
halt the population of Muntordville using on-lot septic tank/soil
absorption systems, no serious malfunctions have baen reported, Due to
the limited growth expected, it is doubtful that the number of addi-
tional septic systems would be great, therefore serious problems
associated witn these systems are not anticipated.
.• ii
Comment: Differentiate between "conventional ani alternative on-lotw
in Id and Je (Page v) , it applicable, here and throughout the
document.
*• "conventional" on-lot system generally refars to a septic
tank soil absorption field utilizing a subsurface soil absorption
field. There are numerous alternatives to the conventional systen
which can be utilized in the study area. They must, however, meet
several criteria: 1) System must be authorized by the State of Ken-
tucky, and 2) System must not contribute to environmental degradation
while protecting public health. Additionally, cost and ease of oper-
ations and maintenance of a system are considered in selecting an
alternative to the conventional on-lot system for a particular area.
Available alternative on-lot systems include: septic tank with soil
absorption field (bed) , with alternating absorption fields, with
absorption field utilizing dosing or closed loops, with leaching chan-
bers, with mound system, with an evapotranspiration bed, with sand
filters, disinfection 6 discharge, with seepage pits, with sloping
field - serial distribution, aerobic tank with mound system,
low-pressure subsurface pipe distribution, holding tank, aerobic tank
with evapotranspiration bed, cluster system (2 or more users on one
alternative system), waterless or low water toilet systems (5 types),
dual systems (blackwater and greywater) , small- diameter gravity sew-
ers, vacuum sewers, land application, pressure sewers (grinder purap) ,
and pressure sewers (septic tank effluent pump) .
Comment: Define "other interests'1 (Page vi. Item 3d).
£es£onse: Trie term "other interests" refers to local, regional,
state, and federal officials and other interested citizens involved in
the preparation of the ?IS,
coifiSS-i1 Second full block, "Treatment of Staging Area and Park City
flows a second time at Cave City" appears unnecessary. Please
explain, (Page 11-34).
Ef.§.E°.e.se: To avoid additional wastewater pumping and to service addi-
tional areas along Route 70 it is necessary to mix treated wastewater
from the Chaumont Plan*- with raw wastewater from along Route 70.
V-6
-------
Figure II-4 provides an illustration of this concept,
Comment: The page (II-4*>) does not adequately summarize alternative
(SA-PC-CC-HC)2 as to ooav>?:yanc9 sequence and treatment sequence (Refer
to Pages 11-31, bottom and T. 1-32, top).
.Besp_onse: Paqe II-<+6 will be corrected to reflect the description of
Alternative (SA-PC-CC-HC)2.
Comment: I) Line sizes should be given (Figure II-3) ; 2) Park City
force main should originate from the pump station, not from the treat-
ment plant; 3) The conveyance line from Park City should terminate
into new Cave City pumping station, not the treatment plant*
Resgonse: \) Line sizes ace not given on any figure because this is
not a design report, hut rather a planning document with recoamen-
dations as to preferred approach to wastewater treatment and disposal
in the area. The design stages of the pro-ject. will develop line
sizes; 2) and 3) the pumping stations for both Cave City and Park City
are located at tne same site as their respective treatment facilities.
Theoretically, tue lines on Figure II-3 are originating and terminat-
ing from those particular sites not. from specific buildings.
Comment: I) Show "Chauraont" on Figure 11-4. 2) Force main from Park
City should terminate at new pumping station at Chaumont, not at the
STP. 3) Show "Toohoy Ridge" on figure. 4} According to block 3, Page
11-34, the Staging Area, Park City and Cave City flows are treated in
the upgraded Cave City STP, therefore, the line from the Staging Area
terminates at STP rather than at the pump station, as shown; 5J Figure
II-5. According to block 1, page 11-37, combined Park City and Cave
City flow is pumped to Horse Cave pumping station, not the treatment
plant, as shown. Other figures may need correction for the same rea-
sons given tor Figures II-3, II-4 and II-5.
Response: 1) S 3) Chan-yes to base map will not be made at this point
in the study. 2), 4) & 5) flefer to response to above Comment, parts 2
and 3.
Comment: Figure 1II-5. Noting the numerous point sources shown on
this figure, it cnn be concluded that not enough is mentioned in the
document about the fate of all existing point sources in the plans or
selected plan area; in other words, which sources are phased out,
which remain operating, etc,
.Resgonse: It is assumed that with implementation of the semi-regional
systenToption ot Phase 2 (Alternative 5) of the preferred alternative,
all existing point sources within the Cave City and Horse Cave city
limits «ill be picked up. Additionally, because it is along the pro-
posed force main route, the Caverna High School would be picked up.
Should trie regional system option of Phase 2 (Alternative 2) of the
preferred approach be implemented, the KOA Campground, the Park City
Campgtound, the Park City School and the Southern States Feed Hill
would probably be picked up. Those not picked up would probably
include the Pirk Mammoth Resort, the Bow-Ayr Toll Plaza, the Jelly-
stone Park and the Crystal Onyx Cave. The Mammoth Cave National Park
and the Great Onyx Civilian Conservation Corps will not be included
V-7
-------
because they have their own treatment facilities, Munfordville would
also not ha picked up.
Comment: Page 111-66. Under "Small Wastewater Treatment Plants," the
statements and conclusions made in this section are based on supposi-
tion and are not valid in tue absence of dat.a. At. minimum, data
should be obtained tor the treatment plants which discharge directly
or indirectly to the grouridwater to determine conclusively whether
this total floh (34,9iJQ gpd) has potential to adversely impact the
groundwater in this sensitive area.
Besgonse: The last sentence of the second paragraph on page 111-66,
beginning with "Because of the nature,..." will be eliminated,
Comraent: Section 10 of the Rivers and Harbors Act of 1899 requires
that any work to be done on a "navigable water of the United States"
be authorized by a Department of tha ^rmy (DA) permit. The proposed
outfall site is above our Section 10 jurisdiction on the Green River
and, therefore, will not require a DA permit under this section of the
law.
Hejs£>onse: Comment diops not require a response.
Cojiment: The Green River, at the proposed outfall site, has an aver-
age annual flow exceeding five cubic feet per second. Therefore, any
placement ot dredged or fill material below the Ordinary High Hater
(OHW) elevation will require authorisation under Section 40U of the
Clean Water Act.
Hes£onse: Authorization will be requested if necessary.
Comment: Backfill for utility line crossings is already authorized
under the provisions of 33 CFR 323,4-3{a)(1) of our regulations as
published in the Federal Register, Voluie 42, No. 138, on 19 July
1977, Therefore, an individual DA permit will not be required if the
streambed is returned to pre-construction contours, excess excavation
material is removed to a contained upland disposal area and there is
compliance to the attached special conditions,
MSSESDJje.' Comment does not require a response.
Comment: According to the DEIS, cofferdam construction tor the out-
fall system would involve the building of a dirt peninsula into the
river. If the selected plan includes the cofferdam construction, an
individual DA permit application must be made and received before work
can commence. Any questions on permit matters should be directed to
the above address, ATTN: Regulatory Functions Branch, OFLOP-FS, or by
calling (502) 582-5452,
Response: If necessary, a permit will he requested,
Comment: Munfordville is the only city of the tour Wammoth Cave Area
cities participating in the National Flood Insurance Program and is
currently in the emergency phase, Being in this phase, special flood
V-8
-------
hazard areas have been delineated for Hunfordville and certain con-
trols are administered by the city to reduce or prevent flood damage
in these areas.
Comment does not require a response,
CoB»en|.: Any construction should be carefully evaluated to insure
that flood damages that could be incurred by the proposed facilities
are prevented or reduced. This would be applicable to such damages to
other existing structures that could be caused by the proposed facili-
ties. Construction should be evaluated to insure compliance with Exe-
cutive Order 11988, Flood Plain Management. In essence, the Executive
Order directs federal agencies to use practicable alternatives to con-
struction in the 100-year flood plain, if available, and, if not, take
measures to minimize the impacts of such construction.
Bgsgonse: An evaluation will be made when appropriate.
Comment: The deficiencies in the EIS as it relates to the Endangered
Species Act requirements concern the need for:
1. Survey data on the extent of mussel populations, espe-
cially at site of diffuser system,
2, Secondary impacts
3, Cumulative effects
4. Efforts that will be taken to eliminate, reduce, or mit-
igate any adverse effects.
i§tf»E2SJIS" Extensive discussions have been held between the U.S. Fish
and wildlife Service (PWS), EPA and EPA's consultants concerning the
presence of protected species near the proposed discharge to the Green
River, A three step process was agreed upon for the EIS, First, all
protected species known or suspected to be present in the study area
should be reviewed in detail to confirm or deny presence and impact
from the project, If this review indicates no impact then no further
action woald be necessary. However, if the review does not eliminate
all species then one of the two remaining steps could be required.
Either biological assessment surveys could be required to demonstrate
the presence or absence of the species in question or the project
could assume that the species in question were present and proceed
with tie descriptions outlined in the FHS letter of January 12, 1981,
The process was used and reduced those species of concern from 15 (F8S
letter of January 12, 1981) to three species, These three endangered
mussels ILa«£silis_orbicul.ata_orb.icul
~ known from the Green Biver above Munfordville,
V-9
-------
KY and may exist in the study area from the proposed point of dis-
charge downstream to the slack water associated with Lock No. 6 on the
Green River. Based on this knowledge, the assumption was made that
these three species do exist in the area. The EIS discusses the pro-
posed alternative system, possible impacts to these species associated
with this alternative system, possible mitiqative measures which would
reduce the extent of these impacts, and other measures.
The FWS has raised four specific areas of inquiry; (1) survey data,
(2) secondary impacts, (3) cumulative impacts, (4) mitigative
measures. The following section discusses these points.
(I) Survey data on the extent of mussel populations especially at site
of diffuse system,
FHS and EP& have agreed that site surveys are not required at this
time but will be required before the irreversible or irretrievable
commitment of resources, It has been the position of the EIS that
such surveys are within the scope of design work, & stady which
includes the mussel fauna of the Green River is being conducted at
this time by Dr» Arthur Clarice of the Smithsonian Institution; Divi-
sion of Hollusks; Washington, D.C, The results of this survey will be
important information and should be incorporated into the design and
construction activities associated with the outfall structures.
(2) Secondary Impacts
The secondary impacts of the proposed alternative are expected to be
minor. The proposal included upgrading existing facilities at the
existing population centers and the pumping of treated effluent to the
Green Biver. The construction of this system is not expected to pro-
duce significant changes in the rate or distribution of population
growth for the area. The area near the Green River is not proposed
for sewering in the project,
(3) Cumulative Effects
Cumulative Effects are expected to be minimal, The probable discharge
point is downstream of the Interstate Highway 65 bridge and upstream
of the Lock No. 6 pool, This area is characterized by low population
density and predominately steep slopes along the river. It is unlike-
ly that other projects will have any significant impacts on this area.
(4) Efforts to Eliminate, Reduce or Mitigate Adverse Impacts
The EIS discusses primarily three areas for reduction and mitigation
of impacts:
V-10
-------
Sedimentation impacts irom construction, toxicity impacts from resi-
dual chlorine, and design measures to improve plant operation and mit-
igate the impacts of plant malfunctions.
Sedimentation from construction activities could have severe impacts
on the river system as a whole unless properly controlled. The design
and construction phases of the project will be required to address
this issue in detail, Existing techniques are available to control
this activity.
Residual chlorine levels and treatment plant design will be addressed
in detail in the design staqe of the project. The EIS has been con-
cerned over these issues and has corresponded with the FWS on them
(FHS; Asheville; NC: February 3, 1981). Again, the design phase of
the project will detail the systems to control these impacts. If nec-
essary dechlorination can be included or an alternate disinfection
technique. Impacts of plant malfunctions can be controlled through
enforcement of the local pre-treatment ordinance and plant design.
9l_Keatuc|i_ Depart §ent
So questions or comments requiring a response.
Comment; The EIS has not adequately considered or evaluated alterna-
tives to conventional sewering such as on-site disposal.
£esgouse: Horse Cave, Cave City and a portion of Muntordville are
currently sewered and served by their own wastewater treatment facili-
ties, It is, therefore, not appropriate to convert these currently
sewered communities to an on-lot disposal system. The community of
Park City, a portion of Munfordville and the homes and tourist facili-
ties along Eoute 70 (Route 70 development area) are currently served
by some form of on-lot system. In these areas, it would certainly be
the least cost approach to maintain on-lot systems and upgrade, where
appropriate. This is, in fact, the recommended approach for the Mam-
moth Cave area from EPA's standpoint, However, the National Park
Service has expressed strong concern over the continued use of on-lot
systems in areas (Park City and Route 70 area) that are drained by
groundwater sub-basins that ultimately flow through the Park. In
response to the Park Service*s concerns the option of implementing a
full regional system (by including Park City and the Route 70 area)
will remain open until local fundinq decisions are made. Therefore,
unless the Park Service provides funding or other non-EPA funding is
made available to remove the financial constraints of a regional sys-
tem, a semi-regional system with upgraded on-lot systems in Park City
V-ll
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and along fioute 70 will be implemented. The concerns of this comment
have, therefore, been responded to in the Draft BIS.
Comment; The EIS completely iqnores the problem of leaking sewers.
Response: As indicated in the Draft EIS (pages 11-28 and 11-44), when
wastewater is conveyed from one population center to another, poten-
tial environmental benefits dictate that only treated wastewater be
conveyed. The benefits to be derived from pumping treated wastewater
include:
1. to avoid the development of septic conditions in the
sewer lines because of long detention times and
2. in the event that line breaks or leaks occur, treated waste-
water would pose a much less serious threat to the subsurface
systems than would raw wastewater*
Additionally, as suggested by the National Park Service at the Draft
EIS Public Hearing, flow monitoring devices will be installed a't regu-
lar intervals to aid in the expeditious identification and correction
of leaks or breaks.
Comment: The endangered species sections of the DEIS are inadequate
as they relate to the Endangered Species Act's requirements for a
biological assessment.
Response; Comments concerning the Rare and Endangered Species section
and biological assessment have been addressed under the response to
comments from the Fish and Wildlife Service (#8) .
Comment; (Page III- 41, Item 12, paragraph 1, line i) Not. all rare and
endangered flora and fauna of the Commonwealth of Kentucky are cur-
rently protected by Federal legislation. Candidate plant species have
no Federal protection at present and will not unless listed. There
are other species within the State that, although rare, may never be
proposed for Federal protection. In the same item, paragraph 2, line
10, it should be noted that the three categories addressed here refer
to the Smithsonian Institution's list of threatened plants, not endan-
gered species in general.
Line I will be changed to read, "most rare and endangered
flora and fauna of the Commonwealth of Kentucky...", Additionally,
the following sentences will be added following sentence 2, "Plant
species which are candidates for Federal listing have no Federal pro-
tection at present. There are several species within the state which
may never be proposed for Federal protection although they are rare."
The following sentence will be added following line 10, paragraph 2
"these three categories refer specifically to the Smithsonian Insti-
tution's list of threatened plants, not endangered species ift
general."
V-12
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Comment: The National Park Service has contracted with Scruggs and
Hammond", Inc. to conduct a sewerage study for Mammoth Cave National
Park. The results of this study when completed will form the basis of
the National Park Service's decision regarding wastewater management,
He do wish, however, to express support for any upgrading of local
wastewater management facilities that will prevent future pollution of
the cave system.
Response; No response necessary
Coi.ISB.t- We note that the Kentucky Heritage Commission has recom-
mended that a cultural resource survey of the project area be con-
ducted. «e concur with this recommendation since numerous historic
and archaeological resources are known in the area, and we look for-
ward to seeing the results of the survey. The state Historic Preser-
vation Officer should be afforded an opportunity to review and coraaeat
on the survey report and should be consulted on the adequacy of any
proposed mitigation measures. If any cultural resources meeting
National Register criteria are to be affected, the Advisory Council on
Historic Preservation must also be afforded an opportunity to comment.
Cultural resource surveys are required by Section 110 (A) (2) of the
National Historic Preservation Act, as amended, The Advisory Council
on Historic Preservation implementing procedures for this Act are
found in 36 CFB 800»
This has been noted.
Comment: It is stated that, "No surface runoff reaches the river"
(page III-13, paragraph 3} in reference to Green River, That state-
ment appears to be in need of qualification in view of the large fold-
ed map of Groundwater Basins in the Mammoth Cave Region, Kentucky,
which shows a considerable number of streams reaching the north side
of Green River in the northwestern part of Mammoth Cave National Park,
Besgonse: In order to further qualify this statement it should read,
"No surface runoff from the EIS Study Area reaches the Green River."
12L Keatucki 0eBaEtient_fo£_gatacai_gesourcfs_aid_l§iiroi««|til_ieEs-
Comment; Page ix, Shat is the cost difference between upgrading the
Horse Cave and Cave City wastewater treatment plants versus construct-
ing a new oxidation ditch at each city's facility.
Sesgonse: The cost comparison is performed using Alternative 5, which
utilizes two stage biological treatment at Horse Cave and Cave City.
As stated on page iii of the Draft SIS, the Total Project Cost for
Alternative 5 when considering two stage biological treatment at Horse
Cave and Cave City is $6,546,000. The utilization of oxidation ditch-
es at Horse Cave and Cave City would increase the Total Project Cost
of Alternative 5 to $7,925,000, a difference of $1,379,000. Utiliza-
tion of oxidation ditches would increase the Total Present Worth cost
V-13
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of Alternative 5 from $7,975,000 to $10,190,000, an increase of
$2,215,000.
Content: Add Hunfordville, Route 70 and Staging Area to Table II-I on
Pages II-8-9-10 of the Final EIS,
Hesjjonse: Costs for Munfordville, Route 70 and the Staging Area have
been"* added to Table II-1, These costs are taken from Tables 11-14 to
11-19 on pages 11-64 to 11-69 of the Draft SIS. User charges for each
municipality except Hunfordville, Houte 70 and the Staging Area are
illustrated on these tables. User costs for Horse Cave, Cave City and
Park City are based on water records for those towns, These water
records provide data necessary to calculate an Estimated Dwelling Unit
(EDO) figure to take into account commercial aad industrial users. An
EDO figure is necessary in order to calculate an annual user charge
for a particular area. EDU figures and, therefore, user charges were
not calculated for Munfordville, Route 70 and the Staging Area for
the following reasons. A user charge for Munfordville is difficult to
estimate due to lack of water service records, the combined wastewater
service facilities (community on-lot and conventional) in the Hunford-
ville area (refer to Alternative MN-1), and the uncertainty of the
number of customers to be connected during the planning period. The
user charge for the Route 70 development can not be estimated due to
an uncertainty of the number of connections on line and the lack of
water service records. The Local Annual Cost for the Staging Area
would be the user charge for the Park Service since the Park Service
is the only customer at the Staging Area.
Comlent; At Nunfordville, has the upgrading of the facilities been
included and costed, including; disinfection, post aeration and flow
monitoring?
Response; The proposed action for Munfordville, flN-l, does not con-
tain any cost estimates for upgrading the existing facilities to pro-
vide disinfection, post aeration and flow monitoring. It was
determined at the start of the EIS that these facilities were of imme-
diate need in order to meet the existing NPDES permit and would,
therefore, not be considered as part of the EIS» However, these
facilities have not yet been constructed.
V-14
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D. RESPONSES TO ORAL COHHENTS
!L_Caxe_Citi_Council_lLgo_J§ters)L
No response required.
2L_Drft_Ja»es_QuinliQ,_Uplands_Research .Laboratorir Hatioaal_Park_Ser-
vice
Comment: Suggests installation of instrumentation to monitor sewage
flow through pipes at various intervals,
SLS®: This suqqestion will be included as a special requirement
of the EIS.
No response required
No response required
No response required.
V-15
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fl. TRAHSCRIPT OF PUBLIC HEABING HELD OB JURE 8, 1981 OH THE DRAFT BIS
The following is the transcript of the Public Hearing for the
flammoth Cave DEIS held in Cave City on June 8, 1981.
VI-1
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MAMMOTH CAVE AREA
201 FACILITIES PLAN
ENVIRONMENTAL IMPACT STATEMENT
DRAFT EIS
PUBLIC HEARING
Transcript of Public Hearing
held in Cave City, Kentucky,
June 8, 1981.
APPEARANCES:
Mr. John E. Hagan III, Chief, EIS Branch
Mr. Ron Mikulak, EIS Project Officer
U. S. Environmental Protection Agency
Region IV -- 345 Courtland Street
Atlanta, Georgia 30365
REPORTER: Barbara B. Kilgus
2102 Smallhouse Road
Bowling Green, Ky. 42101
Tel: 502/842-1515
-------
WITNESS
Mr. John Hagan
Mr. Ron Mikulak
Mr. John Hagan
Leo E. Esters
Dr. Jim Quinlan
Mr. Tom Chancy
Mr. Campbell Wallace
Mr, Tom Aley
Mr8 Robert Deskins
Mr, John Hagan
Certification
INDEX
EXAMINATION
Opening Comments
Opening Comments
Comments
Comments
Comments
Comments
Comments
Comments
Comments
Closing Comments
PAGE
3- 5
6-17
18-19
19
20
20-22
23-25
26
.27-28
28-29
30
The following is a transcript of the evidence heard
and the proceedings had upon Public Hearing of the Mammoth Cave
Area, 201 Facilities Plan, Environmental Impact Statement, Draf
EIS, before Mr. John Hagan III, and Mr. Ron Mikulak, at the
Cave City Convention Center, Highway 70, Cave City, Barren
County, Kentucky, Monday, June 8, 1981, beginning about the
hour of 7:30 P.M., Central Daylight Time.
-------
MR. HAGAN: Good evening ladies and gentlemen. I would
like to welcome you to this public hearing on the Mammoth Cave
Area Draft Environmental Impact Statement and 201 Facilities
Plan for proposed wastewater facilities in the Mammoth Cave
Area.
I would like to begin the formalities tonight
by introducing myself. My name is John Hagan. I am the Chief
of the Environmental Impact Statement Branch, the U. S. Environ*-
mental Protection Agency in Atlanta.
On my immediate left, to your right, is
Mr. Ron Mikulak who has been the Project Officer on the Mammoth
Cave EIS; and on my right, to your left, is Mr. Campbell Wallace
who is the 201 Facilities Plan consultant for this project.
There are several local elected officials
in the audience this afternoon who signed up by the time I got
the cards and I would like to recognize these folks„ Mrs.
Louise Stinson, Mr. Clyde Hubbard, Mr. Talley, City Attorney.
Mr. Talley, we are glad to have you with us. And Mr. Esters.
Glad to have you folks with us.
It is always gratifying to see elected
officials come out and attend these meetings because basically
wastewater treatment facilities and their operation, mainte-
nance, and their growth of this area is really in your hands,
and it is always gratifying to see you come out and participate
in these formalities.
-------
The purpose of this evening's meeting is to receive
comments from the public and other agencies on the wastewater
management proposals contained in the Draft Environmental Impact
Statement and the 201 Facilities Plan for the Mammoth Cave Area.
These studies are being prepared under the authority of the
Clean Water Act and the National Environmental Policy Act,
The Clean Water Act enables the Environmental
Protection Agency to fund up to 751 of certain eligible costs
for planning, design, and construction of wastewater facilities.
The planning phase of this process results in the preparation
of a facilities plan. In this instance, the Mammoth Cave Area
Facilities Plan is being administered by the Barren River Area
Development District, and I notice in the list there are
several representatives of BRADD here tonight. This 201
Facilities Plan includes the municipalities of Munfordville,
Horse Cave, Cave City, and Park City.
The National Environmental Policy Act requires
Federal Agencies to prepare an Environmental Impact Statement
on major federal actions which significantly affect the quality
of the human environment. Because of the environmental com«
plexities in the cave area and the apparent financial and
management constraints of the applicant cities, EPA made the
decision to prepare an Environmental Impact Statement in con-
junction with this Facilities Plan. Accordingly, in October
of 1977, the Notice of Intent to Prepare an EIS was issued.
-------
Pursuant to the guidelines of the President's
Council on Environmental Quality and the Rules and Regulations
of EPA with regard to the preparation of EIS'S, this Public
Hearing is being held to receive your comments on the Draft EIS.
The Draft EIS and Facilities Plan are being discussed in a
public forum to encourage public participation in the federal
decision-making process and to develop improved public under-
standing of the federally funded projects.
In this regard the Draft EIS was made avail-
able to the public and EPA'S Office of Federal Activities on
May the 1st, 1981, and was listed in the Federal Register • on
Hay 8th, 1981. The Draft EIS Comment Period will extend until
June the 22nd, 1981. The comments received during this even-
ing's meeting and during the remainder of the Comment Period,
which may be submitted in writing, will become a part of the
official record.
Now before we get into the real business of
the evening, which is to hear what you all have to say, Mr.
Mikulak is going to provide us a very brief update on the
project and \vhat has happened todate and a brief description.
Ron, would you take the mike.
MR. MIKULAK:
Thank you, John,
-------
MR. MI KULAK: Good evening. My name is Ron Mikulak. T am
the EIS Project Officer for the Mammoth Cave Area Draft EIS,
and I am also located in Atlanta, Georgia,,
The Draft EIS is addressing the provision
of watewater facilities for a portion of Mammoth Cave National
Park and several communities nearby including, as Mra Hagan
noted, Munfordville, Horse Cave, Cave City, and Park City,
What I propose to do is to just provide you
with a brief summary of what the Draft ETS has addressed, what
we have gone over through the project thus far, and in doing
so I am going to be using this little blue handbook that you
should have picked up on your way in0 If you haven't done so,
I will give you a few moments to pick one upa
For those of you who may not be familiar
with the study area, it is outlined on Page 2 of the
booklet and, of course, encompasses those cities that I just
mentioned.
As Mr0 Hagan also noted, the Barren River
Area Development District, the BRADD, was charged with the
responsibility of administering the Mammoth Cave Area Facilitie
Plan, The purpose of a Facilities Plan is the development of an
appropriate wastewater management strategy course for a specific
area. Because of the environmental complexities in the cave
area, EPA made the decision to prepare the Environmental Impact
Statement in conjunction with the Facilities Plan. The ob~
-------
jectives o£ these studies, therefore, were to establish what
existing conditions were in the Mammoth Cave Area, to develop
and evaluate wastewater management alternatives, to determine
the adverse impacts associated with those alternatives, and
to ultimately recommend a preferred alternative and to present
this information to the public.
In preparing these studies EPA contracted
with a consulting firm to provide technical assistance in
preparing the EIS. That firm was Gannett, Fleming, Corddry and
Carpenter out of Harrisburg, Pennsylvania, and assisted by the
firm of Claude Terry and Associates out of Atlanta, Georgia,
and Campbell Wallace who was contracted as the 201 Engineer
in assisting the BRADD in developing the 201 Plan.
Before I discuss the EIS alternatives that
were produced through these studies, I would briefly like to
explain what the area's existing wastewater management system
is for those of you who may not be familiar with it.
Starting on Page 3 of the handout, it is
indicated that Munfordville is currently served by sewers and
a treatment plant which discharges to the Green River. Both
the cities of Horse Cave and Cave City are sewered and served
by their own treatment facility and discharge treated effluent
to adjacent sinkholes.
Park City is currently served by septic tank
Additionally, several privately owned treatment plants are
-------
located throughout the area. Most of these plants either
have a direct or indirect discharge to groundwater. Those
areas not currently served by private plants or municipal
facilities are typically served by on-lot systems, most often
septic tanks.
As part of the EIS, eight (8) wastewater
management alternatives were developed. These eight (8) alter-
natives range from a regional system involving all communities
except Munfordville to local treatment and local disposal for
each community. Page 4, Figure 2, in your handout provides
you with a schematic representation of those eight (8) waste-
water management alternatives.
The results of the evaluation of alternatives
in terms of cost, impacts to the man-made, impacts to natural
environment and operability are shown on the following page,
Page 5. The costs of the eight (8) alternatives that are shown
are in terms what's called present worth costs„ The present
worth cost analysis establishes a basis for the comparison of
total costs of each alternative. The total costs involved
basically two parts: the capital cost or the cost of constructio
alternative, and then the annual operating or 0 § M cost over
the period of the planning period.
Of the eight (8) alternatives shown on Pages
4 and 5, three, numbers 2, 5, and 8, show the greatest promise.
The capital, 0 § M and present worth costs of these three
-------
alternatives are further detailed in the middle of Page 5.
Of additional concern to both the community
and EPA are the estimated user costs of the alternatives.
These costs have been estimated on the basis of Dollars per
Equivalent Dwelling Unit per year, with an Equivalent Dwelling
Unit representing the average residential user, average home-
owner. Commercial or industrial users may therefore be
represented, in terms of numbers of EDU'S or Equivalent Dwell-
ing Units based on wastewater flow.
The estimated annual user costs for alter-
natives numbers 2, 5, and 8 are shown on the bottom of Page 5.
Please note that these figures do not include the existing user
charges of approximately $37.00 a year for Horse Cave, and
$45.00 a year for Cave City.
Pages 6 through 10 of the handout provide
you with a brief description of alternatives 2, 5, and 8 as
well as a discussion of the pros and cons of each,
I'd like to take the next few moments to
briefly review this information with you before the Draft EIS
preferred alternative is discussed.
Alternative #2^ involves the following com-
ponents of a regional system. And if it helps you to refer
back to Figure 2 on Page 4, please do so and I won't mind the
rustling of pages.
Alternative #2 involves local treatment
9
-------
facilities at each population center.
Joint disposal of all effluent, except for
Munfordville, via surface water discharge to the Green River.
Existing facilities at Cave City and Horse
Cave would require upgrading.
New facilities would be required at Park
City and a proposed Staging Area for Mammoth Cave National Park
Additional on~lot systems would be required
at Munfordville.
An inter-city conveyance and disposal line
would be required.
Among the Pros of Alternative #2 are, that
it provides the greatest amount of groundwater protection from
wastewater discharges.
It corrects existing water quality problems
in the Hidden River groundwater sub-basin.
It corrects existing odor problems in Horse
Cave.
It would exhibit the greatest overall system
operability.
In the past it has received the support of
the communities, environmental/conservation groups as well as
the National Park Service.
It provides service to existing development
along Route 70 between Park and Cave City and, therefore, affor
10
-------
protection of sensitive areas in this location from wastewater
discharges.
It also received a high rating with regard
to natural and man-made environmental impact.
Among the Cons of Alternative #2 are, that
it has the highest net present worth cost.
The cost to the community of Park City would
be prohibitive unless other funding sources could be make
available.
The potential exists for development to be
encouraged along Route 70.
There is currently no multi- city or county
sewer authority to implement this option. All the groundwork
has been laid to develop such an authority.
Considerable construction activities
associated with the inter-city conveyance and disposal line,
approximately 114,000 feet of gravity and force mains.
Alternative #5 involves the following
components:
Local treatment facilities at each populatioi
center.
Joint disposal of only Horse Cave's and
Cave City's effluent to the Green River.
Existing facilities at Horse Cave and Cave
City would require upgrading.
11
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Additional conventional and alternative
on-lot systems would be required at Park City.
Additional on-lot systems would be required
at Munfordville.
The Park's proposed Staging Area would
employ on-lot systems.
Among the Pros of Alternative #5 are, that
it has the next to the lowest net present worth cost.
It corrects the obvious water quality and
odor problems in the Hidden River groundwater sub-basin by
removing Horse Cave's and Cave City's sub-surface discharges.
As with Alternative #2 it provides the
greatest degree of protection of the groundwater system and
cave environment for the Hidden River area.
It involves less than half of Alternative
#2's construction activity for the inter~city conveyance line.
When compared to Alternative #2, the local
cost is significantly less for Park City, and slightly more for
Cave City, and roughly the same for Horse Cave.
If the force mains from Cave City to Horse
Cave to the Green River were designed to include flows from
the proposed Staging Area and Park City, this alternative could
be the initial phase of what might eventually be a regional
system.
Among the QoH.s_oJ_Arternative #5 are, that
"""" " ' I III - _ „ •! [
12
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existing residential and commercial developments now using on-
lot systems in Park City and along, Route 70 would not be served
The local cost to Cave City is slightly
higher than #2.
The system operability is slightly less than
#2.
Although the alternative does address the
water quality problems in Horse Cave and Cave City, it does
not receive the overwhelming support of the Park Service and
other interests as did #2 because all sub-surface wastewater
discharges would not be removed.
^Alternative #8 involves the following ele-
ments :
Local treatment facilities at each populatioi
center.
Conventional and alternative on~lot systems
at Park City.
On-lot systems at the Park's proposed Staging
Area.
Cave City's existing facility would require
upgrading for a sub-surface discharge.
Horse Cave's existing facility would require
upgrading for surface water discharge .
And additional on-lot systems would be
required at Munfordville.
13
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Alternative #8 has the lowest net present
worth cost.
Lowest local costs for Cave City and same
local cost for Park City as in Alternative #5.
Removes Horse Cave's discharge from the
Hidden River Sub-basin.
It involves the least amount of construction
activity for inter-city conveyance and disposal systems, approxi
mately 36,000 feet.
Among the Cons of Alternative#8 are, as in
#5, existing residential and commercial developments now using
on-lot systems in Park City and along Route 70 would not be
served.
Cave City's sub-surface discharge would not
be removed. The potential for the Hidden River sub-basin to be
adversely impacted by wastewater discharge \vould remain.
The option is rated lowest with regard to
the impacts to the natural and man-made environment.
This option is rated lowest with regard to
system operability.
This option has received the least amount
of community support from the Park Service, and interested
groups and individuals.
Although wasteload allocations for a sub-
surface discharges have been developed, a lesser degree of con-
14
-------
fidence is attached to those allocations than" t"o'surface water"
discharges to Green River.
This option would preclude the possibility
\
of Park City or the Park Service being served by a regional
system.
Rounding out my brief discussion I would
just like to quickly go over what is the Draft EIS Preferred
Alternative or more appropriately the Draft EIS Preferred
Strategy. Starting on Page 10 in the handbook we indicate
that the underlying theme of the EIS is that the provision of
wastewater services should be compatible with efforts to
preserve and protect this area's nationally significant cave
systems and their unique physical, biological, and historical
resources. The local EIS review committee and the National
Park Service have voiced their support for a regional waste-
water management system that would afford the greatest pro-
tection of the area's groundwater and sub-surface systems.
Although a regional system is viewed as the environmentally
preferred option, local economic constraints may dictate that
another environmentally acceptable option be pursued.
In light of the concerns regarding costs
and the protection of the cave resources, a phased approach
for the Draft EIS is recommended which would ultimately result
in either a regional system or a semi-regional system.
This approach involves the following
15
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components:
1. Initiate Phase I of the project which would
provide for design for upgrading the treatment facilities at
Cave City and Horse Cave and for conveyance facilities to the
Green River. The conveyance facilities would be evaluated
with and without future flows from Park City and the proposed
Mammoth Cave National Park Staging Area, and the Route 70 area.
2. The establishment of a critical decision
date to coincide with completion of the preliminary design for
Horse Cave and Cave City and for the National Park's decision
regarding the development of the proposed Staging Area or the
local communities' commitment to obtain additional non-EPA
funding sources.
Point 3. Provide final design for facilities based
on the above decisions. At that point, EPA and the Common-
wealth of Kentucky will also have to define the extent of EPA
eligibility for remaining design and construction.
If the NFS does develop the Staging Area
and is able to provide funding assistance for Park City or
if additional non-EPA funds are available, the remaining,,
components of the regional alternative would then be con~
structed.
If the National Park Service does not
develop the proposed Staging Area or if additional non-EPA
funds are not available, the remaining components of a semi-
16
-------
regional alternative would be constructed.
The figure on Page 12 of your handout present
the preferred approach to wastewater management in the Mammoth
.. !•' '
Cave Area as recommended in the Draft EIS and briefly summarizes
what I have just said.
In conjunction with the development of the
EIS, a Citizen Review Committee was established to provide
opportunities for interested groups," individuals, and govern-
mental agencies to participate in the development of the EIS.
Additionally to the Citizens Review Committee a Groundwater
Technical Advisory Committee was established to provide data
review and input into the groundwater studies that were being
conducted during the development of the EIS.
The committees provided comments and ideas
and suggestions during various stages of EIS. I would like to
express my appreciation for the time and effort expended by
committee members in reviewing the EIS materials, and providing
comments and participating in meetings. The contribution of
the committees was invaluable for the completion of the Draft
EIS.
I might have lied to you. My comments
might not have been brief but I had a captive audiance and I
couldn't help myself. This concludes the presentation of the
Draft EIS summary.
I turn the meeting back over to Mr. Hagan,
17
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MR. HAGAN: Thank you, Ron. I would like to reiterate
Ron's words about participation of local citizens and the
committee activity. We started several years ago on what has
turned out to be a very extensive public participation program
in connection with our EIS activities, and we settled in on
this committee structure as a preferred way to handling public
participation. This kind of a meeting here is a rather cold
and formal sort of an arrangement in which you listen to us
and then you talk back to us but we don't really communicate,
and the committee structure was designed to get a smaller
group where it could be much less formal and much closer
communication, and we do very sincerely appreciate the assistance
of these folks, the time and effort these folks have put into
this committee.
Now as you came into the hall right here
behind you there was a table. I hope all of you registered.
We would like this registration for several purposes. First
of all, to justify our coming up here. I mean, I have to tell
my boss, "Yes, there really was a public hearing up here, you
know, and all these folks came." We would like to make sure
you get on the mailing list to know what we are doing, if you
are not on it already. But most important for tonight's
activities I would like for any of you who wish to speak to
fill out one of these cards and indicate that you want to speak
At this time I have two yeses, one maybe, an
18
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two unmarked. So, without further ado I think we will get into
the reason for our being here which is for us to listen to you.
1 will call on these folks in the order in which I received
their cards and taking first those who said they definitely
wish to speak. Now I will call on Mr. Leo Esters of Cave City
City Council. Mr. Esters.
MR0 LEO E. ESTERS: I am Leo Esters with the Cave City Council
and I would like to express our opinion on it. We want on
record as not opposing the 201 study right now but we want to
kindly defer it until we can get some definite commitment from
the National Park Service on this 201 study.
The way it started out everybody was suppose
to be involved in it and right now it has got down to the point
that only Cave City and Horse Cave are involved, and we feel
like for the citizens of Cave City that the cost is prohibitive,
MR, HAGAN: Thank you, Mr. Esters. Dr0 Jim Quinlan is
the other gentleman that has indicated he wished to speak,
Jim, would you come up to the microphone so we can all hear
you. While Jim is coming up I will express publically to him
my thanks for the 50 cent tour that we had this afternoon. It
was very quick but it was very informative and we saw a lot of
the surface features. I hope tomorrow morning to see some of
the underground features that are of so much interest.
19
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DR0 JIM QUINLAN: I just wanted to say that I saw nowhere in
the plan or the supplementary volumns any discussion of monitor
ing the amount of flow through the pipes. We know from
experience elsewhere in this area that sometimes the pipes
which convey the sewage can leak, so they should be installed
at reasonable intervals whether it is a one mile, five miles,
what-have-you. That is not the point to be decided now, but at
reasonable intervals there should be instrumentation installed
to monitor the flow so between, shall we say, points 5 and 6
we can say, "Hey, half the flow is gone. We have got a leak
there. Let's find it," and these should be monitored at a
regular basis. That's all.
MR. HACAN: I have a maybe here, Mr. Tom Chaney. Tom,
have you decided whether you wish to speak or not.
MR, TOM CHANEY:
MR. HACAN:
Yeah, I will raise some questions
That's why we are here.
MR, TOM CHANEY: This started out -- way back when this thing
started I was a very small boy.
MR. HAGAN:
Yes, me too. (laughter in hearing roonu)
20
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MR. TOM CHANEY: We got your grammar and style straightened
out a little bit. I hope that spreads throughout the government
I have my doubts. I just want to register my chief concern and
I am not a resident of the immediate area involved. I was
invited to be on the committee and accepted that invitation.
And, so, my concern is a little bit broader than maybe those
representing specific areas, but my chief concerns are as
I am concerned with the preservation of the
unique underground system that we have in the area which
includes groundwater as a viable resource,,
I am also concerned related to that with the
elimination of the odor in Horse Cave0
I am concerned that on Page A through 5
that 40 percent of the BOD stuff in Hidden River at Horse Cave
is unaccounted for, T wonder what happens if we spend all this
money and we still have the same problem0
I am concerned with the protection of the
known and unknown cave environmental state within the parks
and that the wastewater capacity in the region is sufficient to
sustain the future tourist and industrial growth that will come
to the area. And I don't know how «~ I keep saying this over
and over at the committee meetings and everything else, but we
have got to have the help of the entire region and in a sense
the entire country to preserve the resources that we are en-
21
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trusted with here, which means that Horse Cave and Cave City
can't exclude Park City, Which means that all of us in the
region ~~ and I speak as a dairy farmer and I have a suspicion
that maybe I am a part of that 40 percent BOD problem in
Hidden River Cave,, I don't know that, I am, you know, doing
my best to contribute to it, (laughter in hearing room.)
And I want to urge the gentlemen of the National Park Service
to accept its responsibility which starts as a user of any
kind of regional system but which is broader than that which
expands to the chief object of protection here or, at least,
the center of protection in the area.
And I am concerned about all the alterna«
tives that allow for groundwater discharge which flow through
the Park and that are not taken care of«
And I am concerned by the apparent re-
luctance of the Park Service to jump in this with all four
feet. Thank you,
MR. HAGGAN: We appreciate those comments and particu~
larly the comment about the need for this particular region's
undertaking. Whether you folks realize this or not, those of
us who work for EPA, particularly way down there in Atlanta,
do care about preserving the options of the Barren River
Area Development District to solve their problems with the
assistance that the law has provided within the Clean Water
22
-------
Act, and we think that this is a regional problem and that was
one of the big reasons for determining that this particular
project should receive the detailed analysis it has through
the ETS.
I have two other cards here which have no
indication as to whether they wish to speak or not, Mr0 Campbel
Wallace,, Campbell, would you like to say something for us?
MR0 CAMPBELL Wallace: I feel like I should say something about
the 201 but I will try to be «« just go through my documents
here and be as brief as possible and then I will go through
the re-wrote about two«page summary based on a little bit of
the background.
One, there was a meeting back about the
first of the year when we brought this down to where there
were three alternatives which were viable. These were to be
investigated further,.
These were Horse Cave going seemingly to
Green River with Cave City's local discharge« Local discharge
into two towns and the two towns combined and going to the
Green River as the first phase of a two-phase project.
The second phase was as shown in this handou
to be the remaining items. The total cost as we developed it
on the first phase is estimated at $3,612,.000.00,
At the time this was written there was some
23
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idea of what the local individual share might be because the
funds were readily available from the Farmer's Home Adminis-
tration at a low interest rate. As of todate we can get the
loan anywhere from 5 to 11 percent interest; and, so, the
actual costs to individuals are a little bit up in the air.
Based on this the first phase was approximately 43 cents per
1,QQO for Cave City and 25 cents per 1,000 for Horse Cave.
Now'this was on the combined units, and the third phases was
Mammoth Cave National Park. We assumed that the Staging Area,
whereas inclined, was not constructing the improvements to their
Green River plant estimated at $93,600.008
'. ">
) Munfordville from a cost standpoint, it
looked like . they would go with the on~lot disposal and the
plant upgrade was $76,800.00.
• ; We estimated the entire Park City System
and .based it on a low pressure with a small line current with
loc§l disposal components, tertiary treatment, followed by land
* •
disposal and came up with $1,365,000.00 which brought this
down to about a $7.00 minimum and about $1.86 per 1,000. This
is all based on a 5 percent rate interest.
The Highway 70 area would pretty well have
to be controlled on this basis and have to be controlled on-lot
disposal facilities through a management association which we
intend to make recommendations on this.
To make it as brief as possible, if anybody
24
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has any further questions? There appears to oe with full
participation by everyone on this. Very little difference
in costs from the first stage regional approach and local
approach. There is some at Cave City and it depends on the
way the figures are developed. I do not feel there is a great
deal of difference.
MR. HAGAN: Thank you, sir. The other gentleman who
must have come in a little bit late is Mr, Charles Bryanto
You didn't indicate whether you wish to speak but I would like
to recognize you as being a member of the Cave City Council.
I didn't get to recognize you the first time around. Where
is Mr. Bryant? (A gentleman raises his hand.) Would you
care --
MRo CHARLES Bryant: No, sir, I don't wish to.
MR0 HAGAN: At this time I will open the floor to any
one who has not previously indicated a desire to speak. If
there is anyone else that would wish to contribute to this
record? (A gentleman indicates a desire to speak.) Yes, sir,
would you come to the microphone and identify yourself for us,
please, sir? (Two gentlemen start to microphone,) T am sorry,
1 will get to you next.
25
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MR. ROBERT DESKINS: Okay.
MR8 TOM ALEY: I didn't see you. My name is Tom Aley. I
have been involved «-
MR, HAGAN:
please?
Would you spell that for the Court Reporter,
MR. TOM ALEY: A~l~e~y. I have been involved in this issue
for the last couple of years on behalf of the City of Horse
Cave and I appreciate their interest in it0 I have also served
on the Groundwater Technical Panel so I have had the opportunity
of reviewing an awful lot of your data in detail,
I pride myself in being a practical person
and it's that that brings me up in front of this, I think at
this point in time with the reports that we have here that we
have the solution to the problems in view and the money is
available now and it may not be in the. future. So, for the
people who live in the area who have a lot to dowith the
decisions, I certainly hope that will be kept in mind. Thank
you.
MR. HAGAN: Thank you, sirs Mr0 Deskins. I am sure
everybody in this area already knows Mr. Deskins, We haven't
had the pleasure of meeting but Ron told me who you are.
26
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MR. ROBERT DESKINS: I feel like Improbably should come before
the group and T don't know that T need to defend the National
Park Service for our position about the 201 today, I would like
to say that the National Park Service still thinks the 201 and
the regional system is the best system, but to respond to Tom's
question about why we haven't jumped with all four feet to get
in on this thing comes down to the bottom line and that's money.
And, quite frankly, if I had money in my budget I'd be nore
than willing to put it out and see that that money comes forth
and see this project carried out.
I think all of us know and when I say "if
we had the money," it is not the National Park Service money
but it is your money, maybe coming through a different funding
process. You know, it is just not available. The money is just
not there. I would say this and I have worked desperately and
T have made an attempt to see that if something is put in our
program to possibly assist with such a project. Now T am
willing to go on record and state here tonight that the National
Park Service is willing to come forth and try to share our costs
of this design for a phase that we may not be a part of, may
not have an opportunity to be a part of,
I can't tell you here tonight that the
Staging Area is going to be out one year or ten years from
now. So far that is a project that has been on the drawing
board for about 12 or 13 years and we are about where we were
27
-------
when we started several years ago. But, you know, the Park
Service feels very dedicated to protecting the resources, the
underground resources here and the Park, and even in the area,
but whether or not we can come up with the money is another
question. It is just unknown at this time but we do want to go
on record and state that we \\rould be willing to come forth with
that phase or that part of the design that you are calling for
in your alternatives. Thank you,
MR. HAGAN: Thank yous Is there anyone else who would
like to make a statement,,
MR0 ROBERT DESKINS: Let me clear that statement there, the
design money. I hope they don't expect the National Park
Service to pay the entire tab, but I think we are willing to
pay our fair share, maybe plus0
MR, HAGAN: I understood that. Thank youa Anyone else?
(No one indicating a desire to speak8)
I wish to thank you all for your partici-
pation tonight. The comments that we received here tonight
plus any other written comment which may come into our office
between now and June 22nd will be fully evaluated. These com-
ments will then be incorporated into the final Environmental
Impact Statement and that final Environmental Impact Statement
28
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will indicate EPA's decision as to the project which we support*
T want to emphasize again that the ultimate
decision in terms of what gets built on the ground is largely
the responsibility of the BRADD.
The final Environmental Impact Statement
will be filed with the Environmental Protection Agency's
headquaters office. It will appear in the Federal Register
and approximately 30 days after that date ~- I know that none
of you are anxious to read the Federal Register , I am neither,
but 30 clays after that date money will be then available for
the phase two design for this project,,
For those of you who have commented tonight
and for those of you who have indicated on the registration
card that you wish to get a copy of the final EIS, we will send
that to you in the mail.
Again I would say the Comment Period is open
until June the 22nd,, My name and address is in the little blue
handout which you have and if you wish to add any comments to
the record, please feel free to do so.
Again 1 thank you for coming and good even-
ing-
29
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STATE OF KENTUCKY )
COUNTY OF WARREN )
SCT,
I, Barbara B. Kilgus, Notary Public in and for
the State of Kentucky at Large, do hereby certify that the
foregoing Public Hearing regarding the Mammoth Cave Area
201 Facilities Plan, Environmental Impact Statement, was
taken by me at the time, place, and for the purpose mentioned
in the caption; that same was taken by me in shorthand notes
and tape recording and thereafter transcribed by me on the
typewriter; and the foregoing pages of typewritten matter
contain a true, correct and complete copy of my said notes,
to the best of my ability.
Given undermy hand this June 11, 1981.«
BARBARA B." KILGUS ,?NOt ARY^UBL I G"
State of Kentucky at Large
My commission expires: 4/26/82
30
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MAMMOTH CAVE AREA
201 FACILITIES PLAN
Environmental Impact Statement
DRAFT EIS
PUBLIC HEARING
JUNE 8,1981
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
-------
MAMMOTH CAVE AREA
DRAFT ENVIRONMENTAL IMPACT STATEMENT
201 FACILITIES PLAN
PUBLIC HEARING
June 8, 1981
7:30 P.M.
CAVE CITY CONVENTION CENTER
AGENDA
o Introduction and Purpose
o Summary of Draft EIS
- Purpose
- Background
- Wastewater Alternatives
- Preferred Alternative
o Comments From Elected Officials
o Comments From The Floor
o Adjourn
Written comments should be forwarded to:
John E. Hagan III, P.E.
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
404/881-7458
-------
MAMMOTH CAVE AREA
DRAFT ENVIRONMENTAL IMPACT STATEMENT
201 FACILITIES PLAN
PUBLIC HEARING
June 8, 1981
7:30 P.M.
CAVE CITY CONVENTION CENTER
AGENDA
o Introduction and Purpose
o Summary of Draft EIS
- Purpose
- Background
- Wastewater Alternatives
- Preferred Alternative
o Comments From Elected Officials
o Comments From The Floor
o Adjourn
Written comments should be forwarded to:
John E. Hagan III, P.E.
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
404/881-7458
-------
-1-
I. BACKGROUND
The Mammoth Cave Area Environmental Impact Statement is being prepared to
address the provision of wastewater management facilities for a portion
of the Mammoth Cave National Park and several communities proximal to the
southeastern and eastern boundaries of the Park (See Figure 1). The EIS
study area is situated in the Central Kentucky Karst which is
characterized by a gently rolling terrain pitted with sinkholes. The
subsurface contains a complex structure of limestone caves and
free-flowing groundwaters. The area's geological features are recognized
as unique national resources and provide the area with a strong tourist
attraction at the National Park and other local commercial caves.
Due to the complexities of existing pollution problems in the cave area
and the financial and apparent management constraints of the applicant
cities, EPA made the decision to prepare an EIS in conjunction with the
201 Facilities Plan.
The EIS was initiated in October 1977. The focus of the study was on the
development and evaluation of alternative wastewater management systems
in the cave area and to ensure the integration of environmental and
economic considerations at the earliest stage of facilities planning.
The major issues that were identified included:
the determination of subsurface water uses and water quality goals
resolution of local groundwater pollution problems, and
resolution of local funding responsibilities and capabilities.
During the EIS process, the issue areas were defined. The following
issues were determined to be the most significant: (1) the sensitivity
of the cave environment to wastewater discharges (2) resource
value/importance of the caves (3) the complexity of the area's subsurface
hydrology (4) financial impacts of wastewater management systems and
funding options.
-------
N
• STUDY AREAllMITS
i
ts)
I
FIGURE 1
MAMMOTH CAVE AREA
201 FACILITIES PLAN
ENVIRONMENTAL IMPACT STATEMENT
STUDY AREA
I2.OOO 600O O
I&OQQ
Safe 1* F»l
US. Environm«nlal Proltclion Aj«nc»
El Atlanta,Georgia
-------
-3-
II. ALTERNATIVES
A. Existing Wastewater Management
There are 5 major population centers in the study area. These
include the municipalities of Munfordville (1975 population of
1,233), Horse Cave (1975 population of 2,068), Cave City (1975
population of 1,818), and Park City (1975 population of 576), and the
proposed Staging Area at Mammoth Cave National Park. With the
exception of Park City, these population centers maintain and operate
wastewater treatment facilities. The disposal technique practiced by
Munfordville and Mammoth Cave National Park is surface water
discharge to the Green River. Treated effluent is disposed of in
Horse Cave and Cave City, however, by direct discharge to adjacent
sinkholes. Additionally, several privately owned treatment plants
are located throughout the study area. Most of these small
wastewater treatment plants have either a direct or indirect
discharge to groundwater. Those areas not serviced by municipal or
private treatment and disposal facilities, including Park City,
employ on-lot treatment and sub-surface disposal techniques
(including direct discharge- to sinkholes).
B. Description of Alternatives
Initially, eight wastewater management alternatives were generated in
the EIS. These 8 alternatives range from a regional management
concept involving local treatment and joint disposal by all
population centers (except for Munfordville) to local treatment and
local disposal of wastewater at each population center. The 8
alternatives are displayed schematically on Figure 2.
C. Evaluation of Alternatives
The analysis of the eight alternatives has resulted in the following
breakdown with respect to cost, impacts on the natural environment,
impacts on the man-made environment and operability.
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Figure 2. MAMMOTH CAVE AREA EIS ALTERNATIVES
-4-
#1
MAftOTH CAVE
*•* NATIONAL
*>> to*.
MUHrOIIDVXUE
o
CAVE
ait
PAW
MAMMOTH CAVE
**> NATIONAL
"*•» rnxt
MUNFDKDVILLE
o
STACDK
PAIX CITY
O
CAVE
cm
FAK CTTT
MAMMOTH CAVE
"*» NATIONAL
HUNTORDVILLE
O
/ GKEEH RIVER sft
BOUSE
\^/ CMt
CAVC
cnr
PAK CTTT
MDMTORDVILLE
o
MUNFUMWILLZ
PAK CTTT
-------
-5-
Estimated Net
Present Worth Impacts/ Impacts/
Alternative (In Millions) Natural Env. Man-Made Env. Operability
1 7 - ($10.9) 411
2 8 - ($11.6) 411
3 5 - ($9.9) 243
4 6 - ($10.3) 342
5 2 - ($8.0) 135
6 3 - ($9.6) 874
7 4 - ($9.7) 666
8 1 - ($7.6) 787
Of these 8 alternatives, 3 alternatives (numbers 2, 5, and 8) show
the greatest promise. The cost of these alternatives have been
refined and are presented below. Additionally, the pro/con
discussion will be limited to these 3 options.
Alternative # Project Annual Net Present
Cost 0 & M Worth
2 $10,574,000 $261,000 $11,620,000
5 6,546,000 230,000 7,975,000
8 5,876,000 249,000 7,630,000
Of additional concern in the evaluation of alternatives is the
estimated user costs of the alternatives, and the local implications
of these costs. These costs for alternatives 2, 5, and 8 for three
of the communities are presented below:
ESTIMATED ANNUAL USER COST
($/EQUIVALENT DWELLING UNITS)
Alternative # Horse Cave* Cave City** Park City
2 $39 $68 $460***
5 40 79 155
8 44 71 150
* Does not include existing user cost of approximately $37/
EDU/year
** Does not include existing user cost of approximately $45/
EDU/year
*** Assumes 75* funding for conventional/collection systems,
however, conventional collection systems are generally
not funded
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-6-
1. Alternative 2
(a) Description of Alternative 2:
•^^••••^•^•ll^^MMMMMMMM^HMMHMMIMnMMMMMMM^^^^^^M^ f
This alternative involves the following components of a
regional system:
(1) Local treatment facilities at each population center.
(2) Joint disposal of all effluent (except Munfordville) via
surface water discharge (secondary treatment) to the
Green River.
(3) Existing facilities at Cave City and Horse Cave would
require upgrading.
(4) New facilities would be required at Park City and the
Staging Area.
(5) Additional on-lot systems would be required at
Munfordville.
(6) An inter-city conveyance and disposal line would be
required.
(b) Pros of Alternative 2;
(1) Provides greatest amount of protection for free flowing
groundwater, groundwater supplies, sensitive cave
systems and rare and endangered species by removing all
wastewater discharges from the subsurface water network.
(2) Corrects existing water quality problems in the Hidden
River groundwater sub-basin.
(3) Corrects existing odor problems in Horse Cave.
(4) Exhibits greatest overall system operability
(reliability, flexibility and maintainability).
(5) Has received the support of the communities,
environmental/conservation groups and the National Park
Service.
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-7-
(6) Provides service to existing development along Route 70
(between the Park and Cave City) and affords protection
of sensitive areas from wastewater discharges.
(7) Received a high rating with regard to natural and
man-made environmental impact.
(c) Cons of Alternative 2:
(1) Has the highest net present worth cost.
(2) The cost to Park City would be prohibitive unless other
funding sources could be tapped.
(3) The potential exists for development to be encouraged
along Route 70. In this instance, non-point source
problems could adversely impact area cave systems.
(4) There is currently no multi- city or county sewer
authority to implement this option. Local communities
are, however, in the process of developing one.
(5) Considerable construction activity is associated with
the inter-city conveyance and disposal line (114,000
feet of gravity lines and force mains).
2. Alternative 5
(a) Description of Alternative 5:
This alternative involves the following components:
(1) Local treatment facilities at each population center.
(2) Joint disposal of Horse Cave's and Cave City's effluent
via surface water discharge (secondary treatment) to the
Green River.
(3) Existing facilities at Horse Cave and Cave City would
require upgrading.
'(4) Additional conventional and alternative on-lot systems
would be required at Park City.
(5) Additional on-lot systems would be required at
Munfordville.
(6) The Park's proposed Staging Area would employ on-lot
systems.
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-8-
(b) Pros of Alternative 5:
(1) Has the next to lowest net present worth cost.
(2) Corrects the obvious water quality and odor problems in
the Hidden River groundwater sub-basin by removing Horse
Cave's and Cave City's sub-surface discharges.
(3) As with #2, provides the greatest degree of protection
of the groundwater system and cave environment for the
Hidden River sub-basin.
(4) Involves less than half of alternative 2's construction
activity for the inter-city conveyance system
(approximately 51,000 feet of gravity lines and force
mains).
(5) when compared to #2, the local cost is significantly
less for Park City, slightly more for Cave City and the
same for Horse Cave.
(6) If the force mains from Cave City to Horse Cave to the
Green River were designed to include flows from the
Staging Area and Park City, this alternative could be
the initial phase of what could eventually be a regional
system to include Park City and the Park Service.
(c) Cons of Alternative 5:
(1) Existing residential and commercial developments now
using on-lot systems in Park City and along Route 70
would not be served. According to the Park Service's
dye tracing studies these areas are drained by
groundwater basins that flow through the Park, Although
no problems have yet been detected, the potential does
exist for the continued use of these on-lot systems to
adversely impact these sensitive areas and the proposed
critical habitat of the Kentucky Cave Shrimp within the
boundaries of the Park.
(2) The local cost to Cave City is slightly higher than #2.
(3) System operability (reliability, flexibility and
maintainability) is less than #2.
(4) Although this alternative does address the water quality
problems in Horse Cave and Cave City, it does not
receive the support of the Park Service and other
interests as does #2 because all sub-surface wastewater
discharges are not removed.
-------
3. Alternative 8
(a) Description of Alternative 8;
This alternative involves the following components:
(1) Local treatment facilities at each population center.
(2) Additional conventional and alternative on-lot systems
at Park City.
(3) On-lot systems at the Park's proposed Staging Area.
(4) Cave City's existing facility would require upgrading
for sub-surface discharge (advanced secondary treatment).
(5) Horse Cave's existing facility would require upgrading
for surface water discharge (secondary treatment) to the
Green River.
(6) Additional on-lot systems would be required at
Munfordville.
(b) Pros of Alternative 8:
(1) Has the lowest net present worth cost.
(2) Lowest local costs for Cave City and same local cost for
Park City as in Alternative 5.
(3) Removes Horse Cave's discharge from the Hidden River
Sub-basin.
(A) Least amount of construction activity for inter-city
conveyance and disposal system (approximately 36,000
feet of gravity lines and force mains).
(c) Cons of Alternative 8:
(1) Existing residential and commercial developments now
using on-lot systems in Park City and along Route 70
would not be served. According to the Park Service's
dye tracing studies, these areas are drained by
groundwater basins that flow through the Park. Although
no problems have yet been detected, the potential does
exist for the continued use of these on-lot systems to
adversely impact these sensitive areas and the proposed
critical habitat of the Kentucky Cave Shrimp within the
boundaries of the Park.
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-10-
(2) Cave City's sub-surface discharge would not be removed.
The potential for the Hidden River sub-basin to be
adversely impacted by wastewater discharges does exist.
(3) This option is rated lowest concerning impacts to the
natural and man-made environment.
(4) This option is rated lowest concerning system
operability (flexibility, reliability, and
maintainability).
(5) This option has received the least amount of support
from the Park Service, the communities and interested
groups and individuals.
(6) Although wasteload allocations for sub-surface
discharges have been developed, a lesser degree of
confidence is attached to these allocations than to
surface water discharges.
(7) This option would preclude the possibility of Park City
or the Park Service being served by a regional system.
HI- DRAFT EIS PREFERRED ALTERNATIVE
The underlying theme of the EIS is that the provision of wastewater
services should be compatible with efforts to preserve and protect
this areas's nationally significant cave systems and their' unique
physical, biological and historical resources. The local EIS review
committee and the National Park Service (NPS) have voiced their
support for a regional wastewater management system that would afford
the greatest protection of the area's groundwater and sub-surface
systems. Although a regional system is viewed as the environmentally
preferred option, local economic constraints may dictate that another
environmentally acceptable option be pursued.
In light of the concerns regarding cost and the protection of the
cave resources, a phased approach is recommended which will
ultimately result in a regional (Alternative 2) or semi-regional
(Alternative 5) wastewater management system.
This approach involves the following components:
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-11-
1. Initiate Phase I of the project which would provide for design
for upgrading the treatment facilities at Cave City (0.37 MGD)
and Horse Cave (0.53 MGD) and
for conveyance facilities to the Green River. The
conveyance facilities would be evaluated with and without future
flows from Park City (0.08 MGD), the proposed Mammoth Cave
National Park Staging Area (0.105 MGD), and the Route 70 area.
2. The establishment of a critical decision date to coincide with
completion of the preliminary design for Horse Cave and Cave City
for the NPS's decision regarding the development of the proposed
Staging Area or the local communities' commitment to obtain
additional non-EPA funding sources.
3. Provide final design for facilities based on the above
decisions. At that point, EPA and the Commonwealth of Kentucky
will also have^ to define the extent of EPA eligibility for
remaining design and construction.
(a) If the NPS does develop the Staging Area and is able to
provide significant funding assistance for Park City or
additional non-EPA funds are available, the remaining
components of the regional alternative could be
constructed. These construction elements would involve
treatment facilities at Park City and the Mammoth Cave
National Park Staging Area, conveyance facilities from Park
City to the Staging Area along Route 70 to Cave City and
expand Cave City's facility to 0.58 MGD. This would, in
essence, be Alternative 2.
(b) If the NPS does not develop the proposed Staging Area or
additional non-EPA funds are not available, the remaining
components of a semi-regional alternative would be
constructed. This construction element would involve on-lot
systems for Park City's residential areas and a community
sub-surface absorption field for the Park City business
district. Presently available funding mechanisms would
allow for EPA participation in the cost of these activities
but would be contingent on Congressional continuation of
these mechanisms. Also, funding would have to be in
accordance with the State priority list. This would, in
essence, be Alternative 5.
The regional alternative is most responsive to local and the NPS
desires regarding protection of the groundwater and the cave
systems. However, because of high cost and the resultant financial
burden to be seen locally, the regional alternative may not be viable
at this time. Local funding decisions to be made in the near future
are critical to the ultimate wastewater management system for this
-------
-12-
area. Additional non-EPA funds must be available for a regional
system to be affordable to Park City. Until the appropriate
decisions related to NFS funding or other npn-EPA financial
assistance are made, EPA is moving to resolve existing wastewater
management and water quality problems. In essence, the proposed
phased approach would allow for resolving the current more serious
problems while remaining flexibile to future local funding decisions.
The following figure presents the preferred approach to wastewater
management in the Mammoth Cave study area, as recommended in the
Draft EIS.
MAMMOTH CAVE AREA
PREFERRED STRATEGY FOR WASTEWATER MANAGEMENT
PHASE I
MAMMOTH
CAVE
NATIONAL
PARK
HORSE CAVE
STAGINO AREA
PARK CITY
YES
1
NPS OR ADDITIONAL NON-EPA
FUNDING AVAILABLE ?
PHASE Lt
1
ALTERNATIVE 2
ALTERNATIVE 5
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fll. COMMENTS RECEIVED OB THE DRAFT BIS
This sect.ion includes all those letters received from persons
coromentinq on the Draft EIS. These persons or agencies are listed in
Section V., Part A of this document.
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OHIO RIVER BASIN COMMISSION
Suite 208-20
Cincinnati, Ohio 45202
36 East Fourth Street
513/684-3831 (FTS)
May 5, 1981
Mr. John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
This is in response to your letter of April 30, 1981 requesting comments
of the Ohio River Basin Commission on the draft environmental impact
statement (EIS) and 201 Facilities Plan for the Mammoth Cave Area, Kentucky.
The draft environmental impact statement appears to have been properly
coordinated with the appropriate Commission members.
The Ohio River Basin Commission staff has examined the draft EIS and
finds that it is consistent with the Commission's Comprehensive Coordi-
nated Joint Plan (CCJP) as it exists today.
Should you have any questions, please contact Edward Hood at the address
or telephone number above.
FOR THE OHIO RIVER BASIN COMMISSION:
cc:
Kentucky:
USEPA:
Frank TCudrna
Vice-Chairman
Jackie Swigart
Thomas L. Grissom
Ofc. of Fed. Rel. (3 copies)
-------
fritz. Jr. Dr. Jamm R. Rich
Ky. 1st District Cowngton, Ky. 5th District Uiitjton. Ky. 6th District
•• Pj.*
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UNIVERSITY OF KENTUCKY
LEXINGTON. KENTUCKY 4O5O6
COLLEGE OF ARTS AND SCIENCES
DBPANTMMIT Or ANTM«OI«OUOOy
June 3, 1981
Environmental Review
Office of Special Projects
Department for Natural Resources
and Environmental Protection
4th Floor, Capital Plaza Tower
Frankfort, Kentucky 40601
Re: Environmental Impact Statement (Draft), Mammoth Cave Area, Kentucky,
Gentlemen:
A review of the archaeological site files maintained by this office
revealed that there are 23 previously recorded sites within the Mammoth
Cave plan area. The majority of these sites were reported during an
archaeological survey of the park conducted by the National Park Service.
Undoubtedly, there are additional sites outside of the park boundary but
within this plan area which have not been reported. We agree with the
comment provided by the Kentucky Heritage Commission (p. III-116) that
an archaeological survey be conducted prior to any construction activities.
In addition, should any archaeological materials such as chipped-stone tools,
pottery or bone be uncovered during construction, then the Office of State
Archaeology should be notified immediately so that appropriate action can
be taken.
If you have any questions regarding this response, please don't hesi-
tate to contact us.
Sincerely,
Robert'L. Brooks
Office of State Archaeology
DEPT. NATURAL RES. 4 ENV. PROT.
POLICY & PROGRAM ANALYSIS
AN EQUAL OPPORTUNITY UNIVERSITY
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SIERRA CLUB
CUMBERLAND CHAPTER
P.O. !<0x !**•?•
V'-rsnill es, Kentucky .'» C 5
'"'ear Mr . Hap,an :
"L '. c f n 11 o •.-.' i r g c o r m e n t s a r e s u b n i 11 e d o r. behalf oft h e F, e n t. u c 1 y
Chapter of the Sierrn Cluk in regards to the Draft Fnvironmenta .1.
Impact Statement (PETS) for the Mammoth Cavo Area 201 Facilities
I' 1 a n .
The Sierra Club- has reviewed the plan and its range of alternatives
a n d u o e s u e r e h v v o i c e its support for a 11 e r n a t i v e ~'12 , This alternative
is the only one that attempts to deal with the problem of waste water
control in a comprehensive manner. The area along highway 70, the
site of much of the. existing d e v e 1 o p m v n t_> a n d the likely location of
future growth would he served. Additionally, the wastewater of all
known major polluters would he controlled.
'[hank vou for this opportunity to comment on the Draft E IS.
We look forward to the. development of the final FIS and the eventual
mitigation of a problem that threatens the future of one of the most
significant karst regions in the world.
l'. i n c e r e 1 y ,
Uilliara T.,. Schneider
Conservation Chairman,
Sierra f' 1u h
cc II-ink- Grudciv
"When we try to pick out anything by itself, we find it hitched to everything else in the universe.'
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333
(404) 262-6649
June 8, 1981
John E. Hagan III, P.E.
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement on the Mammoth Cave
Area, Kentucky. We are responding on behalf of the Public Health Service.
From our review of this document, it appears that a wastewater management
system that is compatible with the cave's sensitive natural resources and can
be supported by the local economy is the main issue.
We did not find any mention of present or past public health implications from
the contaminated sub-surface waters. However, we are supportive of any efforts
to eliminate untreated discharges to sub-surface water resources and the environ-
ment .
Thank you for the opportunity to review this statement. We would appreciate
receiving a copy of the final document when it is issued.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
-------
MEMORANDUM
;T
TO ; Environmental Review
Office of Special Projects
FROM: (Mrs.) Anne Armstrong Thompson
Executive Director
DATE: June 8, 1981
SUBJECT: Draft Environmental Impact Statement;
Mammoth Cave Area, Kentucky
The Kentucky Heritage Commission has reviewed the Draft
Environmental Impact Statement for the Mammoth Cave Area,
Kentucky. Our review of the statement indicates that the
applicant is in compliance with the Advisory Council's
Regulations for the Protection of Historic and Cultural
Properties (36 CFR, Part 800) pursuant to the National
Historic Preservation Act of 1966, National Environ-
mental Policy Act of 1969 and Executive Order 11593.
pm
attachment
P196i
a & ENV ....
4 PROGRAM ANALYSIS
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DEPARTMENT OF THE ARMY
LOUISVILLE DISTRICT CORPS OF ENGINEERS
P O BOX 59
LOUISVILLE KENTUCKY 4O2O1
ORLPD-R JUN 9
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
EPA, Region 4
345 Courtland Street, N.E.
Atlanta, GA 30365
Dear Mr. Hagan:
Thank you for the opportunity to comment on the draft Environmental Impact
Statement concerning proposed construction of wastewater facilities in the
Mammoth Cave Area, Kentucky. We would like to submit the following comments:
A. Page IV
1. Item le. Define "on-lot systems" and the number of systems to be
utilized. Additional "on-lot systems" may contribute to further problems. If
so, add to subsections 3, Page V.
>2. Item 2. Change "Pros" to advantages here and throughout the
document.
B. Page V
' 1. Item 3. Change "cons" to "disadvantages" here and throughout the
document.
2. Items Id and le. Differentiate between "conventional and alter-
native on-lot" and "on-let" in Id and le, if applicable, here and throughout
the document.
C. Page VI
1. Item 2f. Delete "what could eventually be" since this is
speculative.
2. Item 3a. Reword sente%cfe* 3 to read, "Although no problems have
yet been detected, continued use o'lf' these on-lot systems has the potential to
adversely impact these sensitive areas ....."
-------
JUN 9 5981
ORLPD-R
Mr. John E. Hagan, III
3. Item 3a. The wording, "proposed critical habitat," is unclear and
not mentioned elsewhere in the document.
4. Item 3d. Define "other interest."
D. Page VII
1. Item Id. Change "for subsurface discharge advanced secondary
treatment" to read "advanced secondary treatment for subsurface discharge."
2. Item 3a. Add "by a collection system" to the first sentence.
Also same comments for "proposed critical habitat" as found in item 3a, page
VI.
E. Page II-3, third line from bottom. Change "cost-effective" to
"cost-effectiveness."
F. Page 11-34.
1. Correct redundant phrase in first full block (Alternative 2)-
Suggest deletion of "conveyance of Park City treatment plant."
2. Second full block. Treatment of staging area and Park City flows
a second time at Cave City appears unnecessary. Please explain.
G. Page 11-46. The page does not adequately summarize alternative
(SA-PC-CC-HC) as to conveyance sequence and treatment sequence. (Refer to
Pages 11-31, bottom and 11-32, top).
H, Figure I1-3.
1. Line sizes should be given.
2. Park City force main should originate from the new pump station,
not from the treatment plant.
3. The conveyance line from Park City should terminate into new Cave
City pumping station, not the treatment plant.
I. Figure I1-4.
1. Show "Chaumont" on figure.
2. Force main from Park City should terminate at new pumping station
at Chaumont, not at the STP.
3. Show "Toohey Ridge" on figure.
-------
JUN 9
ORLPD-R
Mr. John E. Hagan, III
4. According to block 3, Page 11-34, the staging area, Park City and
Cave City flows are treated in the upgraded Cave City STP, therefore, the line
from the staging area terminates at STP rather than at the pump station, as
shown.
J. Figure II-5. According to block 1, page 11-37, combined Park City and
Cave City flow is pumped to Horse Cave Pumping Station, not the treatment
plant, as shown. Other figures may need correction for the same reasons given
for Figures II-3, II-4, and II-5.
K. Figure III-5. Noting the numerous point sources shown on this figure,
it can be concluded that not enough is mentioned in the document about the fate
of all existing point sources in the plans or selected plan area; in other
words, which sources are phased out, which remain operating, etc.
L. Page 111-66. Under "Small Wastewater Treatment Plants," the statements
and conclusions made in this section are based on supposition and are not valid
in the absence of data. At minimum, data should be obtained for the treatment
plants which discharge directly or indirectly to the ground water to determine
conclusively whether this total flow (34,900 gpd) has potential to adversely
impact the ground water in this sensitive area.
M. Section 10 of the Rivers and Harbors Act of 1899 requires that any work
to be done on a "navigable water of the United States" be authorized by a
Department of the Army (DA) permit. The proposed outfall site is above our
Section 10 jurisdiction on the Green River and, therefore, will not require a
DA permit under this section of the law.
N. The Green River, at the proposed outfall site, has an average annual
flow exceeding five cubic feet per second. Therefore, any placement of dredged
or fill material below the Ordinary High Water (OHW) elevation will require
authorization under Section 404 of the Clean Water Act.
0. Backfill for utility line crossings is already authorized under the
provisions of 33 CFR 323.4-3(a)(l) of our regulations as published in the
Federal Register, Volume 42, No. 138, on 19 July 1977. Therefore, an
individual DA permit will not be required if the streambed is returned to pre-
construction contours, excess excavation material is removed to a contained
upland disposal area and there is compliance to the attached special
conditions.
P. According to the DEIS, cofferdam construction for the outfall system
would involve the building of a dirt peninsula into the river. If the selected
plan includes the cofferdam construction, an individual DA permit application
must be made and received before work can commence. Any questions on permit
matters should be directed to the above address, ATTN: Regulatory Functions
Branch, ORLOP-FS, or by calling (502) 582-5452.
-------
JUN 3 1381
ORLPD-R
Mr. John E. Hagan, III
Q. Munfordville is the only city of the four Mammoth Cave Area cities
participating in the National Flood Insurance Program and is currently in the
emergency phase. Being in this phase, special flood hazard areas have been
delineated for Munfordville and certain controls are administered by the city
to reduce or prevent flood damage in these areas.
R. Any construction should be carefully evaluated to insure that flood
damages that could be incurred by the proposed facilities are prevented or
reduced. This would applicable to such damages to other existing structures
that could be caused by the proposed facilities. Construction should be
evaluated to insure compliance with Executive Order 11988, Flood Plain Manage-
ment. In essence, the Executive Order directs federal agencies to use
practicable alternatives to construction in the 100-year flood plain, if avail-
able, and, if not, take measures to minimize the impacts of such construction.
We are inclosing a marked-up copy of the subject DEIS to enable you to more
easily note our comments, especially b through m.
Sincerely,
2 Incl C. 1. EASTBURN
As stated Colonel, Corps of Engineers
District Engineer
-------
•JUN 3 1981
SPECIAL CONDITIONS
SECTION NO. ACTIVITY
323.4-3(a)(l) Dredged or fill material placed as
backfill or bedding for utility line
crossings.
323.4-3(a)(2) Bank stabilization material, 500 feet
in length, average 1 cubic yard/running
foot.
323.4-3(a)(3) Minor road crossing fills.
323.4-3(a)(4) Fill placed with bridges.
323.4-3(a)(5) Repair or replacement of previously
authorized fill.
1. That the discharge will not be located in the proximity of a public
water supply intake;
2. That the discharge will not occur in areas of concentrated shellfish
production;
3. That the discharge will not destroy a threatened or, endangered species
as identified under the Endangered Species Act, or endanger the critical
habitat of such species;
4. That the discharge will not disrupt the movement of those species of
aquatic life indigenous to the waterbody;
5. That the discharge will consist of suitable material free from toxic
pollutants in other than trace quantities;
6. That the fill created by the discharge will be properly maintained
to prevent erosion and other non-point sources of pollution; and
7. That the discharge will not occur in a component of the National Wild
and Scenic River System or in a component of a State Wild and Scenic River
System.
-------
United States Department of the interior
FISH AND WILDLIFE SERVICE
PLATEAU BUILDING, ROOM A-5
50 SOUTH FRENCH BROAD AVENUE
ASHEV1LLE, NORTH CAROLINA 28801
June 11, 1981
Ms. Rebecca Hanmer
Regional Administrator
Environmental Protection Agency
345 Court!and Street, NE
Atlanta, 6A 30308
Re: 4-2-81-051
Dear Ms. Hanmer:
This letter is intended as an endangered species Section 7 review of the
EIS for Mammoth Cave area: Kentucky, as concerns proposed wastewater
facilities. This letter does npt constitute a review of all Fish and
Wildlife Service concerns. These will be addressed by the Office of
Environmental Project Review in separate correspondence pursuant to the
Fish and Wildlife Coordination Act.
On June 3, 1981, Richard Biggins of my staff spoke by phone with Ronald
Mikulak of your office concerning using the endangered species section
of your EIS as a biological assessment. As the document presently
stands, the endangered species sections of the EIS are inadequate as
they relate to the Endangered Species Act's requirement for a biological
assessment. While literature review, contact with recognized experts,
and knowledge of the Mammoth Cave area and its habitats have reduced the
species potentially present to five species (three endangered mussels,
the proposed cave shrimp, and one plant currently under status review),
the biological assessment requirements have not been fulfilled for the
three mussels. A conclusion of no jeopardy to the cave shrimp from the
proposal would seem in order based upon the information presented and
the plant incurs no legal requirements at this time.
Our January 12, 1981, letter to Claude Terry and Associates, Inc. (copy
enclosed) outlined what we felt were the minimum requirements of a
biological assessment. It included the following language:,^
. A ^ ~
1. Identification of the listed species, species proposed for listing
and Critical Habitat determined to be present within th^ area
affected by the proposal. r ' ' .
2. Description of the survey methods used to ^determine presence of
listed species or species proposed for listing within the area.
-------
3. The results of a comprehensive survey of the area.
4. Description of any difficulties encountered in obtaining data and
completing proposed studies.
5. Description of the proposed construction project and associated
activities.
6. Description of methods and results of studies made to determine the
actual and potential impacts of project or associated activities on
listed species, species proposed for listing, or Critical Habitat.
In addition to the direct (site related) impacts of project con-
struction the biological assessments should include, when applicable,
descriptions of:
A. Impacts associated with project operation.
B. Secondary impacts from activities, such as development, which
will be generated by the proposed project.
C. The cumulative effects of the proposal on the species and/or
its Critical Habitat. Cumulative effects are defined as the
direct and indirect impacts of the Federal action under con-
sideration coupled with the identifiable effects of other
reasonably foreseeable actions of the Federal agency; other
Federal, State, and local agencies; corporations; and individuals
upon a species or its Critical Habitat.
7. Where impacts to listed species, species proposed for listing, or
Critical Habitat are identified;, the assessment should include a
discussion of the efforts that will be taken to eliminate, reduce,
or mitigate any adverse effects.
8. Conclusions of the agency including recommendations regarding
further studies.
9. Any other relevant information.
The major deficiencies in the EIS as it relates to the Endangered Species
Act requirements concern the need for:
1. Survey data on the extent of mussel populations, expecially at site
of diffuser system.
2. Secondary impacts.
3. Cumulative effects.
4. Efforts that will be taken to eliminate, reduce, or mitigate any
adverse effects.
As discussed within the June 3, 1981, phone conversation between our
staffs, the biological assessment does not need to be incorporated into
-------
the EIS. Therefore, the collection of data for above concerns could be
delayed. This delay is allowable under the Act as long as there are no
irreversible or irretrievable commitment of resources which would deny
the formulation or implementation of reasonable alternatives regarding
your actions on any endangered or threatened species. You should,
however, reference in the EIS that a biological assessment will be
conducted and Section 7 formal consultation initiated if any affect on
endangered species are anticipated.
Thank you for your interest in endangered species. If this office can
be of further assistance, please contact Gary Henry, Robert Currie, or
Nora Murdock at FTS 672-0321, commercial 704/258-2850, ext. 321.
Sincerely yours,
Robert D. Pacific
Acting Area Manager
-------
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-------
FRANK R. METTS
SECRETARY
COMMONWEALTH OF KENTUCKY
DEPARTMENT OF TRANSPORTATION
FRANKFORT. KENTUCKY 40622
June 11, 1981
JOHN Y. BROWN, JR.
GOVERNOR
Environmental Review
Office of Special Projects
Department for Natural Resources and
Environmental Protection
4th Floor-Capital Plaza Tower
Frankfort, Kentucky 40601
DEPT. NATURAL RES. & ENV. PROT.
POUCY & PROGRAM ANALYSIS
Dear Sir:
Subject:
E.I.S. 81-11
Mammoth Cave Area, Kentucky
The Kentucky Department of Transportation (KYDOT) has completed its review
of the subject proposal.
KYDOT is responsible for controlling both public and private usage of
right-of-way of the State road system. Any firm, individual, or governmental
agency desiring access to a State road or desiring to perform any type of work
on State right-of-way must obtain a permit from KYDOT. A contractor performing
the work must have in his possession at all times a copy of the permit, authori-
zation letter, and detailed drawings of work to be done.
KYDQT encourages the use of private property for placement of utility facili-
ties where possible and practical; but we realize that in some instances, highway
rights-of-way are the only reasonable places to locate the proposed utilities. In
these cases, we respectfully request and require the conscientious efforts of both
the applicant and the contractor to minimize any adverse effects on the roadway
and on the traveling public due to construction of the applicant's project.
The following State maintained roads and maybe others may be affected by
this proposal:
1-65
US 31E
US 31W
KY 70
KY 90
Cumberland Parkway
KY 218
KY 88
KY 685
KY 255
KY 259
KY 474
KY 422
Any proposed access or encroachment should be coordinated at the earliest
possible stage with Joseph Kelly, Highway General Manager, P. 0. Box 309, East
Dixie, Elizabethtown, Kentucky 42701, phone (502) 765-4181 for Hart County,
and E. V. Hilton, Highway General Manager, P. 0. Box 599, Morgantown Road, Bowling
Green, Kentucky 42101, phone (502) 842-0391 for the other involved counties.
Sincerely yours,
Thomas A. Scott, P.E.
Division of Design
-------
2053 Oleander Dr.
Lexington, Ky 40504
June 22, 1981
John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland St. NE
Atlanta, Ga. 30365
re: Mammoth Cave, Ky., EIS
Dear Mr. Hagan:
It is this commenter's opinion that the Mammoth Cave EIS has not adequately
considered relative environmental impacts of the described alternatives and
that the preferred alternative may not achieve any greater degree of pro-
tection to cave waters than one of the lowest cost alternatives.
The EIS concludes that conventional sewering and long distance transport
of effluent will provide a higher degree of protection to cave waters than
local disposal by land application or on-site disposal by soil absorption.
But no documentation is presented of any cave damage caused by well design-
ed and installed septic tank systems. Likewise, no data are presented on
the probable percolate quality from land application systems. Such data
are available from other sources.
The EIS completely ignores the problem of leaking sewer systems. Sewer
systems commonly leak, particularly in unsaturated zones such as karst
limestone. Neither Infiltration-Inflow Studies nor Sewer System Evaluation
-------
Page 2
June 22, 1981
Surveys will normally report leaks from sewer systems into groundwater.
Case in point: one of Kentucky! largest cities is built on Karst lime-
stone. Personal communication with one of the fieldmen doing the SSES
for that city revealed many leaks from the sewers were noticed during the
SSES, but none were reported. One leak was reported to be 50,000 gpd and
was located in a fairly recent part of the system.
Others have reported leaks from sewers in karst areas, i.e. The Hydrology
of the Lexington and Fayette County, Kentucky, area by USGS, 1968, page
17:
'For instance, many sewer lines in Lexington are laid within the
upper few feet of bedrock. Leakage from these lines enters the
underlying water body almost immediately. Hopkins (1963) esti-
mated the leakage from sanitary sewers in the Lexington area is
substantial after heavy rains, perhaps as much as 4 or 5 times
the normal inflow of 8.5 mgd at the Lexington sewage treatment
plant in 1962. Thus, a large amount of bacteria laden water is
flowing in the bedrock and undoubtedly, so some of this water
mixes with the natural groundwater."
This hazard to cave waters (from leaking sewers) should be given con-
siderable weight in the EIS. In the Mammoth Cave area the effects of sewer
leaks at present may be partly masked by the effects of direct connections
to the cave system.
Little or no weight is placed on impacts of urban runoff on the cave waters.
Runoff could have enough imoact to degrade the cave waters far beyond the
-------
O Wllli I Id^Ctll JU JL. j
Page 3
June 22, 1981
effect of percolate from properly managed land application systems. No
attempt was made or documented for calculating mass balances of cave
basin pollutants. In contrast, the 7 lakes EIS found that, normally, the
effects of pollutants from septic tank systems were insignificant com-
pared to other non-point sources, even where septic tank installation
violated state standards for separation distances from groundwater. (2)
After giving adequate consideration to these additional factors, one of
the more affordable alternatives may be selected. It would be an injustice
to select an excessively costly alternative only to find cave waters remained
degraded.
Yours sincerely,
Jack L. Abney
Environmental Planner
JLA/jrm
cc: Larry Silverman, ACWA
James Kreissl, EPA
Keith Berth, EPA
-------
References
1. Pitt, Wm. A., Harold C. Mattraw, Jr. and Howard Klein. "Ground-Water
Quality in Selected Areas Serviced by Septic Tanks, Hade County,
Florida." 1975 Open file report 75-607. US Geological Survey, 901
S. Miami Ave., Miami, Florida.
(.
2. Environmental Impact Statement. Alternative Waste Treatment Systems
for Rural Lake Projects - Case Study Number 1, Crystal Lake Area,
Benzie County, Michigan. US Environmental Protection Agencv, Region
V, 230 S. Dearborn St., Chicago, 111.
3. Rajagopal, R. , R.L. Patterson, R.P. Canale and M.J. Armstrong. "Water
Quality and Economic Criteria for Rural VJastewater and Water Supply
Systems," J. Water Pollution Control Fed. 47(7). (July 1975).
4. Report to Congress - Waste Disposal Practices and Their Effect on
Ground Water. January 1977. U.S. Environmental Protection Agency,
Office of Water Supply and Office of Solid Waste Management Programs,
Washington, D.C. 20460.
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER-81/970 „. 4.0.
JUN 29 1981
Mr- John E. Hagan, III •'•
Chief, EIS Branch, Region IV
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
The Department of the Interior has reviewed the draft environmental
statement for Wastewater Facilities for the Mammoth Cave Area,
Edmonson, Barren and Hart Counties, Kentucky and, in general, we
favor implementation of Alternative 2. The following are our
specific concerns and comments on the impact statement.
Endangered Species
As the document presently stands, the endangered species sections
of the EIS are inadequate as they relate to the Endangered Species
Act's requirements for a biological assessment. This fact, how-
ever, does not mean the EIS must be delayed pending a completed
biological assessment.
As discussed in a June 3, 1981, phone conversation between our
Fish and Wildlife Service and Environmental Protection Agency
staffs, the biological assessment does not need to be incorporated
into the EIS. Therefore, the collection of data for specific
endangered species concerns could be delayed. This delay is
allowable under the Act as long as there are no irreversible or
irretrievable commitments of resources which would deny the formu-
lation or implementation of reasonable alternatives regarding the
Environmental Protection Agency's actions. The EIS should, how-
ever, address the fact that Section 7 responsibilities will be
fulfilled through the consultation process. Our specific
Section 7 concerns will be addressed in a letter from our Fish
and Wildlife Service's Asheville Area Office.
On page III-4-1, item 12, paragraph 1, line 1, we wish to point
out that not all rare and endangered flora and fauna of the
Commonwealth of Kentucky are currently protected by Federal
legislation. Candidate plant species have no Federal protection
at present and will not unless listed. There are other species
within the State that, although rare, may never be proposed for
Federal protection. In the same item, paragraph 2, line 10, it
should be noted that the three categories that you address here
refer to the Smithsonian Institution's list of threatened plants,
not endangered species in general.
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Mr. John E. Hagan, III 2
National Parks
Our National Park Service has contracted with Scruggs and Hammond,
Inc. to conduct a sewerage study for Mammoth Cave National Park.
The results of this study when completed will form the basis of
the National Park Service's decision regarding wastewater
management.
We do wish, however, to express support for any upgrading of local
wastewater management facilities that will prevent future pollution
of the cave system.
Cultural Resources
We note that the Kentucky Heritage Commission has recommended that
a cultural resource survey of the project area be conducted. We
concur with this recommendation since numerous historic and
archeological resources are known in the area, and we look forward
to seeing the results of the survey. The State Historic Preserva-
tion Officer should be afforded an opportunity to review and
comment on the survey report and should be consulted on the
adequacy of any proposed mitigation measures. If any cultural
resources meeting National Register criteria are to be affected,
the Advisory Council on Historic Preservation must also be afforded
an opportunity to comment.
Cultural resource surveys are required by Section 110(A)(2) of the
National Historic Preservation Act, as amended. The Advisory
Council on Historic Preservation implementing procedures for this
Act are found in 36 CFR 800.
Water Resources
It is stated that, "No surface runoff reaches the river" (page
111-13, paragraph 3) in reference to Green River. That statement
appears to be in need of qualification in view of the large
folded map of Groundwater Basins in the Mammouth Cave Region,
Kentucky, which shows a considerable number of streams reaching
the north side of Green River in the northwestern part of Mammoth
Cave National Park.
Thank you for the opportunity to comment on this impact statement
Si
"CECIL S. HOFFMANN
Special Assistant te
SECRETARY
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Jackie Swigart
Secretary
John Y. Brown, Ji
Governor
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
DIVISION OF WATER
CENTURY PLAZA
1065 U.S. 127 BYPASS SOUTH
FRANKFORT, KENTUCKY 40601
MEMORANDUM
TO: Environmental Review Officer
Office of Special Projects
THRU: Thomas L. Grissom
Director
Division of Water
FROM: T. James Fries, Chief
Planning and Standards Branch
DATE: June 22, 1981
SUBJECT: Mammoth Cave Area Wastewater Treatment Facilities DEIS, EIS 81-11
Attached are the Division of Water's comments on the draft
Environmental Impact Statement on the Mammoth Cave Area Wastewater Treatment
Facilities, EIS 81-11.
TJF:TK:jdb
Attachments
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DNREP ENVIRONMENTAL REVIEW
Division of Water Project Number: 81-11
Project Title: Draft EIS Mammoth Cave Area Wastewater Treatment Facilities.
The Division of Water's comments on this draft Environmental Impact
Statement address aquatic habitat and wastewater treatment.
AQUATIC HABITAT
Technical Reference Document Volume I
1. Page 1-50, paragraph 2. A statement reads: "Ratios greater
than 1 usually indicate that the source of pollution is from man." This
statement is not true as written. Ratios greater than 4:1 usually indicate
human sources of pollution. Ratios less than 0.7 usually indicate animal
sources. However, ratios between 0.7 and 4.0 are not definitive and should
not be relied upon since this is a gray area and may indicate mixed sources.
References: Microbiological Methods for Monitoring the Environment,
EPA-600/8-78-017, page 145.
2. The following corrections are needed:
a. Fish Species List:
Page AI-15. Notropis conutus chrysocephalus (Rafinesque)
central common shiner should be Notropis Chrysocephalus
(Rafinesque) striped shiner.
Page AI-15. Chromsonus Erythrogaster (Rafinesque)
redbelly dace should be Phoxinus erythrogaster (Rafinesque)
southern redbelly dace.
Page AI-16. Family Amolyopsidae:
"Karst springfish" should be "Spring cavefish"
"Lesser blindfish" should be "Southern cavefish"
"Mammonth cave blindfish" should be "Northern cavefish"
Page AI-17. Percina uranidea (Jordan & Gilbert) Stargazing
darter should be Percina ouachitae (Jordan & Gilbert) saddleback
darter. Percina uranidea occurs only west of the Mississippi
River.
b. Mussel Species List:
Page AI-19. Cumerlandia monodonta should be Cumberlandia
monodonta.
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Strophitus undulatus undulatus "square foot" should be "squaw
foot".
Carunculna parva and Toxolasma parva are the same. Should be
Carunculina parva.
Dysnomia Trlquetra and Epiolasma [SIC] triquetra are the same
and should be Plagiola triquetra.
Epiolasma [SICli sulcata sulcata should be Plagiola sulcata.
Potamilus alatus is the same as Proptera alata.
Potamilus laevissimus should be Leptodea laevissima.
Page AI-20. Ptycholbranchus fasciolare should be Ptychobranchus
fasciolare.
Anblema costata is the same as Anblema plicata plicata.
Fusconaia ebeng should be Fusconaia ebenus.
Megalonqius nervosa is the same as Megalonaias gigantea
which is the proper spelling.
Quadrula guadrula should be Quadrula quadrula.
WASTE WATER TREATMEOT
I. The following corrections are needed:
1. DRAFT
a. 111-15 and 111-16, Groundwater Quality Standards.
This paragraph cites Kentucky Water Quality Standards as
found in 40 CFR § 120.21 [SIC]. The date of this document is
April 7, 1980, and it is signed by Regional Administrator
Hanmer. In a letter dated May 7, 1980, Regional Administrator
Hanmer approved the Kentucky Standards promulgated December 5,
1979 (See 401 KAR 5:031, 6 Ky. Reg. 344). The withdrawal of
40 CFR § 120.27 was made final on December 3, 1980 (see 45 Fed.
Reg. 59598). 401 KAR 5:031 § 5, Aquatic Life, should have been
cited. The Kentucky Division of Water questions the citing of the
outdated standards eleven months after the Regional Administrator
approved the new standards.
b. 11-22. Table III-5 exhibits "Red Book" criteria. This table
should display Kentucky's current water quality standards
as found in 401 KAR 5:031. Attached is a copy of this table
which has been corrected to show the applicable standards.
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2. TECHNICAL REFERENCE DOCUMENT VOLUME II
a. 11-15, Treatment and Discharge to the Groundwater. The
Commonwealth has approved the effluent limits of the sub-
surface discharges in this area. The Kentucky Division of
Water and the U.S. EPA conducted independent evaluations
of the waste load allocations for the subject publicly
owned treatment works. The U.S. EPA results were submitted
to the Kentucky Division of Water in November 10, 1980,
letter from Robert F. McGhee, Chief, Water Quality Standards
Section, U.S. EPA Region IV. These results were not in
complete agreement with Kentucky's findings. Due to insufficient
justification at that time, the Kentucky Division of Water
rejected the more stringent effluent limitations based on
a proposed Outstanding Resource Water designation and
associated 6.5 ag/1 dissolved oxygen criterion. However,
in the Division's letter to Mr. McGhee on December 10, 1980,'
the Division concurred with EPA's effluent limits based on
the protection of the current warmwater aquatic habitat
designation and associated 5.0 mg/1 dissolved oxygen criterion.
(See attached letters.)
Th«-. Tiventual effluent limitations utilized for evaluating the
alternatives correlate closely with the numbers agreed on
by the Division and EPA. As a result, comparison of
alternatives in this draft EIS based on necessary levels
of wastewater treatment should be valid.
II. The following question is raised:
1. DRAFT
a. Page ix. What is the cost difference between upgrading the
Horse Cave and Cave City wastewater treatment plants versus
constructing a new oxidation ditch at each city's facility?
s~
/
T. James Fries, Chief DATE
Planning and Standards Branch
Division of Water
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EPA CRITERIA FOR SELECTED
JF Av^JnTIC
PARAMETERS FOR USE CLASSIFICATIONS
DRINKING WATER AND SECONDARY CONTACT
Parameter
Ammonia
Chromium
Fecal Coliform
Chlorides
Copper
I ton
Lead
Nickel
Nitrates
Dissolved Oxygen
PH
Total Dissolved
Solids
Sul fates
Sulfides
Zinc
Aquatic Life
-05s*
Use Classification
Raw
Drinking Water
Secondary
Contact
(as un-ionized ammonia)
.1 mg/1
.1 times 96-hr
LC 50 for resident
species
1.0 mg/1
.01 times 96-hr LC 50
for resident species
.01 times 96-hr LC 50
for resident species
mg/1
- 9.0
234/1
undissociated H.S
.01 times 96-hr LC 50
for resident species
,05 mg/1
-266/100 ml
Clog mean)
250 mg/1
1 mg/1
.05 mg/1
10 mg/1 (NO,-N)
-250 mg/1 for
chlorides and
sulfates
250 mg/1
5 mg/1
111-22
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Swigart ^-^ii^y J°hn Y"
.-•. =.arv ~' '-. Governor
H OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND SIWIRONf/jSNTAL PRC75CT:CN
BUREAU CP ENVIRONMENTAL PROTECTION
DIVISION OF WATER
Cc -TL!."V °'_AZA
1D65 U.S. !27 3V?ASS SOUTH
EfjT'JCKY J0501
December 10, 1980
Robert F. McGhee, Chief
Water Quality Standards Section
United States Environmental Protection Agency
Region IV
345 Court!and St.
Atlanta, GA. 30365
Dear Mr. McGhee:
The Division of Water concurs with EPA's most recent waste!oad
allocations for POTW effluents to the Hidden River based on protection of
the current warmwater aquatic habitat designation and associated 5.0 mg/1
minimum daily average dissolved oxygen concentration. We do not concur
with the alternative effluent limits based on the proposed outstanding
resource waters designation and associated 6.5 mg/1 dissolved oxygen.
The Cave Research Foundation's outstanding resource waters designation
petition proposed this criteria for a 40 mile segment of the Green River
and not the Hidden River system. We have received no proposed criteria
nor supporting documentation for the underground streams in the Mammoth
Cave area.
In the absence of verifying documentation for determining the
geographic scope and associated criteria for the outstanding resource
waters designation, the State can take no action on the reelassification
proposal. We support your contention that the wasteload allocations
generated from the latest modeling efforts are sufficient to compare 201
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Robert F. McGhee, Chief
Page Two
December 10, 1980
alternatives. We hope that our concurrence in this matter will result
in the timely completion of the EIS and 201 Plan to the mutual satisfaction
of all concerned parties.
If you should have any questions regarding our activities in this
area, please contact Bob Ware at 502/564-77S3.
Sincerely,
Thomas L. Grissom
Director
Ky. Division of Water
TLG:bjm
cc: Bob!Ware
KY. Division of Water
Jim Fries
KY. Division of Water
Ron Mi kulak, EPA
Kip Duchon, CRF
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<*
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
URTLAND ST
ATLANTA. GEORGIA 3 03 6 5
NOV JO ISfift 345 COURTLAND STREET
REF: 4W-WQ
Bob Ware
KDNREP
Century Plaza
1065 U.S. 127 By-Pass South
Frankfort, KY 40601
Dear Bob:
Enclosed is a summary of recent EPA modeling for the Hidden River in
Kentucky. The model we have applied is a steady state, one dimensional,
modified Streater-Phelps model, developed for simulating water quality in
free-flowing streams. Based on the limited data available, the model appears
to reasonably predict the observed water quality dynamics occurring within
the Hidden River system. After the model was calibrated, effluent limitations
for various wastewater treatment alternatives were established. We did not
see a basis for seasonal effluent limits, so none were developed. The
effluent limits developed from this model are somewhat more stringent than
those proposed by KDNR, however, as a result of our meeting on October 9 and
subsequent discussions, the model is now acceptable to both EPA and KDNR. The
alternatives for which effluent limits were computed include the proposed
Outstanding Resource Waters designation and associated 6.5 mg/1 dissolved
oxygen standard. Unless the State takes some action soon on that proposal,
unnecessary delays in the 201 process will likely occur. We strongly
encourage the State to take action on the proposed designation.
We do agree with you that the Hidden River is a very complex environmental
system and the applicability of a free-flowing stream model is uncertain even
though the model does reasonably predict actual water quality. However, we
believe that wasteload allocations developed from the model are sufficient to
compare 201 alternatives.
We request your prompt concurrence with the enclosed waste load allocations so
that our respective facilities planning staffs can take the actions necessary
to insure completion of the EIS and 201 Plan during FY 81.
Sincerely yours,•
Robert F. McGhee, Chief
Water Quality Standards Section
Enclosure
cc: Kip Duchon
James Quinlan
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Jackie Swigart Ifl ml M John Y. Brown, Jr.
Secretary ^S^X^t/ Governor
COMMONWEALTH OF KENTUCKY
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
OFFICE OF THE SECRETARY
OFFICE OF SPECIAL PROJECTS
CAPITAL PLAZA TOWER
FRANKFORT, KENTUCKY 40601
PHONE 1502) 564-7320
July 2, 1981
Mr. John Hagan, III, Chief
EIS Branch
EPA, Region IV
345 Court!and Street, N.E.
Atlanta, Georgia 30365
Subject: DEIS - Mammoth Cave Area Wastewater Facilities
Dear Mr. Hagan:
Enclosed for your information and use are copies of all comments
received by this Office, acting as the State Clearinghouse for
environmental impact statements, from Kentucky Environmental Review
Agencies concerning the Draft Environmental Impact Statement (DEIS)
for Mammoth Cave Area, Kentucky wastewater treatment facilities.
These comments should be appropriately considered in accordance
with the National Environmental Policy Act (NEPA) and associated
regulations in preparing the final environmental impact statement.
Sincerely,
I
Don Beevers
Assistant Administrator
Office of Special Projects
DB:kp
Enclosure
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fill. LIST OF PHBPABEES
Robert B. Howard Chief, EIS Preparation Section
Richard B, Green BIS Project Officer (1977-1979)
Ronald J, Mikulak ETS Project Officer (!979-present)
Peter T. HcGarry Chief, North Carolina/Kentucky
Facilities Planning Section
Consultints
Gannett Fleming Corddry and Carpenter, Inc.
Thomas «, Bachford Senior Prolect Manager
Richard N. Koch Prplect Manager
Lynette J. Deuel Bnvironraental Scientist
Jeffrey G, Wendle Prolect Engineer
Michael S. Moulds Assistant Project Engineer
Claude Terry and Associates, Inc.
Claude E. Terry Prolect Executive
Robert J. Hunter project Manager
James C. Hodges Environmental Scientist
Virginia Hayles Environmental Scientist
Louise B. franklin Environmental Planner
VIII-i
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