ENVIRONMENTAL  IMPACT STATEMENT
    COBB COUNTY SEWERAGE IMPROVEMENT PROJECT
                  Prepared by

         ENVIRONMENTAL PROTECTION AGENCY
                  REGION IV
             ATLANTA, GEORGIA 30309
                  July 1971

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ENVIRONMENTAL  IMPACT  STATEMENT
       COBB COUNTY SEWERAGE IMPROVEMENT PROJECT
                      Prepared by
              ENVIRONMENTAL PROTECTION AGENCY
                        REGION IV
                ATLANTA, GEORGIA   30309
                       July  1971

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                      TABLE OF CONTENTS
SUBJECTS                                                   PAGE

I.        Summary ..........<>...	 1

II.      Description of Applicant's Project	 A

III.      Background	 15

IV.      Environmental Consequences

         1.  Water Quality	17
         2.  Air....	23
         3.  Land.. ,	25
         4.  Noise. . ,, „.	26
         5.  Impact of the Project on Historical and
               Archaeological Values of the Area	26
         6.  Impact on Recreational Values of Natural
               Areas ....<>	28

V.       Any Adverse Environmental Effects Which Cannot
           be Avoided	33

VI.      Alternatives to the Proposed Plan:

         a.  Continuation of Present System of Small
               Treatment Plants for Each Subdivision
               or Community	35
         bo  Least Cost Alternative as Selected by Cobb
               County for the Sope Creek Interceptor	35
         c.  Lift Station at Powers Ferry Road, with
               Force Main along Akers Mill Road to Rotten-
               wood Creek, and a 48" Parallel Sewer to the
               Existing Rottenwood Creek Sewer down Rotten-
               wood Creek to  the Chattahoochee River	36
         d.  A Single Tunnel  Between Rottenwood Creek and
               the Chattahoochee River at 1-285 with some
               Open Cut	36
         e.  Tunneling  to Prevent Destruction of the
               Natural  Rock Cliffs and Outcrops along
               the Chattahoochee Scenic Easement and Open
               Cut with Buffer Zone of Trees and Foliage
               Between  River's Edge and Construction
               Right-of-Way.	36

 VII.     Any Irreversible or  Irretrievable Commitments
           of Resources Which Would be Involved in the
           Proposed Action	39
 VIII.
Conclusions and Recommendations	40
 BIBLIOGRAPHY...........		42

 APPENDIXES	. o	44

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                        LIST OF TABLES




TABLE                                               PAGE




  I.     Construciton Contract Schedule, Cobb         5




            County Sewerage Improvement Project

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                           LIST OF FIGURES






FIGURE                                                 PAGE




   1.   Proposed Cobb County Sewerage Project            8




   2.   Location Map, Proposed Revised Unit A            9




          Sewerage, Cobb County, Georgia




   3.   Bacteriological Quality, Chattahoochee          22




          River, Atlanta Raw Water Intake




   4.   Existing Sewage Treatment Facilities in         24




          Cobb County




   5.   Sope Creek-Rottenwood Creek Interceptor         37




          Sewer, Cobb County

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I.  SUMMARY




     On May 15, 1967, Cobb County, Georgia applied to the




Federal Water Pollution Control Administration (FWPCA) of the




Department of the Interior [now the Water Programs of the




Environmental Protection Agency (EPA) ] for a grant under




Section 8 of the Federal Water Pollution Control Act of 1965




to fund a planned progrrm for expanding and improving waste




water conveyance and treatment in Cobb County.  The program was




a commendable and forward looking effort designed to bring immediate




improvement to water quality in the Chattahoochee River.




     The river lies between Fulton and Cobb Counties and is




landscaped by natural palisades.  The river itself serves as a




sport and recreation resort for the citizens of the region and is




heavily contaminated by bacteria which limits its use.




     The project was originally the subject of a grant offer in




1968 which was accepted by the County.  The program is designed




to satisfy water pollution control requirements to meet flow




projections for a fifty-year period, utilizing cost effective




phasing.  Treatment will be centralized,  based on environmental




and economic considerations,  permitting retirement of numerous




privately and publicly owned-and-operated package plants and




waste stabilization ponds.  The net result will be the upgrading




of presently polluted streams, providing favorable conditions for




water contact sports and other water-related recreation in the




Chattahoochee River to which  many of these streams are tributary;




insuring a continued high quality of water at the Atlanta water






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intake, and providing sewerage service for a large area of the




county.




       The program is compatible with actions of the Georgia Water




Quality Control Board and Environmental Protection Agency Water




Programs to improve the quality of surface water and to satisfy




present and future uses of the Chattahoochee River.




       To protect the uses of the River, a Federal-State Enforcement




Conference was called by the Secretary of the Interior.  This




Conference was held July 14-15, 1966, and reconvened February 17,




1970..  Cobb County is required to provide waste treatment by




December of 1972.




       In September 1970, a modification was proposed to combine the




treatment of Cobb and Fulton Counties into one facility in order to




preserve the Fulton palisades and leave as undisturbed as possible




the naturally scenic areas.  Cobb County has cooperated to the




fullest extent possible in this effort.




       In March  1971, a draft assessment of  the project was prepared,




notwithstanding  previous commitments, and circulated to other Federal




Agencies to obtain their reactions.  Consistent with EPA policy




to implement the National Environmental Policy Act  (NEPA) of  1969,




a Draft Environmental Impact Statement was developed and distributed




to these agencies  for their formal review and comment.  This  final




statement  is prepared on the basis of those  comments and  those of




State and  local  interest groups  and  concerned individuals.  The




primary issue  identified was  the  proposal to run  the interceptor




facilities  through the Cobb County palisades.   This area  is naturally





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scenic and may have the possibility for reclamation as a natural




wilderness area.  A solution is that the project as described




in the statement be constructed.  It will substantially improve




water quality in the region, establish a principle of cooperative




county planning, and preserve to the greatest possible extent




the natural landscape.  The short-range impact, resulting from




construction, will be minimized and should cause no long-term




defacement of the natural habitat.
                          -3-

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II.  DESCRIPTION OF APPLICANT'S PROJECT




     Table No. 1 shows the contracts that are a part of this project




and the present proposed construction schedule.for each contract.




Figures No. 1 & 2 are maps of the County showing the location of




each contract.  The program consists of interceptor sewers,




treatment facilities and outfall sewers, pumping stations and force




mains serving six natural drainage areas described below.  An




interceptor may be defined as a sewer whose primary purpose




is to transport rather than to collect wastes.  An outfall sewer's




function is to transport effluent from treatment facilities to




receiving waters.




        I.  Nickajack Creek Drainage Area:  An interceptor sewer




            running generally north to south along Nickajack Creek




            will transport sewage from two abandoned treatment




            plants to the mouth of Nickajaek Creek, then it will




            be pumped an additional 1.5 miles through an existing




            trunk line to the South Cobb Sewage Treatment Plant.




            The South Cobb Sewage Treatment Plant will be expanded




            to handle the additional flow.




        2,  Rottenwood Greek Drainage Area:  An interceptor sewer,




            being constructed along Rottenwood Creek, will extend




            3.5 miles south along the Chattahoochee River to a




            new treatment facility, the Chattahoochee River Sewage




            Treatment Plant.  This interceptor will serve the City




            of Marietta when the existing Soatheast Side Treatment

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TABLE I-CONSTRUCTION CONTRACT SCHEDULE
Contract
No.
Contract Name
Estimated Date For
Compl'n of Eng'ng
Bid Date
Compl'n Const.
Nickajack Sewerage
3
9A
9B
9C
10
11

S. Cobb Treatment Plant Exp.
Nickajack Creek Interceptor
Nickajack Creek Lft. Station
Bohannon Crk. O.F. Sewer
Laural Lake & Mill Crk. Int.
E. Mableton-N. Nickajack &
Milan Church Allen Rd. Sewers
Complete
Complete
Complete

Complete

8-3-72
Received
Received
Received

Received

10-27-72
2-1-72
Complete
7-21-71

8-1-71

Deferred
Rottenwood Sewerage
5
15A
15B

100


Chattahoochee Sewage T.P.
Rottenwood Crk. Int. to E.Smyrna
E. Smyrna & W. Paces Ferry
Road Collectors
Rottenwood Crk. Int. Exten.
to Marietta S. E. Side T. P.
Hwy. 41@ 1-75, 1-285 @ 1-75
Complete
Complete

Complete



9-1-71
Received

8-10-72

11 - 71
11-71
3-1-73
11-1-71

11-1-72

11 - 72
2-72
Fulton County Sewerage




Game Creek Pump Station &
Force Main
Marsh Creek Pump Station &
Force Main





8-71

11 - 71

1-72

12 - 72

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Sheet 2 of 3
TABLE I - Cont'd
Contract Estimated Date For
No. Compl'n of Eng'ng Bid Date Compl'n Const.

102B
103

104

105

106

107

110

111

102 AI

102AII

Sope Creek Sewerage
Sope Creek Interceptor (48") Complete
along Chatt. River from Sope
Crk. to Marsh Crk. T.P.
Sope Creek Int. (48") from
Chatt. River to Fox Hills S/D
Sope Creek Int. (42"& 36") -
Fox Hills S/D to Fork in Sope Crk.
Sope Crk. Int. Sewer (30" & 27")-
Fork in Creek to Holt Road
Sope Creek Int. Sewer (27" & 24")
Holt Rd. to Marietta E. Side T.P.
Sope Creek Outfall Sewer (30")
Sope Creek N. Fork to Roswell Rd.
Sope Crk. O.F. Sewer - N. W. Fork
above Roswell Rd. (30", 24" & 18")
Sope Crk. O.F. Sewer- Northeast Fork
above Roswell Rd. (24" & 18")
Sope Crk Int. from Rottenwood Crk.
to Powers Ferry Rd. Complete
Sope Creek Int. from Powers
Ferry Rd. to Sope Creek Complete


7-27-71

11 -

11 -
11 -


11 -

11 -
1 -


1 -


71

71
71


71

71
72


72

Received


7-27-71


5-1-72

1 -

2 -
2 -


2 -

2 -
6 -


6 -


72

72
72


72

72
72


72

3-1-72


5-1-72
Buttermilk Creek Sewerage
24
Buttermilk Creek Interceptor

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Sheet 3 of 3
TABLE I - Cont'd
Contract
No.
Contract Name
Estimated Date For
Compl'n of Eng'ng
Bid Date
Compl'n Const.
Olley Creek Sewerage
26

27A
28A

108
7
27A

34

25
26A
Olley Creek Interceptor to N.
Austell
Olley Creek Int. to S. Side P.
Noses Creek Int. to Powder
Springs
Coats & Clark Outfall
Noonday Creek Treatment Plant
Olley Creek Int. to S. Side
Plant
Noonday Creek Collectors
Bells Ferry-Canton Rd. Collector
N. & S. Buttermilk Creek Collectors
N. Austell Collectors

8-1-71
8-1-71

8-1-71
7-1-71
Complete



Complete
8-1-71
11-24-71

10-26-71
10-26-71

10-26-71
1-72
8-10-72



8-10-72
10-26-71
2-18-72

12-10-72
Deferred

12-1-72
12 - 72
11-1-72

Deferred

11-1-72
12-1-72
12-1-72

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       .   Acworth

      '    kennesow^\         MARIETTA
                                            -
\
                     PROPOSED  COBB  COUNTY
                         SEWERAGE  PROJECT
                                  E.PA-I97I
                                                           8
                                                                                            INTERCEPTOR LINES


                                                                                            PUMPING STATIONS

                                                                                            TWEATMCNT PLANT
 A NOONDAY CR INTERCEPTOR
 B SOPE CR INTERCEPTOR
 C ROTTENWOOD CR INTERCEPTOR
 D NICKAJACK CR. INTERCEPTOR
 E NOSES CR INTERCEPTOR
 F OLLEY CR INTERCEPTOR
 G BUTTERMILK CR INTERCEPTOR
 H COATS ft CLAftK OUTFALL
 DRAINAGE BASINS	
 1 SOPE CREEK
 S NOONDAY CREEK
 m ROTTENWOOD CREEK
 TZ NICKAJACK CREEK
 I OLi.1.1 » BUTTERMILK CREEKS
 II MUD S NOSES CREEKS
3E POWDER SPRINSS CREEK
                                                                                                              FIG.

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                                                                                      MMBH CWIK
                                                                                           mmtm

                                                                                TEMPOMARV PACKAOE
                                                                                          P1.ANT
                                                                             B) CMATTAMOOCMU («Vt*
                                                                               TWATMEtfT PLANT
                                                                               FULTON  COUNTY
           DOUGLAS  COUNTY
                                                              NICKAJ4PK  PUMP tTATIOM
                                                           SOUTH COMB (EWAW
                                                           TREATMENT PLANT
                       INTERIM SEWERAGE
                       TO SOUTH COBS
                       TREATMENT PLANT
Not*

caitfraeti »uwk»r»d 100
      rt net
      Unit A
LEGEND
             INTERCEPTOR  SEWER

             CONTRACT  NUMKft

             DRAINAGE  AREA  BOUNDARY

             PUMP STATION
                                                                 LOCATION  MAP
                                                   PROPOSED  REVISED  UNIT  A  SEWERAGE
                                                           COBB COUNTY, GEORGIA
                                                                                  A-404B-B.4

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    Plant is retired, and will also provide sewer service




    to the Vinings, Georgia area.  Sewage from the East




    Smyrna area, now served by the Bohannon Creek Treat-




    ment Plant which is being phased out, will join the




    Rottenwood Creek interceptor and will be transported




    to the Chattahoocb.ee Sewage Treatment Plant.




3.  Sope Creek Drainage Area:  A proposed interceptor




    along Sope Creek will relieve treatment at the




    existing Marietta East Side Plant.   Sewage will be




    transported along Sope Creek in an interceptor which




    will tie into the Rottenwood Creek Interceptor to




    convey the sewage to the Chattahoochee River




    Sewage Treatment Plant.




4.  Olley Creek and Buttermilk Creek Drainage Basin:




    Construction of interceptors along Olley Creek and Butter-




    milk Creek will provide sanitary sewerage services for




    many residents in this area.  Sewage will ultimately




    be transported to a new treatment facility on




    Sweetwater Creek.  However, until development and




    population growth justifies the construction  of the




    Sweetwater Creek Sewage Treatment Plant, wastes




    from Olley and Buttermilk Creek Interceptors  will be




    transported from the City of Austell to the Chattahoochee




    River, then to the South Cobb Treatment Plant.  Pumping




    Stations will be required to lift the sewage  from




                    -10-

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    Austell to the South Cobb Sewage Treatment Plant.




5-  Mud and Noses Drainage Area:  This area will ultimately be




    served by sewers along Mud Creek and Noses Creek with




    sewage intercepting at a common point with Olley Creek




    just north of Austell and thence transported to the




    proposed Sweetwater Creek Treatment Plant.




6.  Powder Springs Drainage Area:  A proposed interceptor sewer




    along Powder Springs Creek will serve the Powder Springs




    Drainage Area.  Waste will be transported into the Mud




    and Noses sewer for treatment at the South Cobb Sewage




    Treatment  Plant.




7.  Noonday Creek Drainage Area:  This area will be served by




    an interceptor running northerly along Noonday Creek, with




    flow  terminating at a proposed Noonday Creek Sewage Treatment




    Plant.




8.  Chattahoochee River Sewage Treatment Plant:  (Secondary




    Treatment)  This proposed plant will have a capacity




    capable of treating waste emanating from  the Sope Creek




    and Rottenwood Creek Drainage Areas.  It will also treat




    sewage  transported  from  Fulton  County along the Sope




    Creek-Rottenwood Creek Interceptor.




 9.  South Cobb Treatment Plant:  This  plant will be expanded  to




    meet  future waste water  treatment  requirements of the




    Nickajack Creek Drainage Area.  As an interim measure,




     it will also  receive  sewage from  the Olley  Creek and




     Buttermilk Creek Drainage Areas,  the Mud  and Noses




                         -11-

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        Drainage Area, and the Powder Springs Drainage Area




        until population growth and development warrant construction




        of the proposed Sweetwater Sewage Treatment Plant




        (Not included in the project).   The engineering design




        of the temporary pump station linking these drainage




        areas with the South Cobb Treatment Plant allows for its




        conversion to a permanent facility in the event the area




        adjacent to Sweetwater Creek is developed into a park




        and location of a treatment  facility on the creek would




        be undesirable.




    Subsequent modifications of the project originally proposed by




Cobb County have come about as a result of an agreement to work




jointly with Fulton County.   In August 1970, the Fulton County




and Cobb County Commissioners tentatively agreed to work jointly




on a sewerage project between Sope Creek and the site of the




proposed Chattahoochee River Sewage Treatment Plant.  Until then,




both counties planned to construct sewers which, for the most part,




would run  parallel to the Chattahoochee River between 1-285 and




1-75.  In the interest of efficiency and preservation of scenic




territory, the counties, on January 25, 1971, agreed that Cobb




County would proceed with construction of a Sope Creek Interceptor
    •'"Contract, Cobb & Fulton Counties, October 7, 1970.
                            -12-

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along the Chattahoochee through the Palisades Area to 1-75, where it




joins the Rottenwood Creek Interceptor.  The Sope Creek and




Rottenwood Creek Interceptors will be designed to accommodate flow




entering  the Sope Creek Interceptor from Fulton County at the




Marsh Creek Treatment Plant (to be phased out), and also waste




water from the Fulton County Game Creek Basin entering the Sope




Creek Interceptor at 1-285.  The Fulton County agreement eliminates




the redundancy of two large interceptor sewers along both sides




of the Chattahoochee River through the Palisades region.




    All applications are accompanied by the comments and




recommendations of the State, Metropolitan, or Regional Planning




Agencies as to the project's conformance with the comprehensive




plan developed for the area and a statement from the applicant




relative to Planning Agency review.  On August 4, 1967, the




Atlanta Regional Metropolitan Planning Commission certified that




the Cobb County project does conform with the Comprehensive Plan




developed or in process of development for the Atlanta Metropolitan




Area with these comments:




     (1)  The proposed project does conform to the objectives




         of the current Regional Development Plan and with the




         Regional Plan for water and sewer facilities as it has




         progressed to date.




     (2)  The proposed project conforms with recommendations for




         a county sewer plan and the county land use plan.




     (3)  Timing of the proposed project is in conformance with the




          county sewer plan.





                              -13-

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    Other letters from the Atlanta Regional Metropolitan Planning




Commission dated October 1, 1970, and June 28,  1971, commenting on




the Cobb County project are found in the Appendix.




    The Cobb County project is in conformance with the "Atlanta




Region Comprehensive Plan:  Water and Sewerage - February 1969"




prepared by Horner and Shifrin Consulting Engineers for the




Atlanta Regional Metropolitan Planning Commission.




    Within the Federal Government the Department of Housing and




Urban Development (DHUD) has been given the general responsibility




of coordinating overall urban planning and development.  DHUD




makes grants and loans to State, Regional and Local Planning Agencies




to assist in the development and implementation of comprehensive




long-range urban plans.




    The Hensley-Schmidt Engineering Report dated February, 1967,




covering  the seven drainage basins which make up the County's




present  sewage program was financed in part by a Public Works




Planning  Loan  (P-GA-3078)  from  the Department of Housing and




Urban Development and approved  on December 8, 1965.  This plan was




 reviewed for conformance  with DHUD Planning Critera and approved




 by DHUD on  June  30,  1967.
                               -14-

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III.  BACKGROUND




    A 1964 study by the Atlanta Regional Metropolitan Planning Com-




mission and the Comprehensive Sewer Study released in 1967 by




Hensley-Schmidt, Inc., for Cobb County revealed that 68% of




Cobb County's population live in unincorporated areas.  Rapidly




increasing county population is making heavy demands on public




utilities and other services.  Cobb County has recognized the




need for a consolidated county effort to provide sewerage services




for the most at the least expense.









         Interstate Highways 75 and 285 have provided quicker and




easier access to undeveloped areas of the county and present




zoning indicates that such areas adjacent to metropolitan




Atlanta will be developed for private homes, apartment complexes




and industrial business parks.




    Other areas, rich in natural beauty and historical interest,




have the potential for parks and recreational and historical sites




Of particular interest is that section along  the Chattahoochee




River from Peachtree Creek to  Buford Dam, a distance of 48.1 miles.




In October 1970, a Task Force and Citizens Steering Committee,




under the auspices of the Bureau of Outdoor Recreation, studied




this area for possible development as a National Urban Park.




    That section along the Chattahoochee between 1-285 and




Rottenwood Creek known as the "Palisades" has become the concern




of the Georgia Conservancy, other  private groups and individuals.




This section, privately owned, is in a natural state, but the





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Georgia law of riparian right prevails, with riparian ownership




extending to the center of the stream bed.  This area is zoned on




the Cobb County side of the Chattahoochee River for multiple family




units, single family residences and industrial office parks.  The




owner has indicated his intent to develop this area to its fullest




potential as zoning allows.




    Of particular interest is the proposed site of the Chattahoochee




River Sewage Treatment Plant.  A 1970 survey of archaeologial




sites in Cobb County revealed that it is the location of the




historic Indian village of Standing Peachtree.  In the interest




of preserving this site and other significant historical findings,




the county employed two archaeologist to coordinate studies




and excavations so that construction of the project would not




conflict with these interests.




    The environmental and archaeological questions raised by the




construction of the interceptor sewers and sewerage treatment




facilities  will be discussed in detail.
                            -16-

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IV.   ENVIRONMENTAL CONSEQUENCES




     Water Quality




     To improve the quality and satisfy present and future




uses of the Chattachoochee River, a Federal-State Enforcement




Conference was held July 14-15, 1966, and reconvened




February 17, 1970.  Completion date for facilitating remedial




waste treatment was set for July 1, 1971 and later extended




to December 1972.   Cobb County was one of the few areas that




recognized its responsibility for water pollution control and




was on schedule.  Even adjacent Atlanta had to be given a




180-day clean-up order on December 10, 1970, to maintain




progress in cleaning up the Chattahoochee.  Studies conducted




in the last decade by Federal, State and metropolitan




entities emphasized the necessity of obtaining and maintaining




a high quality of water in the Chattahoochee River and its




tributaries.  These studies prior to the Enforcement Conference




indicated that a minimum of secondary treatment would be required




of municipalities in the Atlanta Area if the water quality criteria




in the Chattahoochee below Atlanta were to be met.  The reports




of these studies are on file with the Georgia Water Quality




Control Board and the Regional Office of the Environmental Protection




Agency.  An independent study conducted in 1969 shows that




secondary treatment and sufficient flow regulation at Buford Dam
                              -17-

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will provide adequate water supply and wastewater

                                       2
assimilation in the foreseeable future.


     The proposed Chattahoochee River Sewage Treatment Plant


located across from and just south of the City of Atlanta's


freshwater intake will discharge its effluent through an


outfall sewer at a point below Peachtree Creek.  The


Chattahoochee River Sewage Treatment Plant will be constructed


in phases to keep pace with the development of Cobb and Fulton


Counties.  The first phase will provide capacity of an average


daily flow of 10 million gallons per day.  Phases II and III will


increase the treatment plant capacity to an eventual 40 million


gallons per day capacity projected for the year 2020.


     The State of Georgia's Water Pollution Control Legislation


gives the Georgia Water Quality Control Board the authority to


place a ban on new sewer connections for any municipality that


does not have adequate wastewater treatment.  This authority


was recently used when the City of Atlanta began to fall behind


schedule with their pollution abatement program.  Present Federal


legislation does not give a Federal Agency the authority to pro-


hibit new sewer connections if municipal treatment facilities are


inadequate.
      2
      Water and Sewerage, A Report Prepared by the Atlanta

 Region Metropolitan Planning Commission, February 1969.
                             -18-

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      River and creek flooding potential will be taken into

 consideration in design of sewer lines and location of

 treatment facilities, pumping stations and outfall lines.

 Executive Order No.  11296 (See Appendix B-4) describes this

 agency's  policy regarding adequate flood protection for struc-

 tures in  the flood plain.  Manhole covers will be sealed to

 prevent infiltration during floods and the top elevation of

 critical  structures  in the treatment  plant will be above the

 50  year flood elevation.

      Contractors will take appropriate steps during construction

 to  minimize  siltation and shoaling resulting from construction

 activities.   This is a condition which EPA requires in each

 contract.

      Completion of  the Sope Creek  and Rottenwood Creek Interceptor

 Sewers and installation of the temporary treatment facility will

 result in  the immediate phasing out of the Marsh Creek Treat-

 ment  Plant and several small  plants in Cobb County..  The effect

 will  be to restore this section of  the River and adjacent

 creeks for recreational use and benefit  the fishery resource.

     At the  February 1970  Enforcement  Conference,  a member  of

 the Georgia  Water Quality  Control Board  pointed  out  that the

 Chattahoochee  River  above  the Atlanta  intake  "is  generally  of

 high quality with occasional high bacterial  population". 3  The
     Conference:  In the Matter of Pollution of the Interstate
Waters of the Chattahoochee River and its Tributaries - Georgia
Alabama, Proceedings, Second Session, February 17, 1970,
Atlanta, Georgia p. 89.
                             -19-

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concentration of fecal coliform bacteria is commonly used as

a criteria for indicating the possible presence of pathogenic

organisms and evaluating a stream's suitability for water

contact recreation and water supply.

     The Chattahoochee River is an interstate stream and from

Buford Dam to Peachtree Creek classified for "drinking water

supply".   Test data obtained at numerous locations along the

Chattahoochee and its tributaries during 1969 and 1970 indicate

pollution sources at Marsh Creek, Sope Creek, Long Island Creek,

and Rottenwood Creek.  Total fecal coliform counts approach in

many cases, and exceed in a few cases, the maximum allowable

under present classification.

     The section of the Chattahoochee River north of the Atlanta

water intake is utilized for water contact sports in the form

of "tubing" or "floating".  The Georgia Conservancy estimates

that on a yearly average upwards to 30,000 people enjoy this

section of the river in this fashion.   Even with the limited

access people continue to utilize the river for water-based

recreation.

     At Powers Ferry Road, Atlanta Waterworks data for 1969

and 1970 recorded median total coliform counts/100 ml of 4,100

and 3,400 while fecal counts were 640 and 140.   Data from the
     4
      Federal Water Pollution Control Act, Public Law 84-660
Sec. 10.
     5The Georgia Conservancy, Inc.  News Letter, August 1970
     6chattahoochee Water Systems Laboratories, (Highlights 1969),
A Report Prepared by the Atlanta Water Works.
                            -20-

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State Water Quality Control Board from March 1969 to

September 1970 found fecal coliform counts ranging from 91

to 9,300/100 ml at the Atlanta Water intake, with a median of

750/100 ml.   Figure No. 3 shows the fecal coliform data for

water samples taken at the City of Atlanta's raw water intake
                                                          Q
on the Chattahoochee River for January 1970 to March 1971.

     The solid lines representing maximum permissible

concentrations recommended by various groups are indicated
                        q
for recreational waters.   Georgia's criteria for "Recreational

Waters" is a median of 1000/100 ml for fecal coliform.  Although

the formal water classification of this section of the river

is for "fresh water supply" another undeniable use is water-

based recreation.  Because water contact sports may involve

ingestion of and contact with untreated water of lakes and

rivers, the maximum permissible concentration of bacteria in

recreational waters is lower than water used as a drinking

supply where modern treatment and disinfection techniques are

employed prior to distribution to consumers.
     ?Water Quality Analysis, A Report Prepared by  the  Georgia
Water Quality Control Board, 1969.
      Atlanta Water Works Chattahoochee Laboratories Monthly
Reports, January 1970 - March 1971.
     ^Establishment of Water Quality Standards and  Classifications
for  Interstate Waters in the State of Georgia, Prepared by  the
Georgia Water Quality Control Board, June  1967; Rules of the
State Water Quality Control Board, Chapter 730-3, Water Use
Classifications and Water Quality Standards (Proposed), Prepared
by the Georgia Water Quality Control Board, April 22, 1971;
Water Quality Criteria, Report of the National Technical Advisory
Committee  to the Secretary of the Interior, April 1, 1968.


                         -21-

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    BACTERIOLOGICAL  HUALITY
        CHATTAWOOCHCC RIV£R.
   1500
   1400
     MPN  Fecal Coliform dt Atldhta raw ujdter intake
          DIVISION OP WATER MVGIENE
E
o
o
 a>
Cl
£
k.
o
 o
U
 o
 <^-
 4,'
 a
 
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     The total fecal coliform level in the Chattahoochee River

grossly exceeds that allowable for "recreation waters" for water

contact sports and is unsuitable for water contact recreation

under present conditions.   Recreational use of the river should

be discouraged until conditions improve.  When this project is

completed, the river will be restored.

     The Georgia Water Quality Control Board points out

that the "extensive pollution of the Chattahoochee River

by the metropolitan area renders it unsatisfactory for

most water uses for at least forty miles below Atlanta."    This

program is one of the necessary measures to abate pollution

in the Chattahoochee River south of Atlanta.  Actions of

the Federal and State agencies to restore adjacent sections

of the river are well documented.

AIR

     There are approximately 75 package sewage treatment

plants and waste stabilization ponds  in Cobb County  (refer

to Figure 4), some of which are privately owned and operated.

At one time or another, most have been overloaded, improperly

operated and maintained, and in some  cases neglected.    In

recent years, there have been numerous  complaints about
       Conference:  op. cit., February 17, 1970.
             Sewage Treatment Operations, A Report Prepared  on
 the Cobb County Water and Sewer System by the Georgia Water
 Quality Control Board.
                              -23-

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          'ROSWELL
     *•
MARIETTA
                                               ATLANlf
                                        UJSJING
                                       TKITMtNT FACILITIES
                                        IN COBE> COUNTY

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                        LEGEND - FIGURE 4
       EXISTING SEWERAGE TREATMENT  FACILITIES IN COBB COUNTY
 1.   Marietta-South East  Plant
 2.   Fulton County-Marsh  Creek  Treatment
     Plant
 3.   Marietta-East Side Plant
 4.   Lockheed Plant
 5.   Marietta-South Side  Plant
 6.   Marietta-West Side Plant
 7.   Cobb County-Church Road Plant
 8.   Smyrna-Bohannon Creek Plant
 9.   South Cobb Treatment Plant
10.   Austell Plant

 COBB COUNTY PLANTS
 In order of capacity
 (400,000 gpd - 5000 gpd)
11.   Kennesaw
12.   Windy Hill
13.   Cumberland
14.   Bordeaux West
15.   Riverbend
16.   Cobb General Hospital
17.   Treetop
18.   Shiloh Hills
19.   Terrell Mill
20.   Interstate North
21.   Kenwood
22.   Atlanta County Club
23.   Regency
24.   Maggie Valley
25.   Seven Springs
26.   Cochise
27.  Vinings
28.  Huntington Woods
29.  Eastern Air Lines
30.  Farmington
31.  Blue  Springs
32.  Clarkdale Imhoff
33.  Allatoona Plaza
34.  Wesley Heights
35.  Waverly Woods
36.  Atlanta Metro Industrial Park
37.  Woodland Brook  (Bakers)
38.  Awtrey School
39.  Canton Road Plaza
40.  Lindley School
41.  Franklin Road
42.  Atlanta Metro Ind. Park Imhoff
43.  Rollins
COBB COUNTY PONDS

44.  Addison Heights
45.  Brookhaven
46.  Heritage Hills
47.  Piedmont Hills
48.  County Farm
49.  Galloway Acres
50.  Civitania Woods
51.  Clarkdale School
52.  Compton School
53.  Frontier Trails
54.  Elmwood (Whites)
55.  Maple Valley
56.  Rustic Village
57.  McEachern School
58.  Lincoln
59.  Pebblebrook
60.  Allyson
61.  Marietta-Sope Creek
     Farms

PRIVATE

62.  Hill Haven Trailer
     Park-Plant
63.  Lamplighter Trailer
     Park-Plant
64.  Green Acres Trailer
     Park-Pond
65.  Kennesaw Mountain
     Trailer Park-Pond
66.  Austell Box Board-Pond

OTHER MUNICIPAL PLANTS

67.  Austell-Wildwood-
     Pond
68.  Acworth-Treatment
     Plant
69.  Powder  Springs-
     Piedmont Valley Apt.-
     Plant

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undesirable odors emanating from these facilities.   Centralizing




them in four or five strategic areas in the county will




facilitate retirement of most of the facilities.




     Operation of large treatment facilities by full-time staffs




means better overall treatment operation.  The proposed treat-




ment plants will require permanent staffs for operation and




maintenance.  In addition, the sites are away from residential




areas, and the county will be requested to provide a buffer




zone around treatment facilities.




     If final disposition of sludge wastes is by incineration,




EPA will insure that proper measures are taken to prevent




pollution of the atmosphere.




LAND




     The proposed Cobb County Sewerage Project, which will




provide sewerage facilities for most of the county now




unsewered, is a much preferred alternative to sewage disposal




by private, public and commercial entities now operating




inefficient plants and ponds.  The total land committed to




sanitary facilities will be minimized as numerous small plants




and ponds are retired and buffer zones are limited to a few




large treatment facilities that replace them.  Reclamation




of retired package plant sites and ponds may benefit the




public.
                              -25-

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     By improving quality of water in presently polluted




streams, desirable land uses will be restored.   Coordinated




development may proceed in the newly-sewered, undeveloped




areas of the county as urbanization progresses in Atlanta,




Marietta, Austell and Powder Springs.




     If final disposition of solid wastes rests with the




disposal of sludge, disposal methods will be incorporated




in the  design to prevent health hazards in accordance




with State Regulations.  Benefits to the public by use in




landfill may be possible.




NOISE




     Retirement of  the many  existing package plants,




some of which  are near residential  areas, will  eliminate




noise  pollution.  The proposed  sites of  the  new sewage




 treatment  facilities  are in areas away from  residences




 and  projected  residential development.




     Adequate  acoustic design will be  incorporated into




 the  facility plans, along with  specifications,  to insure




 that noise levels are not harmful to plant  employees or




 others in the  immediate vicinity.




 IMPACT OF THE  PROJECT ON HISTORICAL AND ARCHAEOLOGICAL VALUES




 OF THE AREA




      A survey  of some 133 archaeological sites in Cobb




 County was conducted in the summer of 1970 by high school




 and college students and others, under the supervision of







                          -26-

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local archaeologists.   Those related to the Cobb County

Sewerage Improvement Plan are the Sope Creek Area and

the proposed site of the Chattahoochee River Sewage Treat-

ment Plant near the site of a former Indian village.

     Cobb County has established a plan for preserving and,

if necessary, relocating significant archaeological and

historical discoveries.  Since the Fall of 1970, excavations have

been undertaken at the Village of Standing Peachtree and

other areas to salvage relics and artifacts and collect

historic and pre-historic data.  The contract with the

Consulting Engineer has been amended to make whatever soil

tests and investigations may be required to prevent destruction

of this historic site and preserve scientific data.  Findings to

date have yielded valuable archaeological data; however, no sites

have been uncovered that would be worthy of preserving
                     12
as in-place exhibits.     Archaeological exploration and

salvage operations will continue to precede future construction.

     Also of historical interest are the old mill ruins

along Sope Creek in the vicinity of Paper Mill Road.  Preserving

these ruins and the scenic areas along Sope Creek will be a

prime consideration in the design of the Sope Creek Interceptor

along Sope Creek.  Neither these nor any other properties

involved are on the National Register of Historical Places.
     12
       Appraisals of the Archaeological Resources, Cobb and Fulton
Counties, Georgia, and Other Related Areas of the Chattahoochee
River Valley. (See Appendix B-3). A Report Prepared by Archaeologist
on Behalf of Hensley-Schmidt Engineers, Inc., for Cobb County,
June 1971.

                               -27-

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     Within the County are the Kennesaw Mountain National


Battlefield Park and the proposed southern terminus of the


Blue Ridge Parkway, both under the jurisdiction of the


National Park Service.  The present sewerage program of the


County will have no effect on either of these areas.


Impact of the Project on Recreational Values of Natural Areas


     An interceptor sewer along much of the Chattahoochee


River (Figure 1) is proposed to serve Fulton County's


Beard's Creek, Marsh Creek, River Ridge, and Game Creek


Basins and Cobb County's Rottenwood Creek and Sope Creek


Drainage Areas.  This sewer, five feet or more in diameter


and extending from Sope Creek down the Cobb County side of


the Chattahoochee River to Rottenwood Creek at 1-75, will


join with an interceptor passing down Rottenwood Creek


(Rottenwood Creek Interceptor) at 1-75 and continue along


the Chattahoochee River to the location of the proposed


Chattahoochee River Sewage Treatment Plant at Bolton.


     A preliminary report on "A Plan for the Chattahoochee"


by the Bureau of Outdoor Recreation proposed that the section


between 1-285 and 1-75 known as the "Palisades", be preserved

as a natural area.    The question is whether construction
     I O
      ^Chattahoochee Recreation Area Study, A Preliminary Plan

 for the (Jhattanoochee Frepared by the Department of the Interior,
 Bureau of Outdoor Recreation, March 19, 1971.
                                -28-

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of an interceptor along the river bed through a unique steeped,




cliffed and wooded area is compatible with the potential




reclamation and preservation of that area for recreational




uses and natural park development.




     When construction on the Rottenwood Creek Interceptor




began in August 1970, concerned citizens raised objections




to the damage and disruption of the natural environment along




the creek bed.  In the interest of preserving the privately-




owned scenic creek corridor, the Environmental Protection




Agency met with representatives of the Bureau of Outdoor




Recreation, members of the Georgia Conservancy, the Cobb




County Engineer, Superintendent of Construction of the contracted




construction company, a representative of Cobb County's




Consulting Engineers, and the Chairman of the Cobb County




Commission.  Following approval by the property owner, it




was determined that the center line of the sewer line would




pass along the creek bed, thus eliminating the necessity of blasting




the adjacent rock bluffs.  To help preserve the aesthetic




values, it was also determined that the sewer would be covered




throughout its entire length; that specific trees would be




avoided; that measures would be taken after installation




of  the interceptor to return the  area as  far as practicable




to  its original, natural  state.
                           -29-

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     Placement of sewers in creek beds as opposed to instal-




lation in deep cuts adjacent to creeks is a matter to be




determined on a project-by-project basis.  The deeper a




sewer is buried, the wider must be the construction right-




of-way.  The increased width is for temporary deposition




of spoils used for back fill and for access for vehicles




used to carry excess materials outside of the construction




area.  Clearing of wider construction rights-of-way and




the effects of demolitions are considered to have adverse




effects on local eco-systems and the surrounding environ-




ment.




     The property adjacent to this section of the river is




privately owned and riparian rights prevail, with ownership to




the  center of the stream bed.  The owner of 388 acres on the




Cobb County side adjacent  to the Chattahoochee River and




Rottenwood Creek and  200 acres on the Fulton County side of




the  river adjacent  to  the  river has indicated he will develop




this land to  the fullest extent possible within limits  of  the




zoning.  He has delayed construction  of  a  210-apartment unit




complex pending the construction of sewer  trunk lines to




service this  area.




     The Proposed  Chattahoochee River Scenic  Shorelands and




Flood  Plain Protective Act,  S. B.  228 was  introduced  February  1971




to the Georgia  Senate Natural  Resources  Committee.  The
                            -30-

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Proposed Act provides for a moratorium on development which



might alter the existing natural topography and flora until



approval is given by a Board.  The Act was tabled in the



discussion stages and the Georgia Legislature has adjourned.




     The preliminary report on "A Plan for the Chattahoochee",



released by BOR, recommends that "to assure that the river



surface will be available for public outdoor recreational use,



from Peachtree Creek to Buford Dam, scenic easements should




be obtained for lands along the entire length of the river


         14
corridor.    The purpose of such easements would be to



arrest further development on lands immediate to the river



which would intrude or create an adverse impact on the



quality of the natural values of the corridor."



     Private organizations such as the Canoeing Association



and American Adventures are raising funds on behalf of all



organizations which advocate preserving the Chattahoochee River



for recreational and park use (Georgia Conservancy, Georgia



Appalachian Hiking Club, The Sierra Club, etc.) to establish a



"Land Fund" for the acquisition of land and/or options along



the Chattahoochee River corridor.



     Since no positive steps have been taken by any Federal,



State, or local legislative body to insure preservation of this



area during the interim of BOR's study of the Chattahoochee,



EPA's participation is essential in assuring that construction
       op. cit. ref. 13
                           -31-

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damage is minimized.   This can be accomplished by requiring and




supervising such precautions as minimizing right-of-way clearance,




disposal of excavated material outside of the river corridor,




controlled demolitions in the interest of preservation of rock




areas, etc.
                            -32-

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V.   ANY ADVERSE ENVIRONMENTAL EFFECTS WHICH CANNOT BE AVOIDED




     Adverse environmental effects which cannot be avoided will




be those related to the actual construction of facilities.  These




include construction noise, clearing of right-of-way, which




includes stripping of trees and foliage and, in some cases, de-




struction of rock formation, and soil erosion.  Many of these




effects will be minimized by implementation of construction




precautions.  For projects along the Chattahoochee:




     a.  A minimum buffer zone of 20 feet will be left between




         the construction right-of-way and the river's edge.




         Where practical, at least a 75-foot undisturbed zone




         will be observed.  Representatives of EPA have and will




         continue to make on-site evaluations to influence sewer




         alignment.   In doing so, routes will be developed which




         will have the least adverse effect to the environment.




     b.  Care will be taken in trench excavation and disposal of




         excavated material to prevent endangering the life of




         trees.  Experts of the Federal or State Forestry




         Services will be consulted for their expertise and




         advice to insure design  and construction  techniques




         employed are compatible  with the preservation of




         natural vegetative cover immediately adjacent to  con-




         struction rights-of-way.
                              -33-

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c.  All surplus excavated material from blasting




    operations, trenching, or tunneling will be removed




    at once by the contractor, and hauled away from the




    river corridor for disposal.




d.  All disturbed surface areas will be restored to as




    near natural condition as possible as soon as




    practicable.  Temporary measures will be employed




    by contractors to prevent the loss of topsoil and




    direct or indirect pollution of the Chattahoochee




    River through soil erosion or siltation.




e.  A landscape architect will be employed to advise in




    restoration of disturbed natural area.
                       -34-

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VI. ALTERNATIVES  TO THE PROPOSED PLAN




     A.  Continuation of the Present System of Small Treatment




Plants for Each Subdivision or Community:  Cobb County, almost




unincorporated, consists of numerous subdivisions and small




communities.  This places the administrative authority for




wastewater disposition in the hands of many, both private and




public entities.  A consolidated Cobb County effort is essential




to eliminate this problem.




     Experience has shown that large treatment facilities operated




by trained permanent staffing results in better waste treatment.




Many of Cobb County's 75 package plants and stabilization ponds




have failed to yield an acceptable effluent because of poor




operation and maintenance and lack of trained personnel.  These




points are  clearly identified and delineated in the May 1968




"Report on  Small  Sewage Treatment Plant Operation; Cobb Water




Sewer  System'' released by the Atlanta Water Works  (See Encl. 3,




Appendix B).




     Centralized  sewerage facilities and administrative control




 is more desirable than  continuing with  small, unregulated,  isolated




 treatment facilities.




     B.  Least  Cost Alternative  as  Selected by  Cobb  County  for




 the  Sope Creek  Interceptor:   Installation  of  approximately  5,200




 linear feet of  sewer pipe in excess  of  five feet  in  diameter




 immediately adjacent to the river's  edge,  which will require




 blasting rock  formations  and clearing  trees up  to the river's
                          -35-

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edge, and approximately 3,100 linear feet of pipe placed far




enough inland to provide a buffer zone of trees and foliage




between the river's edge and the cleared sewer right-of-way.




Bid cost for construction was $912,467.00 (Refer to Figure #5).




     C.  Lift Station at Powers Ferry Road, with Force Main




along Akers Mill Road to Rottenwood Creek and a 48" Parallel




Sewer to the Existing Rottenwood Creek Sewer down Rottenwood




Creek to the Chattahoochee River;  This alternative is undesirable




from the standpoint of hydraulic design, since pumping would




be required.  Initial construction costs of this alternative




are considerably higher than that for the proposed sewer along




the Chattahoochee.  Estimated construction cost is $1,650,000.00




and operating costs are estimated at $150.00 per day  (Refer




to Figure #5).




     D.  A Single Tunnel Between Rottenwood Creek and the




Chattahoochee River at 1-285 with some Open Cut;  There would




be no possible danger of mechanical breakdown as the  flow




would be gravity, and the construction of single tunnel spanning




the whole reach along the Palisades section of the Chattahoochee




eliminates conflict with natural area preservation interests.




Estimated construction cost is $2,070,000.00  (Refer to Figure  #5).




     E.  Tunneling to Prevent Destruction of  the Natural Rock




Cliffs and Outcrops along the Chattahoochee Scenic Easement




and Open Cut with Adequate Buffer Zone of Trees and Foliage




Between River's Edge and Construction    Right-of-way:  This






                          -36-

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          PftOPOSIO MM* CAMK

          PUMPIM* •TMTIOM
«OPC
                - R.OTTCNUJOOO CRteK
                     SCWCR

           COBB  COUNTY
                          CPA- 1*71
37
                              FIG. 5

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is a desirable solution from the standpoint of hydraulic




design.  Gravity flow requires no operation and minimal




maintenance.  By tunneling approximately 3,700 feet and inter-




mittent open cuts with buffer zones between the river and




construction right-of-way, the scenic easement along the Palisades




can be preserved.  Construction cost of this alternative will be




$1,475,892.00.
                          -38-

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VII.  ANY IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES




WHICH WOULD BE INVOLVED IN THE PROPOSED ACTION




      Irreversible commitment of resources include land used




for construction rights-of-way, treatment facility sites, and




their buffer zones.
                          -39-

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VIII.  CONCLUSIONS AND RECOMMENDATIONS




       The Cobb County Sewerage Improvement plan is




a thorough, comprehensive program for providing




sewerage services now and far into the future for




Cobb County residents.  It is in accord with Federal,




State, and metropolitan programs for improving the quality




of water in the waterways of Cobb County and adjacent counties




into which these waters flow.  Cobb County has set an example




for the metropolitan area in coordinating a cooperative effort




to implement a program to serve the most at the least expense in




an expeditious manner.  The program as descreibed in this statement




is recommended for construction.




       With Cobb County and Fulton County joining in a pre-




cedent-setting venture, Game Creek sewer, in the palisades




area, has been totally eliminated.  Providing a buffer zone




between construction right-of-way and the riverbank,




tunneling rather than blasting of scenic rock cliffs,




hauling spoil away, taking special precautions to avoid damage




to unusual vegetation, and restoring of disturbed areas will




be accomplished.  Incorporating these considerations will cost




$563,000.00 of the $1,476,000.00 construction cost of the




project through the palisades area.  The cooperation of the




counties involved, who bear two-thirds of the cost, has been




outstanding.
                           -40-

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       EPA and the counties are moving to restore the




river so that the water will be safe for recreational




use.  Everyone will benefit by the initiative Cobb




County has taken towards preserving historical and pre-




historical discoveries, which were found during construction




of  this project, and its willingness to apply additional




funds towards the conservation of natural areas which




have planned public  scenic  and  recreational values.  EPA recom-




mends other agencies move to acquire the 48 miles of




right-of-way needed  to develop the park.




        Specific details  of  sewer  line  location and




construction can be  obtained  from the  construction




contract  documents  on  file  in the Cobb County Engineering




Department,  the Georgia  Water Quality  Control Board  or




the Construction Grants  Office of the  Environmental  Protection




Agency.
                         -41-

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BIBLIOGRAPHY

-------
                         BIBLIOGRAPHY
Chattahoochee Laboratories Monthly Reports, January 1970 -
     March 1971.

Chattahoochee Recreation Area Study.  A Preliminary Plan for
     the Chattahoochee Prepared by the Bureau of Outdoor
     Recreation,  March 10, 1971.

Chattahoochee Water System Laboratories.  (Highlights 1969),
     A Report Prepared by the Atlanta Water Works.

Comprehensive Sewer Study for Cobb County, Georgia.  A Report
     Prepared by  Hensley-Schmidt, Inc., Consulting Engineers,
     Marietta, Georgia, February 1967.

Conference:  In the Matter of Pollution of the Interstate
     Waters of the Chattahoochee River and Its Tributaries -
     Georgia - Proceedings, Second Session, February 17, 1970,
     Atlanta, Georgia.

Contract, Cobb and Fulton Counties, October 7, 1970.

Establishment of  Water Quality Standards and Classifications
     for Interstate Waters in the State of Georgia, Prepared
     by the Georgia Water Quality Control Board, June 1967.

Federal Water Pollution Control Act, Public Law 84-660, U. S.
     Department of the Interior, Federal Water Pollution Control
     Administration.

The Georgia Conservancy, Inc., News Letter, August 1970.

Open Land/Regional Problems and Opportunities, A Report Prepared
     by the Atlanta Region Metropolitan Planning Commission,
     June 1964.

Rules of the State Water Quality Control Board, Chapter 7303,
     Water Use Classifications and Water Quality Standards
     (Proposed),  Prepared by the Georgia Water Quality Control
     Board, April 22, 1971.
                         -42-

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Water Quality Analysis.  A Report by the Georgia Water
     Quality Control Board, 1969.

Water Quality Criteria.  Report of the National Technical
     Advisory Committee to the Secretary of the Interior,
     April 1, 1968.

Water and Sewerage, A Report Prepared by the Atlanta Region
     Metropolitan Planning Commission, February 1969.
                         -43-

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APPENDIXES

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                             APPENDIXES

A.  Correspondence

    1.  Memorandum from the U. S. Department of the Interior,
        Bureau of Outdoor Recreation (Roy K. Wood) to EPA
        (John R. Thoman), July 14, 1970.

    2.  Letter from the Georgia Conservancy, Inc.(Allen C. Hart)
        to EPA (John R. Thoman), August 17, 1970.

    3.  Letter from Alfred D.  Kennedy to Cobb County Water System
        (Robert L.  Sutton,Jr.), August 28, 1970.

    4.  Letter from Cobb County Water System (Robert L. Sutton)
        to EPA (Asa B.  Foster,Jr.), September 3, 1970.

    5.  Letter from Atlanta Region Metropolitan Planning Commission
        (Glenn E. Bennett) to  Cobb County Commission of Roads
        and Revenues (Ernest W. Barrett), October  1, 1970.

    6.  Memo from U. S. Department of the Interior, Bureau of
        Outdoor Recreation (Roy K. Wood) to EPA (John R. Thoman)
        November 18, 1970.

    7.  Letter from Hensley-Schmidt,  Inc. (Kenneth W.  Rich)  to
        EPA (Douglas C. McCurry), November 18,  1970.

    8.  Memo from EPA (John R. Thoman)  to U.S.  Department of the
        Interior, Bureau of Outdoor Recreation  (Regional Director)
        December 28, 1970.

    9.  Letter from Georgia Water Quality Control  Board (W.  C.
        Mason, P.E.) to Cobb County Water System(Robert L. Sutton)
        February 8, 1971.

   10.  Letter from Cobb County Commission of Roads and Revenues
        (Ernest W.  Barrett)  to EPA (Asa B. Foster,  Jr.), February 23,
        1971.

   11.  Letter from Cobb County Water System (Robert L. Sutton) to
        EPA (Asa B. Foster,  Jr.), March 11, 1971.

   12.  Letter from Secretary  of the  Interior (Roger B. Morton) to
        Administrator of EPA ( William D. Ruckelshaus), March 16, 1971.

   13.  Letter from Georgia Forestry  Commission (Wilson H. Wright)  to
        EPA (Fred A. Eidsness, Jr.)  ,  April 20, 1971.

   14.  Letter from Administrator of  EPA (William  D.  Ruckelshaus)
        to  Secretary of the  Interior  (Roger B.  Morton), April 30,
        1971.
                          -44-

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    15.   Letter from A.  R.  Kelley,  PhD.,  Cobb  County Archaeology
         Consultant, to  Hensley-Schmidt,  Inc., June  25,  1971.

    16.   Letter from Cobb  County Water System  (Robert L.  Sutton)
         to EPA (Asa B.  Foster,  Jr.),  June 28, 1971.

    17.   Letter from Cobb  County Water System  (RobertL.  Sutton)
         to EPA (Asa B.  Foster,  Jr),  June 28,  1971,  with
         Enclosure (1)   Chattahoochee River Sewage Treatment
         Plant, CRSTP,  Selection of Site; Enclosure  (2)  Correspon-
         dence with Army Corps of Engineers regarding site of
         proposed CRSTP.

    18.   Letter from Cobb  County Water System  (Robert L.  Sutton)
         to EPA (Asa B.  Foster,  Jr.),  June 28, 1971  with
         Enclosure (See Appendix C-2)  Appraisals of  the
         Archaeological Resources,  Cobb County and Fulton County.
         Georgia, and Other Related Areas of the Chattahoochee
         River Valley.

    19.   Letter from Atlanta  Region Metropolitan Planning Commission
         (Glenn E. Bennett) to EPA (Joseph R.  Franzmathes, P.E}
         June 28, 1971.
B.  Reports

    1.  Archaeological Survey of Cobb County, A Report c/o
         Pebblebrook High School Site.

    2.  Appraisals of the Archaeological Resources.  Cobb and
         Fulton Counties. Georgia, and Other Related Areas of
         the Chattahoochee River Valley. June 1971.

    3.  Small Sewage Treatment Operations. A Report  Prepared
         on the Cobb County Water and Sewerage System by the
         Georgia Water Quality Control Board.

    4.  Evaluation of Flood Hazard in Locating Federally Owned
         or Financed Buildings. Roads, and Other Facilities, and
         in Disposal of Federal Lands/Property.  Executive
         Order 11296, Federal Register, Vol. 31, No. 115J,
         August 11, 1966.

    5.  Comments and Recommendations of Atlanta Region
         Metropolitan Planning Commission, August 4, 1967.
                           -45-

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C.  Comments

    1.  Letter commentary of Department of Housing and Urban
        Development (Thomas J.  Armstrong)  to EPA (John R.  Thoman)
        April 5, 1971.

    2.  Letter commentary of Department of the Interior,
        National Park Service (L.  Boyd Finch)  to EPA
        (John R. Thoman), April 6, 1971.

    3.  Letter commentary of the Department of the Interior, Fish
        and Wildlife Service (Ernest C. Martin)  to EPA
        (John R. Thoman), April 7, 1971.

    4.  Letter commentary of the Department of Agriculture,
        Forest Service (W. R. Phelps) to EPA (John R.  Thoman)
        April 7, 1971.

    5.  Letter commentary of the Department of the Interior,
        Geological Survey, (John R.  George) to EPA
        (John R. Thoman), April 8, 1971.

    6.  Letter commentary of the Department of Army, Corps of
        Engineers (J. J.  Danaher)  to EPA (Frank M. Redmond)
        April 0, 1971.

    7.  Letter commentary of the Department of the Interior, Bureau
        of Outdoor Recreation (Roy K. Wood) to EPA (John R.
        Thoman), April 13, 1971

    8.  Letter of Advisory Council on Historic Preservation
        (John D. McDermott) to EPA (John R. Thoman), April 12,
        1971.

    9.  Letter commentary of Department of the Interior, National
        Park Service (John W. Griffin) to EPA (John R. Thoman)
        April 13, 1971.

   10.  Letter commentary of Office of Equal Opportunity (Roy E.
        Batchelor)  to EPA (John R. Thoman), April 15,  1971.

   11.  Letter from Georgia Historical Commission (Mrs.  Mary G.
        Jewett)  to EPA (John R.  Thoman), April 23, 1971.

   12.  Letter from Department of Housing and Urban Development
        (Thomas  J.  Armstrong),  to EPA (John R.  Thoman),  May 7,
        1971.
                             -46-

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13.   Letter from Department of the Interior, National Park
     Service (Richard D. Faust) to EPA (Frank M. Redmond)
     May 13, 1971.

14.   Letter from Department of Agriculture, Forest Service
     (G. L. Downing) to EPA (Frank M. Redmond), May 17, 1971.

15.   Letter commentary of Department of the Interior, National
     Park Service (Vincent Ellis) to EPA (Frank M. Redmond)
     May 21, 1971.

16.   Letter commentary of Department of the Army, Corps of
     Engineers, (Harry A. Griffith) to EPA  (John R. Thoman)
     May 27, 1971.

17.   Letter from Sierra Club (Kenneth W. Martin) to EPA
     (John R. Thoman), June 21, 1971.

18.   Letter from Friends of the River, Inc. (Mrs. Harold C.
     McKenzie, Jr.) to EPA (John R. Thoman), June 23, 1971.

19.   Letter from SAVE (Mrs. Charles Yarn) to EPA (John R.
     Thoman), June  23, 1971.

20.   Letter from Georgia Conservancy (Claude E. Terry) to
     EPA (John R. Thoman), June 24, 1971.
                           -47-

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APPENDIX A

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IN KEPLY REFER TO:
  United States Department of the Interior
       HURF.AU OF OUTDOOR RCCRKATION
         SOUTHEAST REGIONAL OFFICE
              810 New AValton liuikling
               Aihiiita, Georgia 30303

                  July 14, 1970
        Memorandum

        To:
         From:
Regional Director, Southeast Region, Federal Water Quality
Administration, Atlanta, Georgia

Regional Director, Southeast Region, Bureau of Outdoor
Recreation, Atlanta, Georgia
         Subject:  Chattahoochce River Area


         Enclosed  is  a  copy of  the July  14 letter, with  enclosure,  from  this
         office  to Mr.  James H. Aldredge, Chairman,  Board  of Commissioners  of
         Fulton  County. I believe the matter  of  immediate concern  to  the
         Georgia Conservancy people  is a prospective sewerline  project proposed
         for a scenic area adjacent  to the Chattahoochee River  between 1-285
         and the Paces  Ferry Road bridge.

         I would like to take the liberty of suggesting  that, in considering
         the grant which will be requested of  you for this project, the
         long-range  environmental^ scenic, and recreational  potential  of_ the
         Cn"aTtai6ocBee"River and immediate" adjacent" lands" be considered^

         As suggested in my  letter to Mr. Aldredge,  this area can be one of
         the outstanding features of a great and  growing urban  center  or it
         can be  just another stream  running  through  a city.  The projects and
         developments initiated in this  area will determine  its future.
                                            Roy K. Wood
         Enclosures

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                  NITING GEORGIA'S CONSERVATIONIST
                Tin-: (JKOW.IA ('ONSKRVANCY,

                        IO25 CANDLER BUILDING
                     ATLANTA. GKOROIA .to:to:i
                           4O4/525-I82S
                        August 17, 1970
Mr. John Thoman, Regional Director
Federal Water Quality Administration
Suite 300
1421 Peachtree Street, N.E.
Atlanta, Georgia

Dear Mr. Thoman:

We request that you give due consideration, under the Environmental
Policy Act of 1969, to the environmental effects of two sewer line
grant applications you have for review at this time.

The Game Creek Interceptor proposed by Fulton County would run
approximately 1.5 miles through magnificent rock palisades in
the last wild stretch of the Chattahoochee near Atlanta.  Consid-
erable environmental damage as well as encouragement to further
development is inevitable with the route proposed.

The Rottenwood Creek Interceptor proposed by Cobb County would for
part of its length lie in the creek gorge from Akers Mill Road to
the Chattahoochee.  This is the best of the very few such gorges
near Atlanta.  Its unique habitat harbors many plants recognized
as rather rare by the Georgia Botanical Society.

The Atlanta Region Metropolitan Planning Commission recognized in
their 1963 open spaces study that this area (the remainder of
which is shown unshaded on the enclosed map) had tremendous re-
creation and educational value.  I quote from their report, "The
Long Island-Rottenwood Creek area, for example, is probably unique
in its rugged and almost unspoiled beauty considering its close-
in location."  Indeed, Atlanta is unique among large American cities
to have such a river at its doorstep.  The planners' judgment
seems borne out by the many thousands of people who float, hike,
fish, and observe the beauty and wildlife in this area each year,
even though such use is discouraged by private owners  and lack of
access.

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Theman
August 17, 1970
Page 2

We feel that sewer lines down either bank of the river between
Interstate 285 and Interstate 75, or down the Rottenwood Creek
gorge, should be carefully weighed against their impact on the
environment.  In addition, cooperation between Cobb and Fulton
Counties ought to be encouraged to avoid expensive duplication.

These sewer plans seem to have come before the A-95 review pro-
cedure, but we would suggest that expert advice now be sought
from appropriate sources on environmental and recreational matters.

We would specifically request your cooperation in an examination
of feasible routes or alternate methods, even if some possible
increase in cost may result, before irreversible actions are
taken that might destroy the irreplaceable natural, scenic, re-
creational, and educational values of this area.  If possible,
we would ask your consideration of withholding funds for these
two projects until their possible effec±s are known.

Sincerely,
Allen C. Hart
Executive Director

AH/mt

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                      A i. r i%« i: i j 1). K i; N x K ii Y
                        •ILK n«»v<>n 01 4.1011 C..KO
                          ATLANTA, t IKO'WIHA
                                             August  28,  1970
Mr. Kobt-rt L.  Siii.uo.i.Jr .
County Luj.;irit';cir ,
Cobb Cci..v>ty  jin^jnr.orir.;; D
?. 0. Fox 6/,'J
Marietta , . Gt-ory J a

Dear Mr. i>ultoi>:

                1  iin: enclosing  copies -of plntu shoviny  development
plans fo)- cur  38!) aeros of property in Co";./o County.  As you can
sec, th(i£.e ijlan.s  are quite detailed and are based  on research
ar.coir.plishf.cj t!irou;>.h years- of  study by nationally  known feasibility
and land str.dy organisations at  a cost of several  thousand dollars
to us ss ittdividu.-ilfl.   Wo have no intftvt'.sc \;!i.-'tr> cover  in seeing j^ny
of this  land become public pa::ii  &rea.

                I  have shaded in  red the yroup of .210 apartment
units whjch  v» WP ':"*&£, to bf!\in v;ir.h .in 'he.' next  few weeks.  We
have delayed bi;j;j lining constiruction en t'.iasn bcc.'nise of- the lack
of sewer and because wo felt the county v.'ould shortly  provide a
sewer line.  We  cannot delay much longer.  As I have pointed out
to Mr. Bcurkie. in a recent telephone conversation,  if  the county
has not provided ' scv.'crajro by the t.ir.c our apr.rtr.ents are ready,
we will have to  run an eight inch line. down Rottcnwood Creek
ourselves.

             •   I  fc^l that our overall plan is one which preserves
as much of the luit.ural beauty  of this area as- possible v:hile
providing living  and working space for people and  an increased tax
base for the county.
                                             Sincerely,
                                             — '
ADR:h
                                             Alfred  D.  Kennedy

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!OBB COUNTY
.;MM ••-ujNT'Hri OF ROADS AND Rl"ViNUt:
o  -i x • J <
A.I,:,-"l TA GEORGIA
ERNEST W. BARRETT. CHAIRMAN •  ROBERT J. AUSTIN, DEPUTY  • THOMAS H. BROWN • T. L. DICKSON • ERNEST P. ELLISON •  HARRY E. INORAM
                                                       September 3,  1970
   Mr. Asa B. Foster, Jr.
   Director of Facilities Program Office
   Suite 300
   1421 Peachtree Street N.E.
   Atlanta, Georgia
    Dear Mr.  Foster:
                                                   RE:   Cobb County WPC-GA-173
                                                         Rottenwood Creek
    We have investigated the proposed and  existing  land  use by the  owners  of the
    property abutting the proposed recreational  park along  the Chattahoochee River,
    in Cobb County,  South of the 1-285 crossing  and North of the Paces  Ferry Road
    Bridge.   The  owners have developed this land or proposed to develop this land
    as apartments and office park.   (See enclosed development plan  and  letter).

    In addition to this, the feasibility of constructing a  lift station in the
    vicinity of 1-285 crossing and pumping to  the Rottenwood Creek  and  then
    pumping  from  Rottenwood Creek along the interstate Right-of-way,  to the line
    on the River  at  1-75.  Our estimates indicate that the  cost of  constructing
    the line as proposed in our comprehensive  report is  $1,400,000.   The cost of
    constructing  the Lift Stations and Force Mains  as investigated  indicate a cost
    of $3,000,000.   The Static heads of the Lift Station locations will exceed 100 ft.
    In additional  to construction cost, the cost of operation (lift stations) that
   must be borne by the customer will be  approximately  $300 per day  initially and
   ultimately reaching $500 per day.

   Therefore, it is our conclusion that the Federal Water  Quality Adminstration
   must allow us to proceed with the installation  of the gravity sewers along
   Rottenwood Creek and Chattahoochee River.

   We have  further investigated the proposed addition of flow from Fulton  County
   with the idea  in  mind  that  this  will climate the Marsh Creek Treatment Plant
   and the  proposed  Games  Creek Outfall.   Fulton County has furnished information
   that their drainage daily flows  for year 2020 will be 14 mgd.  Attached you will
   find data on this design from our consulting Engineer.

  Attached  is a comparison of estimated  cost that will be incurred  if Cobb County
  and Fulton County merge facilities.  At this  time we  have not reached an agree-
  ment with Fulton County but anticipate  doing  so  within the next  week.  Due to the
  urgency of this program to Cobb County  in its efforts td clean up  our streams
  and end our pollution of the Chattahoochee River we are  requesting that you  re-
   ease the contracts for Rottenwood Creek.

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September 3, 1970
Page 2
If we can answer any further questions please contact us.
                                           Sincerely yours,
                                           Robert L.  Button,  Jr.
                                           County Engineer
 RLS/hs

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 A'
>•!»'
      CITY OF ATLANTA • CLAYTON COUNTV . COBB COUNTY • OBKALB COUNTV • FULTON COUNTS • GWINNETT COUNT V

      ATLANTA  REGION METROPOLITAN  PLANNIN6 COMMISSION

    ) 9OO Glenn Building • Atlanta, 3«orgl« 3O3O3 •  Telephone (4O4; S 2 S • 7 E; 7 7.


Nelson Se veringhous, Chairman                          Harmon M. Born, Secretary-Treasurer

Cecil A. Alexander, Vice-Chairman                       Glenn E. Bennett, Executive Director
                           October 1, 1970
     Mr. Krnest Barrett,  Chairman
     Cobb County Consniccion
     P. O. Box 649
     Marietta, Georgia 30060

     Dear Ernest t

     Ke have received & copy of th«  plan showing the Fulton/CoLb
     joint propoaal for »«wormgtj facilities along a portion of
     tha Chattahoochaa River.  Aa you know, our regional water
     and bew«rago Plan wa» an»ndad on September 28, 1970, to
     account tor tfaio project  
-------
                    United States Department of the Interior
                         BUREAU OF OUTDOOR RECREATION
                           SOUTHEAST REGIONAL  OFFICE
                                810 New Walton Ituilding
                                 Atlanta, Georgia S030S
IN MK.Y REFER TO:
                                   NOV t  8 1970
                                                                V • f* •*."• .'.*
         Memorandum

         To:       Regional Director, Federal Water Quality Administration,
                   Southeast Region, Atlanta,  Georgia

         From:     Regional Director, Bureau  of Outdoor Recreation,
                   Southeast Region, Atlanta,  Georgia

         Subject:  Rottenwood  Creek and  Sope  Creek Sewerlines


         Thank  you for  your letter  of September 24, 1970, concerning
         contract  stipulations for  sewerline  projects  in Cobb  County,
         Georgia.  We also appreciated the  opportunity of meeting with
         Messrs. Asa Foster and Doug McCurdy,  of  your  staff, on November 5,
         1970,  to  discuss  the  Rottenwood Creek and the Sopc Creek Sewerline
         project."..

         In  your letter of September  24, 1970, you quoted a stipulation
         from your approval of Cobb County's  request to proceed with the
         construction of the Rottenwood  Creek interceptor sewerline.
         We  were pleased to see this  stipulation  added to this project
         and would be interested in knowing what  response you  have had
         from Cobb County concerning  it. Specific information on what
         steps  will be  taken by the county  and/or the  contractor to
         change the project alignment to protect  natural scenic areas,
         cover  the sewerline,  and restore disturbed areas would also be
         appreciated.   We are  most  concerned  with the  portion  between
         Akers  Mill Road and the Chattahoochee River and along the banks
         of  the Chattahoochee  to the  State  Highway- 3 bridge.

         As  discussed at our November 5, 1970, meeting, we are particularly
         interested  in  examining the  preliminary  plans for the Sope Creek
         interceptor  as soon as they  are available. We have provided
         Mr. Foster  a copy of  the enclosed  map delineating areas of  the
         Cobb Palisades where  scenic  values need  consideration and
         protection.  For your further  identification, photographs of
         these areas keyed to  the map are  enclosed.

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We would like to know if all feasible alternative routes for
this line have been evaluated, especially a route from Powers
Ferry Road following the curvature of 1-285 and Akcrs Mill Road
to combine with the Rottcnwood Creek line now being constructed.
This route appears to be about one-half the distance that would
be required to follow the bank of the river and connect onto the
Rottenwood line at the creek mouth.

Since pumping stations may already be required under the present
plan at Powers Ferry Koad for sewage from the upstream Fulton
County area, would additional pumping capacity be required for
the upstream Cobb area's effluent?  Even if this plan is more
expensive on. a short-range basis, protecting this irreplaceable
natural resource may justify a larger initial expenditure as
well as some additional operating expense.

Another alternative which we discussed with Mr. Foster would be
one to three tunnels for the Sope Creek line through the major
portion of the Cobb Palisades to avoid defacing the rock out-
croppings .  This alternative would require hauling the spoil
away from the scenic river gorge area, exercising care to avoid
damage to the natural landscape and vegetation during construc-
tion, and restoring disturbed areas to their natural condition
after construction is completed.  We would appreciate your
evaluation of these alternatives.

We suggest an onsite inspection of these areas with you and your
staff to investigate these alternatives for the Sope Creek line
in an effort to insure that the scenic rock outcroppings and
other natural values will not be permanently scarfed during project
construction.

Our recreation study will investigate the feasibility of hiking
or riding trails along the routes of these and other riverside
sewerlincs along the Chattahoochee from Buford Dam to Peachtree
Creek.  Do your regulations permit local -governments to acquire
public access rights at the same time that construction ease-
ments are acquired for the sewerline?

In addition to the lines under discussion, we need information
on any other projects that may have been approved or for which
applications are pending in the Chattahoochee River study area
from Bufofd Dam to Peachtree Creek.
                                     }" Eoy K. Wood
                               Roy K'. Wood
Enclosures

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      , TENNESSEE
,„,. HMW.tr
jaB*. JOMMSON, JR.
HENSLEY-SCHMIDT, INC.
  CONSULTING ENGINEERS
    November 18, 1970
                                     METROPOLITAN ATLANTA, GEORGIA
                                           4053.
  PLEASE REPLY To

  P.O. BOX NO. 835
MARIETTA. GEORGIA 3OO6O
MOM* I- DOWNS

OBU.W" MM, •>*•
 W «.l«OLt«TM

  ft. MITCHELL, JR
     Mr. Douglas C.  Me Curry
     Federal Water Quality Administration
     1421 Peachtree Street,  N. E.
     Atlanta, Georgia 30323
                                    Re:  WPC-GA-173
                                         Rottenwood Creek Interceptor Sewer
                                         Cobb County Sewer Program
     Dear Mr.  Me Curry:
     Pursuant to our meeting this morning with members of the Georgia
     Conservancy to discuss possible realignments of the now contracted
     sewer line that will parallel Rottenwood Creek from the Chattahoochee
     River to Akers Mill Road, we  wish to indicate that both the plan and
     profile for this  sewer as  shown on our drawings numbered E-4053-13. 0,
     E-4053-14. 0, and E-4053-15.  0 was studied by an engineer and architect
     commissioned by the owner  of the property in question.

     The property owner was concerned that the sewer would not be exposed
     in any location and that the alignment was such that damage to the natural
     beauty of the property would be minimized allowing for construction
     necessities.

     He granted the easement only  after a review of the alignment in the field;
     after which his representatives were satisfied that the proposed sewer
     location met with his stipulations.

                                         Very truly yours,

                                         HENSLEY-SCHMIDT,  INC.
                                          Kenneth W.  Rich
      KWR/jgt
      cc:  Mr.  Robert L. Sutton,  Jr.
     AIRPORTS, BRIDGES, rOUNDA'
                   IT,ONS, HYDROELECTRIC. SEWERAGE,STREETS, STROCTURES.TRAFFIC, TRANSPORTAT.ON.TUNNELS,WATER WORKS

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Baglonal Dlroctor,  B.O.I.                                  Bacambor 28,  1970
Southaaat Bagion, Atlanta,  Oaorgla

Bagioaal Director,  F.W.Q.A.
Southeat Begion, Atlanta, Georgia

WC-CA-173
Cobb County
Thank you for your memorandum of November 18,  1970,  and for tha
Intereet ehown and commenta made on the interceptor  eewers now being
constructed  in Cobb County.

Because of the Fulton-Cobb  joint treatment agreement  acme explanation
la needed concerning  the  tope Creek, Bottenwood Creek and Game Creek
aewere and the conditions referred to la my letter of 9/24/70 to you.
When the Game Creek Sower in  Fulton Canary wee proposed bids were
already being reviewed  for  construction  of the Bottenwood Creek
sewer in Cobb County.   Formal approval of the  Bottenwood Creek Sewer
contract waa withheld by  this office until Informal  agreement had been
reached concerning a  Joint  treatment project between Cobb and Fulton
fiountiee.  Thia agreement between Cobb and Fulton Counties will
permit abandonment of the Game Creek Sewer and the Marsh Creek Treatment
Flant in Fulton County.   Since part of tha Bottenwood Creek Sewer will
transport waatoweter  from Fulton County it wee neceeeary that the
Bottenwood Creek Sewer  be enlarged to provide  additional capacity.  If
construction of the Bottenwood Creek Sewer had proceeded before  an
agreement had been reached  tho Cobb-Fultoa pact might have never been
e reality.   Becauee of  the  agreement between Cobb and Fulton Counties
to provide joint treatment  the original time schedule for construction
of Cobb County's Sope Creek Sever ha* been moved up  due to the
           needs in Fulton  County.
In rogard to your •pacific quaationa concarning  tha  Bottonwood Croak
contract tho changa ordar raforrod  to  In aw *  lattar  of 9/24/70 haa
not baon iaouod aa yat.  Tha oawar  will  ba covorad throughout ita
langth axcapt for two croak crooaiagatnacaaaary  to obtain bat tar
aligBaaat.  On Moiioaiiar 18, 1970, a rapraaantatlva from  thia Of flea
tourod tha plannod oawar Una along Bottonwood Gorga with rapraaantativaa
of tba following organicationa:  Tho Otorgia  Conaarvancy, Tha Gaorgia
Botanical Socioty, Cobb County. Hanalay  - Sebaldt  Conaulting Bnginaara
and Blytho Brothora Construction Company.  Tha noatlog indlcatod aona
diaagraoaont aaong intaraotod groupa aa  to how tho natural araaa might
ba baat praaarvad.  Soaa fait that  tha aowar  ahottld  ba laid abovo
ground or on plora to mlnimiaa tho  damaga that blaatlng  or traaching
might do.  Othora fait that 1C waa  important  to  hava tha aawar

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WPC-GA-173
Cobb County                       -2-                 December  28,  1970
completely covered, but the owner of  the  property had  agreed  to the
sewer easement only on the condition  that the  pipe  be  completely
covered and that the alignment would  be subject  to  his approval so
as to minimise the damage to the natural  beauty  of  the property. Tie
contractor has agreed to minimise blasting and clearing damage  insofar
as is possible.  The value of  the tree in photo  H.  was realised and
will be saved.  The other areas shown  are  in the  Sope Creek Sewer area.
If your review of the plans and speclflcatlonczleft in your office on
November 5, 1970, does not indicate this  to be true please let  us
know at once.

In regard to the alternative to the Sope  Creek Sewer which you
have mentioned, this alternative was  considered  in  conjunction  with
an alternative to abandon the Rottenwood Creek  Sewer through
Rottenwood Gorge.  The alternative would  have  involved two additional
pump stations, force mains and interceptor sewers around Alters  Mill
toad and down 1-73 to the river.  The additional present worth  costs
of this alternative is estimated to be 3.1 million  dollars more than
the alternate gravity sewers.

As discussed with your staff on November  5, 1970, our  staff is  working
with Cobb County officials on tunneling,  alignment, and other means of
minimizing damage in the design layout for the Sope Creek Sewer along
the River.  The preliminary plans for this sewer are now available and
a copy is enclosed for your review and comment.  Any comments you
might have should be submitted as soon as possible  eo  that we may  have
the benefit of your counsel in our detailed review.

Our regulations do not aJfaw us to participate  in the cost of  land
acquisition or easements.  Our regulations only  require that  the applicant
acquire the necessary easement for construction. Whether or  not Public
.eeess rights could be obtained along with sewer easements would be a.
question for discussion with the local government constructing  the project.

Tour question concerning other projects in the Chattahoochee  River
Study Area Is best answered by Mr. Al Herdon's recent  report  submitted
to Mr. Idward C. Chidlaw, B.O.R.  As  you  know  Mr. Berftdon is  Chairman
of the Water Data Committee part of the present  B.O.R. Study  of the
Chattahoochee.  His report summarises present  and future projects  now
planned within the "Study Area."

Pleaee contact us if we can be of further assistance to you in  any way.
                                        John R.  Tnoman

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                £tatc Water (Qualitg Control JBoard
                            47 Trinity Avarae, S. W.
                          ATLANTA, GEORGIA 30334

                           February 8, 1971
Mr. Robert L. Sutton,
Cobb County Engineer
P. 0. Box 649
Mtrietta, Georgia
Jr.
                                  El:  Sope Creek Intercept or Sewer
                                       (lotteevood to Power* Ferry)
                                       VPC-Oa-173, Coke Goaty
Deer Mr. Satt«
          Pleas and epecifieatioaa for the firet phaae of the Sope Creek
Interceptor Sewer have hen reviewed and ere hereby approved for con-
etnetioa.  Bo Ceaatruetioa Permit will be iaeaod in keeping with the
policy of thle off lev.
          The Georgie Meter Quality Control Boerd e«Aoreei end
with the EegioMl tfeeteweter Collection 4 Treetmet Project for irfiicii
the eewers doeeribed ia theee plese ere aeeeeeery.  The Sope Crook
Intercept or Sever, totteaoeed Interceptor Sever, ead the Chettehoechee
River Treetewnt Pleat vill do ••eh to iaprevo the fvelity of the Chatte-
hoocbee liver e»4 Ite tributary etve«M eariag the «o*i«t ooeaiee.  He
           that theee oewere vill provide the temporary fuaetioa (fro*
       1971 uatil the Chattiheofhee liver Plant it coa»leto<) of conrey-
iaf vaeteveter fro* the Oeva Creek area of Paltoa County aad the lc
Sepe Crook area of Cooh Covnty.  Ihia itvegi vill be treated at a
rary pleat aad diaeharfod to the river belov Atlanta'* vater intake.
Thie preeadvre cannot fail to have a beneficial effoet vpoa the ooality
of the Chattahooehoe liver and Atlanta '• drinking vater.  We offer our
fail avnpoct Cor the project.
          He are forwarding two oote of plane and epeeifieatione to the
Knvironwantal Protection Agency of the 0. 8. Departnent of the Interior
for their review.  By copy of thie letter, we «rge that office to do
everything within ite power to •peed the inplenentation of thle vital
project.

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Mr. loaart L. tettoa, Jr.
February i, 1971
rat* z
         On* aaarava* Mt Of plaM Mrf ••OelfUatiaaa ia aaalOM4 f«T
y«wr UMI  OM Mt will to r«tvnHtf t» tte •o(iM«r|  OM Mt will
IB 0«r MTHUMBt fil««.
         Thaak you far yoar coaparatioa
                                IIo Co HB4MMRy W • m •
                                Chltf, Faeilitloa Dorolopaoat toetioa
HCMsjl
eet j*»tor Quality Offica. I.  V. A.
     laaalaySetaUt* IM.
     Mr.  I. W. Barratt
     Mr.  J. M. VoMak
     Mr.  T. A. Caatrall

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RECEIVED
  FEB  3  1971
WATER QUALITY
   CONTROL
                       GEORGIA WATER QUALITY COHTROL BOARD
                            FOR GEORGIA WATER QUALITY COHTROL
                                47 Trinity AveniM, S.W.
                                     i, Georgia 30334
                     APPLICATIOH FOR A "CONSTRUCTION PE«,
                            FOR A WASTff DISPOSAL SYSTEM
   In accordance with provisions of the Georgia Water Quality
and the Rules of the State Water Quality Control Board,  applicatic n
below for a Construction Permit to construct the described Waste
                                                                    DO NOT WRITE IN THIS AREA
                                                      Disposal System.
                                                           	FFB  S
I Minor APPLICANT (CITY. TOWN, INDUSTRY. CORPORATION, INDIVIDUAL K
 Cobb county V at«r It Soworngo System
1 ADDRESS OF APPLICANT (STREET OR ROUTE NO )
 1771 County Farm Road
                                                      C.)
                                                       WATER QUALITY CONTROL BOARD
                                                         DIVISION FOR GEORGIA WATER I
! CTTT, STATE AND ZIP CODE
 iitrtotta,  Georgia  10060
                                                   cou
                                                       TY
                               	1	TlliillB V '  mrowm  *«  *••
                       .DISPOSAL SYSTEM Approximately 2. t ; miles  of 4o Uch diam. unitary
             >. cotnploto with manholoa, tnnnoU,  and ota«r accessories  to  provide
 itwtrage for tho >opo Crook Area of Cobb County.
tXAHEOP RECEIVING STREAM AND IT'S TRIBUTARY
                                          Supplomoatal  >h««t
                         PHYSICAL CHARACTERISTICS OF ESTABLISHMENT
 1 TTPI OF ESTABLISHMENT (IF NOT A POLITICAL SUBDIVISION)
IJTPEOr WASTE TO BE DISCHARGED (DOMESTIC, TEXTILE, CANNERY, ETC.)
DftaMtie (poioiblo commercial f. light Industrial)
». ESTIMATED BOD (LB8/DAY)
"•TREATED AFTER TREATMENT
9. VOLUME OF DISCHARGED WASTE
(50 yr.) ADF«3J. 25
11. MINIMUM RECEIVING STREAM FLOW
MOD
cf.
                          > EXPECTED EFrECT 0» Tftf RECEIVING STREAM .
                          r.  daily year 2020 fat itottoawooa junction)
 bnwstic 53. 20 MCD cum.  poak yoar 2020 (at  Eotteawood junction)
                               SUPPLEMENTAL INFORMATION
 NnciPLE FEATURES OF PRESENT AND/OR PROPOSED WASTE TREATMENT FACILITIES
                            uppl«mont«l
'UOCATION OF WASTE DISCHARGE
QtttMkooelMO Rlror
* APPLICANT'S PROFESSIONAL ENGINEER
HmUy-Sckmia*. toe.
IS. OPERATOR IN .CHARGE OF FACILITY
17. OFFICIAL TO BE CONTACTED IF ADDITIONAL DATA IS NEEDED
Honolcy- Schmidt, Inc.
"onm PERTINENT DATA Contract 1 1 UZ Al (* WUA f * PC- UA- 173) (first pbaco) of Sop* Crook
l«»»reoptor from Povor* For*; Rood to Rottonwood Crook iacludo* junction elumbor to
Kctiv* toworog o boing pumpod from Fulton County by C*mo Crook pumping station.
          PRPORATIPN.ORJ)THERJOFFICIALNAME)
                   I.OR.OTHER OFFICIAL NAME)
                   • sowomgo Syotom
                                                                    20 DATE
                                                                     February 2, 1971
                                          22. AUTHORIZED OFFICIAL'S TITLE
                (USE SUPPLEMENTAL SHEETS IF ADDITIONAL SPACE IS NEEDED)

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                       SUPPLEMENTAL SHEET
 4.  Chattahoochee River via Rottenwood Creek Interceptor and after
    treatment at proposed Chattahoochee Treatment Plant (Interim
    treatment to be provided by temporary package treatment plant
    until completion of permanent Chattahooehee Treatment Plant).


IS.  This phase includes Initial portion of Sope Creek Interceptor being
    constructed to receive sewerage from the "Game Creek" area
    across the Chattahoochee  River la Fulton County which will be
    pumped under the  river from the Came Creek pumping station now
    presently being designed.  Rottenwood Interceptor below Is presently
    under  construction and Sope Creek Contract f 102AI and the Came
    Creek Pump Station are committed to an August 1971 completion
    date under terms of an agreement between Cobb and Fulton Counties.

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RECEIVE
 FEB
         1971
WATER QUALITY
   CONTROL.
   GEORGIA WATER QUALITY CONTROL BOARD
DIVISIOH FOR CEORC/A WATER QUALITY CONTROL
           47 Trinity Avtnwt, S.W,
           Atfonfa, Georgia 30334

 APPLICATION FOR A "CONSTRUCTION PERMIT
       FOR A WASTE DISPOSAL
                                                               DO NOT WRITE IN THIS AREA
                                                               PERMIT NO
                                                               DATE ISSUED
    In accordance with provisions of the Georgia Water Qu ilit
 and the Rules of the State Water Quality Control Board, app
 below for a Construction Permit to construct the described \
                                                 APPROVED
                                              cal
                                             aste Disposalrfewl
                                      by made
                                                                              416),
                                                                             dentified
 1 RAM OF APPLICANT (CITY, TOWN, INDUSTRY. CORPORATION, INDIVID
  Cobb County V ater it Sewerage Syatem
                                                      QUALITY CONTROL BOARD
                                                  SION TOR GCOHCIA WATER QUAUIX BBMTHQt.
 I ADDRESS OF APPLICANT (STREET OR ROUTE NO.)
  1771 County Farm R oad
                                                By
 J. OTY. STATE AND ZIP CODE
  Marietta. Georgia  30060
                                                               Mason, P. K.
 s DESCRIPTION or PROPOSED WASTE DISPOSAL SYSTEM  Approximately 2.0 miles of 60 inch diam.  sanitary
  itwer pipeline, complete with manhole*,  tuaael*. and other acce.sorle. to provide
 mrtrage for the bope Creek Area of Cobb County.
I KANE Or RECEIVING STREAM AND IT'S TRIBUTARY
                                        SuppUm€ntal Sh«et
                         PHYSICAL CHARACTERISTICS OF ESTABLISHMENT
       ESTABLISHMENT Or NOT A POLITICAL SUBDIVISION)
 I TfPEOr WASTE TO BE DISCHARGED (DOMESTIC. TEXTILE, CANNERY, ETC.)
  D«ne»ttc (po»«ible commercial fc light induatrial)
                                                   9. VOLUME or DISCHARGED WASTE
                                                    <50 yr. ) ADF=33. ZS
                                                             MOD
  II.MTIIIATED BOD (LBS/DAY)
   UHTREATED
                                                    H MINIMUM RECEIVING STREAM rLOW
                       AFTER TREATMENT
                                                                                cf.
                          ^

  Domestic  53.20 MOD cum. peak year 2020 (at Rottenwood junction)
                              SUPPLEMENTAL INFORMATION
  U MHHCIPLE FEATURES OF PRESENT AND'OR PROPOSED WASTE TREATMENT FACILITIES

                       See Supplemental Sheet
  « LOCATION OF WASTE DISCHARGE
  Chrttahoochee River
  If. APPLICANT'S PROFESSIONAL ENGINEER
        - Schmidt, Inc.
                                          15 OPERATOR IN CHARGE OF FACILITY
                                         17 orFICIAL TO BE CONTACTED IF ADDITIONAL DATA IS NEEDED
                  «^                       Heneley-Schmidt, Inc.	
 >                  ontract IIU2AI (FWc  f WPC-GA-173Mfir.t +».} of Sop. Creek
 bterceptor from Power. Feiy Road to Rotteawood Creek include. Junction chamber to
 t*«i»e .ewerage beiag pumped from Fultoa County by Came Creek pumping .Ution.
   8KWED (CITY. CORPORATION OR OTHER OFFICIAL NAME)
   Cfibb Countv Water fc Sewerage System
                                                                20 DATE
                                                                   February 2, 1971
                                         \22. AUTHORIZED OFFICIAL'S TITLE
                                                County Engineer
                 [(USE SUPPLEMENTAL SHEETS IF ADDITIONAL SPACE IS NEEDED)
  IQl.l;

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                     SUPPLEMENTAL SHEET
 6.  Chattahoochee River via Rottenwood Creek Interceptor and after
    treatment at proposed Chattahoochee Treatment Plant (Interim
    treatment to be provided by temporary package treatment plant
    until completion of permanent Chattahoochee Treatment Plant).
13.  This phase includes initial portion of Sope Creek Interceptor being
    constructed to receive sewerage from the "Game Creek" area
    across the Chattahoochee River in Fulton County which will be
    pumped under the river from the Came Creek pumping station now
    presently being designed. Rottenwood Interceptor below is presently
    under construction and Sope Creek Contract #102AI and the Game
    Creek Pump Station are  committed to an August 1971 completion
    date under terms of an agreement between Cobb and Fulton Counties.
                            "APPROVED
                             STATE  OF  GEORGIA
                                    FEB 8  1971
                            WATER QUALITY CONTROL BOARD
                             WVlSi W* KOWIA WATER QUUTY COHTIWL
                             By

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• [JNEST W. BARRETT, CHAIRMAN • ROBERT J. AUSTIN, DEPUTY • THOMAS H. BROWN • T. L. DICKSON • ERNEST P. ELLISON • OEOKSE W. LANKFORD
                                     February 23, 1971
         Mr. Asa G.  Foster,  Jr.
         Water Quality  Office
         1421 Peachtree Street  N.E.
         Atlanta,  Georgia    30309
                                     RE:   WPC-GA-173
                                          Cobb County, Georgia
          Dear Mr.  Foster:
          I am  returning  to  you the signed Enviromental Assessment Statement
          for the  above referenced project.

          I would  like to call  to your attention that the portion of this
          project  along the  Chattahoochee River from Rottenwood Creek to
          Powers Ferry Road  is  planned for advertisement on or before April
          2, 1971.   This  is  necessary to meet the requirements placed on us
          by our agreement with Fulton County.
                                     Since
                                     ERNEST W. BARRETT, Chairman
                                     Cobb County Board of Commissioners
          EWBrjg

          cc:   Robert L.  Sutton, Jr.
               County Engineer
          Enclosure

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                                           JSV5-
       ENVIRONMENTAL ASSESSMENT - PL 660 WASTEWATER TREATMENT PROJECTS



Applicant:   Cobb County Water and Sewerage System    project NO: WPC-GA-173

Address:  P.O.  Box 649                           County: Cobb

Location of  Project:     Cobb County, Georgia

Brief Description:  A System of Sewer lines and Treatment Plants that
                 will begin sewering the county.  Primary service will
                 be to areas tributary'to the Chattahoochee River and
                 Lake Allatoona.

I.   Probable  impact  of the project on environment:


               See Attached Sheet
II.  Any probable adverse environmental effects which cannot be avoided:
              See Attached  bheet
III.  Alternatives considered' with evaluation of each:
              See Attached Sheet

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                    ENVIRONMENTAL ASSESSMENT - PL 660 WASTEWATER
                                               TREATMENT PROJECTS
 I.  The project at its completion will reverse the present pollution level
    of the creeks and streams in Cobb County that are not only tributary to
    the Chattahoochee River, but are also tributary to Lake Allatoona.  At
    present these streams are polluted to the point that it is unsafe for
    anyone to be around or in them.  This pollution is coming mainly from
    septic tanks not functioning properly and existing treatment plants not
    being able to handle demands placed on them.


II.  The only adverse effect that can be determined is damage to the terrain
    that will occur during construction.


III.  Alternate methods and locations were  investigated in an effort to
    reduce the damage to the terrain.  After careful  consideration it was
    determined by this office that the elimination of the polluted water
    in the streams was the greatest environmental problem and must be met.
    Cobb County and Fulton County combined in a  joint effort to eliminate
    the water pollution along the Chattahoochee  River in order to reduce
    the damage done to the terrain.


 IV.  The program is not a short  term project  in  that  all  of  the work being
    accomplished has a life beyond the year  2020.   If the work is not
    accomplished the Chattahoochee River  will not have  any  fish or marine
    life in  it and the life in  and around the streams will  be damaged or
    destroyed as a result of the pollution.

 ¥.  The two  items that will be  removed  and cannot be  restored exactly
    as they  exist are the trees and some  of  the rapids  in  the streams.


 VI.  General  discussion arose in regards  to the  Water Pollution,  Ecological
    Systems,  Natural  Beauty and Archelogical  aspects  of the areas.
        After numerous meetings with  the  general public and representatives
    of various groups, it was  determined  by  the majority of these  groups
    and individuals  that Cobb  County  should  precede on  the  following  course
    of action and in  the order listed:

        1    Install  and  complete the  construction of the sewer  lines  to
             combat and overcome the  Water Pollution Problem existing
             in our environment.                                   .
        2.   Contract  with .an Archelogical group to  advise and aid  in  the
             relocation of  the  archelogical  finds on the line to  protect these

        3.   Preserve  the Ecoiogical  Systems  and Natural Beauty where  possible
             and  to restore  to  its  original  state if possible.

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                                   -2-
IV.   Relationship between local short-term uses of environment and
      maintenance and enhancement of long-term productivity:
                   bee Attacnea Sheet
V.    Any irreversible and irretrievable commitment of resources:
                   See Attached  Sheet
VI.   Public objections to project, if any, and their resolution:
                  See Attached Sheet
              (Use additional sheet(s) if needed.)
Applicant's Representative
                                                                       fZL
                                             Title
                                                                Date
                 (State Agency comments to be attached.)

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    . BARRETT
 COIIIIISSIONER

K08ERT J. AUSTIN
 PEP. COMMISSIONER

LOUIS WATTS
 KMUOER

tBW S. McNEELY
    MANAGER
                                         32 DISTRICT
                                      HARRY INGRAM
                                       T. L. OICKSON

                                         S3 DISTRICT
                                    THOMAS H. BROWN
                                    A. L.  AL BURRUS
           COBB  COUNTY  WATER  SYSTEM
           115 SOUTH COBB DR.
P. 0 BOX 529
                                                    MARIETTA, GA. 30060
                                                     March 11, 1971
     Mr. Asa B. Foster, Jr., P.E.
     Regional Construction Grants
     Program Director
     Federal Water Quality Administration
     Suite 300,  1421 Peachtree Street, N.E.
     Atlanta, Georgia 30309

                                   Re: WPC-GA-173
                                       Sope Creek Interceptor Sewer
                                       Cobb County, Georgia

     Dear Mr.  Foster:

     Pursuant to the request of Mr. Fred Eidsness at a meeting in this office
     Monday,  March 8,  1971,  we have arrived at the following cost estimates
     for alternate solutions for this interceptor sewer between the mouth of
     Rottenwood Creek and Powers Ferry Road.

         1.  Planned sewer as approved by Georgia Water Quality Control
             Board                                           $1,028,000

         2.  Tunnel between Rottenwood Creek and River Bend
             Apartments, plus 2, 000 +_ L. F.  of open cut 60"
             sewer to Powers Ferry Road                     $2, 070, 000

         3.  Lift Station at Powers Ferry Road, with Force
             Main along Akers Mill Road to Rottenwood Creek,
             and a 48" Parallel Sewer  to the  Rottenwood
             Interceptor down Rottenwood Creek to the
             Chattahoochee River                             $1, 650, 000

     The last alternate would also involve perpetual operation  and maintenance
     C08ts.  This cost is estimated to be $150. 00 per day for the necessary
     continuous 24 hour  operation.  Another factor would be additional damage
     to the Rottenwood Gorge between the Chattahoochee River and Akers Mill
     Road.

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Mr. Asa B. Foster, Jr.           -2-              March 11, 1971


The amortization of the difference in cost between Scheme 2 and Scheme 1
and the amortization of additional cost of Scheme 3, plus operation and
maintenance compared to Scheme 1, are about equal.   Based on the initial
number of users to be served by this facility, the necessary increase in
sewer charges to these customers to finance this additional cost is estimated
to be $3.40 per month on an average billing.
                                    Robert L. Sutton, Jr.
                                    County Engineer
RLS, Jr. /jt
cc: Hensley-Schmidt, Inc.

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           United States Department of the Interior

                        OFFICE OF THE SECRETARY
                         WASHINGTON, D.C.  20240
                                            MAR1 6 1971
Dear Mr. Ruckelshaus:

On September 14, 1970, the Bureau of Outdoor Recreation was instructed
to study the Chattahoochee River in Metropolitan Atlanta as the site of
a possible major urban recreation area.  The heart of this area is a
primitive, virtually untouched stretch of unique scenic river bordered
by granite outcroppings.

The natural beauty of a total of 20 of the 48 miles  in the river study
area is threatened as a result of planned sewerline  construction closely
paralleling the riverbanks.

Applications for Federal assistance have been made by the local governments
for all of these projects to the Water Quality Office.  Current projects
include the Rottenwood Creek and Sope Creek interceptor sewer projects,
Cobb County, Georgia, and the Game Creek, River Ridge, and Roberts Drive
interceptor sewer projects of Fulton County, Georgia.  Construction has
been underway for several months on portions of the  Rottenwood Creek and
Roberts Drive lines.  Both include several miles of  high value scenic
riverbank.  Such construction appears to require the preparation and
review of an environmental impact statement consistent with the requirements
of Section 102(2)
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While our main concern is the  potentially adverse effects of sewerline
construction on the scenic and recreation values, potentially enhancing
features of this project—such as  use of sewerline right-of-way easements
for public hiking or bicycling paths and access to the river—should be
considered in the preparation  of the environmental statement.  The Bureau
of Outdoor Recreation's Southeast  Regional Office can furnish assistance
in the preparation and planning of appropriate features.

While we fully understand and  support your efforts to protect the water
quality of the Chattahooch.ee River, sewerline construction must be subject
to the same requirements for environmental protection as any other federally
supported development.  Therefore, we urge immediate completion of environ-
nental statements on all segments  of the sewerlines along the Chattahoochee
River from Buford Dam to Peachtree Creek which are being constructed with
Federal funds or'assistance.   Further, it would appear appropriate to place
a hold on present construction activity pending review and approval of
environmental impact statements.   This action is necessary if we are to
avoid irreversible damage.

                                   Sincerely yours,
                             ^   Secretary of the Interior
Honorable William D. Ruckelshaus
Administrator, Environmental Protection Agency
1626 K Street, N. W.
Washington, D.C. 20460

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    A. R.-SHIRLEY
       DIRECTOR
    Georgia  Forestry  Commission
         7 HUNTER ST., S. W. ROOM 645 - ATLANTA. GEORGIA 30334
                            April  20, 1971
HUGH M. DIXON
  Chairman, Vldolla
W. GEORGE BEASLEY
  Ltvonla
M.-£. GARR4SON
  Honor
LUKE H. MORGAN
  Eastmon
ALEXANDER SESSOMS
  Coptell
Mr. Fred A. Eidsness,  Jr.
Sanitary Engineer
Suite 300
1421 Peachtree Street, N.  E.
Atlanta, Georgia  30309

Dear Mr. Eidsness:

This is in reference to your  letter of April 16, 1971  concerning extent of damage
trees can endure in sewer  line construction projects.  (John Miaon is assigned to
a special study for the next  few months.)  Therefore,  I am answering your letter.

Enclosed is a copy of your letter to which I will refer to in answering your
questions.

Question No. 1 and No.  2 - It is best to stay at least ten-fifteen feet from the
base of a tree when putting in a sewer trench.   If a trench is any closer than
this the chances are that  not only large roots will be torn away or severely
damaged but hair roots will suffer too.   Hair roots are responsible for bringing
minerals and water into the tree 's system for its survival.  Large roots go
out in radial directions to help support the tree.   Therefore, a number of large
roots cut away could cause a  tree to fall over in a windstorm.

Question No. 3 - Fill  dirt applied around the base of  a tree can be quite dQt&vsnen&sl,,,
A certain amount of oxygen must get to the root system in order for a tree to survive.
When an abnormal layer of  earth is applied to the base of a tree then complications
will arise.   Sometimes in  a period of six months a tree will die due to fill earth
or it might take as long as three to four years.   The  signs  of a tree dying from
fill earth are:

          1.  The foliage  size will become dwarf in comparison to healthy
          foliage.
          2.  The foliage  will become sparse and will  tend to have a yellowish
          cast during  the  spring and summer months.
          3.  A general dying condition  beginning at the top and going down
          the trunk.   Compaction can occur and cut off water and oxygen to the
          root system.   Of course, when  a tree  is weak,  susceptibility to insect
          or disease rises  greatly.

Only a few inches of fill earth is needed to cause  species such as bellow Poplar and
American Beech trees to  die.

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Aft*.  Fred A. Eidsness, Jr.
April 20, 1971
Question 4 - Six Flags Over Georgia Corp.  have  trees about six inches in diameter
relocated.  However, this is a  large  task  and takes special equipment.   (Diameter
is measured at a point 4 1/2 feet from  the ground) .

Fill dirt cannot remain at the  base of  a tree for several months and then be dug
awry.  The reason is that the tree Dill have suffered from being in a state of
shock.

Cut roots exposed in sewer trenches are excellent port of entries for a decay
pathogen.  In a period of years a tree  could die due to the injury to the root
system.

Aft*. EidsnesSj if you need more information  on the subject covered above, please
contact me.

                                      Sincerely,
                                       Wilson E.  Wright
                                       Metro Forester
                                       Metro Atlanta Area
WHW:sf
Fncl.

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                                                          ~~\ n
                           APR 30 1971
Honorable Rogers C. B. Norton
Secretary of the Interior
Washington, D. C.  20240

Dear Bog<

     Thank yon for your letter of March 16,  1971,  inquiring
into the status of the Chattabooehee River Sewage  Project
in Cobb County, Oeorgia. and your request to sew a draft
            l Xispaet Statement on that  progri
     In the course of developing • draft iopact  «tatea*mt
on this project, our regional office na» been in close
contact with your Bureau of Outdoor  Becreation,  which has
been «o»t concerned about  the project  design. We share
your concern for preserving natural  surroundings ac«5  th#
Envii-unaantal •xotection ftfemry is,  wherever possible,
cosnUtted to protecting the country's  wilderness ar*ac.
It is uy understanding that aytessjsnt  bus been reached  to
preserve the palisades along th* Cobb  County side of  the
river so that they nwy sovsday  be ruelaiaed for  a %rildern«ss
     This is reflected in the draft which X am enclosing
for fonaal review by you  and your office.  I hope you wi
give the natter expedited attention.
         urgency of proceeding with this project can hardly
be overemphasized  in view of  the poor water quality con-
ditions in the Chattahoochee  River.  A  federal-state
enforoesMBt conference requires  both Cobb and Fulton
Countie* to have cssMrtl •!  facilities in operation by
December, 1972, and this  important project is a key eleasnt
in swetiag this deadline.  Further urgency arises by virtu*

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Honorable Rogers e* B, Morton
of th* fact that citizens of the am* oa* the ri
and sport, and recant stadia* show that the
taaination is too high  for ht»an contact ajporta by • factor
of three to six.  while this rirer is glMsjIftoi for fefljlU
vater suppli*», Vrhicb peraits a nlgHssr  bnetaarial lave;!
this is exce-«d*d a  stibstaixtial portion  of tte tivs «t tbt
raw vater intakes of the city of Atlanta sad BeTalto Oovnt;
Hater-work* officials are on  constant alext to fara%sjet tlui
safety of over a Billion people*
     X trust you viil  give tkia »att*r yew* ynapfc attaation,
and o«r regional office appreciates yowr offac ta aia«t again
vith the Bur«ftu of Outdoor K»cr«»cioa f f UMT* ara- any
further o&re«olv«d questions iirrolving tlM pcojact.  It is
«y ui«5«r standing tlxat  the Regional Director of tha ««r«au
of Outdoor recreation  has s«nt our regional offioa a latter
concurring in  the  basic design of the peo}*et aa now proposed
la the attached *t&t«o«nt*

     Your interest, is  greatly appreciated*

                                 Sincerely
                                 Willi
 •aaloearft
oci Mr. Carroll
    Mr.
         (2)
    noo       ,
    Region IV /

CFabrikaat/ro

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                                                 June  25,  1971

Htnsley-Schmidt,  Inc.
Interstate  North
Marietta, Georgia

Gwtlemen:

    Herein *e are submitting an interim report on  the  •rcheoiogieai
salvage  at  the Standing i-eachtree site, 9-Co-l.  He realise that  you
ar« interested in the  appraisal of tne archeological and  scientific
values that will  be permanently destroyed in the construction  of  th*
Jtottenwood  Creek  *-lant on this particular acrage.

    On  the basis of eleven weeko of survey, operating  under our
contractual agreement, we have accomplished the following results:


    In  one contiguous and related prehistoric village  unit, cor.prisiiig
oter ten acres,  we have exposed five recognizable house patterns
btlonging to the  village.  *e have recovered a good sampling of pottery
and other artifactual  materials, adequate to diag»oae the fairly  precise
archeological determination of the time and cultural affinities of
these particular  villagers.

    All of the  structures uncovered thus far and all of  the exposed
t«8t areas  indicate extensive truncation of the site throughout the
latter part of the nineteenth century, extending forty  years into the
present  century.   The  t furcated zone of plowed and  disturbed eoil is
between  b1 to 18  inches deep.  We find only the basal reanants  of
»«rtical post supports of the cabins, and occasionally  partially  fused
Ud charcoal blackenea hearth areas.

    No  in-place  exhibit  requiring possible preservative  treatment  in
the ground  seeits  possible.  The field collections and data  will provide
»d«quate illustrative  u.ateria] for any local museum exhibit which might
b» planned  in the future.

    We  consicer  that  this portion of the project carried to conclusion
•ill suffice to  clear  the area of ten acres, where  the  disposal unit»
•ill be  conetructed, for building operations without destroying any
pertinent data.

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   To the North  and  taet  is the larger industrial tract,  covering
an additional  80 acres,  which will need to be tested and appraised
by the same procedure  we have employed in the present instance.   In
as much as construction  will come later in this section, presumably
arrangements can be  tade for clearance there in line with the tine
latitudes of the completed  archeological salvage.

   We are enclosing  a  map of the relative location of the excavated
areas, the archeological structures and features, in relation to  the
surveyed but unexcavated portions of the tract.

   Beyond the present  critical area of ten acres, to the  immediate
South, contiguous  with the  right-of-way of the Seaboard Railway,  the
survey has uncovered evidence of a fairly extensive village belonging
to an earlier  period of  prehistoric occupation.  There is only a
slight horizontal  fringing  overlap where this earlier village impacts
OB the ten acre strip.  The major archeological village unit is
traversed by the Seaboard right-of-way which has incorporated and
staled in a mound  and  deep  midden, estimated in places to be four
feet thick.

   The whole village unit of this earlier site is identified with
an early development of  the same culture which later gave rise to the
nationally known site  of the Etowah Mounds near Cartersville, Ga.
lot significant point  so far as you are concerned, is that  this
important archeological  villg* lies outside the are* of the
Bottenwood Plant.

   The projected Plant might intersect a portion of this  early
Etonh village.  Actual  determination can be Bade only on the basis
of finalizing  present  plant construction plans to insure this
particular section of  the site will not be involved In the  Rottenwood
Plant operation.
                                                     l
                                                      Kelly/,
                                                 Project Direc
Dictated  in the  field.
9-Co-l Site
Junt 25,  1971

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            ROADS AND REVENUES
I'.'.TW. PAntlETT, CHAIRMAN Q ROBERT J. AUSTIN. DEPUTY 0 THOMAS H. 8ROWN • T. L. DICKSON 9 ERNEST P. ELLISON © GEORGE W. UANKFOHD
                                                  June 28,  1971
    Mr. Asa G. Foster, Jr., P.E.
    Regional Construction Grants Program  Director
    Environmental Protection Agency
    Water Quality Office
    Suite 300
    1421 Peachtree Street, N.E.
    Atlanta, Georgia
                                     RE:  Cobb County Sewerage  Program
                                          Project No. WPC-Ga-173
    Dear Sir:
         In response to your question regarding the relation of  the Cobb  County
    Sewerage Program to Kennesaw Mountain Park and the proposed  Blue Ridge
    Parkway, we are pleased to furnish the following information:

         Kennesaw Mountain Park - The park has inside its boundries certain
    areas of private land that is being developed and in one drainage basin the
    City of Marietta has a sewage treatment plant.  These are to be served under
    the Cobb County Sewerage Program, but will not be served under the Unit A
    of the program.

         Blue Ridge Parkway- Since the location hearing on the Blue Ridge Parkway
    has just been held, the final location is not exact but from our understanding
    of its proposed location near Acworth, Georgia.  This location will put such
    a small  portion in Cobb County that it will not be affected by Unit A of the
    Cobb County Sewerage Program.

         If there are any further questions,  please contact me.


                                                   jrs,
                                       ROBERT L. SuTMW, JR. s P.E.
                                       County Engineer
    RLS/hs

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                       sr
       -••;. Oi~ ROADS AND REVENUES
ErWES'f W. BARRETT, CHAIRMAN • ROBERT J. AUSTIN, DEPUTY • THOMAS H. BROWN • T. L. DfCKSON • ERNEST P. ELLJSON • GEORGE W, LANKFORD
                                                 June  28,  1971
     Mr. Asa B. Foster, Jr. , P.E.
     Regional Construction Grants Program Director
     Environmental Protection Agency
     Water Quality Office
     Suite 300
     1421 Peachtree Street,  N.E.
     Atlanta, Georgia
                                         RE:  Cobb County Sewerage  Program
                                              Project No. WPC-GA-173
     Dear Mr. Foster:
           I am attaching two letters from our consulting Engineers, Hensley-
     Schmidt, Inc., which indicate the study and review that went  into our
     decision to locate our Chattahoochee Treatment Plant, plus the report
     from  the Corps of Engineers regarding the flood plain of the  Chattahoochee
     River at our existing South Cobb Treatment Plant and our Chattahoochee
     River Treatment Plant Site.

           The site for the Chattahoochee River Treatment Plant as  selected is
     the most desirable site.  In addition to the reasons furnished by our
     Consulting Engineer, it was also selected and sized to be able to support
     tertiary treatment in the future plus having a potential of relieving
     part  of the future needs of the City of Atlanta.

           If you have any further questions, please contact us.


                                        Sincerely yours,
                                        ROBERT L. SUTON, JR., P.E.
                                        County Engineer
    RLS/hs

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                        HENSLEY-SCHMIDT, INC.
                          CONSULTING ENGINEERS    4562
                               June 25,  1971
Mr.  Robert  I,. Sutton,  Jr. ,  County Engineer
(!iil>li (!oimly  I'll i)'i in • i • r i i ii1  I )e p.ir I n lent
IJ. (). I',ox  (>•]'!
Marietta,  Georgia  '.iUOoO
                                       Re:  Chattahoochee Rivor Sewage
                                            Trealment Plan!
                                            Selection  of Site
Dear Mr.  Sutton:
As requested we art' summarising below factors involved in the  selectim
of the ]) ropi >s ed  Chat ( ahoor lice  llivev Se\vai;c Trealment  Plan', site.   Our
allach'-d m,"i[) slin\vs (lie  localion  of various siles \\lri< li \\-ere  studied. Sit
No. /. i:. I he i i K .ili'in lin.illy :;clc-< led.

The various sites are discussed  below:

Site No.  1

This site was determined to be undesirable  due to the following:

    A.   It is located upstream of the City of Atlanta  Raw Water Intake
         and would have  resulted in \:ndue haxarcl.

    T).   Since the .site \v.is located hi i;h  up river in the drainage area,
         e •-; I e 11:; i v e  p 11111 p i 11 < • r»I (lie t 11 \v< • r  po:; i t i (>n i > I file d r. t in "i ; M i . i r i •. i
         v. i >i 11 d  lie i n v i > i v < 11 .

    C.   Cxiylinu. and  proposc'd land use;  indicated il would  be  very
         close to residential development, which  is undesirable.

Site No.  2

Site No.  2 was  selected  for the following reasons:

    A.   The- site is opposite  the  Atlanta Raw Water Intake with plant
         cffHient piping  discharging below the Raw Water Intake.
  . TOUNDA ' .'^JS. '

-------
Mr.  Robert  I,. Siitlon.  Jr.
    R.   The silo is  located on properly /.oned for industrial develop-
         ment.  There is a major existing sewage treatment plant
         nearby, and proposed adjacent development is anticipated
         to be of an industrial nature.   No problems from residential
         development arc- anticipated at this  site.

    C.   Being undeveloped,  and at the fringe of existing industrial
         development, the land costs are more  favorable than at
         most other  sites.

    I'.   Tin- sile is  .1 < •( e p| ,i I >1 e I rom Ihe standpoint of  location within
         ils d rail i.i re aie.i lo 11 11 n i i o i/. e (be pimuMii!1. up river of Ihe
         lower portions  o| | be drainage area.  1.1 is less ideal (ban
         Sites 3, -I and  .^,  but better than Site- 1.

    I7!.   The site  wa .s user]  lor agriculture unli.l several deeados ai;o.-
         Trees, topographic  and other natural leatures are  not of
         outstanding  or unusual  significance.  Archeological iTivesli-
         g a: ions are  being conducted to extract  data prior to any con-
         struction, and at. this time no ar choological discoveries have
         been  made winch would merit in-placo exhibits.
Sit.- N...  '.

Til is \\.IS 1 In- Slli-  ' i r I ]'.1 n.i ! I V seleeled lor lite Si-VvMJ'.e  I re . I I I 1 11 • 111  pl.llll .Ii ill.-
time of the preliminary report in ll.>67.  In tin- period  between  l')i,7 ami
1969 the property chan;2,<-d in ownership and the new  owner  constructed
buildings rind did extensive grading work as part of an  overall development
plan.   The  reduced  acreage available and t be increased cost for  pa r! i ;i I Iv
developed  land made this  original site  no longer feasible.

Site No.  4

This site \va s  eon si de red  undesirable for two reasons:

    A.   I ' i'r • I 11111 ii.i r •./ in-r • i| i .1 I i c HI .--.  mdi< .iled lli.- prii e per  ii re \vniild  be
         . i 111 > r ii'-. i ii i.i I < I -.- I r i | > I' • I I i.i I  ' 11 :. 11 r r 0111 id i 11 :• . i i • r e.i j1e din- I o i I .•:
         s I rat e ;; i e I oe.: I i . MI  , i d |.i 11 y ' s
         Plant Atkinson.  An industrial use  related to  the Plant
         Atkinson operation is proposed  in  the  future.

    R.   The rugged terrain would  have, resulted in very heavy earthwork
         c ost s.

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Mr. 'Robert L.  Sutton,  Jr.          3                       June"25,  197!


gtc No.  5

This and other  sites below Plant Atkinson were eliminated due to the
following reasons:

   A.   The <-xl cnsivr development  of Plant  Atkinson a lorn1,  the bank
        ol lln-  ( )hat 1 ali< M >e I ie e Kiver  makes installation ol a  r.ravily
        sewer  at I he cilice i>l  llic  river  .ilmosl  an i mpossibi lii y.

   B.   Existing and proposed  residential development would have
        been very close  1o any site  below Plant Atkinson.

Site No.  2 was  selected afler  careful study of relation to  environment,
functional and operational considerations and economy of construction.
We feel the proper site was selected.

Please contact  us i!"  additional data is needed.

                                              Very I r ul v von r s ,

                                              I IKNSLl-IY-SCllMlDT, INC.
                                            ,/Joe F.. Bork, Jr.,  P. E.
 JFBmnw
 Attachments
 <^c:  Ildnorable F.rnest Vv".  T'.arrflt

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                       HENSLEY-SCHMIDT. INC
                        CONSULTING ENGINEERS
                            Juno 2.5,  1971
                                                                     f
                                                                     HAMHV II W«* Ik*
                                                                     l*tr»*« Rfw,* to

                                                                          "5 so
                                                                2<»0 IWT«l#f AT*
                                                                   4050 - 456Z
Mr.  Robert L. Sutton,  Jr.,  County Engineer
Cobb County Engineering Department
P. O. Box 649
Marietta,  Georgia  30060

                                 Rr: Cobb County Sewerage Program
                                     duitlahoot:h«:e Sewage Treatment Plant
                                     South Cobb Treatment Plant

Dear Mr.  Siitton:

As requested, we are attaching copies of correspondence with the Corps   of.
Engineers regarding construction of the Chattahoochee and South Cobb Treat-
ment Plants within the flood plain of the Chattahoochee River.

Prior to this correspondence we contacted the Corps of Engineers to establish
their SO year  flood elevation.  All building ground floor elevations and tops
of aeration tanks, aerobic digestors, chlorine contact tanks,  etc.  are set
above I  In-  f>0 year flood.

At the Chattahoochee Treatment Plant site a severe flood would surround
certain of the tankage, requiring a boat for operation.  The operating features
of the plant  would not be affected by the flood.  This is considered preferable
to extensive diking which would interfere with flood flows.

Oar  attached letter of May 27,  1971 to Mr. Trafton-W. Fleetwood of the Corps
of Engineers, summari'/,es the points discussed with him in a. meeting of May 20,
1971.   A reply of June 14,  1971  from Colonel R. P. Tabb of the Corps of
Engineers is also attached.
f- ''-; OKI- u iul«; i-<; | ;mf|i ii)' I haf. l.lu- (Jorps ol Knj;i n«'«> rs has m> nbjor.l.inns lo ln«*
I ri>al it ii-n |  (ilanl. const rtid inn  ;il lln- ('.\\:\\ lah«>o<:h«-i-  Iviver or South Cobb  Tnraf-
itient I'lanl. sites.
   . FOUNDATIONS. >< Y OR OF L EC TRIC. INOUSTI1IA- WASTE. Brr RCA1ION. S EWERAGC. STREETS. STRUCTURES, TRAFFIC. TRANSPORTATION. 1
                                                                    . TUMNC15, WATER WORKS

                          I HAriAllfin.iA II I

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,Mr. UobcH  !,.  Sul.l.ein,  ,1 r.           .  -2-                 Juno  25,  l')7t


 Please contact  tis if ahy additional data is needed.

                                        Very trxily yours,

                                        HENSLEY-SCHMIDT, INC.
                                      I/ Joe F.  Bork,  Jr., P.  E.
 JFM. Jr. /.it
 A 1 1 .")( li I ) !<• ill •:
 Cf.:  I lono r;vl >'»•  l-ji-iu-sl  W.  Knrnrtt

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                                                  11 KN^Ti J^' -SCHMIDT,   INC.
                                                       '  »    ./V
                                                         uTiuKii'uy»
                                                         _, U	-
                                                      Hoy f-/i-.ir.ri-.  I*.  '•'-.

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                        DEPARTMENT OF THE ARMY
                 South Atlantic Division, Corps of Enginairs
                  510 Title Buildini. 30 Pryor Strwt. S.l.^
                         Atlanta, Giorgn  30303
SADYF                                                 1* June 1971
Mr. J.  Roy Fraser
Hensley-Schmidt, Inc.
Suite  220
290 Interstate North Parkway
Atlanta,  Georgia  30339
Dear Mr.  Fraaer:

Your  letter of 27 May to Mr. Fleetwood of ay staff satisfactorily
sutoraarizes the discussions of the 20 May meeting concerning the
Chnttahoochee and South Cobb waste treatment plants.

It  should be noted that the Corps of Engineers does not establish
the degree of flood protection for sewage treatment facilities; this
is  a  responsibility of EPA.  As stated in your letter, there are two
major  problems in developing flood plain areas:  (1)  direct flood
damage Co the proposed structures; and (2) the constriction of flood*
way channel by the proposed development which causes  higher flood
stages upstream.   The net effect of the flood plain development on
streamflow conditions can be evaluated; however, such an evaluation
requires an extensive bydrologic investigation including detailed
topographic surveys of the before and after-construction condition!
of  the flood plain.  Ultimately, the final decision on the location
of  a  sewage treatment plant must be baaed on an evaluation of both
the environmental factors and economic considerations.

From  the review of the preliminary site plena for the two sewage
treatment plants, it was observed that there would be minimal adverse
effects of flood stages and that the facilities would be inundated
only  under extreme flood conditions.  Accordingly, it was concluded
that  from the standpoint of flood plain management, the Corps would
not object to the proposed construction of two sewage treatment plants
for Cobb County as shown on the site plans.  The Corps will be glad to
review Lhc final construction plans if Cobb County, or EPA, doaires
detailed comments concernlnH the construction ot subject facilities In
S'he I loud plain.

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SADYF


As  indicated in your letter, discharges from municipal sewage treat-
ment plants are exempted at present from the permit  authority of the
Corps  under the 1899 River and Harbor Act, however the policies
concerning the protection of the environment are under review and
could  br changed in the  future.  I am sure you ar« aware  that the  out-
fall s  nnd associated structures related to the plants will  require
pcrmitr, under Section  10 of the 1899 Act for those portions lying  below
oi-iH.il/irv My.li wnter in navigable wntcrs and their tributaries.
 I  trust the above comments  clarify the position of the Corps concerning
 flood plain development.   If we can be of further service,  you can
 conr.nct Mr. Fleetwood  of  ray staff.
                                    Sincerely,
                                     R. P. TABB
                                     Colonel, Corps of Engineers
                                     Deputy  Division Engineer

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    t; OUMTY
            «,N • ROBERT J AUSTIN. DEPUTY • THOMAS H. MOWN • T. L. DICKBON • ERNEST P. ELLISON • GEORGE W. LANKFORD
                                                  June 28, 1971
Mr.  Asa B. Foster, Jr.,  P.E.
Regional Construction Grants Program Director
Environmental Protection Agency
Water Quality Office
Suite 300
1421  Peachtree Street, N.E.
Atlanta, Georgia
                                   RE:  Cobb County Sewerage Program
                                        Project No. WPC-GA-173
Dear Sir:
      I am transmitting to you a copy of our archeological study being
conducted by the County along our various line location and at wastewater
treatment plants.

      Exploration and salvage are being conducted on the site of the
Chattahoochee Treatment Plant and the Rottenwood Creek Temporary Treatment
Plant Site, which are the same with the idea of having an in-place exhibit
at  this site.  At this time, we have not found anything worthy of constructing
this  exhibit.

      None of the digging to date have demonstrated or produced any finds  worthy
of  preserving as an in-place exhibit.

      Cobb County even though we have not had any success to date, intends to
continue these investigations ahead of the proposed construction in hopes
of  finding an in-place exhibit.

      I would like to assure that Cobb County is concerned with its history
and preserving it for the future.
                                        Sincerely yours,
                                        ROBERT L. SUTTON, JR., P.E.
                                        County Engineer
RLS/hs

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                                                                                 >HILtP A.LUTIH
                                                                                 CHAB4.CC Mi Li. CM

                                 HENS LEY-SCHMIDT, INC.                    ****».»*«»**,**
                                                                                 w. Htmmrrr MCCI
                                   CONSULTING ENGINEERS                      HA««»O.«UU.
                                                               4firO2"*5           TKO SCHULCft
                                                                                 nut.** j. SUTTON
                                                                                 WILUAM T. SWAIN
                                                                                 muicm C.TWMS
                                            24,  197 I                             HMMT H-WLKUMOM

                                                                                 PLEASt REPLY To
                                                                            MO lwra*TAT> NORTH PARKWAY
                                                                              ATLANTA, OBOiraiA SO33B
                                                                             TMPHQNCi (4O4) 43S-7IS*
        Mr. Robert  L.  Sutton, Jr., County Engineer
        Cobb County Engineering Departnent
        P.  0. Box 649
        Marietta, Georgia  30060
                                            Re:  Arcbeological Study
                                                 Chattaboocbee River Sewage Treatment Site
        Dear Mr. Sutton:
        Transmitted herewith are two (21 copies of a report by Mr. Larry Meier and
        others on "Appraisal Of The Archeologlcal Resources, Cobb and Fulton Counties,
        Georgia, and Other Related Areas Of The Chattaboocbee River Valley."

        Please note that  with specific reference to the Chattahoochee River Sewage
        Treatment Plant Site the report states that to date no archeologtcal features
        have been discovered which are suitable for in-place exhibit, and once the
        date has been extracted and analyzed, no further preservation Is feasible.
        With the archeologlcal work nownore than two-thirds complete it appears unlikely
        that there will be any conflict between archeological considerations and the
        proposed treatment plant construction.

        After completion  of your review, will you please transmit a copy of  this
        archeological report to the Environmental Protection Agency, with any consents
        you  may have.

                                            Very truly yours,

                                            HENSLEY-SCHNUDT, INC.
                                                F. Bork,  Jr., P. E.
        JFB/ps
        cc:  Honorable Ernest W.  Barrett
             Fulton County Pub) ic Works Department
             Mayes, Sudderth and  Etheredge,  Inc.
             Fulton County Planning Department
             Cobb County Planning Department
             Southeastern Archeological Research  Center,  national  Park Service
             Blythe Brothers Construction Company
?ORTs.Bs:BiE:s. FOUNDATIONS. HYDROELECTRIC. INDUSTRIAL WASTE,RECREATION,sn«iiASe,STi»ttTS. STRUCTURES,T«*rric,TRANSPORTATION,TUNNELS,WATER WORKS


-'-N~A. GEOWC.iA                       CHATTANOGC-VTENNrSSTE                       NEW GB'-EAN S, -OC . SI AN &

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               ARCHEOIOGICAL SURVEY OP COBB COtWW

                    c/o PEULIBKXX HQH SCHOOL SIIB
                                    ClrcU
                                 6Mt|la. 30059
                                 943 1310
                                                June 221 1971
I-iens le y- wJclv -.idt, Inc.
Interstate liorth
marietta, Georgia
Gentlemen:

      The enclosed report is herewith transmitted as per your
reqv.est by letter June 21st.

      r~ae "Appraisal of the Archeclogical He sources of Cobb
and  ^-Iton Counties, Georgia" is very preliminary due to the
fact that the amount of materials recovered dxzring the survey
r,7ill require nore tirae than anyone could anticipate.  The 183
sites hav? produced a nass of data and artifacts in such b'*.!lc
that it is not possible to make a valid interpretive report
in a brief period of tine.

      I believe that the reconmendations listed in the Appraisal
to be correct, within reason and xTitliin the resources of the
local governments, i?ederal agencies,  local civic organizations
and  general public of the greater Atlanta area.

      Please duplicate and transmit copies to the following:

          uhairman, Jobb County Board  of Cortaissioners
               \
          Cobb Counter Engineer

          llayes,  Suddeth and .-thcridge

           nviron nental ^Totection Agency

          Fulton County Planning Dept.

          Cobb County Planning Oept.

          southeastern Archeological Research Center,
          National Park Service, liacon, Georgia.
                                    Rcsoectfull

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       CITY OF ATLANTA • CLAYTON COUNTY . COSB COUNTY . DCKALB COUNTY . FULTON COUNTY . OWINNETT COUNTY

       ATLANTA REGION METROPOLITAN PLANNING COMMISSION

       900 Glenn Building •  Atlanta, Georgia 3O3O3 •  Telephone (4O4) 522-7577


Nelson Sev er mghaui. Chairman                        Harmon M. Bern, Secretary-Treasurer

Cecil  A  Alexander, Vice-Chairman                      Glenn E. Bennett, Executive Director


                             June 28,  1971
    Mr. Joe  Franzmathes
    Environmental Protection Agency
    1421 Peachtree Street,  N. E.
    Atlanta,  Georgia 30309

    Dear Mr.  Franzmathes:

    I refer  to  Ga. 173 Cobb County Sewer Construction Project.  We
    have reviewed this project over many months and have  also
    commented upon the environmental impact  statement.

    Our Commission approved the sewer project several months ago
    and revised our sewer plan to conform  at the same time.  It
    has been our view that the environmental statement did not
    call for an official A-95 review in the  same way we handle
    construction grant requests.  We cannot  approve or disapprove
    the statement; we can only discuss it.   Who is to say if the
    ecological  analysis is adequate?

    I consider  A-95 requirements have been met and hope all
    agencies concerned can get on with the job.  The project
    conforms to regional and local plans,  it is indeed a  good
    one, and the environmental study sufficiently satisfies
    requirements set forth in various regulations.
                                    Sincerely yours,
                                    Glenn E. Bennett
                                    Executive Director
    GEB r cp
    cct  State  Clearinghouse
         Mr.  Robert L. Button,  Cobb County Engineer

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                                               Date:   June  28,  1971
          Mr. Joe Franzmathes          I
          Environmental Protection Agency
          1421  Peachtree Street, N.  E.
          Atlanta,  Georgia 30309
        FROM:      Name:     Glenn E. Bennett

                   Title:     Executive Director

                   Regional Clearinghouse:   Atlanta  Region Metropolitan
                                           Planning Commission

        SUBJECT:       PROJECT NOTIFICATION AND REVIEW

                       Applicant:   Cobb County

                       Project:  Ga.  173 - Environmental Impact  Statement

                       State Clearinghouse Control Number:

                       Regional Clearinghouse Staff Contact:  Richard S. Courtney

        The Regional Clearinghouse has reviewed the Summary Notification  for the above
        project.

        As a result of the review it has been determined that the proposed project  is
        in accord with regional and local plans, programs and objectives  as of this
        date.  You should  now complete and file your formal application with the appro-
        priate Federal agency(s).  A copy of this form must be attached to your appli-
        cation.

        If you have any questions, please contact the clearinghouse staff member named
        above, who will be pleased to  assist you.

        Comment:   The Atlanta Region  Metropolitan Planning  Commission has
        approved  this project and has noted that an environmental study
         has been completed.  Fulton County and  the City of  Atlanta have
         also taken note of the statement.   We consider all  clearances
         to  have  been completed.  Appropriate State agencies have been
         involved from  the beginning.

  Copy to State Clearinghouse
 _Copy to   Mr. Robert  L. Button,  Cobb County Engineer	
              Fold
State of Georgia
BUREAU OF STATE PLANNING AND COMMUNITY AFFAIRS
Form RC-A95-4
     (May  70)
  SPB-70-4-70

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APPENDIX B

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                                                                               /
                ARCIIEOLOGICM, SDRVEV Of COBB COUNT*
                      c/O'-PEIUlLBBMfflt TIBH flPHPffti SHX
                            P«bbl*fcrook CircU
                          Habloton, Georgia. 30059
                               PhOM 94ft 1310
                 REQUEST FOR A SALVAGE ARCHBOLOQICAL PRDORAM
                       9-Co-l, STAHDIKG PEACHTREE VILLAGE

      The site of the proposed Cobb-Fulton Sewage Treatment Plant on the
 Chattahoochee River across frora Bolton is also an archeological site of
 great ethno-historical and pre-historical importance.  The village of
 Standing Peachtree, 9Co-l#, is well documented in Georgia and National
 Archives.1  The very name "Peachtree11, so much an integral part of Atlanta
 and the area's history, has its origin at this site.  Originally the village
 was located in both Cobb and Fulton Counties, however, progressive construc-
 tion of public facilities has completely destroyed the. Fulton site, 9-Fu-10.
      Standing Peachtree as an historic site has import beyond the local
 level, since the role it played in history  had national implications.
 Indeed, the Chattahoochee River at this point was established in the Treaty.
 of Paris as the western boundary of the newly formed United States.  The
 village, with its peculiar location onthe river, was chosen as the loca-
 tion for an experiment in military transportation in 1813.  A small boat-
 yard, guarded by a stockaded fort, was constructed to build flatboats to
 ship military stores one hundred and thirty miles south to. Fort Mitchell,
 * 9- Georgia, Co  -  Cobb  County,  1 - First Site Found in the County.
 *Wilbur Kurta, 19$0 in Early Georgia, "The Village of Standing Peachtree."
•Eugene Mitchell in  Atlanta Historical Quarterly, 1$28, "Standing Peachtree."
 Map, Johnathan Coffee, "Sketch Hap of the Cherokee Country," 1828.

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REQUEST FOR A SALVAGE ARCHRJLOOKH,
9-Co-l, Standing Peaehtrm
just  below modern-day Sblumbun, Ga.  Theee supplies were oM* by (ten.

Andrew Jackson in his campaigns against tht Creek and JWnrit Indians.
                                                       »
The commander of the Standing Paachtree outpost nis It. Cteorge R. Oilmer,

who later became governor of Georgia and was Instrumental in the removal

of the Cherokee Nation from this State*

      Beyond the purely historic value of the site^ there is ,the  scientific

date  to be considered in terms of ethnography and archeology. Sometime

af'-er 1755 and before 1782, the Cherokees invaded and occupied the  Cobb

County portion of the village, creating a confrontation between  members

of the latter Nation and the Creek Indians still living at 9-Pu-10,

across the river.  This we know from documentation; however,  preliminary
                                        •                                • -
tests carried out this summer gave evidence that the site had been  occupied

for at least five hundred years and perhaps even longer.  The transition

period between prelvistoric "Standing Peachtree" and the later historic

era is one which ethnographers and archeologista know very little in the

Southeaster]! United Slates.  The availability of a site which can be iden-

tified absolutely by documentation and then excavated stratigraphically

will  allow researchers to establish concrete chronologies which  are of

great importance in the interpretation of American prehistory.

      The validity of investigation at °-Co-l must be understood  in  terms

of availability of such sites over the country-side.  In recent  years cite

after site has been destroyed without investigation or recordation.  One

half  Or the present site has been totally destroyed without the  most

elementry investigation.  The datA both for history and ethnography has

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REQUEST FOR A SALVAGt-', ARCIIBOLDGICAL PROGRAM
9_Co-l, Standing Poadiiroe Village                             -3-



been lost  and is beyond recovery for study.  9-Co-i will yield not only

                                                        »
scientific material, thus preserving some element for study, but the


County government li.in expressed the desire to create a small museum, perhaps


over an in-place exli.ll.it such as a ceremonial structure or burial complex


and incorporate the whole into the design of the Treatment Plant.  The


greater metropolitan arc a of Atlanta haa no such installation at present


and a  museum of this type would fill a need In area education and cultural


preservation of heritage.  The Cobb County Board of Commissioners has


allocated  and spent $3fl£0.00 to identify and investigate the site.  This


preliminary investigation has yielded the evidence that thejsite has a


deep,  rich stratigraphy and that important data will be destroyed unless


a  salvage  program is Initiated.  It, is within the power of the governing

                            .                 .       '        •    •
Federal agency to grmit matching funds in such a salvage archeology program


and it is  hoped that iuieh aid will be granted in time to preserve this


important  and meaningful example of American heritage.

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AISAL 0? TH'i AilCKlOLOGI-CLU, H.J7

 ?ULTCS CGUSTIJS,  G^RGIA, AKD OKUJ.

AR..AZ OF TH^ ClilTT.'fflfiOGH.^ RIV^l
     Prepared  Jxma  1971
                Prepared by:
                 LavTrehce W. lleicr
                 Cobb County Survey

                 Hdvrard I. Dittaar
                        University
                  Glenn C. Hill.ians
                  University of Georgia

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        ._.arfs
 bri f f;la;icG c.c the  -itcrialc collected droring the past
   - —«s vrorl; show that by conservative estimate the area
     by the  3hattahoochce iliver froni Ixtford Dan to the line
     '-.xlton  ^oi-.nty has  been occupied by nian for at. least    •
                  XTrinr- sono periods-of prehistory the valley
f or- i c: i*  iuhabi tant s .
     Ar-c-.-oj-o^y :.s general.-y not considered to t>e a vital  part
of today's life.  It will riot .ceed the Earth's hungry nor  put an
end to  \var and strife.   But sorse of the lessons fron the Past
co1--"1- 1   '  vital to our  culture's survival in the future.  At the
; obb :-b- cl;  liigh  'chool  Cite (v-oo-100)* tnan occupied the  land
;'cr  .o-^e f-ooo  yor.rs.   7or 3'COO years of that tine, he drew his
;rv;::'^_  ';--" ;clctr:ic^ fro~i  th'i STV,rro-.mdins nalr.tral reGor-rces  trf.thout
di.£^u- ^ b: ; t:Lc balance of Kature to the point he was forced off
t-h- .-.• :--.  "-he -/hiti  ?.rai haa resided in the area for less  than
l':0 y,:.-.;:ro a',v;  already  the water and air-^N'polluted to the point
o:: b..-^a .I:o-j;  v.hc ecological cliain upon "c^-ch ^v.depends to  sustain
     rJA-.:.3 v'J  believe*/that - archeolbgical research does serve an
     ?t.i :'- "vrLCticn beyond fulfilling a ronantic interest  in relics
     i-     .-t.   I.;i*aor and ;;-artial surveys ..'ox sites in the two
     .:xvj.; have been .aade since the 1920's and arc iftiij^uartiiif^t^o^ti^-'
     r•;;„..'. in the following:

          MHistory of ?ulton Ccunty", by Goopar, 1932

          "Archaeological Purvey of Itorthern Georgia" by .vauchope, 1965

          "Survey of Herman Falls Dam","by de 3aillbu,;"19G2"

     The present lixxrvcy is an effort to record every site,  to
          " for a Maxinr.im ret?.im of interpretive data, to construct
                                picture
-nviroi-i:-ient  and hnnan  history.
1  .9 -  Georgiars designated nuraber in the National Xuseun;  Go - the
^-p.iv'ialc v-or  Cobb -Jormty;  100 - the sits nmber in chronololgtcal
0^;-i-I" Of 'i^-n  -'•? O^^.T70^-!T  "   "' "'
o^:  its discovery.

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      Vbe prc  cut vcrl: began in July, -2U?^» tfe«n J*ciar'"t3ttiSertool:
•:-o  r, -r--cy 50QO  acres of  the valltly for the Grs^t  3&$thCfe*tf Vfclanta
T--. ^- c ..rial "ark owners.  This £r«5rv«y resulted in  tno discovery
•;r..:v::  tbc area bctv~.-.n 1-20  and tJartpbellton'llond "rid^e had been
Vi-.T.••.'-!•/ settled .df.ring various p^ioiiii*^-- paJcM-stcas^v*-. Ctl*%-sittt was
c :-;;--: for r-:-:ca*-at5.~n ^jhich we fcit"tlbtxld j^ive a  r-Ja2dmia rct".rn
C.T  .' i :or-- :::r.ou  on the .Jarly V/oodlaz^i ^^^c^f^n&lf^i^^iiff^s»r very

x!-a3 i.va.'er'rahen  fro-. I960 to 1970 and yielded an entire village
witS  arcliitectiTral and cultural data never before recovered in the
               United States.
       ~w- ^i-l4 v;r.s ne^rin^ the end of  woric, a •t/o?-untcer liiglt school
c:.-:^-'; rc-ortc-1 that his  school groitnds contained atimilar materials
.-;:-:;  L-l-ii-;: a si::-fo^t dia'ietcr pip 2 "would croos the property shortly.
_. c.i".--r.:"'- project \r-\ci institT.ted vithiii the Cob'1* Jryunty ^chpol
./ 3;::   airl r.sin^; the: school site -as- a^Living JLabor-afeory" ,  a -M-c^rcn
in i  -- ry v:-.ive  tcachf-ng ronulte-l.  l^ie^ro ject also revealed that
a -r.;"cr -^rc^ran in pipeline contraction waa tmdcrwa-y in Jobb Jovjity.
Jir.~ •  -1^ -oipci.incs x;ere to follow every riajor drainage in the
c~--.-vj~,  It wan ria-liced that the daznage to other, xmreoorded sites
-..-c^.l   '>- cnprr-ions.  The Oo'^nissioncrs T/erc approached with a plan
tc ^r..ci'ie the lines, record -the sites  and test  those which ~ii':ht
'•••^ :.. v rtant to inters rotation .of- hmian. occupation in the.  ot^a.
..v.o   r- ?-—.l of Co:.r-.isr:ion.£r3 approved the plan r.r-cT ftmded the sv.rvey
:lr •:.:  c n-^'-vnt  of $2500. CO.  The area school students volrntccrc .".
;:";,".: •'_-•".. -.c aTi". the cn-'incers ar.--l -:~>ntraetors co-opc^afccd in c'-'er^'
•;•-.••  c'\~-r c^r.ld.  Tlia c'esijp. engineers* fxirn'i shed  -raps and fic!\c Ivies.
::-.i   : r..c • -on-.hs (Ji'ly, /-•".^iist and ^ept^.r-ibcr, 1970) H4 sites v.re
n.'.r// ":r.:; covered or chcclced for cxtrrent s-!:atn.TS.   i>' *:hr ni'Vlc cf
~ic->    ib^r, ':ac :;ccciid ficl.c.1 season of the school project i/ao rrn/.en/a;^
.^i .-v- :otc •" by the Oobb County Ik>ard of .ilncation.   In ^cto'^er the    ^
.Jn.r/.p.iT of C-r.-'.t-'oor Recreation inititated the Cixattahoochcc  Recreation-
al ."-ca ..itridy  and the Jitr-rey teari was rcq»iestu';l  to pr^llc: "t;lie - *in-
     -'r.ta* on archeology in the.- valley f
 Jr,cl;, a total of 9C sq-aarc rnilcs.  Ho f^nds were :-.adi available  so
 ;;hc  t-;a-- donatr.cl the rjas,  filr., r,latt   rental, -.tc. r--3".ltiu3 in an
aV-'itional  o7  sitcc bcins  rccor^-dr-.5o:aa- 5,n Owin-iett and •••Jorsyta
             by  December it  *:as apparent that sonc  s5.tca iu  Pulton
  -
o
  -".n"-;/ '.7Gi-e  very i^ortarvt and ^rcre  endan^erer".  by various  activities
 f pv.blic and  private organizations*   Ti'.lton -Jovoity Gornriiasioners
i-^-s^cn-.Tcd ^Tith" $1200.00.  to complete  a survey of that portion. of >altcn
on  -:VLO Jhattahoochoe ..river raost heavily occupied and o
      /•-I though the tea-.-1, v^as coixiitted  to pxiblishing the ^'-thcrc:'. data,
an ^•-£r--^ncy arose \?hen  it v;as learned  that the x;ell-cloci.v.icnted site
of otaalln^  P.achtrce C6-Co-l) X7ould  scon be taken by tile,  Chattahoo-
         by  the  two cc-ntics and'tlie  7c*1craX'".rat-:r roXiutioa  3ont:rol
^--"i-^i-"-ration  and contracted through "'the design engineers*,

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         -v.'-cr^-o  -:.:.-i Cr-orf.ir. ">:.• hic::cry for

    !-:s ;;.: rtionc c-Vi t- ee~,  .,   -             _
     o- :-th;~c-  bister^ of a lar^c portion .ox  the  ^na :tauooca -:_
     -..,. a-,,: r~vor-:c on sv.cli diverse b-t related. sublets a.c
                                    , o-hnobotany, dle-w^
 .;•.:'.'-  .--viz pattcj-os, and early tfaww -oicnssr  IvLstory.
                             infor-ia-jiovi, the  tecu has
                                    "               "   »"
:ic;s of the  local governments.-
 Vhe fcl?.o-.7irxr; list of  cites  with their cultural identification
---rretit: states are those  considered to  be most  X":porta;;t &>.-•- ~n
     I -  ilost I::.-oortaiit.   To be prc.-jcrvc- if  ~,os-Jiblo  or, at:
           the vcr3- least,  to have salvage projects  uo  co ao ;-•,.>.
           their \raiq-1 e  or  scientific  ir-,p
                                           ort
     o  _   i-portant as  e::hibit arean  for -th- . interpr static-
           of the area's history.   JhpvO.-s. s.:rva as  -ae  oaci.c
           for couaational and/or to-irict co"!p.:.e;;.

     3  -   .Scientifically i -^orta-vt but not  necessary to pr.:o.-.rvo
           •;•' a'cr.^rtelv tecterl.  .3ata conlcl be ^ath-r_.- ^y a
           s..iall crew  iri two or three  days of funded  rccearcn.

 -'•-  is  ho-^d that  v7V.an the current project  at •;.Co-l is c -.. .^/.; tc..,
 -eVhov-rio found  -;here-r7 the trained and cx^erSence* sv.r--ey  -ccr-
-•• bo a?-o;7-:-l to continue carry- out. an .or-aaa.sic...proSi%a:---of   .
 --•' .-rrir^il  rccaarch,  salv^^c -and  d.evc?.opnent.  ..-r.^ovi.icve^ chat.
"- -'refits "'-o t'u: education, eccnouics and recreation of tae ^-jenora..
icTb^th lo^il  2nd tra— it, .tr-v.Id  aio'.y rc-!:-rn^ the re'-i^rc.:.  xv.r.:.^.-.
•— -.  ~.-^';  thai the  ;;nowled;^e th-s "ain-d WO-.L- oa  ln.eraj.ly
            a     e ;;no;                   .          ..
            ince .once i#*&a/ destroyed can never be  replace:...
                 I           •          '
                                 *>,

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     Ji'irxs" z'ss lie ted georprnpliicaj-ly fro-1. South to liorth.
".:r;"...v's an • their approximate dates, arc:
w J. *— •• *,'. •-,* 1. »
: ./ocdlai-
;I Iliotori
... - Jarly
''i'xorit'^
j_
1

1
j.
3
3
i
_/

p
•f
2
3
2
•f 1
2
=-i J. — ™ i 'N— .J, W
- GOOD to
a - 2000 B
ip man - .-i
c - after
- L - late
Site Mo.
C'o-152
Co-101

Co- 120
Co-100
Co- 151
Go-122
Jo-124

Co-123
Fvi-49
Fxi-43 --
Co- 139
Co- 11 3
Co-145
i\i-55
j, ^- *-"^/v-'*-/ *-»« *^»- V«-*W - : tw Ui
•2000 U.C.
.Ci. .to A.D. SOO
.0. SOO to 1500
1492 ( sp;.ie areas have
considered frpn
^•u A. Vi._ <— 0. J. Si '.1 UW «-i^ i <-!..'-'— W . '•- - J.
| . *
! a Proto-historic period
'1450 to 1600)
Typ-3 Site Period . ' . iiidange red by:
canpsite A (P?)
village LW-^-'I

village Jv-7
vi 1 1 afi e A^.LW- 2,-i
vilj.a.^e ' iIJ-I 	 .
roc:;3helt£r A-U
lithic ' £n. -%. . • .
station . '
gun Civil War
village EW
"roclcshdter "A-1-;
^ound-villa3e M CP?)
industrial Civil War
complex
v'.lla^e II
roclcshelter A
Private housing develo-T-.ont
Private trailer co: iple::
(ovTner has set acide 1 acre)
Apartnient corple;:
School expansion
pipeline
Private developivierit
Power lire

Private housing •-•.evelop'-ii- nt
Private liouGin^ develop :e nt
Apartment .cor.vp^.er"
Ap art', tent er :p anc i on
pipeline
pipeline
pipeline
           Co-142    fishweir   xinV.novm     recreation-vandalis

           Co-125    village      I2-I        pipeline ^  flooding
                     (fortified.)

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            ?u-2      village    A to E     Apartne nt complex
            ?u-3
            ?u-6  (considered  to be  components of same village)
            Pu-21

            Fu-60     taound &    EW         industrial complex constructioi
                      village

            Fo-104    village    W-M        Fo-104 and ?u-60 arc  divided
                                             by county line.
    iary:
      The present excavations at 9-Go-l  can serve as a model of  total
co-operation between the National and local governments, engineers,
contractors and conservation organizations to provide an improved
environment while conserving vital cultural and ecological units.
f-.afres fro"-, the -itowah I and Ii periods  ( :H)  are being salvaged.
The  ',x>rl; crews arc desperateljr trying to clear  the area"to be  ta"-en
by the 2.ottenwood Plant in the southern portion of the cite.   "7c
have had no word from Maycs, Cuddeth and .Ithc-.-i-'ge, Inc., as to when
actual construction will begin.  We hope that the worl; can be  co-
ordinated andscheduled xn.th the engineers  and contractors an"  with
lilythe Bros. Co., who are bringing in the  pipeline from upriver,
so that as little archeologica 1 data as possible will be lost.
The ^ crews are working 13 hours a day, seven days a week, to clear the
entire plant site as soon as possible so as not to 'elay plant
construction.  T3ecauce our estimates for the  archcological sa?.vaga
T7-:re  base-! on figures given us in October, we will need an additional
$5000.00 to neet the requirements of the enlarged plant facilities.
it is felt that Cob7-, anrl Pulton cannot bear this a'7 litior.al cost and
we are loolcing for other local funds to complete the last of o".r
"     stija tion.
      If  a -LoritoritT-". is enTorce;' within the  riv:r corridor or. private
-lev;:"1 op-re Tit in the flood plain, it would be  r>on.-.ibbe to --arr;- b\.-.t
the i-acjLiirev tc.^tin.1-; and c:-cavation of the above  biste-1 sites .rur!
give:  tv.e area the -ost ccnplcte prehistoric  an.;i  ecolo':ic ,-r_ r,t~i".y
of axiy no;-1parab'1.e ecological niche in the nation.  TThen. the ^.ata
ran ">e cor^ lated an': placed in the proper   exhibit content, it vcul'l
sc-r-c ?.s a unique acconrplich-tcnt for Georgia TV  tb •  .outheast.  '.,o
cc -ipletc study of this type nov7 ocists and the  chance to have such
available in the ftitv.re is ^possible.

   Attached as Appendix A is a sample progran for a Priority 2 site.
             3 is a report subriitted to  Cobb  Gou^.tr/ at the end of
     ,  1970,  and explains the importance of 9-Jo-l.

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                                                      June 23,  1971
      The investigations at 9-Co-l have been in process since March
29, 1971.  To date no archeological features have been discovered
which would serve as an in-place exhibit.  Provided the data now being
recovered im analyzed and published as general information to the field
of Science and the general public,  no further preservation is feasible.
Other sites within the two counties are important and should be preserved
as aids to interpretation of the area's history and examples of man's works
in the past.

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     Cf '•'  '
                AHCKEOLOGICAL SURVEY OF COBB COUNTY

                     c/o P23BLEB3QOK HIGH SCHOOL SITE
                           Pebblebrook Circle

                         Hableton, Georgia, 30059
                              Phone 948 1310
                                                         .ay  21 •
3ooe  -rack Oc-viittce
O'o*°>  ^01inty Chapter
Georgia Oonsorvancy
Gent. \e~sm:

     7h& Hoi"! owing ita^is -night bs  considered  in th.o ?or~!.-i tiou of
n historic r,arlc  enclosing the mils  *ilong Sope  .Crecl-v above an-7!
bc'ow  "a:?cr ?:i"U  P.oad bridge;
          The  --ill  buildings and subsidiary structure s/t
          -loiuts  to exhibit: as nrine exanr-1.es  of l?th  c-jr.t-Try
          industria'i. archit-Ctr.tre,  as exarv^l.as  of x-rat-^r-pot/cro 1
          •i-cchnolc-cy,  and as t ha only re^ainin-r ^o .--^Tax o-T cv.^Ii
          structures in the greater Atlanta area fro;1 the  ,'ivil
          War era.
          "'reservation of renainin^ structural  feat-ires  rather "than
          "h',11 re-;tor-'ition should  bo  consi-1 rr-. d.   '^his v/nvlcl ^.ntviil
          so^ie clearing of nresent growth b;r  careful selecticn,
          sonTing  the s-tmctural  features fror.-. cnrth.r  v.'onth--ri.ic'
          and vandalism, and minima?,  niaintainevxce.
          li-chlblts  a'-iii interpretation can ?>e  Carrie -T '.^t  by rccon-
          ntri'.ction nsin^ -Irawin^ss  and nodcls.   3c ic arclv-o^.o^ical
          invcGti^^.ti??! wcnl-1 be -necessary to ••:aiii basic  ,lr>tn for
          this an ;  —o'-?. 1 a"5 GO se-Tv.re whatever artifict.T have bcjn
          0verlooV.'--i by Jivil  /ar enthusiasts.   It -:i'>;lvt  be vjol.l to
          add hero  that a fourth r.tory _ potentially crrists ...if . ccLJi'i
          or even on- of 'i:hc -»il1. -workers '* we l^.ir. ••'".*? "an be  "i ocTte.-l,
          Infomation gains' fro"> such an in^c.^ti^Atiorv conld Ic.a'
          to an exhibit of 19th ccntTtry iiid-strial-sociolorri -cv:
          stiv'y for this section of the South a"^. c-^rV-l be  of ^rer^t
          interest  when compared to a Northern  ccjintcr->ar.t^
     4.   The .Jn^rincnrs resoon.^ible  for the '• -dcsijrn o* the  Jor>e  irc-:l;
          .:,.w.r lino  shovld be br-;n«ht into the- nrssible • p.az'k ;-.l n
          at the earliest ^orient, 'certainly before , any dcsi"n is
          be^'-n.   If  possible, one nor-ber of the engineering
                •. be a 'ne-nber of  the  present co^ni^teG.
          in ccnsi'1 e ration of a park, - it v/iV. b^' ncceosai-j- to olan
          for parking,  rest-roo^s,  'Irinhin.^. forcitain.-;,- etc. -. -I v/o-vLJ
          sv.t^cr.t thnt  s^.ch facilities also be  the -vl'-e for tha
          o-chi:;it an-i/or .-.v.se^va .building.  To accomplish this will
          rer^.ire that  ".ore property than the crc':l; -banks  be

-------
 5.   It will be  oractical, therefore,  to Incite  the present
      nrc-.crty ovmr-rs  to participate  in the -."! a :;iiri"'.   I uV.vj
      Gnol.cn i:c ::rs. J">hn Sibley in thr past  in/!  she stit
      that she had  at  one ti;r>e consi-ere--1 prcs^rvinr; tho -li^.
      sitnatc-1 on her  husband's property.

 7.   Other or^^nizntions that conld  cotYtribute va \
      information and  assistance woul.rl  be:

       Thi GGbr-'i.^  "'.^art'-ia-at of Archives and llccoris
       National "ark  i'crvice, N'en.n<2eaw "-itionnl  .iattlcf i^"
       Atlanta Historical Society
       Af-.anta 'Ji*-'i?.  '-Jar ?t.  of Carles an-l I<.c creation  or vv.rhaos  b^-
      xncln-;e-l in the Oobb -Jo. Y'vuth xI-Jsou-:. -  The  latter orsr.nii^atii
      has financial,  oroblc-ns an^ possibly x-^v.l.-'  ba rmwil" inf, to
      talce en a-Vitiona! nrojacts.  I  wo>il-*. s^rrrofst thnt -t:ha
      History  >ey>t.  of ;:.3nnesav,- Junior Jollege an-1 the Architecture
      3ent. oc Southern  Tech "DG annroachecl for a co-operative
      effort in the  interpretive investigation pl
      It shcnl/' be r>ointe-l out that  the 3ooc  Jreok -nills  oonbd -e
      co-bincd '?ith  other historical a'.vr ..rhi'-it  \->nits now  avail-
      able in Job':.- Jotinty to form a  historic connTcx that c-nld
      act as a rvxjor tovirist attraction (as c->no3e " to tourist
      'trap') and nrovi^e an a-^decl source of rex»cnue for  Jobb
      •Jounty in -jrovidin^ a nevr industry.  1"he  Jhar-fbcr of  Jo -raurce.
            be anproachcd fro'i tliat -view.
 I svi.b nit thv.-se ite'-s for y
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Ar

 To:       Mr, Enwat B*r*H, Chain^n, Qa»fUlilfj  Board of GoMdaetoners.

 Subject:  Preliminary Report of Archaologio*! Survey.

 The survey of areheological sites,  pr*hi*toric »nd  historic, comrajenced July
 6, 1970, and continued daily until  August 29.  Initially, the survey employed
 ten students froa junior high school t» coll»g» sophnoresj however in the
 second week of August, the crew was enlftrtred  by fool1,  unpaid volunteers on
 a daily basis.  Randan volunteers,  sowetJjwa  as many as six, joined the field
 work for a weekend*

 A total of 133 sites were checked,   U2 of these were primary discoveries by
 the survey and were previously unknown.  A full report of all sites, their
 location, and present condition is  being prepared,

 The present report will be confined to critical sites, their importance or
 value to historic or scientific knowledge,

 9-Co-l:
 Of prime concern 
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the  -:-.ot:>3 tvr< county --cveriir.-rrr-.ts in salvaging 'the archeological sites along the
i'; r.al route could well  iriion a  reversal in the trend of steady  destruction of
 aluable  c^ta.  Federal funds  would be available in ratio   of  9:1 dollars.

9-Co~113:

The icovs  -number  has  been given to a series of sites along  Sope Creek j  it
:,.:l.,ae5 ir.illiij office  buildings, pylons to support a  former sluice,  and
rv/Y.airnnr;  vails.  These structures have thr°e important  stories to offer:
cno,  they  are  important representations of early industrial architecture in
Ceor.?is; tvo,  water-powered  industrial technology; three, they are the  last
r.:, ••. or  ~roup of structures in rrddcle Georgia of the era  of  the War Between
tho1 States.  It is  reccraendeci  that they be stabilized and  secured fron
vandalism  and  preserved in a unit as a park or historical monument.  Material
was gathered by the survey which could be used in an interpretive exhibit..

Surni^ation:

The survey is  still in  operation.  High school students  and interested  citizens
have  organized to work  in afternoons and on two full days on the weekends as
volunteers.  One  of the major automotive manufacturers has  intimated  that they
night contribute  a  rough-terrain vehicle to facilitate moving equipment and
workers to normally inaccessable site locations.  It is  hoped that the  county-
government will give  the survey an official status by  appointing a. county
archeoiogist to direct  the survey, co-ordinate work schedules with the  various
a~cncies,  departments and contractors to clear critical  areas of valuable data,
assess sites if they  can be  preserved, and to search out assistance from other
frovernment agencies,  foundations and co-crdinate and distribute pertinent
information  as regards  the history and heritage of Cobb  County.
                                   Respectfully,
                                                      , ]f\
                                   Lawrence W. Meier  .

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         Report on Small Sewage Treatment Plant  Operation*
               Cobb County Water and Sewerage  System
INTRODUCTION;


Following receipt of laboratory data furnished by Atlanta Water Works


covering bacteriological analyses of effluents from privately developed


sewage treatment system* operated by Cobb County Water and Sewerage


System during the month of March 1968,  a field evaluation of effectiveness


of operational technique* at these plant* waa undertaken by personnel of


the Division for Georgia Water Quality  Control.  All plant* were visited


on May 3 and May 9, 1968.  A listing of these plant* i* included a*

  p
Apendix 1 to this report.  Effluent col i form count* determined by Atlanta
  $

Water Work* during March and April are  shown in Appendix 2.



PURPOSE OF SCOPE;


This report was written to present the  findings of an evaluation of operation


of privately built sewage treatment plants operated by Cobb County Water and


Sewerage System and located above the Atlanta Water Works intake.  The report


describes conditions as observed at each plant, present* specific recom-


mendations of improvements for operation of each facility, and presents


general recommendations for overall improvements in Cobb County's operational


and maintenance program.

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OBSERVED OPERATIONAL CONDITIOHS;



A total of eleven treatment facilities were visited.   Of the eleven, five



have not yet been accepted by the County for operation but are essentially



completed insofar as construction is concerned.   These plants discharge



directly to the Chattahoochee River, to Sope Creek, to Rottenwood Creek,



and to various tributaries of these streams.  A brief description of




observed conditions at each plant follows.






Seven Springs Estates - Sewage treatment facility serving this subdivision



consists of a 50,000 gallon per day extended aeration package sewage



treatment plant without provision for effluent disinfection.  This plant



was approved for construction in December  1963 and discharges to Bishop



Creek,  tributary to Sope Creek.  The operational ins2ection_confir»gd



that  there  is no chlorinator or chlorine contact chamber, that_there_is_no_



access  ro»d nor lighting.  Weeds inside the  fence needed  cutting.  A surface



water diversion ditch  is needed on  the upper side of  the  plant.  Three or



four  diffusers appeared to be plugged.  Basic design_oj_a_pump__stflt^on
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Franklin Road Plant - This treatment plant serves commercial developments



on U.S. 41 opposite Dobbin* Air Force Base.  Effluent la discharged to a



tributary of Rottenwood Creek.  Design capacity .of the treatment unit is



not known aa this plant was installed without review of plena or issuance



of a construction permit by this office.  The plant la a Chicago pump



extended aeration package unit with sludge holding tank.  There are Major



operational problems with this unit including  the following:
                                 e


    1. Sludge return system cannot be made to function properly.



    2. There is no chlorination; a chlorine contact chamber was



       provided but there is no chlorinator.

     i

    3. Because of the inability to return sludge, septic solids



       float on the clarifier, are lost over the effluent weirs,



       and have filled the chlorine contact tank to its overflow



       elevation.



    4. Although dual blowers were provided, one was found out of



       service and the operator reports that only one blower has



       ever been operable.



    5. The access road ia inadequate and the operator cannot reach



       this plant during wet weather.



    6. The chlorinator house needs a drain.



    7. Because of its location this plant should be followed by



       tertiary treatment; in lieu of this, the possibility of



    ,   pumping to the City of Marietta's system in this area should



       be investigated.

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Recommendations for improved treatment are •• follows:



    1. Provide an operable chlorinator.



    2. Rehabilitate the second blower.



    3. Drain the tank to determine why sludge return is impossible.



    4. Cut trees near the plant and/or provide a screen over the



       aeration and settling tanks to prevent future stoppage of



       sewage by collection of leaves and debris in the plant.



    5. Remove sewage solids from the chlorine contact chaster.



    6. Provide tertiary treatment; apparently there is sufficient



       land area for the tertiary pond.



    7. Provide an adequate all-weather access road to the treatment



       plant.





Terrell Mill Estates - This facility consists of an aerated pond, presumably



intended to operate on the extended aeration principal, followed by a



tertiary waste stabilisation pond.  Design flow is some 71,000 gallons per



day, the waste is discharged to a small stream tributary to the Chattahooche*



River about one mile upriver from the 1-285 bridge.





The operational inspection indicates that the aerated pond does not work



as extended aeration.  Solids are not returned to the aeration compartment
from the •ettUn^£omgart«ent^ resulting in septicity in this laf**-



Considerable septic solids and scum float on the surface in the settling

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cone causing odor* and providing  ideal habitat for Mosquito breading.



There is no influent bar screen and large raw sewage solids can be



observed floating in both compartments.  An overflow weir designed  into



the clarifier cone was not installed because of a discrepancy  in



elevation.  This weir would have been beneficial in Maintaining the



floating solids in the plant, but its installation would have  resulted



in excessive submergence on the aerator and resulting overloading of the



aerator motor.





The polishing pond has generally good color but appears to  be  quite



heavily loaded.  Considerable flotage was noted consisting  of  apparently



septic solids, algae cluaps, and traces of duckweed.  The outlet box waa



not provided with the interior baffle or with an overflow slot.  Slide



gates on this structure need lubrication and painting.  Haintenance of



grounds, weed cutting, etc., is poor at both facilities.





Recoomendat ions:



    1. The aerated pond design should be modified to provide more



       effective solids return from the settling cone to the



       aeration zone.



    2. A water service and light should be provided at the



       aerated pond.



    3. Access roads to both facilitiea are inadequate and should



       be improved.

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    4. Surface water diversion channel* are needed around both



       facilities to exclude runoff.



    5. The pond outlet box should be renovated to bring this



       structure into compliance with State standard recommendations.



    6. Chlorination of the aerated pond effluent prior to its



       discharge to the polishing pond would likely result in better



       overall colifom removal.






Regency Apartments - This facility consists of extended aeration package



plant, subsurface tertiary sand filters, hypochlorinator and chlorine



contact chamber.  Design flow is 57,000 gallons per day; effluent is



discharged to a tributary of Poplar Creek, tributary to Rottenwood Creek.






The operational inspection on May 3, 1968, revealed the following:



 ^- 1. The chlorinator was found out of service and had .been



       removed from the plant for maintenance.



    2. The effluent from both the aeration plant and the sand



       filter was excessively turbid.



    3. Treatment plant grounds needed landscaping and correction



       of previous erosion damage.



    4. The grass was badly in need of cutting.



    5. Arrangement of the comminutor is quite poor; the 10" inlet



       sewer is reduced to a 6" connection immediately ahead of the



       comminutor.   The comminutor does not reverse and stoppages of

-------
       this Machinery together with reduction in cross section



       of the inlet sewer line result in frequent backups of



       sewage in the collection system.



    6. Filter dosing siphons were found out of operation and the



       bell had been removed from one siphon.  All flow bypassed



       through one siphon chamber.



    7. Distribution lines were not level in one distribution box



       and appeared to be broken in the other box.



    8. Equipment such as dosing siphons and distribution boxes



       are not accessible for maintenance because of their basic



       design.





Recommendat ions:



    1. Cooninutor should be replaced with a larger unit which does



       not require reduction in inlet sewer sice.



    2. Improvements should be made to dosing siphon and distribution



       boxes to allow the filter to operate as designed.



    3. The chlorination practices should be improved.  It is



       recomnended that a standby hypochlorinator be provided,  liquid



       solution rather than HTH be used to reduce likelihood of clogging



       solution lines, or that gas chlorinator be provided in lieu of



       hypochlorination facilities.

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Cochise Subdivision - This facility concise* of raw sewage puaping station,



50,000 gallon per day extended aeration treatment plant with disinfection



and tertiary pond.  This plant is located on Paces Ferry Road and



discharges directly to the Chattahoochee River.  The oxidation pond,



presently used as tertiary treatment, has been in service for several



years; other facilities are new and have not yet been issued an operating



permit.





The operation inspection found only one blower working in the raw sewage



ejector pumping station.  The operating cycle on this station is



excessively short and apparently influent flows exceed those anticipated



by the engineer during  design.  The pumping station needs forced draft



ventilation.  The aeration plant clarifier weirs are not level and are



not adjustable.  A walkway is needed around both aeration and settling



tank with protective handrailing.  A water service is needed at the



operating level.  The .chlorinator was found operating with the feeder 1001



open.  Free chlorine residual was only 0.2 mg/1 indicating that a stronger



chlorine solution is needed.  Polishing pond color appeared good but



considerable scum and light duckweed growths were noted.  The operator



attributed the scum problem to a recent bypass of the plant with raw sewage



being fed to the pond.

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Reconmendationa - Operation of thia facility could be greatly improved



by implementation of the following recommendations:



    1. The collection system should be checked and improved aa



       necessary to prevent hydraulic overloadings of treatment



       facilities by ground water infiltration.  The raw aewage



       pumping stations should be improved by installation of larger



       blowera including aufficient standby ao that peak loada can



       be handled with any one blower out of service.  Ventilation



       should be provided for the protection of operating personnel



       when entering the pumping station.



    2. Clarifier performance can be improved by leveling the effluent



       weira.  Improved access walkways, handrailings, and hoae bib



       on the operating level would facilitate, proper operation and



       maintenance of both the clarifier and aeration basin.



    3. More effective chlorination and continuity of chlorination



       could be assured by provision of standby hypochlorinator, use



       of a stronger chlorine solution, uae of liquid chlorine solution



       rather than HTH, or provision of a gaa chlorinator.



    4. Attention should be paid to the pond consisting of weed cutting



       and control of the duckweed problem before it reaches major



       proportions.

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 Johnson Woods Subdivision - (also called Vinings Subdivision) -  This


 facility, consisting of a Chicago pump extended aeration package plant,


 dischargee to a small stream tributary to the Chattahoochee River approx-


 imately two milea upstream of State Highway 3 bridge.  The operator


 estimates that some 30 to 35 connections are served.  The operating


 inspection reveals that a chlorine contact chamber and hypochlorinator
•«™^•n^^^—1—^^••^^••••^^^^^^^^"^^^^^^^^•"•M^^^^^^™^

 were installed but that the chlorinator ia ant of m*mt*»   The plant has


 only one blower and needs a standby.  An access drive and drive-in gate


 in the plant fence would facilitate operation and maintenance activities.


 The grounds within the plant fence are badly grown up in weeds.  The


 effluent was quite clear, mixed liquor color was good, comminutor waa


 operating properly, but solids previously deposited  in the chlorine contact


 chamber should be removed.  A flood light should be  provided to bring  this


 plant up to present day standards.



 Recommendations:  Recommended improvements to optimise this plant's


 operation are as discussed in the foregoing paragraph.  These are namely


 a standby blower, an operable chlorinator, improved  access, cleaning  of


 the grounds, and a flood light.



 Farming ton Subdivision - This plant consists of a master  raw aewage lift


 station, 26,000 gpd extended aeration package plant, and  discharges to


 the Chattahoochee River approximately two miles upstream  from Highway 3

-------
bridge.  Major operational problems were observed during our visit to the




site on May 3, 1968.  These are essentially aa follows:



    1. Biological and clarification processes necessary for proper



       operation are quite ineffective due to surging of the plant




       when the master lift station operates.



    2. The comninutor was found inoperable.



    3. Although a chlorinator was included in original plant




       equipment, this device had been removed.



    4. At the time of this visit the plant contents were found




       septic indicating under-aeration.



    5. The operator reports chronic electrical problems in the




       standby generator.



    6. Grease and scum were quite evident on the surface of the



       contact chamber and are attributed to carryovers of solids



       from the clarifier during excessive flow periods when the raw



       sewage lift station operatea.



    7. Grounds were found badly in need of cutting.



    8. Several diffuaers in the aeration tank appeared to be clogged;



       the operator reports that this is due to fibrous material



       which has settled in the aeration tank.






Recoomendat ions:



    1. Pumping rate in the raw sewage lift station should be reduced



       considerably to prevent drastic temporary overload of the

-------
       plant.   This may b« accomplished perhaps by throttling

       down the pumps in place,  swapping out pump  impellers,

       or replacement of the existing pumps with smaller units.

    2. The comminutor should be  placed back in service which
                       *
       might perhaps alleviate the problem with the diffusers

       clogging by unground incoming raw sewage solids.

    3. An operable chlorinator should be installed and chlorinatioo

       should be practiced constantly.

    4. Time clocks in the aerator controls should  be reset to

       permit sufficient aeration capacity to prevent development

       of septic conditions in the plant.

    5. Competent maintenance personnel should be authorised to

       make repairs as necessary of the standby generator so that

       this piece of equipment can be used when needed.


Woodland Brook Farms - This plant consists of a 16,000 gpd extended

aeration plant with tertiary polishing pond.  Effluent is discharged

to Orchard Knob Creek, tributary to the Chattahoochee River approximately

1% miles upriver from Highway 3 bridge.  This plant has been constructed

recently and has not yet been accepted for operation by Cobb County Water

and Sewerage System.

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An inspection on Hay 3, 1968, revealed several deficiencies which



should be corrected before this plant is accepted by the County.



These are as follows:



    1. The sides of the invert channel in the inlet-bypass



       manhole should be built-up to prevent unintended bypass



       of the treatment plant during peak flow periods.



    2. The clarifier weir should be levelled.



    3. The polishing pond dike along the creek (exterior slope)



       should be riprapped as protection against flood waters.



    4. Grass should be provided on all disturbed areas.  It is



       reconmeuded that top soil be spread and benuda be seeded.



    5. All dike slopes should be redressed and a swale for diversion



       of surface waters should be provided outside the fence in



       the vicinity of the ga'te to prevent further erosion damages.



    6. A flood light should be provided.



    7. It is our opinion that the treatment plant, located inside



       a protective dike, nay be flooded during periods of high



       water in the receiving stream.  It is not necessary that



       flood waters top the dike for the plant to be flooded.  A



       flap valve on the pond effluent will close in all cases when



       the stream level is higher than the pond level and it is



       possible that the treataant plant could be flooded by treated

-------
       effluent with water level in the creek COM two to three



       feet below the top of the dike.





Atlanta Country Club Estates - This facility consists of extended



aeration plant with tertiary pond.  Effluent is discharged to the



Chattahoochee River at the smith of Sope Creek.  This plant has not



yet been accepted for operation by Cobb County although some sewage



is now being discharged to the plant.  Based on an inspection on May 9,



1968, it is strongly recommended that Cobb County require the following



items to be corrected prior to accepting this facility for operation.



The Division for Georgia Water Quality Control will write the designing



engineer of this facility and instruct hi* to do this reaedial work



promptly.  Items requiring remedial attention are as follows:



    1. In the preliminary treatment chamber upstream of the raw



       sewage lift station, a slide gate to the conminutor has



       been welded in place.  All flow is now diverted to the bypass



       bar screen.  The gate to the conminutor should be removed



       and the comminutor put into service.



    2. A water service should be provided on the operating bridge



       of the aeration tank.



    3. A leak in the wall of the aeration tank at ground level in



       the vicinity of the existing hose bib should be stopped.

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    4. The electrical service to the aerator should be cleaped



       in place along the tank wall and access bridge.



    5. Clarifier weirs should be levelled to equalize flow



       through all parts of this basin.



    6. The scum return system fro» the clarifier should be made



       operable.



    7. Finish painting should be done.



    8. Warning signs identifying the facility should be provided.



    9. The access road to the plant should be improved to correct



       erosion damage and provide for all-weather access.
                                 •


   10. The chlorinator should be put into service.



   11. Pond dike slopes should be dressed to correct erosion



       damage and should be grassed to prevent further damage.



   12. A leak in the pond outlet box around the bottom drain pipe



       should be sealed off.



   13. The access walk to the outlet box is substandard and should



       be repaired.



   14. A flood light should be provided as shown on  the approved



       plans and specifications.





Waverly Woods Subdivision - This facility consists of a 20,000 gpd



extended aeration package plant and polishing pond.   Effluent  is

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discharged to  an unnamed branch tributary to Sewell Mill Greek,



.tributary to Sope  Creek.  This facility at present i« not used and



has not yet been accepted for operation by Cobb County Water and



Sewerage System.   Prior to the County's acceptance, the following



corrective work should be done:



    1. A water service should be installed to the site.



    2. An all-weather access road should be provided.



    3. Willow  trees should be removed from the tertiary pond.



    4. Large hardwood trees next to the entrance gate should



       be removed  to facilitate vehicular access.



    5. Brush piles outside the fence should be removed.



    6. Pond effluent line should be extended to a suitable



       headwall at the creek to eliminate stagnation of effluent



       in the  existing ditch below the point of discharge.



    7. Warning signs should be provided.





Interstate North  - This  facility consists of a 70,000  gpd extended



aeration plant with disinfection and polishing pond.   Effluent is



discharged  to Rottenwood Creek, tributary to the Chattahoochee River.



This  plant  is presently under  construction  and apparently will not be



ready for acceptance by the County for  another three months at least.

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An inspection was made of construction in progress on May 9, 1968.

Tankage for the aeration basin and clarifier was found installed.

Mechanical equipment was being installed in these basins.  Rough grading

has been accomplished on the tertiary pond.  No work has been done to date

on the comminutor-bar screen installation or chlorine contact facilities.

It appeared that construction was proceeding satisfactorily.  It is

recommended that Cobb County and this Division maintain close control

over this construction to insure that the plant is properly built and

will be ready for service when the office park to be served opens for

operation.


OPERATION AND MAINTENANCE PRACTICES IN COBB COUNTY WATER AND
SEWERAGE SYSTEM!

Operating personnel at the  Cobb County Water and Sewerage  System report

that they are responsible for operation of some 35 to 40 remotely located

package treatment plants, stabilisation ponds, and sewage  pumping.

stations.  Two  full-time men are assigned to these maintenance  activities.

Each man is responsible  for 15 to  20  facilities and  his route involves

perhaps 120 to  125  miles of driving.


Time consuming  operational  activities include removal  of screenings,

lubrication of  equipment and machinery, and make up  of chlorine solutions

using  HTH powder at those  facilities  where hypochlorinators are used.

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While it is believed Cobb County's operational problems are primarily
those of too few personnel with too ouch work per men, these problems
ere compounded by  the wide diversity in type end manufacture of the
treatment  facilities for which each man is responsible.

Another major problem area is that numerous older installations have
been accepted  for  operation  by the County without adequate inspection
by County  personnel or  the State  regulatory agency to assure that
each  facility  as designed and built could be operated satisfactorily.

In sumaary operational  problems  could  be categorised as follows:
     1.  Lack of trained  manpower.
     2.  The necessity that skilled personnel  spend a good deal_
        of their time on minor routine problems such as
        screenings removal and make up of chlorine solution.
     3.  The wide diversity in equipment which each man must
        operate.
     4. Mediocre quality of engineering design and construction,
        particularly related to older  facilities which  the
        County operates,

 To alleviate the  operational shortcomings as  summarised  above, the
 Division  for Georgia Water  Quality Control recommends  that the County

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undertake a five point program of improved operational, maintenance



and preventive Maintenance activities.  The five basic improvement*



consist of additional skilled operator personnel and establishment of



the most compact possible service routes; establishment of routine sampling



and testing to permit evaluation of treatment effectiveness; a County-wide



program to eliminate as much as possible the necessity of skilled



personnel's spending a great deal of time on routine activities such as



disposal of screenings and make up of hypochlorite solutions; standardisation



insofar as practical of all future treatment equipment installations;



upgrading engineering design and construction inspection to assure



installation  of plants which can be operated to produce satisfactory



effluents.  These five general recommendations are discussed  in further




detail below.





    I. At  present two operators are  charged with  the  responsibility



       of  maintenance attention at  some 35 to 40  sewage pumping and



       treatment facilities which the County operates.  Each



       individual's work load is  excessive; furthermore, there is



       some overlapping of service routes.  It  is recommended that



       the County employ at least three additional operators for



       this work so that each man would be responsible for no more



       than eight to ten facilities.  Furthermore, individual service



       routes should be revamped to make them as compact as possible

-------
    and to hold distances driven and tine spent in transit to a minimum.





II. To permit evaluation of effectiveness of treatment being rendered



    by each plant, it is recommended that the County begin routine



    monitoring of each effluent.  The laboratory facilities at South



    Cobb treatment plant and one full-time chemist could handle necessary



    analytical work.  Samples could be collected by maintenance personnel



    as they drove their routes, iced, and driven to South Cobb plant



    for testing.  It is anticipated that one day weekly could be devoted



    to sampling by each operator with the sampling days staggered to



    equalise  the chemist's work load.





    It  is  recommended that the  operator determine and record mixed



    liquor settleable solids and effluent chlorine  residual and



    that  samples  be  returned to the laboratory for  determination of



    mixed liquor  suspended solids  and dissolved oxygen and effluent suspended




    solids and BOD.





    Results of this  program would  permit evaluation of treatment effectiveness



    and would provide a basis  for  operational control.  A monthly operating



     report for each plant should be submitted to this office.





III. At present each operator is responsible for certain time consuming



     duties which could be eased to a large extent without impairment of

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treatment plant effectiveness.  Two specific recommendations  that
cone to mind.are as follows:
   1. At present each operator is responsible for the disposal
      of screenings at each plant.  The recommended disposal
      method is burial which, if done daily, is a time consuming
      process.  It is recommended that the County furnish galvanized
      garbage cans with tight fitting covers at each treatment plant
      for disposal of screenings and enter a contract with a garbage
      collection  service to pick up screenings from these containers
      at least  twice weekly and to dispose of this material at the
      County land fill.
    2. The  present practice  of using HTH powder to make up chlorine
       solution for hypochlorination  is  time consuming.  Further,
       in many instances the powder does not completely dissolve  and
       solution tubing in the hypochlorinator is  prone to clogging by
       undissolved HTH.   The operator is required to check the solution
       level in the chlorine crock daily and to make up additional
       solution frequently.   This aspect of the operational program
       could be made much earier and chlorination could be made much
       more trustworthy and effective if the County would install gas
       chlorinators at each plant in lieu of hypochlorinator.  Alternative
       improvement would be the use of a liquid hypochlorite solution

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       in lieu of the HTH powder.  This would not, however, save nearly



       as much operational tima or chlorine cost as would the gas chlor-




       inators.





XV. It is suggested that on future treatment plant installations to be




    operated by the County, the County could assure proper design and




    construction if they would have their consulting engineers design



    and supervise construction of needed facilities and be reimbursed



    by individual developers for the cost of these improvements.




    Employment of a larger, more competent engineering firm such aa



    the County's consulting engineers will alleviate many problems



    now encountered by  the Water and Sewerage  System personnel  in




    obtaining  properly  designed  and constructed sewage treatment




    facilities.





  V. Implementation  of recommendation No.  IV  above would  permit  adoption



    of relatively closed specifications by the County's  engineers



    governing equipment to be  included in plants to be operated by the



    County.  This would result in a greater  degree of standarization




    of facilities which the County operates  and will  greatly simplify




    operation of these facilities.

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                                                      APPENDIX X
                                       PRIVATELY BUILT SEWAGE TREATMENT SYSTEMS
                                 WHICH COBB COUNTY WATER AND SEWERAGE SYSTEM OPERATES
             Plant Name

Atlanta Country Club Estates

Cochise Subdivision

Farmington Subdivision

Franklin Road

Interstate North

Johnson Woods (Vinings) Subdivision

Regency Apartments

Seven Springs Estates  *

Terrell Mill Estates

Waverly Woods

Woodland Brook Farms
              Treatment Processes

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination*

Extended Aeration

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination*

Extended Aeration, Sand Filtration*, Chlorination*

Extended Aeration

Aerated Lagoon, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond
Notes:

* Not in service at time of May, 1968 inspection

1 Construction essentially complete; not yet accepted by Cobb County Water and Sewerage System

2 Under construction

3 Not yet receiving sewage flow
Remarks

   1

   1
  2,3
  1.3

   1

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 TREATMENT PLANT EFFLUENT
                                                     APPENDIX 2
                                SELECTED TEST RESULTS ON EFFLUENT SAMPLE ANALYZED BY
                                       ATLANTA WATER WORKS,  MARCH-APRIL, 1968
                           Total Colifora
                           MPN 106AOO ml
                            123
 Atlanta Country Club Estates

 Cochise

 Farmington

 Franklin Road

 Johnson Woods (Vinings) S/D

 Regency Apartment*

 Seven Springs Subdivision

 Terrell Mill Estates

 Woodland Brook Farms (Baker's S/D)
B. 0.0.5
(mg/1)
1
N/A
11.2
28.5
60.0
13.5
14.0
9.0
2
16.0
15.2
61.0
49.0
16.2
12.0
51.6
3

13.4
45.4
53.9
15.0
12.9
32.7
>12.4   25.4  >19.6
                          N/A     0.13

                          0.282   0.507   0.41

                          9.5    13.0    11.4

                          1.355   0.80

                                  6.3
>10.3
7.7  >8.9
                l.f >

                3.59

                0.34

                7.3

0.125   0.037   0.076

0.04    0.36    0.22
                 0.21

                 0.597   0.131

                12.2     1.6
   Fecal Collfont
   MPN 105/100 «1
   I       2      3

 N/A    0.08

 1.80   0.57   1.12

43.25  32.0   37.0

11.05   0.96   5.44

 1.12   4.68   3.10

 1.067  0.139  0.55

88.0    2.05  40.4

 0.70   0.027  0.33

 0.405  0.29   0.34
 1   Arithmetic average of results of four samples collected in March,  1968.

 2   Arithmetic average of results of five samples collected in April,  1968.

 3   Arithmetic average of results of nine samples collected in March and Aoril.  1968.

N/A  No data available

 Note:  No residual chlorine was found in any effluent sample.

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                                                            EXHIBIT 10

  Presidential  Documents
                   Title 3— THE PRESIDED
                    Executive Order 112?6
 EVALUATION CF FLOOD  HAZAHD IN LOCATING FZ-DEEALLY CYVK'SD
   OF! FINA^CSO niHLCIh'GS, SCADS, AND OTilES FACILmSS, AK'D IN
                         LAUD3 AND PRCPi-RTJSS
   WHEREAS uneconomic uses of the Nation's flood plains are oc-
 curring and potential flood losses are increasing despite substantial
 efforts to control floods ; :ind
   WHEREAS national and regional studies of ureas nnd property
 subject to Hooding indicate a further incrtr.so  in flood damage po-
 tential and flood  losses, even  with continuing investment  in  fiocd
 protection structures; and
   WHEREAS the Federal Government has extensive and continuing
 programs for ihs construction of buildings, roads, and other facilities
 and annually disposes oi thousands of acres of Federal lands in  fiood
 hazard areas, all of which activities significantly influence  patterns
 of commercial, residential, and industrial  development; and
   WKE11EAS the availability of Federal loans and mortgage insur-
 ance and land use  planning programs are  determining factors in the
 utilization of lands :
   NOW, THEREFORE,  by virtue of the authority vested in me as
 President of the United States, it is hereby ordered as follows :
   SECTION 1. The heads of  the executive agencies shall provide leader-
 ship in encouraging a broad nnd unified effort to prevent uneconomic
 uses and development of the Nation's flood plains and, in particular,
 to lessen the risk of flood losses in connection with Federal lands and
 installations and  federally  financed  or  supported  improvements.
 Specifically :
   (1) All executive agencies directly responsible for the construction
 of Federal buildings, structures, roads, or other facilities shall evaluate
 flood hazards when planning die location of new facilities and, as far
 as practicable, shall preclude the uneconomic, hazardous, or unneces-
 sary  use of nopd  plains in connection with such  facilities. With
 respect to  existing Federally owned properties  which have  suffered
 flood damage or which may be subject thereto, the responsible agency
 head shall require  conspicuous delineation  of past and probable flood
 heights so  as to assist in creating public awaren--^ of and knowledge
 about flood hazards.  Whenever practical  and economically feasible,
 flood proofing measures shall be applied to existing facilities in order
 to reduce flood damage potential.
   .(2) All  executive  agencies responsible  for the administration of
 Federal grant,  loan, or mortgage insurance programs involving the
. construction of buildings,  structures, pads, or other facilities shall
 evaluate flood hazards in connection with such facilities and, in order
 to minimize the exposure of facilities to potential flood damage and
 the need for future  Federal expenditures for flood protection and
 flood disaster relief, shall,  as far as practicable, preclude the uneco-
 nomic, hazardous, or unnecessary use of flood plains in such connection.
       fIDIIAt MOISTH, VOL 31, NO. 155—THURSDAY, AUGUST 11, 1966

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10M4                                        THI FMSIDINT

                      (8) All executive agencies responsible for tho disposal of Federal
                    lands or properties shall evaluate flood huards in oonneotion with
                    lands or properties proposed for disposal to non-Federal public Instru-
                    mentalities or private interests and, as may be desirable in order to
                    minimise future Federal expenditures for flood protection and flood
                    disaster relief and  as far as  practicable,  shall attach  appropriate
                    restrictions with respect to  uses  of the lands or properties by  tho
                    purchaser and his successors  and may withhold such landi or proper-
                    ties from disposal.  In  carrying out this paragraph, each executive
                    agency may make appropriate allowance for any estimated loss in
                    Mies price resulting from the incorporation of use restrictions in the
                    disposal documents.
                      (4) All executive agencies responsible for programs whioh entail
                    land use planning shall take flood  hazards into account when evaluat-
                    ing plans and shall encourage  land use appropriate to the degree of
                    haiard involved.
                      Sao. fi. As may be permitted by law, the head of each executive
                    agency  shall issue appropriate rules and regulations to govern  the
                    carrying out of the provisions of Section 1 of this order by lus agency.
                      Sao. 8. Bequests for flood haiard information may bo addressed to
                    the Secretary of  the Army or, in the cose of lands lying in the basin of
                    the Tennessee River, to  the Tennessee Valley Authority.   The Secre-
                    tary or the Tennessee Valley Authority shall provide such information
                    as may be available, including requested guidance on flood proofing,
                    The Department of Agriculture, Department of the Interior, Depart-
                    ment 01 Commerce, Department of Housing and Urban Development,
                    and Office of Emergency Planning, and any other executive agency
                    which may have information and  data relating to floods shall cooper-
                    ate with the Secretary of the Army in providing such information and
                    in developing procedures to process information requests.
                      SEC. 4. Any requests for appropriations  for Federal construction
                    of new  buildings, structures, roads, or other facilities transmitted to
                    the Bureau of tEe Budget by  an executive agency shall be accompanied
                    by  a statement  by  the head of the agency on the findings of his
                    agency's evaluation and consideration of flood hazards in the develop-
                    ment of such requests.
                      SBO. 5. As used in this order, tho term "executive agency" includes
                    any department, establishment, corporation, or other organisational
                    entity of the executive branch of the Government.
                      SEC. 6.  The executive agencies shall proceed immediately to develop
                    such procedures, regulations, and  information as are provided for hi,
                    or may be necessary to carry out, the provisions of Sections 1,2, and 8
                    of this order. In other respects this ordor  shall take effect on Janu-
                    ary 1,1967.                                        „  T
                                                              LYNDON B.  JOHNSON
                      TH*  WHITE HOUSE,
                                 August 10, 1966.
                                [F.R. Dor. CO-8838; Filed, Aug. 10, 1000; 12 : H p.m.]
                           HDERM RMISm, VOL 31, NO. 155—THUMOAY, AUGUST 11, 1*M

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        STATE, ME'iv^PGLi/TAi; OR  K^GIG^AL PLANKING AGENCIES

                                                    DATE: August  4,  19 G 7
            /Atlanta Region  Metropolitan Planning Commission
      ddress   900 Glor.n Building, Atlanta,  Georgia 30303	

     o or. roe of  Authoritv  for  Establishment  of  -Agency    Georgia

      ',.;•.-.::,  lv-t-0 - Ga .  Law 3-• 7	
C:x/b .."our. tv  Uat'jr
                                        wera~~- System
               C -r V; jJounty Co-u£th3U3O ,_ Marietta ,  Georgia
                                                 Project No.
                        : .~?: Ji" ovcr^-r: f .?  to co^'.tv -wide sewerage
Cer L i : i f.'i t ii:r. :
     The  proiect descr-bed  above does  (>^)  does not  (  )  conform, with
     the  ccr.ioreher.nive  plan developed  or in process of  development
     for  the" inotirorcl: t on  ;:rca in which  it is located.
Co-
T-I  -v.- -•jiV^rcc- •-.-irn cTirena  for roviev/  -no  comment adopted  by the
AKy.rC^^.i'rs'v'ijtoii'Auri.l  2-3,  1967, the  following response  is  indicated
by  tho  planning agency:
1.  The  proposed
    current negio
    for  water and
2 .  Tho  pro;-o.-•.-;'.; .
    cov;r.ty ^•--wer
3.
        jec"t "doos ccnfcrn  to the objectives  of the
     if-l" Development Plan  and v;ith the  regional plan
      tev:er  facilities  as  it has progressed  to date.
     rro'crt  cor.fcrrs with recommendations  for a
     -l;if. :\:\rl\ the ccur.ty  land use plan.
      i.. i-o:. ..-.-of] orc-cct  .it--,  i.n conforraanco  v;ith t.lif>
                                              '(S innat'.'iro)
                                    5nzed Representative of Planning
                                                 Agency

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APPENDIX C

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Appendix C                     Commentaries of Reviewing Agencies






     In March 1971, a draft environmental assessment was




circulated to various Federal and state agencies  (Listing I




below).  The draft assessment was released to assist EPA in




identifying what issues  should be explored and discussed




relating to the construction of sewer lines and sewage  treat-




ment facilities.   Contact  points and meaningful laison  were




established with Federal and state  agencies and concerned




environment/ecology  oriented citizens groups.




     On April  30,  1971,  copies  of  the Draft Environmental




Impact Statement on  the  Cobb County Sewerage  Project were




distributed  to agencies  on Listing II for their formal




review and comment,  and  to the  Council  on Environmental




Quality  (CEQ)  as provided  for  in  the CEQ guidelines of




April  23,  1971 which are effective for  all draft  environmental




 statements circulated after June  30, 1971.  Thirty days were




 allowed  for review by other Federal agencies  and  no agency




 requested an extension of time.  However, this final Environ-




 mental Impact Statement  is addressed to the issues identified




 in the commentaries of agencies,  groups, and individuals




 received up to June 26,  1971.

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                           LISTING I






Federal Agencies




Advisory Council on Historic Preservation




Department of Agriculture Forest Service




U. S. Army Corps of Engineers




Department of Housing and Urban Development




Department of Interior




     Office of the Secretary




     Bureau of Sports Fisheries and Wildlife




     Bureau of Outdoor Recreation




     National Park Service




     Southeast Archeological Center




     U. S. Geological Survey




Office of Economic Opportunity






Other




Georgia Conservancy, Inc.




Georgia Historical Commission




Congressman Fletcher Thompson






                          LISTING  II






Federal Agencies




Advisory  Council on Historic Preservation




Council on Environmental  Quality




Department of Agriculture

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Federal Agencies -  (Continued)




U. S. Army Corps of Engineers




Department of Housing and Urban Development




Department of Interior




Office of Economic Opportunity






Others




American Adventures




The Atlanta Bird Club (National Audubon Society)




Georgia Conservancy, Inc.




Georgia Historical Commission




Georgia Natural Areas Council




Save America's Vital Environment (SAVE)




The Sierra Club




Congressman Fletcher Thompson

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                                                                      i  I Mi ll'l i  I
   •T0,
                      Metropolitan Development Office
             DEPARTMENT OF  HOUSING AND URBAN DEVELOPMENT
                  PEACHTREE SEVENTH BUILDING, ATLANTA, GEORGIA 30323
                                  Room 645


REGION IV                                                          April 5j  1971


                                                                  IN REPLY REFER TO:
                                                                        4M
    Mr.  John R.  Thoman
    Regional Director
    Environmental Protection Agency
    Suite  300,  1421 Peachtree Street,  NE.
    Atlanta,  Georgia  30309

    Dear Mr.  Thoman:

    Subject:  Cobb County Sewerage Improvement Project
              State of Georgia

    We have  reviewed the draft environmental impact  statement
    transmittal  with your letter of March  31,  1971.   You are to
    be congratulated on the thorough treatment you have  given the
    environmental issues involved in the subject project.

    We,  of course,  defer to your expertise in the area of water
    quality  and  offer no comment on the water quality aspects of
    the  project.

    Regarding outdoor recreation and historic preservation  aspects
    of the project,  we find your analysis  to be fully adequate and
    offer  no objection,  assuming that  Cobb County will accept your
    recommendation of Alternate "E" routiu6.   We also assume that
    you  will monitor the progress of construction to assure that
    the  archeological potentials of the Sope Creek and Chattahoochee
    River  Treatment Plant areas will be protected.

    Approval of  your plan by the ARMPC on  October 1,  1970,  provides
    evidence of  the consistency of this project with HUD's  policy
    of encouraging sound areawide planning of such facilities.

    Finally,  we  must  commend Cobb and  Fulton Counties for their
    demonstration of  good government in the areas of this project

-------
in which they minimized the unavoidable environmental impact by
entering into a joint effort.

We heartily endorse this project and hope that it can be placed
under construction at an early date.

                               Sincerely yours,
                                *!_- - -  T   i^ -
                                Thomas J. Armstrong
                               Assistant/Regional
                                 Administrator

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                United States Department of the Interior
                              NATIONAL PARK SERVICE
                           SOUTHEAST REGION, P. 0. BOX. 10006
                         FEDERAL BUILDING, RICHMOND, VA.  23240
IN REPLY REFER TO:
                                         IP* • *
     A98  SER(CP)                          *
     Mr.  John R.  Thoman, Regional Director
     Environmental  Protection Agency
     Water Quality  Office,  Southeast Region
     1421 Peachtree Street,  N.  E.
     Atlanta,  Georgia  30309

     Dear Mr.  Thoman:

     We have reviewed  the environmental  study of the Cobb County, Georgia
     Sewerage Improvement Project,  enclosed with your letter of March 31,
     1971.

     Kennesaw Mountain National Battlefield Park, an existing unit of the
     National Park  System,  is within the area to be affected by the project.
     When this study was initiated  several years ago, the National Park
     Service indicated its willingness to cooperate with the County with the
     understanding  that safeguards  for the historic features at Kennesaw Moun-
     tain would be  recognized.  The statement should give appropriate recog-
     nition to this Park and assure that the present plan does not endanger
     the historic and  natural values of  the Park.

     A potential unit  of the National Park System, the Blue Ridge Parkway
     Extension,  is  scheduled to terminate near Kennesaw Mountain National
     Battlefield, north of Atlanta  and Marietta, Georgia.  It is possible
     that the subject  project could affect the Parkway.

     The environmental statement should  show evidence of consultation with
     the State Liaison Officer  for  the National Register of Historic Places.
     This officer,  Mrs. Mary Gregory Jewett, Executive Secretary, Georgia
     Historical Commission,  116 Mitchell Street, S. W., Atlanta, Georgia
     30303,  should  be  consulted for possible National Register properties
     that may exist in the  area.  These  include all registered Historic
     Landmarks as well as other Register properties of State and local
     significance.

     The environmental statement on page 6 recognizes archeological resources
     and the employment of  two  archeologists by the County to coordinate
     studies and excavations at the Peachtree Site of the Treatment Plant.

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From our review of the data contained in the report on this matter,
we question whether this includes the entire project area or is limited
to the Treatment Plant site.  We suggest that Mrs. Jewett also be con-
sulted concerning archeo logical resources within the entire project
area as delineated on Figure 1 of the attachments.  Her findings should
be recognized in the final statement.

                                        Sincerely yours,
                                        L. Boyd Finch
                                        Assistant Director
                                        Southeast Region

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        United States Department of the Interior

                   FISH AND WILDLIFE SERVICE
              BUREAU OF SPORT FISHERIES AND WILDLIFE
                       PEACHTREE-SEVENTH BUILDING
                       ATLANTA. GEORGIA  3O323


                                              April  7, 1971
Mr. John R. Thoman, Regional Director
Environmental Protection Agency
Water Quality Office
1U21 Peachtree Street, NE., Suite 300
Atlanta, Georgia  30309

Dear Mr. Thoman:

The draft environmental statement on the Cobb County, Georgia,

Sewerage Improvement project transmitted with your letter of March 31

has been reviewed.  Improved water quality should be of general benefit

to the fishery resource and the sport fisherman.  Construction will

disrupt some areas of value as  wildlife habitat, but this should be of

minor consequence and of short  duration if overall environmental values

are properly considered.  We have no objection to your recommending

alternative "E" as proposed in  the draft of your environmental impact

statement.

                                    Sincerely yours,
                                   Ernest C. Martin
                                   Acting Regional Director

-------
            UN  _D STATES DEPARTMENT OF AGRICULT
                      FOREST SERVICE
                 • Southeastern Area, Staff and Private Forestry
                        Atlanta, Georgia 30323
                                         April 7, 1971

                                         131'0
Mr. John R. Thoman, Reg.  Dir.
Environmental Protection Agency
Water Quality Office
1421 Peachtree Street,  N. E. ,  Suite 300
Atlanta, Georgia 30309

Dear Mr. Thoman:
We have reviewed the environmental study of the Cobb County,
Georgia,  Sewerage Improvement Project.  It is our opinion that
proper consideration has been given to protecting the environ-
ment in all instances mentioned.  The data and information
presented in this  report, show that every effort has been made
to reduce the environmental impact on construction sites and to
return the affected areas back to an original state as soon as
possible after work has been completed.   The positive effects on
all facits of the environment,  i.e. ,  water quality, air,  land,
noise, historical  and recreation, far outweigh the few negative
effects that would occur  during construction activity.

We would like to thank you for the opportunity to review this
environmental impact statement on this most important construc-
tion project.
                                  Sincerely,
                                  W. R.
                                  Acting Assistant Area Director
Enclosure

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          United States Department of the Interior
                                                                      0
                         GEOLOGICAL SURVEY

                       Water Resources  Division
                 900 Peachtree Street,  N.  E., Room 301
                        Atlanta, Georgia 30309
                                                       April 8, 1971
Mr. John R. Thoman
Regional Director
Environmental Protection Agency
Water Quality Office, Southeast Region
1421 Peachtree Street, N. E., Suite 300
Atlanta, Georgia 30309

Dear Mr. Thoman:

The environmental statement covering the expanded and improved waste
water conveyance and treatment facilities in Cobb County, has been
informally reviewed by this office.  The statement does not contain
sufficient specific data for a detailed evaluation of the impact that
the facility may have on the hydrologic environment.  Based upon the
information that was provided, some general comments follow.

The proposed location of the Cobb County, Chattahoochee River Sewage
Treatment Plant (Figure 1) cannot be identified precisely enough to
comment on flooding potential at the plant site.  If you can provide a
more specific site location, we would be happy to prepare an estimate
of flooding potential.

Figure 1 appears to locate the plant directly across from the City of
Atlanta's water supply intake and upstream from Peachtree Creek.  If
this is the correct location, then one concern for that site would be
occasional opportunities for sewage effluent to be carried upstream to
the City of Atlanta's water intakes when flooding of Peachtree Creek is
accompanied by low flow in the Chattahoochee River.

Land excavation for the interceptor lines could cause sedimentation
problems in the Chattahoochee River, depending on which plan is im-
plemented.  Excavation under plans D and E would probably produce the
least sediment, if these plans require that erosion control measures
are to be observed during construction.

-------
The consolidation of numerous sewage discharge outfalls into a single
outlet at the proposed Chattahoochee Sewage Treatment Plant will
certainly improve the general stream quality upstream from the plant.
However, we cannot comment on the impact of the effluent on streamflow
quality downstream from the plant because the statement does not present
data on the following:  (1)  the amount of effluent discharge, (2) the
degree of treatment, (3) the design low-flow discharge of the river, and
(4) the relationship of the Cobb County system to an over-all sewage
treatment and disposal plan for the Chattahoochee River adjacent to the
greater Atlanta area.

                                              Sincerely,
                                                        x*v>vr-
                                              John R. Georgtf
                                              District Chief
cc:  Mr. C. S. Lorentzson, Field Representative USDI
     Chief Hydro lo gist, WRD  (Attn:  Mr. G. H. Davis)
     Regional Hydrologist, WRD., ACR
                                    -2-

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                    DEPARTMENT OF  THE ARMY
                      MOBILE DISTRICT.  CORPS OF ENGINEERS
                               P. 0. BOX 2288
                           HOIILE, ALABAMA  36601
       IN REPLY REFER TO
        SAMEN-EE                                      9 April  1971
Mr. Frank M. Redmond
Interim Regional Coordinator
Environmental Protection Agency
1421 Peachtree Street, N. E.
Atlanta, Georgia  30309
Dear Mr. Redmond:

Reference is made to your  letter dated  31 March  1971,  addressed  to  the
South Atlantic Division Engineer and  requesting  comments regarding  the
environmental impact of Cobb  County,  Georgia,  sewerage improvements.
As you were advised by Mr. Herbert Rogers of the South Atlantic  Division,
this office has been requested  to comment for  the Corps on these projects.
The page numbers refer to  those of the  EPA  inclosure.

     a.  Page 3, Item 7.   Detail of the proposed Noonday Creek Plant
is insufficient for comment.  However,  it is presumed  that the effluent
will reach the recreation  waters of Lake Allatoona and that the  design
will be based on requirements for tertiary  treatment.   We should like
to be kept advised as to plans  as they  develop.

     b.  Page 7. last paragraph.  It  is indicated that this reach of
the Chattahoochee River is considered to be an interstate stream.   It
is suggested that more explanation be made  as  to the reason for  this
classification since many  readers may question this for the Buford  to
Allatoona reach.

     c.  No mention is made regarding the relationship of the Marsh
Creek Plant to the system.  Will it be  phased  out and  waste pumped  to
the Cobb County system via the  Marsh  Creek  Pumping Station?

     d.  Where sewerage facilities are  located below the 50-year flood
levels, necessary precautions are needed for protection of streams,
structures and public health.   Sealed and watertight manholes and pro-
tected lines will be required.

     e.  Flood hazard evaluations should be made along all creeks where
sewers and structures are  proposed.   Determination should be made as to
effects of the proposed construction  upon the  hydraulic characteristics
of the streams and particularly if the  proposed  works  will cause in-
creased flood levels.

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SAMEN-EE
Mr. Frank M. Redmond
9 April 1971
     f.  Precaution is needed to control sediment and prevent shoaling
of streams during construction.  Particular attention should be made to
possible erosion where sewers are located within the stream bed.

     g.  The section on environmental consequences should discuss the
interference with and/or loss of fish habitat and other aquatic biota
of construction within the creek beds.

     h-  Page 1.7.  The permanent commitment of lands for permanent or
maintenance rights-of-way will be irreversible.

We appreciate the opportunity to review and comment on your request.

                                  Sincerely yours,
                                   J. J. DANAHER
                                   Chief, Engineering Division
cc: South Atlantic Div.
    ATTN: SADYN

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                    United  States  Department of the Interior
                         BUREAU OF OUTDOOR RECREATION
                            SOUTHEAST REGIONAL OFFICE
                                810 New Walton Building
                                  Atlanta, Georgia 30303
IN KBPLY WE* TO:
                                                                   1 3 1971
          Mr.  John R. Thoman
          Regional Director
          Water Quality Office
          Environmental Protection Agency
          Suite 300
          1421 Peachtree Street
          Atlanta, Georgia  30309

          Dear Mr. Thoman:

          This is in reply to your letter of March 31, 1971, requesting our
          comments on the environmental study conducted by your agency on the
          Cobb County Sewerage Improvement Project.

          We support the efforts to eliminate and prevent water pollution of
          the Chattahoochee River and its tributaries.  The Department of the
          Interior's position on this project was set forth in Secretary Morton's
          letter of March 16, 1971, to Mr. Ruckelshaus (copy attached).  This is
          essentially the same position I presented to you at our meeting of
          September 18, 1970.

          We are pleased to find that Cobb County has proposed a comprehensive
          sewer system to prevent contamination of the Chattahoochee River and
          its tributaries.  We have been concerned about the water pollution
          problem because of the impact it may have on the recreation potentials
          of the Chattahoochee River and environs.  We fully comprehend the
          urgency of proceeding with the construction of the Rottenwood and
          Sope Creek interceptor lines.  Both Fulton and Cobb Counties have
          financial and other obligations which must be fulfilled.  We intend
          to help expedite action to this effect.

          That part of the Chattahoochee River and adjacent hillside known as
          the Chattahoochee palisades which  lies between the perimeter road
          (Interstate 285) and Interstate 75 is essential to our recreation
          plan for preservation, development, and enhancement of the Chattahoo-
          chee River.  We have identified this as the most outstanding natural
          area in the 48-mile reach of river under study.  We are proposing
          that this palisades area be preserved for all time.  Among its many
          unique  features are the rock outcrops, rapids, mature forests, and

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colorful flora.  These natural features must be protected in
planning and construction  of a sewer system.  We commend Fulton
and Cobb Counties for their cooperative effort in eliminating the
need for sewerline construction on the Fulton County side of the
river in the palisades area.

Attached is a set of guidelines which, if applied, will remove
objections we now have to  completing construction of the Rottenwood
interceptor and proceeding with that section of the Sope Creek
interceptor between Powers Ferry Road and Rottenwood Creek.  We
believe similar guidelines should be developed for all future and on-
going construction and made a part of the grant agreement and con-
struction contracts.

The Chattahoochee River  and adjacent lands constitute a unique scenic
and recreational resource  in the Atlanta urban area.  There is no
substitute or equivalent resource that can fulfill the special role
of this reach of the Chattahoochee.

In your environmental commentary, you acknowledge these unusual values
and suggest actions with a view toward protecting them.  In the
palisades area, you identify six alternatives which you refer to as
alternatives A through E for the location of the interceptor.  These
alternatives provide varying degrees of protection ranging from a
least-cost alternative proposed by Cobb County with no consideration
of other values to complete protection by tunneling along this entire
reach of the river.  We  appreciate the design difficulty and increased
cost of construction of  an interceptor sewer that will preserve the
natural features.  We concur with your statement that these values
are worth preserving and support your efforts to preserve them.  We
agree with your recommendation that alternative E is a preferred
alternative to the proposed Cobb County design.

The Federal Government should demonstrate its good faith by providing
a maximum amount of additional financial assistance to cover the
increased cost of sewer  improvement construction due to environmental
protection considerations.  We would support any action or legislation
which would make additional Federal funds available now or in the
future to aid Cobb and Fulton Counties.

Waterways and their adjacent lands are valuable public resources.  One
of the most appropriate  and important public uses of these corridors,
particularly in urban areas, is for open space and parks.  Three-
fourths of our population  now live in urban areas where there is a
great shortage of recreation opportunity.  Few, if any other, major
urban centers have an unspoiled river resource so beautiful and
secluded, fraught with natural and historical values and offering
such a delightful experience for anglers, boaters, and floaters as the
Chattahoochee between Buford Dam and Feachtree Creek.

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The diminishment of the scenic, recreational, historical, ecological,
and other values of this reach of the river and related lands cannot
be justified by a water pollution abatement program when practical
alternatives exist which can protect these values.  Eliminating
water pollution at the expense of other important public resources,
needs, and values is not in keeping with the intent of the National
Environmental Policy Act.  The time has come when we must accept our
part in effective land use planning.

Already the Chattahoochee riverbanks show the scars from erosion and
construction developments.  The appearance of mud and sandbars in the
river reflects the increase in siltation.  These developments are a
secondary effect which is influenced by sewerline construction and
this must be recognized in the environmental impact assessment and
recommendations.

We cannot accept the material submitted with your letter of March 31
as an adequate evaluation of the entire Cobb County system.  In this
context, we feel that all sewerage improvement projects along the
Chattahoochee River and its tributaries in Fulton and Cobb Counties
should be covered by an environmental impact statement as required by
the President's Council on Environmental Quality guidelines before any
additional applications for grant assistance are approved by your
agency.
                                 Roy K. Wood
                                 Regional  Director
 Attachments

 cc:   Honorable Sam Massell
      Mr.  Charlie Brown
      Mr.  Ernest Barrett

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              Guidelines  for Environmental Protection
         Cobb County, Georgia Sewerage Improvement Project
Rottenwood Creek Interceptor;

1.  To protect the riverbank in areas where clearing has not already
    been completed, it is recommended that a minimum undisturbed
    buffer zone of 20 feet be  left between the river's edge and the
    construction right-of-way.  Where practical, at least a 75-foot
    undisturbed zone should be observed.

2.  A qualified landscape architect should be employed to prepare and
    supervise execution of a plan for restoration of the surface area
    disturbed by construction with suitable vegetation and to prevent
    erosion and siltation.  The plan should insure an early return to
    an attractive natural vegetative cover in the disturbed areas.

3.  The contractor should be required to execute a performance bond
    to guarantee adequate restoration of the surface following
    construction to the satisfaction of the landscape architect.  An
    appropriate monetary penalty adequate to cover the cost of surface
    landscaping should be set in the contract.

4.  The Cobb County Recreation Department should investigate acquiring
    rights of public access for hiking, bicycling, and/or horseback
    trails on the sewerline rights-of-way and other areas in the river
    corridor.  The value of donated or purchased lands and easements
    provided to the county by landowners for public trail purposes
    are eligible as the county's financial share under the matching
    Land and Water Conservation Fund grant program of the Bureau of
    Outdoor Recreation.
Sope Creek Interceptor—Powers Ferry Road to Rottenwood Creek:

1.  Guidelines 1 through 4 above concerning the Rottenwood Creek
    interceptor also apply to this section of the Sope Creek inter-
    ceptor.

2.  The Environmental Protection Agency recommendations for alterna-
    tive E requiring tunneling in lieu of open cut excavation on the
    steep riverbank as originally proposed by Cobb County is appro-
    priate to protect the scenic and natural values through the area
    known as the palisades.

 3.   The tunneling proposal should be slightly amended by addition  of
     a  third  tunnel  to protect the scenic values  of a  highly visible

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rock outcropping on a point at the location of proposed manhole
number 2.

Provisions should be included in the tunneling contract specifying
that all tunnel spoil will be hauled away.from the river corridor
area for disposal and that the tunnel entrance areas, access roads,
and any other disturbed surface areas be restored to as near natural
condition as possible under the supervision of the landscape
architect.  Provisions of the performance bond covering restoration
of disturbed surface areas immediately after construction to restore
vegetative cover and eliminate erosion and siltation should apply
to the tunnel work.

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            United pfritcs Department of the T  ter-»™"

                         OFFICE OF THE SECRETARY
                          WASHINGTON, D.C. 202-10
                                                MAR 16 1971
Dear Mr. Kuckclshaus:
On September 14, 1970, the Bureau of Outdoor Recreation was  instruct?d
to study the Chattahoochce River in Metropolitan Atlanta as  tHe~site 6JT"
a possible major urban recreation area.  The heart of this area  is  a
primitive, virtually untouched stretch of unique scenic river bordered
by granite outcroppings.

Tlie natural beauty of a total of 20 of the 48 miles in the river study
area is threatened as a result of planned sewerlino construction closely
paralleling the rivcrbanks.

Applications for Federal assistance have been made by the local  governments
for all of these projects to the Ifctar Quality Office.  Current  projects
include the Rottenvood Creek*'and Sope Creek interceptor sever projects,
Cobb County, Georgia, and the Can.? Creek,* River Ridge,,and Roberts  Drive \
interceptor sewer projects of Fulton County, Georgia.  Construction has
been underway for several months on portions of the Rottcnvood Creek and
Roberts Drive lines.  Doth include several miles of high value scenic
riverbank.  Such construction appears to require the preparation and
review of an environmental impact statement consistent with  the  requirements
of Section 102(2)(C) of the National )'.nviron::icntal Policy Act of 1969.
The statement should include an analysis of alternative means of accomplishing
the project purpose.  So:!k> time ago we were advised by the Federal  Water
Quality Administration, the predecessor of the Water Quality Office that
an environmental statement was being prepared on the Rottenwood  Creek
interceptor scwerline.  To date we have not been afforded an opportunity
to review such a statement.

Retention of the natural and scenic characteristics of the Chattahoochee
River corridor, particularly the palisades, is central to its value for
public outdoor recreation.

Construction of sewerlincs in the Chattahoochee River study  area from
Buford Dam to Pcachtree Creek should include all possible planning  and
design modifications to protect the scenic and natural qualities of the
streanisidc area.  Consideration should be given to adequate  setback of
construction and clearing from the riverbank, tunneling through  rock out-
croppings in lieu of open-cut excavation and blasting, hauling spoil away
from the scenic river area, exercising care to avoid damage  to the  natural
landscape and significant or unusual vegetation during construction, and
restoring disturbed areas to their natural condition after construction is
completed.

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While our main concern is the potentially adverse effects of sewcrline
construction on the scenic and recreation values, potentially enhancing
features of this project — such as use of sewerline right-of-way easements
for public 1) iking or bicycling paths and access to the river — should be
considered in the preparation of the environmental statement.  The Bureau
of Outdoor Recreation's Southeast Regional Office can furnish assistance
in the preparation and planning of appropriate features.

While we fully understand and support your efforts to protect the water
quality of- the Chattahoochee River, sewerline construction must be subject
to the sawn requirements for environmental protection as any other federally
supported development.  Therefore, we urge immediate completion of environ-
mental statements on all segments of the sewerlines along the Chattahoochee
River from Buford Dam to Peachtree Creek which are being constructed with
Federal funds or assistance.  Further, it would appear appropriate to place
a hold on present construction activity pending review and approval of
environmental impact statements.  This action is necessary if we are to
avoid irreversible damage.

                                   Sincerely yours,

                                      fegd) Rogers C. B. Mortoil
                                    Secretary of the Interior
Honorable William  D.  Ruckelshaus
Administrator, Environmental Protection Agency
1626 K Street, X.  W.
Washington, D.C. 20460
 cc:

 Regional Director, Southeast Region

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ADVISORY COUNCIL.
ON
HISTORIC PRESERVATION

WASHINGTON. D.C. 20Z40
Oou-
                                                                  April  12, 1971
  Mr. John R. Thoman, Regional Director
  Environmental Protection Agency
  Water Quality Office, Southeast Region
  1421 Peachtree Street, NE,  Suite 300
  Atlanta,  Georgia  30309

  Dear Mr.  Thoman:

  Thank you for the opportunity to review your  preliminary environmental
  impact statement  concerning the Cobb County,  Georgia, Sewerage
  Improvement Project.  Because there  are no National Register
  properties involved, the Council will not comment on the project
  with regard to Section 106  of the National Historic Preservation
  Act of 1966 (80 Stat. 915).

  We  suggest that,  if you have not already done so, you ask for a
  review of the project by the Georgia Historical  Commission, 116 Mitchell
  Street, SW, Atlanta, Georgia 30303.   There may be some potential
  National  Register properties that we are not  aware of.
                                          Sincerely  yours,
                                          John D. McDermott
                                          Assistant Executive Secretary

  cc:   Mrs. Mary G. Jewett, State Liaison Officer  for Historic Preservation,
        Georgia Historical Commission, 116 Mitchell Street,  SW, Atlanta,
        Georgia 30303
THE COUNCIL it charged by the Act of October IS, lift. Kith advising tin President and Congress in the field of Historic Preservation,
neon-mending meaturet to coordinate govem-mental with private activities advising on the dissemination of information, encouraging public
interest and participation, recommending the conduct of special studies, advising in the preparation of legislation, and encouraging specialized
training and education. The Council alto hat the retponsiMit* to comment on Federal or Federally-assisted undertakings that have an effect
on cultural property luted in the National Register.

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         United States Department of the Interior

                       NATIONAL PARK SERVICE
                    Southeast Archeological  Center
                            P. 0. Box 454-7
                         Macon, Georgia  31208

H2219                       April 13, 1971
Mr. John R. Thoman
Water Quality Office
Southeast Region
Suite 300
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309

Dear Mr. Thoman:

Our office has reviewed the project data and other information on the
Cobb County, Georgia, Sewerage Improvement  Project and our comments
will be confined to archeological and historical resources.

We were pleased to note that the impact of  the project on archeologi-
cal and historical resources was recognized as one of the environmental
consequences of the development.  Construction projects of many types
cause an irreversible or irretrievable commitment of such resources,
and we are pleased to see that steps are being taken in the Cobb County
Project to mitigate this loss by survey and salvage of the archeologi-
cal and historical data in advance of construction.

The opportunity to review thia project has  been appreciated.

                                   icerely,
                                      W.  Griffin
                                   Lef,  Southeast Archeological
                                   Center

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                                                 EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE  OF ECONOMIC                              Region IV
OPPORTUNITY
       April 15, 1971
730 Peachtree Street, N. E.
  Atlanta.Georgia 30308
       Mr. John R. Thoman
       Regional Administrator
       Environmental Protection Agency
       Suite 300, 1421 Peachtree Street, N. E.
       Atlanta, Georgia  30309

       Dear Mr. Thoman:

       This responds to your letter of March 31,  1971 requesting that
       the Office of Economic Opportunity review  and provide any adverse
       objections to the Cobb County, Georgia Sewerage Improvement Project.

       We have reviewed this proposal from the standpoint of possible
       adverse affects in Urban Areas which may cause congestion or
       have long range special impact on Low-Income Neighborhoods.

       The only area of impact concern which in our opinion may effect
       land use and subsequently the residents would be the "Palisades"
       area between 1-285 and 1-75.  It is gratifying to note that the
       various levels of government responded to  concerned citizens
       objections and provided measures which assures the return of
       the area as far as practicable to its original, natural site.

       We commend Cobb County as well as the other local, state and
       Federal agencies for proceeding  in a continuous, yet cooperative
       effort to  implement this well planned proposal.  We interpose
       no objections to the approval of this project.

       Sincerely,
        Roy E.  Batchelor
        Regional Director

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 CHAIRMAN
 JOSEPH a. CUMMINO
   AUOUBTA, BA.
  GEORGIA HISTORICAL  COMMISSION
  A DIVISION OF THE OFFIBC Or SECRETARY OF STATE SEN W. FORTBON. JR.
                11* MITCHELL BTMECT. B.W.
              ATLANTA, GEORQIA 3O3O3

                  April 23, 1971
                                                         EXECUTIVE SECRETARY
                                                         MARY BMCHOHY JIWETT
 MEMBERS

 OH. JAMES c. BONNER
   MILLCDOEVILLE. OA.

 Mmm. WILLIAM L. BRANNEN
   METTBR, BA,

 DM. J. T. BRYBON
   WASHINGTON. OA,

 BEVERLY M. DUBDSE, JR.
   ATLANTA, OA,

 THOMAS H. QIQNILLIAT
   SAVANNAH, OEDROIA

 JOHN H. BDDDARD
   ORIFFIN, DA.

 DR. HENRY T. MALONE
   ATLANTA. OEOROIA

 GORDON F. PRICE
   ATLANTA • DAHLDNEBA
 HISTORIC SITES
 CONFEDERATE NAVAL MUBEUM
   COLUMBUS, OA,
 DAMLONCOA COURTHOUSE
 GOLD MUSEUM
   DAHLONEOA. BA.
 EAOLE TAVERN
   WATKINSVILLE. OA,
 ETQWAH MOUND*
   OAHTEMVILLE. OA.
 FOUT ilAOCTflN
   BAVANNAH. BA.
 Four KINO BEOHOE
   DAKIEN. OA.
 FOITT MCALLIBTER
   RICHMOND HILL. OA.
 JAMKTT MANOR
   TOCCDA. OA.
 CRAWFORD LONO MUSEUM
   JEFFERBON. DA.
 MACKAY HOUBE
   AUOUBTA. OA.
 MIDWAY MUSEUM
   MIDWAY, OA.
 NEW ECHOTA
   OALHOUN. OA.
 VANN HOUSE
   SmtlNO PLACE.  OA.
 WABHINOTON-WILKEB MUSEUM
   WABHINOTON. OA,
WAYNEBBORD HISTORICAL MUSEUM
  WAYNEBBORO, BA.
Mr.  John R. Thoman, Regional  Director
Environmental Protection Agency
1421 Peachtree  St., NE
Atlanta, Georgia  30309

Dear Mr. Thoman:

      I regret the delay in  reviewing your preliminary
environmental impact statement  concerning the  Cobb County
Sewerage Improvement Project  but wished to have more infor-
mation about potential National Register properties before
making a statement.

      Nominations  to the National Register in Georgia are
far  from complete as the program is fairly new and our staff
is quite small.   However, we  do have a rather  complete
knowledge of the important historical and archaeological
properties in the state.

      There are  two very important historical sites near and
endangered by the plans for the Sewerage Improvement Project.
According to my information,  the ruins on Soap Creek will
probably not be endangered.   I  hope that is true.   One of the
most important  archaeological sites in Georgia is  the site
of Standing Peachtree in the  vicinity of which,  I  understand,
a sewerage treatment facility will be constructed.  Much of
this area has been disturbed  already without any knowledge
gained or study made.  If your  facility can be placed else-
where for the protection of this site, it would be an important
contribution to Georgia's history.   If that is not feasible,
I should hope that any archaeological work would be handled
under strict controls and with  qualified personnel so that
some knowledge  can be gained  from this important site.

      I am interested, of course, in the total  area as the con-
servation of historical and archaeological properties is a part
of a conservation of the total  environment.  I should like
MONUMENTS
  CHEHAW
  New Hart CHURCH
  TROUP TOMB
HISTORICAL MARKERS

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                     -2-
to be advised as to future plans in the area.
                             Sincerely,
MGJ:noh
cc: Mr. John T. McDermott

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                      Metropolitan Development  Office
             DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                   PEACHTREE SEVENTH BUILDING, ATLANTA, GEORGIA 30323
                                 Room 645


REGION iv                                                          May  7}  1971


                                                                  IN REPLY REFER TO:

                                                                       4M
    Mr. John R. Thoman
    Regional Director
    Environmental Protection Agency
    Suite 300, 1421 Peachtree Street, NE.
    Atlanta, Georgia  30309

    Dear Mr. Thoman:

    Subject:  Cobb County Sewerage Improvement Project
              State of Georgia

    We have reviewed the final draft environmental impact statement
    transmitted with your letter of April 28, 1971.

    We find no reason to revise or extend the remarks contained in
    our letter of April 5 on this subject.  You have our wholehearted
    support in carrying out this project as proposed.

    We are returning one copy of the draft as it is in excess of our
    needs.

                                  Sincerely yours,
                                  AssistatvfRegional Administrator

   Enclosure

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                                                          f~*^       ~T
         United States Department of the Interior  O 0 «, <\

                      NATIONAL PARK SERVICE
                   Southeast Archeological Center
                           P.  0. Box 4547
L7423                       May 13, 1971
Mr. Frank M. Redmond,  Jr.
Environmental Protection Agency
Suite 300, 1421 Peachtree  Street,  N.E.
Atlanta, Georgia 30309

Dear Sir:

We acknowledge receipt of  the Draft Environmental Impact Statement
for the Cobb County,  Georgia, sewerage project.

Upon completion of the review, our comments will be forwarded  to the
National Park Service's Southeast  Regional Office, Richmond, for
consolidation and submission to your office.  The opportunity  to
review this draft has been appreciated.

                                Sincerely,
                                 Richard D. Faust
                                 Acting Chief, Southeast
                                   Archeological Center

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              TED STATES  DEPARTMENT OF AGRICU   RE
                    FOREST SERVICE
                Southeastern Area, State and Private Forestry
                     Atlanta, Georgia 3O9O0

                                         1920

                                        .May 17, 1971


 Mr.  Frank M. Redmond, Jr.
 Special Assistant
 Environmental Protection Agency
 Suite 300, 1421 Peachtree  Street,  N.E.
 Atlanta, Georgia  30309

 Dear Mr. Redmond:

 Here are our comments on the Draft Environmental  Impact
 Statement on the Cobb County, Georgia, Sewerage Project.

 As stated in our earlier letter of April 7,  1971  to
 Mr.  Thoman,  proper consideration has been  given to
 protecting the environment in all  facets of  the project
 The  positive effects on  water quality, recreational
 values  and consideration given to  aesthetic  values in
 retention of "Palisades" area are  to be commended.

 We believe that proper consideration has been  given to
 protecting the environment during  construction of this
 project.

 Thank you for the opportunity of reviewing and commenting
 on this  important project.

 Sincerely,
                   fT
G. L. DOWNING   «-—~A
Acting Assistant Atda Director

Enclosure

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                 United States Department of the Interior
                              NATIONAL PARK SERVICE
                           SOUTHEAST REGION, P. O. BOX 10008
                        FEDERAL. BUILDING. RICHMOND. VA. 23240
IN REPLY REFER TO:
                                        W 21
       A98  SER(CP)
        AIR MAIL

        Mr. Frank M.  Redmond,  Jr.
        Special Assistant
        Environmental Protection Agency
        Suite 300, 1421 Peachtree  Street, NE
        Atlanta, Georgia 30309

        Dear Mr. Redmond:

        We have reviewed the Draft Environmental  Impact Statement on the
        Cobb County,  Georgia Sewerage Improvement Project  (Chattahoochee
        River Sewage  Treatment Plant, Rottenwood  Creek Interceptor Sewer,
        Sope Creek Interceptor Sewer), enclosed with your  letter of
        April 28, 1971.

        In a letter to Mr. John R. Thoman,  Regional Director, Environmental
        Protection Agency, dated April 6,  1971, Mr. L. Boyd Finch, Assistant
        Director, Southeast Region, National Park Service, furnished our
        comments on this project.   (Copy enclosed.)

        The Draft Statement does not appear to recognize our comments
        contained in the first two paragraphs of  our April 6 letter.  There
        is no indication that the  State Liaison Officer for the National
        Register of Historic Places has been consulted, as suggested in
        our previous comments.

        The Draft from the standpoint of archeological and historical resources
        notes the recognition given to the impact of  the project upon those
        resources as one of the environmental consequences of development.

        Because construction projects of this type  often cause  an  irreversible
        and irretrievable commitment of prehistoric and historic resources,
        we concur in principle with the steps taken locally to  initiate  a
        survey and salvage program in advance of  construction in order  to
        mitigate that loss.

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Your consideration of our comments in the final Statement will be
appreciated.


                                   Sincerely yours,
                                  fe^-c
                                   Vincent El
Vincent Ellis
Acting Director
Southeast Region
Enclosure

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                                              6 tsn
 A93J5£R
 Ur.  John R.  Thoman, Regional Director
 Environmental Protection Agency
 Water Quality Office. Southeast Region
 1421 Peachtree Street, N. K.
 Atlanta, Georgia 30309

 Dear Mr. Thonan:

 We have reviewed the environmental study of the Cobb County, Georgia
 Sewerage Improvement Project, enclosed with your letter of March 31,
 1371.

 Keanesaw Mountain National Battlefield Park,  an existing unit of the
 National Park Systers, is within the area to be affected by the project.
 »iien this study wns initiated several years ajo,  the National PaA
 Service indicated its willingness to cooperate with  ths County with tae
 understanding that safeguards for the historic features at Eeniiesaw Mour
 t?in T.-oulc? be recognized.  Tlje statement should give appropriate recog-
 nition to this Parlt and assure that the present plan does  not endanger
 the  historic and natural values of the Park.

 A  potential  unit of the National Park System,  the Blue  Ridge Partly
 Extension, is scheduled to terainate near Kennesa^ Mountain National
 Battlefield, north of Atlanta and Marietta,  Georgia.  It is possible
 that the subject project could affect the Parkway.

 The  environmental statement shonld show evidence  of  consultation ^ith
 the  State Liaison Officer for the National register  of  Historic Places.
 Thia officer,  r.Irs.  ilary Gregory Jewett,  Executive Secretary, Georgia
 Historical Commission,  116 Hitchell Street,  S.  W., Atlanta, Georgia
 303^3,  should be consulted for possible National  Register  properties
 that aay exist in the area.   These Include all registered Historic
 LanOaarka) as well aa  other Register properties of State and local
 significance.
The eavlrooaantal statevent on page 6  recognize* archeological resources
•ad the e»ployoent of two archeologiats by the County to coordinate
studies and excavations at the Peachtree Site of the Treatment Plant.

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Froa our review of the data  contained  in the report on this Batter,
we question whether  this includes  the  entire project area or is limited
to the Treatment Plant site.  We suggest that Mrs: Jewett also be con-
sulted concerning areheolc-jical resources within the entire project
area as delineated on Figure 1 of  th«  attachments.  Her findings should
be recognized in the final statement.

                                        Sincerely yours,
                                        L. Boyd Finch
                                        Assistant Director
                                        Southeast Kejion

bcc: w/cpy inc transrnittal Itr
WASO, Special Planning Studies
Mr. Lorentzson, Atlanta
Mr. TVeeas, Atlanta
Chief, Southeast Archeological Center
Supt., Kennesnw Mountain
Supt., Blue Ridge Parhway
     Mary Gregory Jewett

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                     DEPARTMENT OF THE ARMY
                       MOBILE DISTRICT. CORPS OF ENGINEERS
                               P.O. BOX 22BI
                            MOBILE. ALABAMA  36801
        IN REPLY REFER TO

        SAMEN-EE                                       27 May 1971
 Mr.  John R.  Thoman
 Interim Regional Coordinator
 Environmental Protection Agency
 1421 Peachtree Street, N.E.
 Atlanta, Georgia  30309
 Dear Mr.  Thoman:

 Your draft environmental statement for the sewage project in Cobb
 County, Georgia,  was forwarded by Colonel J.  B.  Newman,  OCE, to this
 office  for comment.   We have reviewed the statement and  our comments
 are  as  follows:

 1-   Page  3.  para.  II. third line.   Sentence should read:  "An inter-
 ceptor, for  the purpose of this statement,  is defined  as  a sewer ..."

 2-   Page  4.  para.  I1-7.   Detail of the proposed  Noonday  Creek Plant
 is insufficient for  comment.   However, it is  presumed  that the efflu-
 ent  will  reach the recreation waters of Lake  Allatoona and that the
 design will  be based on requirements for tertiary treatment.   We
 should  like  to be kept advised as  to plans  as they develop.

 3.   Page  8.  para.  IV.

     a.  Much of the  project is located in low areas and no mention is
made of flood protection.   Where sewers and structures are located
below the  50-year  flood  levels,  precautions necessary  to  protect the
structures should  be indicated.   Sealed,  watertight manholes  and pro-
tected lines should  be required.

     b.  Flood hazard evaluations  should be  made  of project areas where
sewers and structures are  proposed.   The statement should indicate
effects of the proposed  construction upon the hydraulic characteristics
of the streams, particularly  if increased flood  levels will result.

     c.  The  statement should  discuss the interferences with and/or
loss of fish habitat and other aquatic biota  which will result from
construction within  the creek and  river beds.

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SAMEN-EE                                               27 May 1971
Mr. John R  Thoman

    d.  Discussion should be made of erosion of trenches where sewers
are located within stream beds and precautions to be taken to control
sediment and to prevent shoaling should be outlined.

4.  Pafte 9. second full para.  It is indicated that this reach of the
Chattahoochee River  is considered to be an interstate stream.  It is
suggested that more  explanation be made as to the reason for this
classification since many readers may question this for the Buford to
Atlanta reach.

5.  Page 19.  The statement should  indicate that the commitment of lands
for permanent or maintenance  rights-of-way and the materials and labor
involved in construction will be irreversible and irretrievable.

We appreciate the opportunity to comment  on the statement.

                                  Sincerely yours,
                                      IY A.  GRIFFITH
                                   COL,  Corps  of Engineers
                                   District  Engineer
 cc:  Council on Environmental
      Quality (10 cys)

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      SIERRA  MB   CLUB
                                Chattahoochee Chapter
                                3575 Summitridge  Dr.
                                Doraville, Georgia
                                30340
                                June 21, 1971

Mr. John R. Thoman
Director, Southeast Region
Environmental Protection Agency
1421 Peachtree St., N.E.
Atlanta, Georgia
30309

Dear Mr. Thoman:

The Chattahoochee Chapter  of the Sierra dub is both pleased
by some of the statements  made in, and disturbed by some of
the fsaterjdssiaf from,  the draft environmental impact
statement made by the Environmental Protection Agency,
Southeast Region, April, 1971, on the Cobb County  Sewerage
Improvement Project.  We request that this letter, which
states our objections and  commendations, .be included in
the final impact statement.

We specifically object to  the following omissions:

     1, Numerous scenic  creekbeds and gorges will  be destroyed
        or significantly altered by construction of inter-
        ceptor sewer lines.  Seven interceptors are described
        in the report, all of which follow creekbeds.   The
        present scene of destruction along Rottenwood  Creek
        between Ahers Mill Road and the Ghattahoochee  River
        demonstrates the virtual impossibility of  constructing
        an interceptor sewer along a creek without destroying
        its beauty.

     2. Alternative routes for the creek sewers are not
        mentioned.  Interceptors can usually be constructed
        along existing roadways with far less environmental
        alteration than  if placed in creekbeds. For example,
        the Rottenwood interceptor could have been located
        along 1-75 between 1-285 and the Chattahoochee
        River rather than  along the parallel Rottenwood
        gorge.  Routing  along roadbeds sometimes requires
       l ore, enjoy, and protect the nation's scenic resources.

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        greater construction and/or maintenance costs, because
        pumping stations must  lift the sewerage over ridge lines.
        However, the American  public in general and the Atlanta-
        area residents in particular must be willing to pay
        for the protection of  their ever-dwindling natural
        resources.

     3. Unique botanical resources will be destroyed by the
        construction of the Sope Creek Interceptor between
        Powers Ferry Road and  Rottenwood Creek.  This area,
        known as the "Palisades" and generally considered
        to be the most scenic  portion of the Chattahoochee,
        contains flora such as flame azalea, mountain laurel,
        rhododendron, and pink lady slipper, which is an
        endangered species.  Destruction of these resources,
        and the rock bluffs, «. 11 limit its usefulne«s as a natural
        area, use which has been recommended by the Bureau of
        Outdoor Recreation in  its draft report.

In spite of these objections,  we commend Cobb County for its
foresight in attacking the sewerage problem before it becomes
critical and for its co-operation with Pulton County in establishing
joint interceptors.  Vfe also commend the Environmental Protection
Agency for recommending alternative E (3700 feet of tunneling)
along the Palisades, and for recommending the following construc-
tion guidelines for projects along the Chattahoochee:

     1. A minimum buffer zone  of twenty feet between the river's
        edge and the construction right of way.

     2. Consultation with the  Forestry Service to determine
        methods to limit the loss of trees.

     3. Removal of surplus excavated material.

     4. Restoration of disturbed surface areas and the employ-
        ment of a landscape architect.

Unfortunately, it is questionable whether these recommendations
will be followed.  The survey  line along the Palisades, as
witnessed by members of our club during recent hikes, does not
honor the twenty foot buffer zone.  Statements have been heard
that indicate that alternative B (excavation) will be selected
rather than alternative E, primarily because the Federal Gov-
ernment will be unable to pay  a reasonable portion of the addi-
tional costs.  The severe damage caused by construction in
Rottenwood Gorge indicates that similar damage will occur during
construction in creek beds.  Wfe therefore strongly recommend
that:

     1. Alternative routes (non-creekbed) be evaluated for

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        interceptor routes*

     2. A means, »uch a* performance bonds or penalty clauses,
        be written into contracts to guarantee compliance with
        construction guidelines,

     3. Alternatives D (complete tunneling) or E (partial
        tunneling) be selected for the Scpe Creek interceptor
        in order to preserve the Palisades*
                                Sincerely,
                                Kenneth W. Martin
                                Secretary

cc:  Mr. Ernest Barrett
     Chairman, Cobb County Commission

     Mr. Rogers C. B« Morton
     Secretary, Department of the Interior

     Mr. William D. Ruckelshaus
     Administrator, Environmental Protection Agency

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                 Friends of  the  River, Inc.
                 Suite  421, 100 Colony Squar
                 1175  Peachtree  Street, N.E.
                   Atlanta,  Georgia  30309
                        404/892-8242
                                        June 23, 1971
Mr. John Thoman, Acting Regional Director
Environmental Protection Agency
Suite 300
1421 Peachtree Street, N.E.
Atlanta, Georgia  30309
Dear Mr. Thoman:

     As president of "Friends of the River, Inc.", I
wish to put on record the consensus of the membership
of this organization regarding the proposed Cobb County
Soap Creek Interceptor sewer line.

     First, let me assure you that we are very aware
of the need for cleaning up the pollution of the Chatta-
hoochee River, and wholeheartedly endorse this objective.
It would, however, seem that these sewer lines could
be better located.

     Based on our evaluation of the preliminary study,
and aware of the impact which developmental sewers have
on the growth patterns of the areas they serve, we are
opposed to the present recommended route.  Alternate
Route "D", as shown in the study, would be far more
desirable from an environmental point of view, however,
it does not appear to be feasable from a cost standpoint.
Therefore, we recommend alternate Route "E" with the
addition of a short tunnel to protect the small out-
cropping which occurs near the head of Long Island.

     We feel that while alternate Route "E* is less
desirable than Route "D" it is the minimum recommenda-
tion that is acceptable.  We recognise that additional
funds will be needed to follow this recommended alterna-
tive and strongly urge that methods be found to insure
maximum participation by the Federal Government in the
funding.

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Page 2                                  June 23, 1971
Mr. John Thoman
     We would be remiss if we failed to commend this
preliminary plan for recognizing the need for exploring
and recommending alternative routes.  We would also like
to compliment Cobb County for its cooperation with the
other agencies which have contributed so much time to
this project.

     In spite of the thoroughness with which this report
was put together, our organization was struck with the
omission of any pre-planning to protect the beds of the
smaller creeks which lie in the path of the proposed
sewer line.

     We are further concerned about the restoration of
the area.  Past experience has proven the need for ade-
quate guarantees that complete restoration will be carried
out, and with a minimum delay between the completion of
the line construction and the beginning of the restoration
process.

     Lastly, we urge you to initiate further intensive
environmental impact studies before further penetration
is made in either the valuable Soap Creek or Rottenwood
Creek areas.
                              Cordially ,
                                s. Harold C. McKenzie,
                              President ,
                              Friends of the River, Inc.
KBM:wo
cc:  Mr. William D. Ruckelshaus, Admin.
     Environmental Protection Agency

     Mr. Rogers C. B. Morton,
     Secretary of the Interior

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nmcFRS

• -Irs. GMarie-, Yafn, Jr., President
i  I C-,-,:ipr. Vicp President
'.'•!:• irrt i . Grrenblatt. Secretary
.: o. >oh'v;on Treasurer

BOARD OF DIRECTORS

1 •' '- •  •' • I'.' -on. Jr.. Composer
   -, ; . Lireml-er:;. Civi<- lender
  ' Cockier. Lawyer
; •- • o.- F Oenn.ird. Lawyer
::i!,'.,:i1 L. :!':) Jl..
             SAVE
              SAVE AMERICA'S VITAL ENVIRONMENT
                      P. 0. Box 52652
                     Atlanta. Ga. 30305
                            June 23, 1971
Mr. John Thoman
Regional Director
Environmental Protection Agency
1421 Peachtree Street. N.E.
Atlanta, Georgia 30309

Dear Mr. Thoman:

We would like to have these  coranents  on the Draft Environmental
Impact Statement of the Cobb County Sewerage Improvement Project
included in the final Impact Statement*

We would like to compliment  the Environmental Protection Agency
on the outstanding environmental protection offered the riverbanks
and scenic rock outcrop areas along the Chattahooche Palisades area.
The tunneling as proposed in alternatives D ,or E is an absolute
necessity for the preservation of the beauty of this unique area
of the river.

The construction precautions recommended on page 15 are excellent,
but we feel they must be guaranteed in  order to be effective.

We applaud Fulton and Cobb Counties for their cooperative efforts
to clean up existing pollution and preserve the scenic aspects of
the river.  However, we were disappointed that no protective en-
vironmental consideration had been offered for the numerous creeks
involved in the project.

We can only conclude that the fate of these creeks may be the same
as or worse than that of the formerly beautiful gorge and valley
of Rottenwood Creek.  The devastation of Rottenwood' Creek is a poignant
example of what can happen to a creek even when a sewer line is placed
in the bed or gorge with care.  Alternate routes for river bank and
creek bed sewers, even though possibly  necessitating pumping stations,
must be found.  No such alternatives  were considered for any except
the Palisades area in this impact statement.

We do not believe the Citizens of these Counties, the State of Georgia,
nor of the United States are willing  to accept the destruction of
their natural resources as the price  they must pay for clean water.
                       We hope the  Federal Government can find a way to  further  supplement
                       the funding  of this project in view of the  local  government's praise-

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                  - 2 -
worthy efforts to clean up and preserve this river which is being
considered for a national urban park.

                            Sincerely yours,
                           Mrs.  Charles  Yarn        ^
                            President,  SAVE



JHT/gn

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             UNITING GEORGIA'S CONSERVATIONISTS
           THE GEOROIA CONSERVANCY, INC.
                   1O25 CANDUER BUILDING
                ATLANTA, GEOROIA 30303
                      4O4/525-I828
                    June 24, 1971
Mr. John Toman
Environmental Protection Agency
Suite 300
1421 Peachtree, N. E.
Atlanta, Georgia  30309

Dear Mr. Toman:

    The Georgia Conservancy would like to comment on the
environmental impact statement on the Chattahoochee River
tendered to us, and have these comments included in the
final draft.

    First, we wish to congratulate the Environmental
Protection Agency for its efforts to simultaneously
stimulate both cleaning up of the pollution in the Chat-
tahoochee, and preservation of its natural beauty.  We
particularly wish to endorse alternative E concerning the
planned Sope Creek Interceptor, which would provide safe,
effective removal of sewage, and maintain the extraordinary
scenic beauty of the Cobb County Palisades.

    We would also like to commend Cobb County for under-
taking a sewage abatement program before the situation
becomes critical, and we urge the allocation of federal
funds to aid Cobb in following alternative E for the Sope
Creek Interceptor.

    There are, however, some curious and serious omissions
from the study.

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 Mr. John Toman
 June 24, 1971
                                                  page 2
    ^Perhaps most  serious  is  the  failure  to discuss any
 environmental assessment  on  the  various  creek basins, and
 to discuss the adverse  impact which sewer construction
 will  have on these historic, beautiful creeks.

    Also not discussed  is whether the creeks will be
 returned to a relatively pure state by the sewer Ci.e.,
 will  it remove the sewage from Sope Creek?  Does the
 Rottenwood sewer make Rottenwood clean?).

    We  feel that the tremendously adverse impact of sewer
 placement in Rottenwood Creek Gorge should be surveyed
 and considered before any new sewers are considered for
 Sope  and other creeks in Cobb County, or before Rotten-
 wood  Creek is  altered, not only for our lifetimes,  but
 for geological  times.

    While we stronfcly advocate pollution abatement, we do
 not believe that it must entail such extensive  environ-
 mental disruption.

                               Sincerely,


                            CLActuAeE

                               Claude  E.  Terry      I
CET:j

cc:  Mr. William D.  Ruckelshaus

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                                                      APPENDIX I
                                       PRIVATELY BUILT SEWAGE TREATMENT SYSTEMS
                                 WHICH COBB COUNTY WATER AND SEWERAGE SYSTEM OPERATES
             Plant M

Atlanta Country Club Estates

Cochise Subdivision

Farmington Subdivision

Franklin Road

Interstate North

Johnson Woods (Vinings) Subdivision

Regency Apartments

Seven Springs Estates

Terrell Mill Estates

Waverly Woods

Woodland Brook Farms
              Treatment Processes

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination*

Extended Aeration

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination*

Extended Aeration, Sand Filtration*, Chlorination*

Extended Aeration

Aerated Lagoon, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond

Extended Aeration, Chlorination, Polishing Pond
Notes:

* Not in service at time of May, 1968 inspection

1 Construction essentially complete; not yet accepted by Cobb County Water and Sewerage Systei

2 Under construction

3 Not yet receiving sewage flow
Remarks

   1

   1
  2,3
  1,3

   1

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