V
DENVER AREA TASK FORCE REPORT

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W/f 7SDJB-	"
01%'
ENVIRONMENTAL PROTECTION AGENCX
Region VIII Library, 8M-ASL
1860 Lincoln St., Suite 103
Denver, CO 80295
j DENVER AREA TASK FORCE REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
FEBRUARY, 1975

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CONTENTS
I.	Introduction
II.	Evaluation of Needs
A.	Municipal Waste Treatment and Interceptor Needs
B.	Alternative Management Strategies
C.	Recommendations on Management Strategy
III.	Recommendations on Colorado Priority System
A.	Guidelines for Development of Construction Grant System
B.	Recommended Policies and Guidelines
C.	Recommended Point Determination
1.	Plant Determination
2.	Sewer Line Determination
D.	Recommended Colorado Priority List
E.	Recommended Construction Priorities for Denver Metro Area
IV.	Special Project Recommendations
A.	City and County of Denver Permit
B.	Sludge Handling
C.	Denver Northside Baseload
D.	Northeast Project
E.	Platte II/Delgany
V.	E.I.S. Considerations

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I. Introduction
On January 16, 1973 John Green, Regional Administrator established a
task force to finalize Agency recommendations on the following items:
Recommendations on
1.	Colorado Construction grant priority system and criteria
Recommendations on
2.	Colorado construction grant priority list and subsequent project
list for construction grants.
3.	Identify the needs and problems of a number of Denver Metropolitan
Area projects.
a.	City and County of Denver Permit
b.	Sludge Handling
c.	Denver Northside baseload
d.	Northeast Project
e.	Platte II/Delgany
f.	Clear Creek/Sand Creek Facilities
g.	Lower Platte Facilities
4.	Recommendations on E.I.S. candidates in Denver Metropolitan area.
Early in the task force meetings it was recognized that the total needs
of the Denver Metropolitan area could not easily be understood if reflected
in one project list. It was decided that a separate list of the Denver area
projects be developed which would indicate the Agency's ranking of said
projects, and which would be, in general, consistent with the Statewide
planning criteria.
The ensueing narrative is the cooperative result of the task force on
the above items and reflects key decision criteria, and data accumulated.
Because of space restrictions and entire data on which we have based our
recommendations could not be included, but is available on request from
Mr. Paul Ferraro.
Those individuals assigned to the task force are:
Messrs. Paul Ferraro, Chairman
Phil Overeynder
Dale Vodehnal
George Hartmann
Bill Bertram
Mike Gansecki
Tom Harris
Jim Rakers
-1-

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II. Evaluation of Needs
A. Municipal Waste Treatment and Interceptor Needs
In order to develop and evaluate alternative strategies for a-
chievement of water quality objectives in the Denver Metropolitan
Area and throughout the remainder of the Colorado, municipal waste
treatment and interceptor needs were developed. A cursory analysis
of needs presented by the State Needs Survey, Basin Plans and Facility
Plans showed a substantial variation in the estimated costs to achieve
secondary treatment and water quality standards on a statewide basis.
These discrepancies are summarized below and in Tables 1, 2, and 3.
1.	The estimated statewide needs for capital construction related
to municipal treatment and interceptors to meet secondary treatment
and water quality standards is $351 million based on information
contained in currently available Colorado's basin plans. This compares
with an estimate of $331 million submitted in the Colorado Needs
Survey to meet the same objectives. The estimated cost to meet the
objectives as reported by "201" waste treatment agencies (adjusted
for AWT needs not included in the priority system] is $471 million.
(Table 5)
2.	There is substantial discrepancy between the estimated needs
contained in the basin plans and the State Needs Survey.
3.	There is a substantial discrepancy between the estimated needs
contained in the basin plans and the adjusted needs reported by indi-
vidual 201 agencies to meet the requirements of FWPCAA, particularly
in the Denver Metropolitan Area.
4.	This large discrepancy ($120 million) in estimated needs in the
Denver Metro Area can be accounted for primarily by the sizing of
facilities reported by individual "201" Agencies rather than due to
inflated construction costs.
a.	The 1985 aggregate design treatment capacity reported to be
required by the Denver Regional Council of Governments is 291 MGD
for the 3(c) Planning Area. For the same planning area, individual
"201" agencies estimate a required total treatment capacity of 446
MGD. (Table 2). This is a discrepancy of approximately 225 MGD
in wastewater treatment plant capacity required ir> the next 10
year period.
b.	Adjustment of the reported costs for treatment needs estimated
by individual "201" Agencies in the Denver Area to reflect ad-
trea^ment needs yields a total treatment need of
$186 million, this compares to $77 million in treatment needs
estimated from the 3(c) Plan. (Table 4)
-2-

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c. Comparing unit costs for wastewater treatment plant expansions
of secondary treatment capacity, the average capital costs estimated
by the "201" Agencies is $142 million =.54 million/MGD
"265 MGD
additional capacity added, vs. the costs estimated in the 3(c)
Plan of approximately $.5 million/MGD additional capacity added.
It is therefore apparent that essentially the same costs per unit
of wastewater treated were used in both cases and the substantial
difference in estimated costs can be related solely to the 225
MGD treatment capacity differential.
5.	Based on a per capita use factor of 100 gpcd, the additional
capacity presently planned for by the "201" agencies would account for
capacity for an additional 2.25 million persons above the projections
developed by the Denver Regional Council of Governments through their
Joint Regional Planning Program.
6.	Examples of specific service areas within the Denver Metropolitan
Area where substantial discrepancies in design capacities projected by
DRCOG and "201" agencies are as follows:
1985 Design Capacity
Service Area	DRCOG	"201" Agency
Denver Metro & Sand Creek & Clear Creek
185.5
•MGD
310 MGD
Big Dry (Westminster)
6
MGD
25 MGD
Brighton (lower South Platte)
7
MGD
30.9 MGD
South Adams
4
MGD
6.8 MGD
Erie
0.5
MGD
2.0 MGD
Other service areas are essentially within the design flow limits
set by DRCOG in the 3(c) Plan.
7. Complete data is not available to substantiate the magnitude of
descrepancies in design capacities between basin plans and facility
plans In the remainder of the State. Spot checks of capacities being
designed by facility planning agencies indicate that generally there
are no large descrepancies. However, there inevitably will be indi-
vidual circumstances where problems will arise.
Alternative Management Strategies
Assessment of the needs for capital expenditures- for wastewater
treatment facilities indicates that there is substantial descrepancies
based primarily on the amount of additional treatment capacity provided
in the Denver Metropolitan Area. Needs were therefore categorized
by needs to meet secondary treatment and needs to meet advanced water
treatment capacities. Similar needs were developed for expanded capaci-
ties for both basin plans and 201 Plans. (Table 5)

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A number of different strategies were developed and evaluated
based on their costs, achievement of secondary treatment and water
quality standards, financial feasibility and administrative imple-
mentation of the strategy. These strategies ranged from funding of
all projects at the level proposed by the "201" agencies and meeting
all requirements for secondary treatment and water quality standards,
to funding only the secondary treatment needs for existing design
capacities. (Table 5). Strategy B using flow projections from
303(e) Plans was selected as the most desirable for the following
reasons.
1.	It meets the major goals of FWPCAA-72, i.e. secondary treatment
and fishable/swimmable waters for those stream segments where this
is attainable.
2.	Using the estimates for future design capacity requirements for
municipal facilities contained in the 303(e) Plan cuts approximately
$120 million in capital construction costs from those estimated by
"201" Agencies and mitigates negative aspects of the higher popula-
tion growth rates on other media, such as air quality.
3.	Providing for reasonable expansion of municipal facilities con-
sistent with historic trends of population growth and distributed
according to land use planning objectives will eliminate most of
the administrative difficulties in implementing the strategy as
opposed to a "no growth" strategy. Providing reasonable reserve
capacity where needs are projected will help to implement land use
planning objectives and will be consistent with other regional plan-
ning activities including water supply, mass transportation, highways,
etc.
4.	Eliminating the large excess design, capacities which would occur
through funding of facilities projected to be needed by "201"
Agencies in the next 10 year period allows for funding of advanced
waste treatment (AWT) needs in order to achieve the water quality
objectives of FWPCAA, within the expected budgeting level for
Federal Grants to municipal facility needs.
5.	Strategies which provided for AWT only in existing high quality
waters were not consistent with the objectives of FWPCAA. Achieve-
ment of water quality objectives in those streams currently not
meeting water quality objectives was assigned only as slightly lower
priority than attainment of secondary treatment and preservation of
high quality waters.
Recommendations on Management Strategy
1. Population and waste flow projections contained in Colorado's
303(e) Plans should be used as the basis for sizing municipal waste
treatment facilities in order to conserve Federal construction grant

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funds and eliminate gross over-sizing of treatment and interceptor
facilities.
2.	First priority should be given to attainment of secondary treat-
ment (including elimination of raw sewage discharges) and protection
of high quality waters. A second order priority is the attainment
of water quality standards in those stream segments capable of
supporting fisheries provided the stream quality is upgraded to
meet the use criteria.
3.	Consideration should be given to implementing water quality
standards on streams which require AWT to upgrade to the standards,
on a segmentation basis. Consideration should be given to the
proximity of parks, public access, water supply intakes and proximity
to population centers, as well as capital costs in developing and
implementation of the strategy. In the South Platte River Basin the
following strategy is recommended:
a.	First priority be given to elimination of raw sewage
discharges to eliminate public health hazards through the
currently developing Platte River Park Area. Specifically,
the Platte River II Interceptor construction from Alameda to
17th Avenue would eliminate these discharges from this vicinity
and should be given highest priority.
b.	Second priority should be given to providing the necessary
secondary and advanced waste treatment required to upgrade to
meet water quality standards for the following stream segments:
(1)	South Platte River from Chatfield Dam outlet to
Exposition Ave. (Cold Water Fishery with cold water
releases from Chatfield Dam).
(2)	South Platte River from Exposition Ave. to York
Street (Warm Water Fishery with proposed total body con-
tact recreation as part of Platte Park development program).
(3)	St. Vrain and Boulder Creeks from source to confluence
with South Platte River.
(4)	Big and Little Thompson Rivers from source to confluence
with South Platte River.
(5)	Cache La Poudre River from source to confluence with
South Platte River.
(6)	South Platte River from confluence with St. Vrain Creek
to confluence with Cache La Poudre.River.
c.	Lower priority should be assigned to upgrading to meet water
-5-

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quality standards on the following stream segments.
(1)	South Platte River from York St. to confluence with
St. Vraln Creek.
(2)	Clear Creek from Farmer's Highline Canal to. confluence
with South Platte River.
(3)	Sand Creek.
(4)	Big Dry Creek from source to confluence with South
Platte River.
4. In general the fundable design life for waste treatment facilities
shall be based on a 10 year projected growth and interceptors for
a 20 year projected growth, unless compelling information on cost-
effectiveness can justify a longer design life.
-6-

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Table Municipal Facility Needs - Basin Plana and Facility Plans
A-l. DRCOG Planning Area - Treatment Needs
Facility,
REGIONAL PLANTS
Denver Metro
Denver Metro
Denver Metfco
Denver Metro
Littleton/
Englewood
1985 Design
Capacity (MGD)
Item
Treatment Level
3(c) Plan	201 Plan Existing
3 (c)
20]
3(c)
201
Estimated Capital Costs
3(c)
201
169
32
310
32
169
105
20.1 "
(17.8)4
Upgrade
to meet •
W.Q.S. +
Secondary
Sludge
Off Site
Sludge
Regional
Plant
Expand
Plant On
Site
Sludge
Off Site
Sludge
Upgrade
Regional
Plant
Secondary
+ Nitr.

Secondary
+ Nitr.
Secondary

Secondary
(1973 $)
39 , 100,000
(Note discrepancy in
treatment levels re-
qu.lred-3(c) vs 201)
26,128,000^
40,000,Q002
10,800,0003
19,000,0003
Included in
Hetcp
34,5oo,ooo1
9,336,000
12,638,000
33,542,888
le.sss.ooo1
9 , 600, 0002,
Sub-Totals
201
342
189
Sub-Total
84,400,000	137,797,000
SATELLITE PLANTS
Boulder
18
(Single Plant)
20
19.9
(Combined)
Expand &
Upgrad:,.
75th
Expand &
Upgrade
Secondary
+ Nitr.
Secondary
+ Nitr.
4,900,000
8,000,0001
12,050,0002
Big Dry
(Wes tmins ter )'
Clear Creek
Sand Creek
Sub-Total
10
6.5
40. 5
25
_ 5
_ 5
45.0
1.0
0
0
20.9
Expand to
6.0 MGD
& Upgrade
New Plant
New Plant
Expand &
Upgrade
_ 5
_ 5
Secondary
+ Nitr.
Secondary
+ Nitr.
Suh-Total
5,700,000
7,700,000
7,500,000
25.800,000
(Not on list)
(20,000,000Y
f
(20,000,000)*
20.050,000

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,1,-1, ,1,1., ,n	tl"W I'lnnl.	Scr.-i .rvlary
(L.S. Platte)	7	30.9	(0)	Now Plant Mow Plant	+ Nitr.
r.(;cnnrln ry
+ Nitr.
4,600,000
21,000,000
South Adams
Longmont
Erie
Lafayette
Louisville
Niwot
Sub-Total
0. 5
1.5
1.0
0.6
19.6
6.8
6. 3
2.0
(est.)
1.5
(est.)
1.0
(est.)
0.6
49.1
2.5
5.6
1.5
0.7
0.7
11.0
Expand &
Upgrade
Upgrade
Upgrade
Expand &
Upgrade
Expand &
Upgrade
New Plant
Upgrade
Expand & Expand &
Upgrade	Upgrade
Secondary
+ Nitr.
Secondary
+ Nitr.
Secondary
+ Nitr.
Secondary
+ Nitr.
Secondary
+ Nitr.
Secondary
Secondary
+ Nitr.
Secondary
+ Nitr.
Secondary
+ Nitr.
900,000
1,200,000
1,000,000
1,700,000
400,000
9,800,000
855,000
1,900,000
(Priority Lis®
3,000,000
(Priority LisO
200,000
Not on List
Not on List
OTHER PLANTS
Broomfield
Lyons
(Phased Out)
10
.29
1.6
Phased
Out
Expand &
Upgrade
Total (Plants)
261.1
446.1
222.5
Treatment Total 120,000,000	184,802,000
(77,000,000^	(141,802,000)*
Treatment capacity after completion of current expansion under EPA Grant costs for 3(c) include costs of current expansion.
2
Costs for Phase II expansion.
^Sludge handling & disposal needs for year 2010 loads s regional facilities
4
Existing combined capacity of Littleton Englewood Facilities
^Metro Denver does not propose to build these facilities in its preferred alternative
^Total excluding $4 3 Million in grants already awarded for area.

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Table 1: Municipal Facility Needs - Basin Plans and Facility Plans (Cont'd)
Estimated
Design Capacity (cfs)	Capital Costs (xS 1000)
Interceptor
Designation
Length (ft.)
Existing
3(c)
3(c)
201




Projection


St. Vrain A-l

6,200
0
'236
254

Boulder A-2-A-7

38,500
21-16
14-38
1798

Big Dry A-8-A-12

•42,800
0
29-70
2821

Clear Crk. A-13-A-20

95 ,300
0-15
10-72
4017

Lakewood A-21-A-25

52,400
0-11.2
6.4-31 .4
2345

Bear Crk. A-26-A-28

20,800


731

South Side A-33
Littleton/Englewood
15,000
0
113
2380

South Side A-36

20,300
0
24.7
1015

South Side A-29,30

51 ,000
0-10
9.7-79.4
2951

31,23,34,35,37,38






Plum A-39-A-43

40,200
0
23-66
2582

Cherry A-44-A-47

73,500
0
15.4-30.7
3222

Charry A=4B-A-E6

153 ,300
0-33.5
3.7-102.9
10568
(9704)
Sand A-57-58

13,700
0-12-4
10.9
528

Irondale A-59-A-61
Lower South Platte
87,900
0
8.9-37.8
4606
5174
S. Platte A-62
South Huron Trunk
12.,600
0
9.2-18.8
643

S. Platte A-63
Platte River II
47,400
0
110-180
16800
20290
S. Platte A-64-A-67
Delganey Relf
11,500
66.1-89.9
215-224
1985
10769

Storm Sewer Sep-






Delganey




996

Combined Sewer






Sep-Delganey




3609

Goldsmith-Gulch




1706

West & Southside




4090

Sloan Lake




2980

Red Seal




1625

Westerly Creek




9225


Total
Interceptor Needs

59346
(70168)
-7-

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Table 3
Needs Summary: Colorado
Basin Plans vs. Facility Plans
Basin/Area
Design Year
Treatment & Interceptor Needs Water Quality
(xlO3 $)"Adjusted Needs Segment Category
303(e)	201	
South Platte/DRCOG	1985
South Platte/Upper	2000
South Platte/Larimer Weld 2000
South Platte/Plains	2000
Colorado/Fraser-
Williams	1995
Colorado/Eagle-Piney	1995
Colorado/Upper Gunnison	1995
Colorado/Rifle-Plateau	1995
Colorado/North Fork-
Uncompahgre	1995
Colorado/Blue	1978
Colorado/Roaring Fork	1978
Republican	1985
Rio Grande	1985
Green	1978
1
136,346
13,583
54,647
2,520
5,491
8,761
2,731
3,5523
1,442
5,301
5,452
205
3,298
4,475
186,402-Treatment
70,168+-Interceptors
II
I
II
E.L.
I
e!l.2
E.L.
E.L.4
I
I
E.L.
E.L.
I
Sub Total
Arkansas
San Juan
North Platte
1985
1985
1985
290,805
56,000;
4,000
4005
III6
E.L.
E.L.
Total
351,205 - Includes Estimated Needs for all basin
lExcludes approximately $43,000,000 in needs for which grants have been awarded.
^This sub-basin is effluent limited except for East River near Crested Butte.
3
Cost level projection of needs based on intensive oil shale development.
4This sub-basin is effluent limited except for Uncompahgre River at Montrose.
5Basin plans not currently available to assess needs. Estimates are based on $80/capita.
^Fountain Creek downstream of Colorado Springs and Arkansas River downstream of Pueblo on:\
-9-

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is-e •
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			5	
—nrA—hxdnr^-
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j3~*i\cV
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?k,rl -k>
"MVirlrfi t*'4"

€j>(-xt^. ||u,iL
- £{f
( I'.to o,
¦^ClO) _
-,?QC) —
Cjcc
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foot1
>7
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'IOO
10 O
*"X$&
¦ci^.y
-caw
I
1Uis
5 >9^
s _
x^s
1.15'°
1.5°"
,,'TSU
W-JOQt,
'ic re
i,30o
2,150
^u-^-Totiis
(7rtii>vvr^ir)
8-1

*ili.'J
rt6n
-
i
-
-loyzv
[i},\-2S]
[st.s-.v'D1
=11,12 5
LiO.^c-y
33.7 Cc-f_
[si,ac3J
• A* ^V; ^. -W> t;v.'. r-v. 'Vf^P^I c-r

-------
Table 5
Alternative Water Quality Management Strategies-Project Funding
Strategy No.



Elements
Funded



Estimated









Total
Needs

Existing Capacity


Expanded Capacity

Funded
For Strat.

Sec./Int.
Needs
Water
I
AWT Needs ,
Quality Category
II III

Sec./Int.
Needs
AWT Needs
Water Quality Category
I II III
1 303(e)
201
A
X
X
X
X

X
X
X
X
351
471+
B
X
X
X


X
X
X
X
338
458+
C
X
X



X
X


279
381 +
D
X




X



266
368+
E
X
X
X
X





257
291 +
F
X
X
X






244
278+
G
X
X







184
222+
H
X








171
209+
^Water Quality Categories Described as follows:
Category I: Existing Cold Water Fisheries (A], Bi Stream Classification)
Category II: Existing or Potential Warm Water Fisheries (A?» B£ Stream Classification)
Category III: Streams not capable of supporting aquatic life
-12-

-------
III. Recommendations for Colorado Priority System
The primary method of implementing the recommendations contained in
Chapter II is through the development of a priority system for construc-
tion grants which is consistent with the water quality management strate-
gy recommended. The following considerations and recommendations were
developed by the task force:
A. GUIDELINES FOR DEVELOPMENT OF CONSTRUCTION GRANT PRIORITY SYSTEM
1.	By regulation, the system must include factors which reflect the
following:
a.	Severity of Pollution
b.	Population affected
c.	Need for preservation of high quality waters
d.	National priorities
2.	System should be capable of being generally understood by non-
technical people (municipal officials, citizens' group, etc.).
3.	It should address the problem of secondary treatment versus AWT.
4.	It should address the growth issue.
5.	It should contain a mechanism for breaking ties.
6.	It should strike a balance between the need to preserve high
quality water in areas of low population densities, and the need
to abate problems in large population centers.
7.	The input data required by the system should be readily available;
8.	It should contain a deadline for filing applications.
9.	It should contain a policy statement regarding the relationship of
available funds to permit requirements.
10. System should provide for a reserve fund of up to 10% of each
year's grant allotment for the funding of Step 1 and Step 2 pro-
jects which are consistent with State strategy but not within
reach on priority list.
-13-

-------
B. RECOMMENDED POLICIES AND GUIDELINES
1.	Not more that 45% of the total available FY-76 Federal construction
grant allocation shall be awarded to the aggregate of projects
within the boundary of the water quality management planning area
set forth in the report titled "Water Quality Management in the
Denver Metropolitan Area, "prepared by the-Denver Regional Council
of Governments. The following are excluded from the limitation
indicated in the preceding sentence: Westminster, Boulder, Erie,
Lafayette, Longmont, Louisville, and Niwot.
2.	Population projections set forth in the basin plans proposed under
Section 303(e) of the Federal Water Pollution Control Act Amend-
ments of 1972 (PL 92-500) or Section 3(c) plans prepared under the
Federal Water Pollution Control Act Amendments of 1966 (PL 89-753)
shall be used in sizing a project for its design life.' In general,
the design life of treatment projects shall be 10 years, and the
design life of interceptor sewers shall be 20 years, unless com-
pelling cost-effectiveness data can be developed to indicate that
the design life of a' project should vary from the 10 or 20 year
design periods just cited.
3.	Advanced waste treatment shall be used as needed to meet Colorado
water quality standards in streams.
4.	Within 10 days of the adoption of this Priority System and Priority
List by the Colorado Water Quality Control Commission, the Commis-
sion will notify those municipalities on the Priority List by cer-
tified mail that Federal grant funds have been reserved for them.
Within 10 days of receipt of such letter, each municipality must
notify the Technical Secretary, Water Quality Control Commission,
of the municipality's intention to file an application for a Step 1,
Step 2, or Step 3 grant, as appropriate. By January 1, 1976, each
municipality shall file an application for a grant. For those
municipalities in possession of a valid National Pollution Discharge
Elimination System Permit, issued by either the United States
Environmental Protection Agency or the Colorado Water Quality
Control Division, failure to apply for a grant for which they are
eligible may result in initiation of an enforcement action against
the muncipality for failing to abide by the permit conditions.
5.	The procedure for breaking ties among municipalities which receive
an equal number of priority points shall be as follows:
(a) The municipality on the highest category stream shall receive
first priority for funding (e.g., if two municipalities had
an equal number of points, but one was on a Category I stream
-14-

-------
and one was on a Category III stream, the municipality on the
Category I stream would receive first priority).
(b) If two or more municipalities have equal points and are on
the same category of stream, the municipality with the greatest
population according to the 1970 federal census shall receive
first priority for funding, and so on in descending order of
population.
6. Ten percent of the Federal grant funds shall be reserved for grant
increases.
-15-

-------
C. RECOMMENDED POINT DETERMINATION FOR COLORADO PRIORITY SYSTEM
1. Wastewater Treatment Plants
(a)	#(Priority points) = .01 BOD5 (additional pounds to remove)
see attachment I for Graph
(b)	#(Priority point = .01 (NH3 as N + 5C12) (pounds needed to
be removed)-
see attachment II for graph
(c)	#(Priority points) = .25 PO4 as P (lbs needed to be removed)
see attachment III for graph
(d)	Facility in energy impact area = 20 points
as defined by Energy Office)
(e)	#(Priority points = (34.5x10.5)~present population + 5
(on semi-long paper)
see attachment IV
(f)	Tie breakers
(1)	The municipality on the highest category stream shall
receive first priority for funding (e.g., if two
municipalities had an equal number of points, but one
was on a Category I stream and one was on a Category
III stream, the municipality on the category I stream
would receive first priority).
(2)	If two or more municipalities have equal points and
are on the same category of stream, the municipality
with the greatest population according to the 1970
Federal census shall receive first priority for funding,
and so in descending order of population.-
-16-

-------
2. Sewer Lines (Select One Only)
Award
(a)	An interceptor sewer which will have
the capacity to eliminate raw sewage
bypasses into a stream, which have been
identified by the State and EPA as
major sources of pollution fo.r which
NPDES permits have been issued
(b)	Interceptor sewer from the treatment
plant up to point where the inter-
ceptor will be at 90% design flow
(c)	Corrections of infiltration/inflow
problems, where the approved Step 1
feasibility study shows such cor-
rections to be cost effective as
compared to additional sewage
treatment facilities
(d)	Interceptor sewer which is shown by
Section 201 facility plan to be" more
cost effective than satellite treat^-
ment plant
(e)	Interceptor sewer which eliminates an
existing treatment plant
(f)	Other interceptors which serve areas
80 percent developed on October 18,
1972
(g)	Sewage collection lines in an area
already 80 percent developed on
October 18, 1972 and which has created
a serious health hazard and/or water
pollution problem and which has been
issued a Cease and Desist Order by
the Colorado Department of Health
50 PTS
Same points as associated
treatment facility.
Same points as associated
treatment facility.
same points as associated
treatment facility
Same as above.
1/4 points of the associate
treatment facility.
1/4 points of the associat-
ed treatment facility.
-17-

-------
BODcj lbs x 102

-------
Toxicity lbs x 10^

-------
PO4 as P lbs

-------
PRESENT POPULATION
-21-

-------
Total
Points
33
33
30
29
27
27
27
26
26
25.5
25
25
25
25
25
22.5
22
20.25
20.25
20
or
14
10
10
18
7
7
7
5
5
18
16
5
5
5
5
11
10
6
7
5
PRIORITY POINTS FOR EPA GRANTS
Name
Excess BOD
Points
Excess CL2 &
NII3-N Points
Excess P
Points
Stream Category
Factor
Energy Impact
Area Points
Grand Junction	10
Glenwood Springs	3
Craig	0
Englewood	0
Paonia	0
Rif±e'	0
Meeker	0
Silt	1
Oak Creek	0
Pueblo	33
Littleton	0
Hotchkiss	0
Hayden	0
W. Glenwood Spgs.	0
New Castle	0
Sterling	34
Estes Park	1
Clifton	1
Rangely	0
Frisco	0
0
0
0
11
0
0
0
0
1
0
8
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
0
0
15
0.75
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.5
1.0
1.0
1.0
1.0
1.0
0.5
1.0
0.75
0.75
1.0
20
20
20
0
20
20
20
20
20
0
0
20
20
20
20
0
0
20
20
0

-------



PRIORITY POINTS FOR EPA
GRANTS


iT
No.
Total
Points
Name
Excess BOD
Points
Excess CL2 &
NHi-N Points
Excess P
Points
Stream Category
Factor
Energy Impact
Area Points
'i
(
Populations
Points |
21
19.5
Palisade
1
0
0
0.75
20
J br«
5 1
22
19
Silverthorne
0
1
10
1.0
0
8 f
23
18.75
Grand Valley
0
0
0
0:75
20
I
5 \
24
18
Aspen Metro
3
4
0
1.0
0
11 [
25
15
Three Lakes
1
0
4
1.0
0
10 I
f
26
14
Breckenridge
0
1
3
1.0
0
10 I
i-*
27
13.5
South Lakewood
2
3
0
0.75
0
13 '*•
ij
28
13.5
Glendale
0
7
0
0.75
0
11 \
29
13.0
Gunnison
2
0
0
1.0
0
11 1
30
13.0
Boulder
8
0
0
0.5
0
18 1
31
12
Steamboat Springs
2
2
0
1.0
0
8 \
32
12
Montrose
2
0
0
1.0
0
10 J
33
12
Snowmass
0
2
0
1.0
0
10 f
34
12
Metro Denver
0
0
0
0.5
0
24 |
35
12
Canon City
4
0
0
0.75
0
12 i
&
36
12
Durango
0
0
0
1.0
0
fr
12 |
t
37
11.5
Longraont
9
0
0
0.5
0
14
38
11
Alamosa
0
0
0
1.0
0
t
11
39
11
UDner Eagle
0
1
0
1.0
0
10
40
10.5
Greeley
4
0
0
0.5
0
17
1
I

-------
PRIORITY 7'OINTS FOR EPA GRANTS
No.
Total
Points
Name
Excess BOD
Points
Excess CL2 &
NIIt-N Points
Excess P
Points
Stream Category
Factor
Energy Impact Population!
Area Points	Points f
41	10.25	Loveland	0
42	10	Monte Vista	1
43	9.5	South Adams	5
44	9.5	Fort Morgan	8
45	8.5	Fort Collins	0
46	8	Woodland Park	0
47	8	Idaho Springs	1
48	8	Evergreen	0
49	7.5	Broomfield	4
50	7	Brighton	2
51	7	Carbondale	0
52	7	Upper Thompson	0
53	7	Summit Co. (Snake R) 0
54	7	Rocky Ford	4
55	7	Tellvtide	1
56	7	Palmer Lake	0
57	7	Vail	0
58	6.75	Delta	0
59	6.5	Clear Creek Valley 2
60	6.5	Arvada	1
0
0
0
0
0
0
0
1
0
0
0
0
0
0
1
0
1
0
0
0
0
0
0,
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0.75
1.0
0..5
0.5
0.5
1.0
1.0
1.0
0.4
0.5
1.0
1.0
1.0
0.5
1.0
1.0
1.0
0.75
0.5
0.5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
14
9
14
11
17
8
7
7
11
12
7
7
5
10
5
7
6
9
11
12

-------
l'RTORTTY POTNTS TOR EPA GRANTS
No.
Total
Points
Name
Excess BOD
Points
Excess CI.2 &
NHtN Points
Excess P
Points
Stream Category
Factor
Energy Impact
Area Points
Populati
Point
61
6
Brush
3
0
0
0.5
0
9
62
6
Kremmling
1
0
0
1.0
0
5
63
6
Mancos
1
0
0
1.0
0
5
64
6
Manassa
1
0
0
1.0
0
5
65
6
Berthoud.
0
0
0
0.75
0
8
66
6
Ft. Garland
1
0
0
1.0
0
5
67
6
Mt. Werner
0
1
0
1.0
0
5
68
6
Monument
1
0
0
1.0
0
5
69
6
Upper Fraser
1
0
0
1.0
0
5
70
6
Lv Veta
1
0
0
1.0
0
5
71
6
Morrison
1
0
0
1.0
0
5
72
6
Georgetown Valley
1
0
0
1.0
0
5
73
•6
Gypsum
1
0
0
1.0
0
5
74
6
Rye
1
0
0
1.0
0
5
75
6
Crested Butte
1
0
0
1.0
0
5
76
6
Dolores
1
0
0
1.0
0
5
77
6
Granby
0
1
0
1.0
0
5
78
5.5
Trinidad
0
0
0
0.5
0
11
79
6
Winter Park
1
0
0
1.0
0
5
80
6
Fraser
1
0
0
1.0
0
5

-------
rKTORITY POINTS FOR EPA GRANTS
No.
Total
Points
Name
Excess BOD
Points
Excess CL2 &
NHr»-N Points
Excess P
Points
Stream Category
Factor
Energy Impact
Area Points
81
6
Del Norte
0
- 0
0
1.0
0
82
6
Crested Butte S.D.
0
1
0
1.0
0
83
6
Ouray
1
0
0
1.0
0
84
6
Saguache
1
0
0
1.0
0
85
6
Florence
0
0
0
0.75
0
86
6
Walden
1
0
0
1.0
0
87
e
Pagosa Springs
0
0
0
1.0
0
88
6
Ignacio
1
0
0
1.0
0
89
6
Aurora
0
0
0
0.5
0
90
6
Crestview
1
0
0
0.5
0
91
5.5
Trinidad
0
0
0
0.5
0
92
5.25
Fruita
0
0
0
0.75
0
93
5.25
Lincoln Park
0
0
0
0.75
0
94
5.25
Colorado Springs
0
0
0
0.25
0
95
5
Walsenburg
0
0
0
0.5
0
96
5
Box Elder
0
0
0
0.5
0
97
5
Evans
0
0
0
0.5
0
98
5
Bayfield
0
0
0
1.0
0
99
5
Central Clear Creek 0
0
0
1.0
0
LOO
5
Empire
0
0
0
1.0
0
Points
6
5
5
5
8
5
6
5
12
11
11
7
7
21
10
10
10
5
5

-------
PRIORITY POINTS FOR EPA GRANTS
No.
Total
Points
Name
Excess BOD Excess CL2 & Excess P Stream Category Energy Impact Population
Points	NH3-N Points	Points	Factor	Area Points	Points
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Basalt	0
W. Jefferson	0
Kittredge	0
Creede	0
Antonito	0
Evans	0
Nederianci	0
Victor	0
Cripple Creek	0
Purgatory	0
Olathe	0
Redcliff	0
Lake City	0
Hot Sulphur Spgs.	0
Silverton	0
San Luis	0
Collbran	0
Redstone	0
St. Marys.	0
Ridgway	0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.0
1.0
1.0
1.0
1.0
0.5
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0
0
0
0
0
0
0
0
0
0
0
0
0.
0
0
0
0
0
0
0
5
5
5
5
5
0
5
5
5
5
5
5
5
5
5
5
5
5
5

-------
PRIORITY POINTS FOR EPA GRANTS
No;
Total
Points
Name
Excess BOD Excess CL2 & Excess P
Points	NH^-N Points	Points
121	5	Bailey
122	5	Lafayette
123	5	Wheatridge
124	5	Westminster
125	5	Eagle
126	5	Blanca
127	5	La Jara
128	4.5	Windsor
129	4.5	Ft. Lupton
130	4.5	Louisville
131	4.5	East Canon
132	4.5	Pueblo West
133	4.5	Erie
134	4.5	Lyons
135	4.5	Dove Creek
136	4.5	Nucla
137	4.5	Norwood
138	3.75	Naturita
139	3.5	Platteville
140	3.5	Julesburg
0
1
5
0
0
0
0
0
1
1
0
0
1
1
i
1
1
0
1
1
0
0
0
.0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
'0
0
Stream Category Energy Impact Population
Factor	Area Points	Points
1.0
.0.5
0.5
0.5
1.0
1.0
1.0
0.5
0.5
0.5
0.75
0.75
0.50
0.75
0.75
0.75
0.75
0.75
0.5
0.5
5
9
5
10
5
5
5
i
9
8
8
6
6
6
5
5
5
5
5
6
6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

-------
PRIORITY POINTS TOR EPA GRANTS
Total
Points
Name
Excess BOD
Points
Excess CL2 &
NHj-N Points
Excess P
Points
Stream Category
Factor 	
Energy Impact Population
Area Points	Points
3.25	Security	1
3	Johnstown	0
3	Crook	1
3	Granada	1
3	La Salle	0
3	Milliken	1
3	So. Ft. Collins	0
3	Ovid	1
2.75	La Junta	0
2.5	Avondale	0
2.5	Kensey	0
2.5	Boone	0
2.5	Leadville	0
2.5	Log Lane Village	0
2.5	Weld Co-Tri Area	1
2.25	Las Animas	1
2.25	Fountain	2
2	Castle Rock	1
2	Burlington	0
2	Stratmoor	1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Q
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.25
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.25
0.5
0.5
0.5
0.25
0.5
0.25
0.25
0.25
0.25
0.25
0.25
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
6
5
5
1
5
6
5
11
5
5
5
10
5
9
8
7
7
8
7
=Hyea«mBS5iGE2
Tws:

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VR70RITY VOINTS FOR EPA C,RANTS
Total
Points
Name
Excess BOD
Points
Excess CL2 &
NHi-N Points
Excess P Stream Category Energy impact Population
Points	Factor	Area Points	Points
2	Springfiled
2	Flagler
1.75	Cortez
1.75	Ordway
1.75	Eaton
1#75	Akron
1.75	llolyoke
1.75	Wray
1.75	Limon
1.75	Fowler
1.5	Elizabeth
1.5	Gilbert
1.5	Yuma
1.5	Bristol
1.5	Calhan
1.5	Carapo
1.5	Hugo
1.5	Kit Carson
1.5	Manzanola
1.5	Penrose
1
3
0
1
0
0
1
c
0
1
0
1
1
1
1
1
1
1
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
D
0
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7
5
7
6
7
7
6
7
7
6
6
5
5
5
5
5
5
5
5
5

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PRIORITY POINTS FOR EPA GRANTS
To.
Total
Points
Name
Excess BOD
Points
excess 1^2 &
NHt-N Points
Excess P
Points
¦Stream Category
Factor
Enersy Impact
Area Points
PopulatioT
Points
181
1.5
Olney Springs
1
.0
0
0.25
0
5
182
1.5
Sugar City
1
0
0
0.25
0
5
183
1.5
Walsh
1
0
0
0.25
0
5
184
1.5
Wi ley
1
0
0
0.25
0
5
185
1.5
Au It
1
0
0
0.25
0
5
186
1.5-
Byers
1
0
0
0.25
0
5
187
1.5
Fleming
1
0
0
0.25
0
5
188
1.5
Cheyenne Wells
1
0
0
0.25
0
5
189
1.5
Eads
1
0
0
0.25
0
5
190
1.5
Academy
1
0
0
0.25
0
5
191
1.5
Hudson
1
0
0
0.25
0
5
192
1.5
Keenesburg
1
0
0
0.25
0
5
193
1.5
Merino
1
0
0
0.25
0
5
194
K5
Oti s
1
0
0
0.25
0
5
195
1.5
Feetz
1
0
0
0.25
0
5
196
1.5
Pi erce
1
0
0
0.25
0
5
197
1.25
Rainall
0
0
0
0.25
0
5
198
1.25
Swink
0
0.
0
0.25
0
5
199
1.25
Deer Trail
0
0
Q
0.25
0
5
.'00
1.25
Arriba
0
0
0
0.25
0
5

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PRIORITY POINTS FOR EPA GRANTS
Total	Excess BOD Excess CL2 & Excess P
No;
Points
Name
Points
NHi-N Points
Points
?01
125
Hightime Park
0
0
0
>02
1.25
Hi-Land Acres.
0
0
0
103
1.25
Stratton
0
0
0
>04
1.25
Haxtun
0
0
0
205
1.25
Wellington
0
0
0
206
1.25
Mead
0
0.
0
207
1.25
Silver Heights
0
0
0
208
1.25
Perry Park
0
0
0
209
1.25
Dinosaur
0
0
0
210
1.25
Center
0
0
0
211
1.25
Wi ggens
0
0
0
212
1.25
Vona
0
0
0
213
1.25
Hazel time Ats.
0
0
0
214
1.25
Holly
0
0
0
215
1.25
Cimmaron
0
0
3
Stream Category
Factor	
f.
Enersy Impact Population?
Area Points	Points }
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
0.25
0
5
I

aggj 'tit» v>	I

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E. Recommended Construction Priorities for Denver Metro Area
.1. Remainder of Platte II east or west side
2.	D.N.S. Headworks and Delgany river crossing
3.	Storm Sewer Separation & Combined Sewer Separation
4.	A. Delgany II if Platte on W.
B. Flow equaligation, where appropriate
5.	Off-site Sludge
6.	Littleton/Englewood AWT
7.	Denver Metro main plant expansion to accomodate higher than
anticipated DRCOG 3(c) 1/1 flows Clear Creek and lower South
Platte Sattelite WWTP's.
8.	Denver Metro AWT
9.	Various Denver Metro and City & County of Denver Interceptors
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Special Project Recommendations
A. CITY AND COUNTY OF DENVER PERMIT
The problems associated	with the identification, implementation
of correction and subsequent	determination of permit conditions, and
issuance of permit have been	corrected. An attached copy of the fact
sheet and proposed permit is	attached in Appendix A.
Publication of intent to issue permit has resulted in comments
so that a public hearing was held June 9, 1975.
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B. SLUDGE DISPOSAL RECOMMENDATIONS
1. The Problem
Metro Denver is experiencing a rapid increase in sludge loads at
their plant; it is the District's contention that they may not have enough
capacity to handle the sludge in 1976 when the oxygen treatment plant
goes on line. They are also in a difficult.position in regard to
disposal of sludge by the current system at the Lowry bombing range.
They report that they will run out of land on which to dispose of sludge
in the near future, and have had much difficulty in obtaining new land.
Metro had contracted with C^l-Hill Consulting Engineers as far
back as 1971 to develop another system of sludge handling and disposal.
Currently the system invokes chemical conditioning, vacuum filtrators.,
and truckhaul to Lowry of four'different sludge types—Denver-North
side anaerobic digested sludge-, Metro raw primary, Metro float concentrated,
secondary activated sludge, and aerobically-digested secondary activated
sludge. Metro's problem is compounded by the.fact that the secondary
facilities are larger than the primary system (the difference being the
DNS primary plant), which results in a high'proportion«of difficult to
handle secondary sludge instead of easily treated, primary sludge.. Figure T-
shows the present Metro system. Metro has also had three flash-dry incinera-
tors on site, but these units have not been used since 1971 because of air
pollution problems, high operating costs, equipment problems, and inadequate
design capacity.
CH?M-Hill first prepared a report in June 1972 recommending land
disposal of sludge on farmland as a type of beneficial reuse. The
proposed system would have involved a sludge pipeline approximately
25 miles to the east, where liquid sludge could be incorporated into
the soil by such methods as sludge injection. It was proposed that
Metro acquire or lease 6000 acres on which t® put the sludge at approxi-
mately 7 tons per acre.
Metro organized a Citizens Advisory Group through which to publicize
this system. It was essential that cooperatiiian of the local farmers be
obtained for such a system to work. Metro presented this system in 1973
to farmers of the Bennett, Colorado area. Veiny strong opposition sur-
faced as well as some profound environmental questions. Because thi-s
was dryland area, the nitrogen limitation became very important to
avoid crop damage. Loading rates on the soil of .3-.6 ton/acre/year
were now considered more reasonable.
Metro therefore reconsidered its plans and in March 1973 CH2M-Hill
released an Agricultural Reuse Program Study that developed an agricultural
reuse alternative of drying anaerobic sludge on drying beds and then having
a stockpile of sludge available for distribution. This is essentially
the system that Metro District is now recommending for funding.
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DNS Wastewater Influent
Landfill Disposal at
Lowrv Bombing Range
Wastewater Discharge to the
South Platte River
Solids Flo-.'s
-J®- Liquid Flows
Figure 1. Schematic Diagram of Existing Denver Northside
and MeLro Denver Treatment Plant. Principal Units
and Flows

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At present there are three potential sludge treatment and disposal
funding areas in the Denver Metro system. They include the following items:
(a)	Upgrading of 8 existing anaerobic digesters at the Denver Northside
Plant.
Two of their digesters are already being upgraded under an older EPA
grant, and the City and County of Denver is requesting additional Federal
funding for improvements on the remaining 6 digesters. Although there is
undoubtedly some excess capacity in the present digesters, the exact extent
of such excess capacity is unknown. Also a question-mark is how their
digesters will function under Metro's land application system.
(b)	8 Anaerobic Digesters at the Metro District Plant.
Metro submitted an application for funding of these digesters* simul-
taneously .with the application for funding, of the secondary treatment p-lent
expansion (1973). When Metro learned that sufficient funding, was not
available for both the secondary plant and digesters, Metro withdrew its
digester grant application. An EIS was written on -the secondary plant
expansion exclusively. It was noted in the final EIS on page 30 that
"Metro has not finalized its plans for solids handling and disposal. I'f:
at some future date Metro submits an application for EPA funding of the
solids handling and disposal system, EPA will prepare an environmental
impact statement at that time."
Metro has resubmitted its application for funding of the digesters.
EPA has put aside $4.7 million dollars at the request of the State for
this project. Since the plans and specifications were done prior to the
Facilities .planning arrangement, there has been no specific facilities plan
for these digesters.
(c)	The recommended Metro farm applicatign! pipeline system.
This system, which may cost as much as $17 million dollars, is about
to be funded in a Step I Facilities Grant. Hovsver, a number of planning
reports have already been done by CH2M and are minder review by EPA. The
planning grant of approximately $125,000 can be released as soon as it is
determined whether the digesters should or shouM not be included under
the Facilities Plan for sludge disposal. Up to ttffiis point, eight alternatives
have-been considered for sludge disposal, and omlly land application appears
feasible from the District's point of view. DROBS is sponsoring a study
for solid waste reclamation that may hold promise for Metro's sludge dis-
posal. EPA shall be commenting in the near future on work done to date
by CH2M-Hi 11 on the sludge disposal facilities pTIan.
Recommendations
The Task Force has developed the following recommendations regarding
EPA action on sludge handling and disposal at Metro:
(a) Information should be obtained from Denver Northside and Metro
Denver regarding the present and possible future jase of Denver Northside
digesters. The information obtained should include as assessment of

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present capacities, capacities with upgrading of all eight digesters, an
limitations on current or future operations because of other deficiencies
at the DNS plant (specifically grit removal), any other recommended improve-
ments needed at the plant, and an estimate of how the DNS digesters will
be operated under future Metro sludge handling and disposal systems.
An evaluation of the near-term uses of the DNS digesters should assess
whether Metro can use the digesters to allow operation of their existing
sludge handling system, especially when the new plant goes into operation
around 1976. Specifically pumping from Metro to DNS should be considered
for alleviating sludge overloads at the Metro plant.
(b)	The Metro District should determine to what extent the construction
and operation of the proposed Metro digester is independent of commitment
to construction the pipeline-farm disposal system. Thus far Metro has pre-
sumed the use of the farm application system in requesting early funding
of the 8 Metro anaerobic digesters.
(c)	Metro should establish more specifically, its rationale that the
digesters are needed for proper sludge treatment by 1976. This justifi-
cation should explain how the digesters will be utilized in the present
sludge treatment and disposal operation.
(d)	EPA should write an environmental impact statement on offsite
sludge disposal for the following reasons:
(i)	The project is controversial. Local county commissioners
as well as the farming populace to be affected have expressed opposition,
and have contributed valid questions about the effects of the project on
farmland.
(ii)	The size and scope of the project. This project represents
a large capital investment (over $20 million with digesters), a new type
of disposal, and will affect perhaps 50-75,000 acres in Adams County. The
project also represents a relatively permanent commitment to this type of
sludge disposal.
(iii)	Intermedia effect. Environmental considerations are very
important in this type of project and its alternatives. We are talking
about land-use effects, air pollution problems, surface and ground water
impacts, etc.
(iv)	Environmental Design parameters. The design of the project
.itself falls within tight environmental constraints including nutrient
loadings, soil permeabilities, vector control, groundwater protection, etc;
Virtually every aspect of the project will have environmental impacts.
The same is true for any other alternatives for sludge disposal.
(e)	An early resolution of separate funding for digesters is needed.
If the DNS digesters cannot be used in the interim and Metro can demonstrate
an immediate -need for the digesters independent of farm application of
sludge, then the digesters should be funded separately. If however, the
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digesters are to be part and parcel of the farm application system and
there is excess capacity at DNS for interim sludge handling, then the
digesters should be considered part of the land application system.
Approval of the digesters should await approval of the sludge disposal
system through the EIS process.
.(f) The facilities grant for sludge disposal should reflect the
decision on the sludge digesters.
(g)	The offsite-sludge disposal study should evaluate two other
potential alternatives:
(i)	Integration with a regional solid waste disposal system now.
under consideration by DRC06.
(ii)	Sludge injection and incineration with coal at the Cherokee,
Power plant.
(h)	A letter to Metro reflecting the concerns on the DNS excess
capacity and potential separate funding for digesters-has been prepared.
'Answers"to these questions should help resolve the issue of early funding
(i)	The EIS process should begin as soon as possible on the offsite-
sludge disposal facilities Dlan.
-39-

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c. DENVER NORTHSIDE BASE LOAD EVALUATION
Summary:
The Task Force, after consideration of the Denver Northside plant
and alternatives available for treatment of wastewater in the Denver North-
side service area, recommends the following:
(1)	That the DNS facility be kept at its present 106 mgd average
daily flow treatment capacity, and that minor modifications be made
to the plant headworks to enable the plant to process a 160 mgd peak
flow.
(2)	That the DNS facility be operated as siuch as possible in a base load
mode to facilitate plant operation.
(3)	That the Platte II interceptor be built between DNS and Denver
Metro to carry raw wastewater flows in excess of the DNS capacity to
Denver Metro for primary and secondary treatment.
(4)	That the modifications to the DNS heaiSyawks be accomplished as
rapidly as possible to enable the DNS faciItitty to treat 160 mgd peak
flows, which will eliminate bypasses occurring at the DNS facility
when flows to the plant exceed 130 mgd.
I. Existing Facility Description
Initial construction of the existing Denver Northside WWTP began in
1936, with additions and modifications to the facility at intervals periodic-
ally since then. The EPA presently has a grant to the City for modifications
to 4 of the existing 8 anaerobic digesters, and other grant is anticipated
for renovation of 2 more of the remaining 4 digesters.
-40-

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The Denver Northside Plant (DNS) gives primary treatment to all of the
wastewater originating within the City of Denver, except for a portion of
the wastewater from the N.E. sector of the City, which is taken directly to.
the Denver Metro WWTP via the Sand Creek Interceptor. The DNS plant
also gives primary treatment to all Denver Metro customers whose wastewater
enters the City of Denver collection and treatment system, including large
portions of Lakewood and Eastern Jefferson County.
The present DNS facility receives 90% or more of its flow from two
interceptors, the W & SS main and the Delgany main. At the present time 'a
small amount of wastewater is received from the Globeville line, 1-2 mgd,
-and from a portion of the Platte II interceptor, which relieves a W & SS.
main bypass at 47th Street.
The DNS plant is a primary treatment facility with the plant primary
effluent being discharged via a 90" effluent line to the Metro Denver plant
for secondary treatment. The anaerobically digested primary sludge is
pumped to the Denver Metro facility for dewatering and transportation to
a land application site.
The plant consists of 2 pump stations, bar screens, grit removal basins",
an aerated oil & grease removal facility, primary clarifiers, anaerobic
digesters, sludge drying beds, chlorine contact basin, and related auxiliary
equipment and structures including a laboratory/administration building
and maintenance building.
The Denver Metro District with a federal grawt constructed 2,500 feet
of the Platte River II interceptor to eliminate a W 8 SS main bypass at
-41-

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47th Street in Denver. At the end of the present line a 26 mgd screw pump
11ft station was constructed to pump Platte River II wastewater to the DNS
plant. Upon completion of the Platte River II interceptor above and below
DNS, it is anticipated that this lift station will be used to help baseload the
DNS plant.
II. Present Plant Capacity and Operational Problems
An analysis by the DRCOG 3(c) report, as well as a detailed analysis by
Camp Dresser'and McKee Consultants (CDM) for the City & County of Denver,
.determined, the plant treatment.capability.. It was found that ..the..various
treatment units were capable of satisfactorily processing a 106 mgd average
daily flow, but because of hydraulic limitations in .the headworks and
channels within the plant itself, the plant-begins to bypass untreated
wastewater when the flow to the plant exceeds 130 mgd. However, most of
the existing process units have the hydraulic capacity to treat a peak flow
of 160 mgd. The anaerobic digesters at the facility, now and after comple-
tion of the modifications, should be more than sufficient to digest the
sludge produced by a 106 mgd average daily flow. The primary effluent dis-
charge line from DNS to Denver Metro has a capadti^ of ,190-210 mgd.
The flow to the DNS plant at present has averaged 92.4 mgd for calendar
year 1974, although much higher peak hourly and daily flows at the plant have
been recorded during that time. Because of bypasses in the City & County
interceptor system above the DNS plant, the amount of dry wastewater flow which
is generated in the City can only be estimated. Because of interceptor
capacity limitations and resultant raw sewage bypasses, the peak wastewater
flows which would be expected to be recorded at DNS are not known. However,
CDM has made an analysis of estimated average wastewater flows and expected
-42-

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peak wastewater flows for the years 1973, 1985, 200.0, and 2020, and are shown
in Table I:
Flow	1973	1985	2000	2020
Minimum Flow (MGD)
(During spring)	114	140	173..	207
Maximum Flow (MGD)
(Instantaneous peak
hourly flow - during
25 year - 1 hour
storm)	254	290	327	378
From the CDM data it is apparent that provisions must be made to either
give primary treatment of this wastewater at DNS with transmission of the
primary effluent to Denver Metro for secondary treatment, or to have the raw
wastewater flow in excess of the DNS capacity to be transported to the Denver
Metro plant for primary and secondary treatment.
III. DRCOG WQM Plan (3(c) Plan) and CDM Report Recommendations for DNS
The 3(c) Plan for the Denver Metropolitan area made a detailed analysis
of possible plant expansion alternatives at the DfiE-plant and/or at the Denver
Metro plant to treat projected wastewater flows until the year 2020. As a
result of this analysis the 3(c) Plan concluded tot either abandoning
the existing DNS plant or keeping it at its present! capacity with minor
modifications would be equally cost effective. The minor modifications needed
would be primarily in the plant headworks and some Tin plant channel modifica-
tions to allow the plant to treat a 105 mgd average daily flow and a 160 mgd
peak flow capacity. This cost was estimated to be®.7 million dollars. All
excess raw wastewater flows above 160 mgd entering ihe plant would be bypassed
to the Platte River II and would receive both primary and secondary treatment
at the Denver Metro facility.
-43-

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The CDM analysis was much mare detailed and looked in depth at the entire
DNS facility. It concluded that the most cost effective solution was a toss-
up between major expansions to the DNS facility to.give primary treatment to
all flows tributary to the DNS plant, or to make minor" improvements to the
plant so that it could process a 106 mgd ADF and 160 mgd peak flow. The CDM
report then recommended that the DNS plant be expanded because of these other
factors:
(1)	The land is available at DNS for expansion, whereas Denver Metro will
have minimal land available for primary expansion.
(2)	Pumping costs should be less overall in the long term with an -ex-
panded DNS.
(3)	Sufficient anaerobic digester capacity was available at DNS to
digest all the expected sludges from the DNS expansion.
(4)	Flow equalization storage tanks could be initially built at DNS
immediately to eliminate peak storm flows from bypassing the plant and
these flow equalization tanks could be later converted to additional
required primary clarifiers.
The CDM study found that the cost of upgrading: the DNS plant to 106/160,
was 7.37 million dollars, not including the Platte GSiver II interceptor be-,
tween DNS and Denver Metro. In addition to the heaitaorks improvements, this
7 million dollars includes an anaerobic digester gas utilization building,
new administration and workshop buildings, screenings- handling improvements,
and some clarifier mechanisms improvements.
When the cost estimates for the two estimates f-j>r only plant upgrading
for a 106/160 flow capacity, the cost estimates are fairly close, that is
between 0.7 and approximately 2 million dollars.
-44-

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Task Force Recommendations
The Taks Force, after considering the alternatives studied for the
DNS plant, determined that the best solution is to make minor improvements to
the DNS facility so that it can process a 106/1 SO hydraulic loading. The
reasons for this determination are listed below:
(1)	Both the 3(c) and CDM reports agree that keeping the plant at a
106/160 size is cost effective.
(2)	Denver Metro has sufficient land available at its central plant
•location for construction of additional primary treatment units.
(3)	Any excess anaerobic digester capacity at DNS could probably be
utilized by Denver Metro when and if the Metro-sludge pipeline to the
District's off-site sludge disposal site is constructed.
(4)	Sending all raw wastewater flows above the DNS plant capacity to
Metro would allow the construction of primary facilities at Denver Metro
that could serve the Sand Creek & Clear Creek Tributary areas as well as
the DNS Tributary area. This would give the District greater flexibility
in utilization of its primary plant capacity if growth predictions for
any one of the 3 major Metro tributary areas proves incorrect.
(5)	By base loading the DNS plant as much as possible, the operation
of that plant should be facilitated especially if the operation of both
facilities is put under one management agency.

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D. N. E. Sanitary Sewer Project (C-080318)
Summary:
The Denver Northeast Sanitary Sewer Project was reviewed by the Task
Force and after consideration of the project and related planned interceptor
projects nearby recommends the following:
(1)	If at all possible and cost effective, the N.E. Sanitary Sewer
System should be connected directly to the Platte II Interceptor rather than
being connected to the DNS facility through the proposed lift station £5.
(2)	If it is shown that the most cost effective solution is to build
lift station #5 and connect the N. E. Sanitary Sewer to the Delgany Main as
proposed, then the following work should be funded under the existing project:
(a)	Construct Lift Station #5, Junction Structure #2 and the
piping between J.S.#2, L.S.#5 and the Delgany Main.
(b)	Make .minor improvements as necessary to J.S.#4 as described
in the original grant application.
(c)	Submit a new grant application for construction of J.S.#6
and the new 48" sewer to connect J.S.#4 and J.S.#2.
(d)	At the present time it appears that L.S.#6 and the associated
14" force main are not grant eligible items.
Appendix B is a memo of a meeting between the DWWC personnel, EPA and
State personnel on January 23, 1975 when the proposed project was discussed.
Subsequent to this meeting the Task Force leaimed that it might be pos-
sible to connect the N.E. Sanitary Sewer System directly into the Platte II
interceptor and eliminate the need for L.S.#5 completely. It was felt that
the city of Denver should investigate the feasibility of this alternative
before beginning construction of the project as originally planned.

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V. EIS CONSIDERATIONS
The facilities plans already in the office and other proposed Metro system
improvements represent a large number of NEPA decisions. Because of the
piecemeal nature of the facility plan segments, an analysis of impacts es-
pecially secondary ones is difficult. The Task Force has reviewed the projects
in the DRCOG planning area and arrived at the following recommendations:
1.	No EIS should be written on the Platte II Interceptor.
Because the interceptor would remove major dry. and wet weather raw sewage
discharges into the Platte River, it has the highest priority for funding.
There will be considerable construction impacts on this project such as traffic
disruptions, river crossings, etc., but these can be reasonably mitigated and
are short-term. A very substantial growth issue is involved, but one that
should be put off for another EIS (discussed below).
2.	An'EIS'should be written on the land application sludge disposal facilities
plan.
The impacts are considerable, whatever alternative is chosen. Headquarters
EPA will probably want to look carefully at this proposal. The anaerobic
digesters should be included in this EIS if they are considered by the District
along with sludge application on farms.
No EIS should be written on the 303(e) DRCOG t'/ater Quality Management
Plan approval.
The plan is already under consideration for two amendments involving Metro
facilities. It was felt that it would be better to consider the plan impacts
in the context of the plan amendments from the facilities plans for the Metro
area.
4.	An EIS should be written on the Lower South Platte project.
The facilities plan represents a deviation from tihe DRCOG plan, with much
higher population projections. The location of trie plant and areas to be
serviced have also changed. The impact of these changes needs to be considered.
5.	An overall EIS on the next Metro plant expansion should be written.
This would include a debate on central plant versus satellite plant expan-
sions, deviations from the DRCOG Water Quality Management Plan, and improve-
ments at Denver Northside plant. If possible, the EIS should include Lower
South Platte as well, since it affects ultimate plant sizing.
This EIS would be broad-based enough to cover air quality problems and the
secondary impact in the Denver metropolitan area. The secondary impacts as-
sociated with Platte II could be discussed in the EIS.

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6. There are other EIS's that may have to be written on,projects around central
Denver metropolitan area.
Boulder is contemplating land treatment, which would almost necessitate
an EIS because of public onctrovery, water rights, and the land involved.
Enqlewood - Littleton advanced waste treatment may also require an EIS to
explore the economic-environmental tradeoffs for the- South Platte from this
additional treatment.

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E. Platte II - Delgany
1. Problem Description
The Platte River II interceptor, as proposed in the DRC0G(3c) Plan
is to 'be designed to convey flows from the western areas to the MDSDD #1
plant via an interceptor located on the west bank of the South Platte
River extending from Alameda Avenue to the MDSDD #1 Plant (See Figure 1).
This interceptor would also relieve the existing overloaded West and
Southside Main which conveys flows to the Denver Northside Plant and is
presently overloaded.
The DRCOG plan also called for an interceptor identified as the
Delgany II to be constructed on the East side of the Platte River.
This interceptor would be designed to relieve the existing Delgany
Main and to serve new areas in the Southeastern part of the city. These
flows would be conveyed to the Denver Northside Treatment Plant (DNS).
A study completed by the consulting firm of Camp, Dresser and McKee
in 1974 for the City and County of Denver has proposed an alternative
to the lower portion of the Platte River II. ThSs alternative would
consist of a river crossing in the vicinity of 1.7tt'b Street into the pro-
posed Delgany Main No. 2. The existing Delgany Main River crossing would-
replated, the Denver Northside Plants primary capacity would be expanded
to treat all sewage generated upstream of the DNS plant, and the primary
effluent would be transmitted to the MDSDD #1 plant via the existing
effluent line (See Figure 2). An additional effluent line would be
necessary around 1985, and, if flow projections develop as anticipated,
an additional line between 17th Street and the DNS plant along the route
of the proposed Platte River II interceptor would be necessary by 1995.

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FIGUR 1
ALTERNATIVE 1 DRCOG (3c) PLAT!
V-
cn
IC2
v/^3r a'.ih 7 7, main
(EXISTING) 50 MGD
ENLARGED PLAT IT. HIVE R LT (1975)
DENVER
NChl II-
SiPE
PLA.'-ir
CG -( m ulil fU v(,L'
90 (E XISTING ) 160 MGD
MGD -
78
66
162 MGD
1
I
t;
SOUTH
78
78
/¦ i. AT T£ A*/1''£
142 f.!GO
DELGANY P.I AI N NO 2
(1275)
DELC--NY r.UIN NO I
(EXISTING)
V
i.: os cd
NO i
FIGURE 2
ALTERNATIVE 2 - CDFrrDELGANY II
o ;;-;) '-go r.'cn
-DELGAMY main no 2
(1975)
— DE LG A H Y MAIN NO I
EX I STI no)
• 'T.ATTE R. CRGGjIf.'G (1970)
13 5' MGD

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FIGURE 3jJ
altuw.tive 3 - ncara-soi-
H
m
jaEvr_^rjP 3 .* 't.-iTj
( EX 131: r,!G ) 50 MOD
90"(1975) 160 MGD - _Raw Sewa.qe
St -urn
L1-"- IC! I? V'5)
PLATTE RIVthi
^242MGD
-DEL G ANY'MAIN NO 2
(1975) .
¦DELG-'.t: f M/WU NCJ I
(EX ISTINGl
•KI..MTE R. C'
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ALTERNATIVE' 1
ACVWTAGES m DISADVANTAGES GF
DRCOG 3(c) PiM INTERCEPTOR ALIGWEHT AND. SIZES
ADVANTAGES
(1)	Platte II, from Alameda to Denver f'ETRo designed and ready for
CONSTRUCTION NOW, AND IF ALL WENT OUT TO CONTRACT BY JULY 1975,
CONSTRUCTION SHOULD BE COf-PLETED BY JANUARY 1977,
(2)	Lowest initial capital cost for abating dry weather overflows,
(3)	The underconstruction Denver ['Ltro plamt will have approximately
25 - 30 MGD primary treatment for raw sewage from the City and'
County of Denver.
(4)	If satellite plants are constructed on Sand Creek, Clear Creek
and'the Lower South Platte, then the underconstruction PfeTRo
PLANT WILL HAVE' a PRIMARY PLANT CAPACITY TO TREAT *K) MGD OF
RAW SEWAGE-FROM THE' ClTY AND COUNTY OF DENVER.
(5)	EaSETCNTS HAVE BEEN OBTAINED IN .MANY AREAS,
DISADVANTAGES
(1)	Highest interceptor cost overall,
(2)	If satellite pu\nts not built, underconstruction Denver Metro
PLANT WILL BE AT ITS PRIMARY .PUNT CAPACITY IN. NEAR FUTURE.
3) Platte.II will not carry all wet weather flcns to Denver.PTetrc
AND WILL, REQUIRE ADDITIONAL INTERCEPTORS TO GET ALL FLCW TO
Denver'f^TRQ'for treatment. .

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ALTERNATIVE 3
AUVAJIAbLb AND UlSADVAJIAGES OF
CDfi DELG/V'JY INTERCEPTOR ALTERNATIVE - DNS 106/160
(1) Lowest long-term interceptor capital cost,
' (2) Hill carry all wet weather flows from west side and east
SIDE TO DENVER NORTHS IDE AREA.
(3) Will allow option of extending Delgany . Mainto Denver
Metro,
DISADVANTAGES
(1)	Time to get 1/th Street crossing and Delgany designed and
constructed is not kncwn with certainty at this time,. The
ESTIMATED TIM; FOR COMPLETING CONSHRUCTION IS 28 MONTHS.
(2)	Higher initial capital costs for abating dry weather overflows,

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TABLE l$f
CDH PFOJFCTFD FLOWS (IB)
Western Areas
YEAR PIW I/I '.Pf-SiXI	A mx I
1973 170 98	69,
1985 182 118	81
2000 189 135	110
2020 21t 159	125
DELGAi'lY miHS NO. 1 AND IS. "2
YEAR P MAX I/I. P FAX I	AmX'I.
1973 80 56	,33
.1985 98 80	A6
,2000 112 9t	,5t
2020 13f: 115	68
P Max I/I - Peak Discharge on Maximum Day Plus Peak I/I
P.Max I - Peak Discharge on Maximum Day Plus Maximum 011
A.Max I - Average Daily Discharge Plus Maximum CM

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A, ALTERNATIVE 1
DRCOG 3 (c) PlPli - DNS 106/160
urn
1975 1385 1995
1,	Platte River II,
17th to Metro	9,9
2,	Delgany II 17m to DNS	5.5
3,	Interceptor DNS to TIetro	1,6
15.4 1.6
b; ALTERT'JATIVE 3
CDf1 - Delgany' 11 Alternative - HIS 106/160'
1.	Rtvfr Crossink n) 17th Strfft 0,9
2.	Enlarged Delgany. II.	9.7
3.	Interceptor DNS to PtTRo	2,7
PR II to Metro	2.9
13.3 2.9
Alternative I Pumping Cost 2-3 Tires higher thai; Alternative 3

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One discrepancy between the two proposals is the magnitude of the pro-
jected flows. The CDM report indicates that the flows generated in the
area served by the proposed Platte River II will be significantly higher
than those projected by the designers of the Platte R-iver II interceptor.
A comparison of the flow projections is shown in Table I. The capacity
of the existing West and SS Main is approximately 50 MGD. The proposed
Platte River II will have a capacity of approximately 100 MGD. These
two interceptors will be hydraulically connected so that the combined
interceptor capacity serving the"western areas-is 150 MGD. Comparing
the 150 MGD interceptor capacity to .the projected flows from the western
areas in Table I indicates that a capacity problesi exists.
It has been recommended that the DNS plant capacity be fixed at 106
MGD average capacity 160 MGD peak capacity for the reason given in that
section of this report entitled "Denver Northside Baseload." If this
is done the CDM proposal would have to be modified as shown in Figure 3.
The main difference between Figure 2 and 3 being that a raw sewage line
would have to be constructed between the DNS and MDSDD #1 plant immediately
and future primary expansion would take place at the MDSDD #1 plant.
A cost comparison of the alternatives shown in Figures 1 and 3.is
given in Table II. Alternative 3 has a somewhat lower initial capital
cost and has the lowest overall interceptor cost.
These cost figures are based upon Alternative 1 being modified to
provide the same flow carrying capacity as Alterciiative 3.
The relative advantages and disadvantages of the two Alternatives
(1 and 3) are shown below.
2. Recommendations
After consideration of the information presented in the various reports

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on interceptor locations and sizing the following is recommended.
1.	The questions concerning volumes of flew from the western
areas be resolved and interceptor sizes adjusted accordingly.
2.	Based upon the information available Alternative #3 should be
considered' as the best technical solution to the question of
interceptor location. However, any cost advantage could be more
than offset by the fact that right of Bay has been obtained for the
Platte II proposed in the DRCOG 3(c) plan and plans and specifi-
cations have been completed. If funds are available for the
whole- Platte II interceptor (Alameda Avenue to MDSDD #1) construc-
-t.i.on. .could begin very soon and existing raw sewage discharges could
be alleviated sooner with any other alternative presently proposed.

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APPENDIX A
U.S. ENVIRONMENTAL PROTECTION AGENCY
PERMITS ADMINISTRATION AND COMPLIANCE BRANCH
ENFORCEMENT DIVISION
SUITE 900, 1860 LINCOLN STREET
DENVER, COLORADO 80203
303+837-3874
APRIL 4, 197b
FACT SHEET
FOR NPDES PERMIT APPLICATION TO DISCHARGE LIQUID EFFLUENT
APPLICANT NAME:	CITY AND COUNTY OF DENVER
MAILING ADDRESS:	CITY AND COUNTY BUILDING
DENVER, COLORADO 80202
FACILITY ADDRESS:	WASTEWATER CONTROL DIVISION
5055 WASHINGTON STREET
DENVER, COLORADO 80216
TELEPHONE NUMBER:	303+297-5894
APPLICATION NUMBER:	CO 0026620
PUBLIC NOTICE NUMBER:	C0-75-025
The City and County of Denver maintains a treatment plant which
provides primary treatment of domestic and industrial wastes. The
wastewater from this facility flows into the Metropolitan Denver
Sewage Disposal District #1 Plant where it receives secondary treatment
prior to discharge to the South Platte River.
The City and County also owns and operates a waste collection
system which intercepts waste from several districts outside the City.
This system-is the facility for which this application has been filed
for the issuance of an NPDES discharge permit.
This collection system is inadequate to handle the present needs
of the serviced community. It does not have the capacity to contain
and transmit to the treatment facility all of the raw wastes collected
by its contributors; nor can the plant handle the treatment of all waste
transferred by the collection system. Therefore, the overburdened
system has developed several overflow points which required the City and
County to install and operate raw waste bypasses at various locations
within the collection system.

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FACT SHEET/CITY AND COUNTY OF DENVER
Page 2
In the past, the overloaded condition of this system has caused raw
waste flows on streets of the City as well as waste backups into the
basements of residences and businesses. Significant volumes of untreated
domestic and industrial wastes have been discharged directly into the
South Platte River. Although, installation of bypasses to prevent
waste floods^ has been undertaken by the City and County, direct discharge
of waste to the South Platte River and occasional .street flooding
still occurs.
The Ci":y and County of Denver's collection system represents a
recognized health problem within the metropolitan area; however, not
all points of untreated waste discharge can be iiiunediately terminated.
The. alternative of permitting such raw waste discharge would be the
denial of issuance of an NPDES permit thereby forbidding the City and
County, to discharge. This would result in waste flooded streets and
basements and serious damage to both' the collection system and'the
treatment plant thus compounding.problems which currently exist.
The application for the collection system covers twelve (12)
untreated waste discharges — seven (7) which flov/ to the South7 Platte
River; three (3) to Sand Creek, near Stapleton Airport;, and one (1)
each to Sloans Lake and the Burlington Ditch. (The Locations of
Discharges are identified on page 5 of the Fact sheet.)
The proposed permit requires the submission of plans to permanently
eliminate all of the systems'discharge points. In the interim, the
City ana County will be required to monitor all points of discharge as
part of a study to determine the nature and extent of the City and
County 's waste treatment problem.
The receiving waters are classified by the State of Colorado Water
Quality Standards as: South Platte River (B2-- warm water fishery);
Sand Creek (Bi - cold water fishery); the Burlington Ditch (Bi - cold
water fishery); and Sloans Lake (A2 - public water supply).
Tentative determinations have been made by the EPA and the
State of Colorado relative to the monitorinq requirements and other conditi
to be imposed on the permit. These conditions will ultimately
assure that State Water Quality Standards and applicable provisions
of the FWPCAA will be protected. The recommended expiration date for
the permit(s) is October 1, 1976.
The U. S. Environmental Protection Agency and the State of
Colorado have identified those conditions which ave pertinent to this
municipality's treatment works (Proposed conditions begin on page 5 of
the proposed permit attached to this Fact Sheet.)

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FACT SHEET/CITY AND COUNTY OF DENVER
Page 3
The discharge of untreated waste is prohibited by Federal law
and violates Colorado Water Quality Standards. The proposed permit
requires the applicant to complete studies and submit plans and
specifications to completely eliminate the waste discharges in order
to assure complaince with State Water Quality Standards and the FWPCAA.
Those parameters not enumerated in the Fact Sheet but enumerated
in the permit application are considered to. be adequately controlled by
key parameters for which effluent limitations have been established.
Written Comments. Interested persons are invited to submit
written comments on the proposed discharges and the EPA Regional
Administrator's or the State of Colorado's proposed determinations.
Comments should be submitted by May -4, 1975, either in person or by
mail to: U. S. Environmental Protection Agency, Permits Administration
and Compliance Branch, Enforcement Division, 1860 Lincoln Street,
Denver, Colorado 80203.
The application number should appear next to
the above address on the envelope and on the first page of any
submitted comments. All comments received by Hay 5, 1975, will be considered
the formulation of final determinations.
Information and Copying. Persons wishing further information may
write to the above address, or call the Permits Administration and Compliance
Branch at 303+837-3874. Copies of the application, the proposed permit,
including proposed effluent limitations and special conditions, comments
and any other documents which are received (other than those which the
EPA Regional Administrator maintains as confidential) are available at
the Permits Administration and Compliance Branch Office for inspection and
copying. A copying machine is available for public use at a charge of
$0.10 per copy sheet.
Register of Interested Persons. Any person, interested in a particu-
lar application, or group of applications, may leave his name, address,
and telephone number as part of the application if'iile. This list of
names will be maintained as a means for persons with an interest
in an application to contact others with similar interests.
Public Hearing. If submitted comments indicate significant
public interest in the application or if it is believed that useful
information may be produced thereby, the Regional Administrator, at
his»discretion, may hold a public hearing on the application. Any
person may request the Regional Administrator to hold a public hearing
on an application.

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FACT SHEET/CITY AND COUNTY OF DENVER
Page 4
Public notice of a hearing will be published
and circulated at least 30 days in advance of the hearing. The hearing
will be held in the vicinity of the discharge. The Regional Administrator
will provide final determinations within 20 days of the date of the
public hearing.
Further information relative to the procedures
and nature of public hearings concerning discharge permits may be
obtained by calling 303+837-3874, or by writing to the U. S.
Environmental Protection Agency, Permits Administration and Compliance
Branch, Enforcement Division, 1860 Lincoln Street, Denver, Colorado
80203.

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FACT SHEET/CITY AND COUNTY OF DENVER
Page 5
LOCATION OF DISCHARGES
City and County of Denver
Colorado
There are twelve (12) untreated.domestic and industrial waste
discharges from the City and County of Denver waste collection system
which are located as follows:
Point Source
001
002
003
004
Description and Location
Denver Northside Treatment Plant main
plant bypass on the west bank of the
South-Platte River, located at, latitude
39°47'00" North, longitude 104°56'05"
West, at the Delgany Main River Crossing.
Denver Northside Treatment Plant
Rocky Mountain Overflow on the west-
bank of the South Platte River,
located at latitude 39°47'50" North,
longitude 104°56'05" West, approxi-
mately 200 feet downstream from
the Delgany Main River Crossing.
51st and York Street Overflow, on the,
east side of the Burlington Ditch,
located at latitude 39°47'34" North, ,
longitude 104°57'31" West, approximately
0.2 miles (0.4 kilometers) upstream
from the York Street bridge, across the
Burlington Ditch.
Dumb Friend's League Bypass on the
east bank of the South Platte River,
located at latitude 39°41'40" North,
longitude 10'4o58'45" West, at 1295
South Santa Fe Drive, approximately
2.5 miles (3 kilometers) upstream
from the Alameda Avenue bridge across
the South Platte.
005	East Side Treatment Plant storm
overflow on the South bank of Sand Creek,
located at latitude 39°46'15" North,
longitude 1>M°'53'20" West, approxi-
mately 0.7 miles (1.1 kilometers)
upstream from' the 1-70 bridge across
Sand Creek.

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FACT SHEET/CITY AND COUNTY OF DENVER
Point Source
006
007
008
009
010
Page 6
Description and Location
Delgany Main Overflow on the east bank
of the South Platte River, located at
latitude 39°46'03" North, longitude
104°59'01" West, at the former river
crossing of the 31st Street Bridge
(31st Street and Arkins Court).
Sand Creek at Syracuse Street storm
drain outfall on the south bank of
Sand Creek, located at latitude 39°46'37"
North, longitude 104°53'51" West,
approximately 0.375 miles (0.6
kilometers) upstream from the 1-70
bridge across Sand Creek.
Sand Creek at Zenia and Smith Road
storm drain outfall on the west bank
of Sand Creek, located at latitude
39°46'13" North, longitude 104o53'6"
West, approximately 200 feet (61 meters)
upstream from the Smith Road bridge
across Sand Creek.
Fifth Avenue and Zuni Street storm
drain identified as Denver Health
Department index number N-51-W, on the
west bank of the South Platte River,
located at latitude 39°43'26" North,
longitude 105°00'37" West, approximately
500 feet (153 meters) upstream
from the 6th Avenue Freeway bridge
across the South Platte.
Alameda Avenue and Kalamath Street.
Discharge is from a storm drain
identified as.Denver Health Department
index number S-33-E, on the east bank
of the" South Platte River, located at
latitude 39°42'37" North, longitude
104 59156" West, immediately upstream
from the Alameda Avenue crossing of
the South Platte.
Delgany Bypass on the east bank of
the South Platte River, located at
latitude 3§°46'57" North, and long-
itude 104°58'32" West, approximately
0.15 miles (0.25 kilometers)
downstream from the 1-70 South-Platte-
River Crossing.

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FACT SHEET/CITY AND COUNTY OF DENVER
Point Source
012.
Page 7
Description and Location
Sloans Lake - West Byron Place and
Vrain Street. Discharge is from a
storm drain on the north shore of
Sloans Lake at latitude 39o45'10"
North, longitude 105°02'50" West,
immediately south of the above-
cited intersection.

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APPLICANT
PERMIT NO.
EFFECTIVE DATE
EXPIRATION DATE
City and County of Denver
CO-0026620
Date of Issuance*
October 1, 1976
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution Control
Act, as amended (33 U.S.C. 1251 et. seq..) (hereinafter referred to as
"the Act"),
the City and County of Denver, Department of Public Works
is authorized by the Regional Administrator, Region VIII, U.S. Environ-
mental Protection Agency, to discharge from pomt sources with discharge
serial numbers 001 through 012 (See Section 14.(GO of the Special Conditions
for location of these sources) to the South Platte River and its tribu-
taries in accordance with the conditions specified herein.
Authorized Permitting Official
Date
Title
*Thirty (30) days after the date of receipt of this permit by the Applicant,

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Permit No. C0-0026620
Page 2 of 19
General Conditions
1.	All discharges authorized herein shall be consistent with the
terms and conditions of this permit. The discharge of any pollutant
not authorized by this permit shall constitute a violation of the terms
and conditions of this permit. Such a violation may result in the
imposition of civil and/or criminal penalties as provided for in Section 309
of the Act. Facility modification, additions, and/or expansions that
increase the plant capacity must be reported to the permit issuing
authority and this permit then modified or re-issued to reflect such
changes. The permittee shall provide notice to the authorizing permitting
official of the following:
(a.) Any new introduction of pollutants, into the treatment works
from a source which would be a new source as defined.in Section 306 of
the Act if such source were discharging pollutants;
(b)	Except as to such categories and classes of.point sources
or discharges specified by the Administrator, any new introduction of
pollutants into the treatment works from a source which"would be subject "
to Section 301 of the Act if such source were discharging pollutants; and
(c)	Any substantial change in volume or.character of pollutants
being introduced into the treatment system by a source introducing
pollutants into such system at the time of issuance of the permit.
The notice shall include:
(d)	The quality and quanity of the discharge to be introduced
into the system, and the anticipated impact of such change in the quality
or quantity of the effluent being discharged from the permitted discharge-
points .
2.	Af-ter notice and opportunity for a hearing, this permit may
be modified, suspended, or revoked in whole or in part during its term
for cause including, but not limited to, the following:
(a)	Violation of any terms or conditions of this permit;
(b)	Obtaining this permit by misrepresentation of or failure to
disclose fully all relevant facts; or,
(c) A change in any condition that requires either a temporary
or permanent reduction or elimination of the permitted discharge.

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APPLICANT
PERMIT NO.
EFFECTIVE DATE
EXPIRATION DATE
City and County of Denver
C0-0026620
Date of Issuance*
October 1, 1976
AUTHORIZATION TO DISCHARGE U.NDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution Control
Act, as amended (33 U.S.C. 1251 et. seq.) (hereinafter referred to as
"the Act"),
the City and County of Denver, Department of Public Works
is authorized by the Regional Administrator, Region VIII, U.S. Environ-
mental Protection Agency, to discharge from point sources with discharge
serial numbers 001 through 012 (See Section 14.00 of the Special Conditions
for location of these sources) to the South Platte River and its tribu-
taries in accordance with the conditions .specified herein.
Authorized Permitting Official
Date
Ti tie
*Thirty (30) days after the date of receipt of this permit by the Applicant.

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3.7
Permit No. C0-0Q26620
Page 3 of 19
3.	Any schedule of compliance in this permit may, upon request
of the applicant, and after public notice, be revised or modified by
the permit issuing authority, if it is found that good and valid cause
exists for such revision.
4.	Notwithstanding 2 above, if a toxic effluent prohibition
(including any schedule of compliance specified in such effluent prohibition)
is established under Section 307(a) of the Act for a toxic pollutant which
is present in the discharge authorized herein and such prohibition is not
included in this permit, this permit shall be revised or modified in
accordance with the toxic effluent prohibition and the permittee shall
be notified.
5., The permittee shall allow the Director of the Water Quality
Control Division of the Colorado Department of Health, the Regional
Administrator of Region VIII of the Environmental' Protection Agency,
and/or their authorized representatives, upon the presentation of
credentials:
(a)	To enter upon the permittee's premises where an effluent
source is located or in which any records are required to be kept under
the terms and conditions of this permit;
(b)	To have access to and copy at reasonable times, any records
required tc be kept under the terms and conditions of this permit;
(c)	To inspect, at reasonable times, any monitoring equipment
or monitoring method required in this permit; or,
(d)	To sample, at reasonable times, an$ discharge of pollutants.
6.	The issuance of this permit does not c®nvey any property rights
in either real or personal property, or any exclusive privileges, nor
does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal,, state, or local laws
or regulations.
7.	Except for data determined to be confidential under Section 308
of the Act, all monitoring reports required by this permit shall be avail-
able for public inspection at the offices of the Director and the Regional
Administrator. Knowingly making any false stateiient on any such report
may result in the imposition of criminal penalties 'as provided for in
Section 305 of the Act.
8.	The permittee shall take all reasonable steps to minimize any
adverse impact to navigable waters resulting fron noncompliance with
any conditions specified in this permit. The permittee will provide
additional monitoring as necessary to determine Hhe nature and impact
of this discharge.

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Permit No. C0-0026620
Page 4 of 19
9. The permittee shall operate the sewerage system, including the
treatment plant and total sewer system in a manner which will minimize
discharges from sanitary and combined sewer overflows, and from bypasses.
10.	Except as provided specifically in the Special Conditions of
this permit, nothing in this permit shall be construed to relieve the
permittee from civil or criminal penalties for norfcompliance.
11.	Nothing in this permit shall be construed to preclude the
institution of any legal action nor relieve the permittee from any
responsibilities, liabilities, or penalties established pursuant to any
applicable state law or regulation under authority preserved by Section 510
of the Act.
12.. Tne .permittee shall prevent any of the following connections from
being made to its collection system:
(a)	Any new source of storm water into a separate sanitary sewer
or into a combined sewer system intercepted by a sewer line tributary to
the treatment plant.
(b)	Any new source of domestic or industrial wastewater into
a separate storm sewer or into a combined sewer system not intercepted
by a sewer line tributary to the treatment plant.
13. This permit cannot be transferred or assigned, nor shall a new
owner or successor be authorized to discharge from this facility, until
the following requirements are met:
(a)	The permittee shall notify the succeeding owner or successor
of the existence of this permit by a letter; a copy of which shall be for-
warded to the Director and the Regional Administrator.
(b)	The new owner or successor shall submit a letter to the
Director and the Regional Administrator, stating that he will comply
with the requirements of the permit on this facility and receive confirma-
tion and approval of the transfer from the Water Quality Control Division
of the Colorado Department of Health.
14. The provisions of this permit are severable, and if any provision
of this permit, or the application of any provision, of this permit, to any
circumstance is held invalid, the application of such provision to other"
circumstances, and the remainder of this permit, shall not be affected
thereby.

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Permit No. C0-0026620
Page 5 of 19
Special Conditions
1.00 Discharge Location
During the period beginning on the effective date of this
permit, the permittee is authorized to discharge to the South Platte
River and its tributaries, an effluent which shall be consistent with
the conditions specified herein.
2.00 Discharge Limitations
2?.01 Main Plant Bypass and Rocky Mountain Overflow (001 , 002)
(1)	Upon issuance of this permit and until its expiration,
the" permittee is authorized to" discharge from point sources 001 and'002
(Main. Plant Bypass and Rocky Mountain-Overflow).when the inflow to the
treatment .piant exceeds a rate of 130 mgd. When the rate of inflow is
less than 130 mgd, a discharge is- authorized only to prevent: (1) loss
of li.fe or severe property damage; or (2) damage, to any facilities
necessary for compliance with the terms and conditions of this permit.
The permittee shall notify the permit issuing authority within five (5)
days in writing, of any such bypass in accordance with the procedure
specified in Section 5.00 of the Special Conditions of this permit.
If, for other reasons, a partial or complete bypass is considered
necessary, a request for such bypass shall be submitted to the permit
issuing authority at least 60 days prior to the proposed bypass. The
request shall conform to the format specified in Section 5.00. If the
proposed bypass is judged acceptable, the bypass will be allowed subject
to limitations imposed by the permit issuing authority.
If, after review and consideration, the proposed bypass is deter-
mined to be unacceptable by the permit issuing authority, or if limita-
tions imposed on an approved bypass are violated, such bypass shall be
considered a violation of this permit; and the fact that application was
made, or that a partial bypass was approved, stall 1 not be a defense to
any ection brought thereunder.
(2)	The permittee shall within iminety (90) days of the
effective date of this permit, submit to the permit issuing authority for
approval, plans and specifications for such facilities necessary to
eliminate the need to use discharge points 001 arcd 002. The permittee
shall commence construction of such facilities nra later than August 1, 1975.
2.02 Burlington Ditch Outfall (003)
(1) Upon issuance of this permit and until its expiration,

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Permit No. C0-0026620
Page 6 of 19
or until such time during the life of this permit that the permittee
installs facilities to eliminate this discharge, the permittee is
authorized to discharge a combined sewer discharge from point source 003
(Burlingtoi Ditch Outfall).
(2)	The completion of the Northeast Sanitary Project
will reduce the flow discharged from point 003. It is a requirement of
this permit, that the permittee complete the construction of this
project during the life of this permit (see Section 9.00). The permittee
shall also operate its collection system tributary to point.003 in such
a manner as to minimize the volume of sewage discharged through point 003.
(3)	The permittee shall periodically monitor the' volume
of fl.QW being discharged through point 003.and by means of a monthly,
report submitted to the permit issuing authority, report the estimated
volume of discharge and peak rate-of-flow on no less than a biweekly
basi s.
(4)	Within ninety (90) days of the issuance of this
permit, the permittee shall submit to the permit issuing authority for
approval, a proposed schedule of compliance which shall include but is
not limited to, dates for the initiation and completion of: (i) Prelim-,
inary plans; (ii) Final plans and specifications; and (iii) Construction-
of all facilities necessary to eliminate the need to use discharge point 003.
2.03 Dumb Friend's League Bypass (004)
(1)	Upon issuance of this permit and until its expiration,
or until such time during the life of this permit that the permittee
installs facilities to eliminate this discharge point, the permittee is
authorized to discharge from discharge point 004 (Dumb Friend's League
Bypass), only to prevent overflows of raw sewage in the immediate area
of the West and Southside Main River Crossing (near the intersection of
Alameda Avenue and 1-25).
(2)	The permittee shall monitor the volume of flow being
discharged through point 004. The procedure forr monitoring such flow
shall be the same as that contained in Section 2!JD8, paragraph (4), of
this permit.
(3)	The permittee shall investigate long-term solutions
to permanently eliminate discharges from point 004. Within ninety (90)
days of the issuance of this permit, the permittee shall submit to the
permit issuing authority for approval, a proposed schedule of compliance
which shall include, but is not limited to, dates for the initiation and
completion of: (i) Preliminary plans; (ii) Final plans and specifications;
and (iii) Construction of all facilities necessary to eliminate the need
to use discharge point 004.

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3 7
Permit No. C0-0026620
Page 7 of 19
2.04 East Side Plant Storm Overflow (005)
(1)	Upon issuance of this permit and for ninety (90) days
thereafter, the permittee is authorized to discharge from point source 005
(East Side Dlant Storm Overflow), only to prevent loss of life or severe
property damage. The permittee shall notify the permit issuing authority
within twenty-four (24) hours by telephone, and within five (5) days in
writing, of any such discharge in accordance with the procedure specified
in Section 5.00 of the Special Conditions of this permit.
(2)	Discharge point 005 shall not be used for any
discharge whatsoever after the expiration of the ninety (90) day period,
authorized in paragraph (1) of this Section (2.04).
2.Go Delgany Overflow (006) - 31st Street and Arkins Court
(1)	Upon issuance of this permit and until its expiration,
the permittee is authorized to discharge from discharge point 006, only
when sewage flows exceed the carrying capacity of that portion of the
Delgany Main on which the discharge point is located.
(2)	The permittee shall notify the permit issuing authority
of each bypass event from discharge point 006 by"means of a monthly report.
The report shall include:
(i) The cause for the discharge
(ii) The duration of the discharge
(iii) The estimated volume of the discharge and
peak rate-of-flow.
(3)	The permittee shall investigate long-term solutions
to permanently eliminate discharges from point '016. Within ninety (90)
days of the issuance of this permit, the permittee shall submit to the
permit issuing authority for approval, a proposed schedule of compliance
which shall include, but is not limited to, dates for the initiation and
completion of: (i) Preliminary plans; (ii) Final plans and specifications;
and (iii) Construction of all facilities necessary to eliminate the need
to use discharge point 006.
(4)	During past floods on the South Platte River, the
permittee has indicated flood waters may enter the permittee's collection
system, through discharge point 006. Upon issuance of this permit, if
such investigation has not already been completed, the permittee shall
investigate the likelihood of flood waters entering its system through
point 006 in the future, and the costs of installing facilities necessary
to eliminate this occurrence. The results of this investigation shall
be submitted to the permit issuing authority within sixty (60) days of

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Permit No. CO-0026620
Page 8 of 19
the issuance of this permit. If, upon determination by the permit
issuing authority, the investigation indicates a significant frequency
of flood waters entering the system through point 006, the permittee shall
submit a schedule for the installation of such facilities as are necessary
to prevent this occurrence.
2.06	Delgany Bypass (007)
Upon issuance of this permit, the permittee shall not
use discharge point 007 (Delgany Bypass), for any discharge whatsoever.
This discharge point is on an abandoned portion of the Delgany Main and
the permittee shall, no later than ninety (90) days from the date of
issuance of this permit, have taken such steps as necessary to insure
this abandoned portion of the Main is permanently "disconnected from the
present functioning portion of the Main.
2.07	Sand Creek Discharge Points (008, 009)
(1)	Upon issuance of this permit and until its expiration,
the permittee is authorized to discharge from discharge points 008 and
009 (Sand Creek Discharge Points at Syracuse Street, and Xenia and Smith
Roads), only wet weather flows in excess of the capacity of the permittee's
two (2) interception pump stations, located at Stapleton Airport on Smith
Road.
(2)	Within one (1) year of the date of issuance of this
permit, the permittee shall complete a study to determine the sources of
all pollutants discharged from discharge points 008 and 009. This study
shall include an investigation of the chemical and biological characteristics
of the wastewaters discharged under all conditions of discharge (wet and	
dry weather), including the concentration and pounds, per day of such
pollutants as are contained in the wastewaters. -As part of this aspect
of the study, the permittee shall monitor frequency of discharge, rates
of flow, COD, Suspended Solids, Oil and Grease, airid toxic substances,
including Cadmium, Chromium, Copper, Cyanides, Lead, Nickel, Phenols,
and Zinc.
The study shall also determine what modifications and changes in
present facilities are necessary to eliminate the need to use discharge
points 008 and 009, or to treat the wastes discharge^, to a level adequate
to meet the requirements of Public Law 92-500.
The study shall also provide a compliance schedule for either the
elimination of the discharges or development of adequate treatment. This
schedule of compliance shall include, but is not limited to, dates for
the initiation and completion of: (i) Pre!iminary plans; (ii) Final plans
and specifications; and (iii) Construction of all necessary facilities.

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5 7
Permit No. C0-0026620
Page 9 of 19
All study requirements shall be summarized in a report to be
completed and submitted to the permit issuing authority for review and
approval within sixty (60) days of the completion of the study.
(3) The present facilities for pumping and pretreatment
now existing in conjunction with discharge points 008 and 009, shall be
operated and maintained by the permittee, in such a manner as to minimize
the discharge of pollutants to Sana Creek, and achieve maximum removals
of Oil and Grease and sediment before discharging pretreated wastewaters
to the Sana Creek interceptor.
2.08 Fifth Avenue and Zuni Street Discharge (010)
Alameda Avenue and Kalamath Street Discharge (011)
(1)	Upon issuance of this permit and until its expiration,
or until such time during the life of this permit that the permittee
installs facilities to eliminate this discharge point, the permittee is
authorized to discharge from discharge point 010 only to prevent; the
;backup of sanitary sewage into the basements of homes and businesses
connected to the system tributary to this discharge, and flooding of
streets in the immediate area.of Bryant Street and Fourth Avenue.
(2)	Upon issuance of this permit and until its expiration,
or until such time during the life of this permit that the permittee
installs facilities to eliminate this discharge, the permittee is authorized
to discharge from discharge point 011, only to prevent the overflow of
sanitary sewage into the Alameda Avenue-I-25 intersection complex.
(3)	The permittee shall investigate long-term solutions
to permanently eliminate discharges from points ©10 and 011 and all such
similar points in its system. Within ninety (90)) days of the issuance
of this permit, the permittee shall submit to the permit issuing authority
for approval, a proposed schedule of compliance wHirich shall include, but
is not limited to, dates for the initiation and completion of: (i) Pre-
liminary plans; (ii) Final plans and specifications; and (iii) Construction
of such facilities necessary to eliminate discharge of anything other than
storm water from points 010 and 011.
(4)	The permittee shall within miimety (90)
days of the date of issuance of this permit, begiim monitoring the volume
of flow of sanitary sewage being discharged from discharge" points 010 and 011.
This monitoring shall be representative of all filw discharged during any
period of discharge and shall include the duration of the discharge, the
peak rate-of-flow, and the estimated volume discharrged. The records of
this flow monitoring shall be submitted to the perrrnit issuing authority
on a monthly basis beginning at the end of the fiirst complete or partial
calendar month after issuance of this permit.

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Permit No. C0-0026620
Page 10 of 19
2.09 Sloans .Lake - West Byron Place "and Vrain Street Discharge (012)
(1)	Upon issuance of this permit and until its expiration,
or until such time as alternative facilities are constructed during the
life of this permit, the permittee is authorized to discharge from dis-
charge point 012, only to prevent the backup of sanitary sewage into
homes connected to the system tributary to- this discharge point.
The permittee shall notify the permit issuing authority within five
(5) days in writing, of each such discharge, in accordance with the
procedures specified in Section 5.00 of the Special Conditions of this
permi t.
(2)	Within ninety (90) days of the issuance of this permit,
the permittee shall submit to the permit'issuing authority, a plan to
eliminate1 the discharge of sanitary sewage through discharge point 012.
The plan shall include, but is not limited to, the dates for the initiation
and completion of: preliminary plans and specifications, and construction
of those"facilities necessary to" permanently eliminate the discharge of
anything other than storm water from discharge point 012.
(3)	The permittee shall monitor the volume of flow of
sanitary sewage being discharged through point 012. The procedure for
monitoring such flow shall be the same as.that contained in Section
2.08, paragraph (4), of this permit.
3.00 Monitoring and Reporting Requirements
3.01 Monitoring Program
No later than ninety (90) days from the
date of issuance of this permit, the permittee s.hall monitor the flow
of all discharges of sanitary sewage through discharge points 004, 010,
011, and 0!2. This monitoring shall be repres'eroliative of any period of
discharge. The permittee shall submit to the .peirmit issuing authority,
monthly reports containing the total daily volume of sewage discharged
through each of the points for that month.
Any flow monitoring device used by the permittee to achieve compliance
with this Section shall have a recording chart, and charts obtained from
this monitoring program shall be retained by the permittee for inspection
and use of the permit issuing authority.
This requirement in no way limits or precludes any other monitoring
and reporting requirements required by the State or any other authority,
and is not intended to comprise an inclusive listing of monitoring pro-
grams that might be in use by the permittee.

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, H
Permit No. C0-0026620
Page 11 of 19
3.02	Data Collection
Monitoring shall be in accord with the best methods
technologically feasible, and shall be in a manner acceptable to the
Regional Administrator. (Consult the Region VIII Treatment and
Preservation Guide for basic considerations.)
Analytical and sampling methods utilized by the permittee shall
conform to the test procedures as defined pursuant to 40 CFR 136 (Title
40, Code of Federal Regulations, Part 136) or any tnodifications thereto.
A-c the request of the Regional Administrator, the permittee must
be able to show proof of the accuracy of the flow-sneasuring and flow-
recording device used in obtaining data submitted for discharge monitoring.
3.03	Records and Reports
The permittee shall record: the.type of monitoring,
monitoring location, date and time of monitoring-, the'technique used,
and name of person(s) responsible for the monitoring. Instrument recording
charts, and records of maintenance and/or calibration of instruments,
shall be retained by the permittee for a minimum of three (3) years,
and shall be available for inspection in the offices of the permittee's
facility. The record retention period may be extended at the direction
of the Regional Administrator, and also must be retained during the
course of any period of unresolved litigation. The sampling point
location shall be subject to the approval of the permit issuing authority.
Monitoring results shall be summarized and reported on a Discharge
Monitoring Report Form 0MB No. 158-R0073 or subsequent revisions, post-
marked no later than the 28th day of the month following the end of the
reporting period. Results shall be reported at monthly intervals and
the first period shall be submitted for the first complete or partial
calendar month following the installation of flow monitoring devices.
Reports are to be submitted to the permit issuing authority over the
signature of the authorized signing official or his agent, as authorized
by a letter of delegation.
3.04	Other Consideration
Any unforeseen modifications or anticipated chanqes in
waste collection systems, industrial contribution, treatment and disposal
facilities, changes in operational procedures, elimination of discharge,
industry relocation, or other significant activities which alter the
nature and/or frequency of the discharge(s), or otherwise affect the
conditions of this permit, shall be enumerated in a written report

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Permit No. C0-0026620
Page 12 of "19
accompanying the first monitoring report following the development of
the aforementioned alterations or anticipated changes.
4.00 Solids Disposal
Effluent screenings, sludges, or other--ssl id wastes, shall not
be discharged into the receiving waters or their tributaries, and shall
not be disposed of in such a manner as to allow the entry of pollutants
from such materials into the receiving waters or their tributaries.
5.00 Accidental Discharge or Plant Upsets
5.01 Notification
The permittee shall notify the"permit issuing authority,
within five (5) days in writing, of any accidental discharge, upset,, or...
any other discharge or action or omission which will tend to violate the
conditions of this permit. Failure to provide such notification may
result in,the revocation of this permit. Within sixty (60) days: of the
issuance of this permit, the permittee shall file a statement with the
permit issuing authority, which shall contain the names of the person
or persons, who are designated to report conditions as noted in this
Section, which will tend to violate permit conditions. In the event of
such conditions, the'above-named person(s) will report the following
information as well as all other pertinent information:
(1)	The cause of the accidental or irregular discharge.
(2)	The anticipated amount of time the discharge of
condition is expected to continue, or the length of time it did continue
if it has been corrected prior to notification.
(3)	The contents of the accidental or irregular discharge.
(4)	Steps which will be, and have been taken by the
permittee, to mitigate any effect of the irregular discharge or condition
on the receiving water.
(5)	The anticipated effect on the receiving water.
(6)	Any measures that might' be necessary for downstream
users to take, in order to protect their interests.
(7)	What additional monitoring and recording activity
is being-conducted.

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Permit No. C0-0026620
Page 14 of 19
the collection system, and the Stapleton Airport storm water discharge
system (discharge points 008 and 009), this permit may be revised to
specify effluent limitations for any or all pollutants.
7.03	Industrial Waste Monitoring
Immediately upon issuance of this permit, the permittee
shall establish and implement, a procedure to obtain specific information
on the quality and quantity of effluents introduced by all major con-
tributing industries.
This information shall be submitted to the permit issuing authority
on a semiannual basis, beginning June 30, 1975. This information shall
be submitted; using the NPDES Standard Form A, Section IV, as a format.
)nce~the specific nature of the industrial contribution hasbeen
identified-, data collection and reporting requirements may be levied for
other parameters in addition to those included in Section 3.00.
7.04	Industrial Effluent Guidelines '
Based on the information regarding industrial inputs
reported by the permittee pursuant to the preceding Section, the permit .
may be amended to reflect effluent requirements for incompatible pollu-
tants. In addition, the permittee will be notified by the permit
issuing authority of the pretreatment requirements necessary for each
major contributing industry discharging incompatible pollutants to the
municipal system. The permittee'shall require all such major contributing
industries to implement the necessary pretreatment requirements. Not later
than one hundred twenty (120) days following receipt of the above informa-
tion, the permittee shall notify the permit issuing authority of specific
actions taken to achieve compliance with the pretreatment requirements...
8.00 Permit Duration and Reapplication
This permit will be in effect until October 1, 1976.	If the
permittee desires to continue to discharge, he shall reapply at	least
one hundred eighty (180) days before this permit expires, using	the
application forms then in use.
9.00 Abatement Program
9.01 Implementation Plan
(1) The permittee shall achieve compliance with the
preceding permit conditions, based on the following construction and
operational schedule:

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Permit No. C0-0026620
Page 15 of 19
(a)	Complete final plans and specifications for
main plant headworks improvement and equalization basins, within thirty
(30) days of the issuance of this permit.
(b)	Complete final plans and specifications for the
Northeast Sanitary Project (lift station and associated interceptors)
within thirty (30) days of the issuance of this permit.
(c)	Commence construction on the Northeast Sanitary
Project by June 1, 1975.
(d)	Submit progress report by December 31, 1975.
(e)	Complete construction of the'Northeast
Sanitary Project by September 1, 1976.
(f)	Northeast Sanitary Project to be fully opera-
tional by October 1, 1976.
(2) The permittee shall submit to the permit issuing
authority within ten (10) days following each interim date and the final
date on the implementation schedule, a report detailing compliance or
noncompliance. If noncompliance is reported, reasons shall be stated
plus an estimate of the date by which the permittee wiM complete the
delayed event. The permittee will notify the permit issuing authority
by letter when he has returned to compliance with the implementation
schedule.
10.00 Planning and Management Requirement
The permittee, in consultation with .'ttte several local govern-
ments served by its collection system, shall develop a schedule of new
extensions, connections, and hookups of new-sources (e.g., dwelling
units), to its waste treatment system, covering ttte period of time until
permanent facilities relieving the present overloaded conditions can be
constructed. This schedule should be phased to -prevent aggravating the
existing overflow conditions that exist at the pe>nnittee's several over-
flow discharge points. A copy of this schedule, along with a statement
of concurrence (or nonconcurrence), from the locail governments, shall be
submitted to the permit issuing authority for review, within ninety (90)
days of issuance of this permit. Thereafter, a tv>ice-yearly report shall
be submitted by the permittee to the permit issuing authority, and the
various local governments, tracking the rate of actual hookups, connections,
and extensions, against the agreed-upon schedule. If the schedule is
revised, copies of the new schedule shall be provided with the semiannual
report.

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Permit No. C0-0026620
Page 16 of 19
11.00 Expansion Requirements
The permittee shall:
Initiate engineering and financial planning for expansion
of the sewage treatment works whenever throughput and treatment reaches
eighty (80) percent of design capacity;
Commence construction of such sewage treatment works
expansion whenever throughput and treatment reaches ninety-five (95)
percent of design capacity or, in case of a municipality, either commence
such construction or cease issuance of building permits within such
municipality, until such construction is commenced, except that building
permits may continue to be issued for any construction which would not
have the effect of increasing the input of sewage to the sewage treatment
works of the municipality involved (CRS 25-8-501(6)).
12.00 Enforcement Notice
Should there be a violation of^any conditions of this permit,
the Environmental Protection Agency has the authority under Section 402(h)
of the Act, "to proceed in a court of competent jurisdiction, to restrict
or prohibit the introduction of any pollutant into the treatment system
covered by this permit by a source not utilizing such treatment system
prior to the finding that such condition was violated. It is intended
that this provision will be implemented by the Agency, or the State,
as appropriate.
13.00 Definitions
Except as otherwise specifically-provided:
(a)	The term "Act" means the Federal Water Pollution
Control Act Amendments of 1972, Public Law 92-500.
(b)	The term "Director" means the Director of the
Water Quality Control Division of the Colorado Department of Health or
his designated representative.
(c)	The term "Regional Administrator" means the Regional
• Administrator of Region VIII of the Environmental Protection Agency or
his designated representative.
(d)	The term "Major Contributing Industry" means any
industry that: (1) has a flow of 50,000 gallons or more per average
workday; (2) has a flow greater than five (5) percent of the flow

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Permit No. CO-0026620
Page 17 of 19
carried by the municipal system receiving the waste"; (3) has in its
waste, a toxic pollutant in toxic amounts as defined in standards
issued under Section 307(a) of the Act; or (4) has significant impact,
either singly or in combination with other contributing industries, on
the treatment works or the quality of its effluent.
(e) The term "Permit Issuing Authority" means:
(1) U.S. Environmental Protection Agency, Region VIII
1860 Lincoln Street, Suite 900
Denver, Colorado 80220
Attention: Enforcement - Permits
(2) State of Colorado Department of Health
Water Quality Control Division
4210 East 11th Avenue
Denver, Colorado 80220
14.00 Point Source Location
Point Source	Description and Location
001	Denver Northside Treatment Plant main
plant bypass on the west bank of the South
Platte River, located at latitude 39°47'00"
North, longitude 104°56'05" West, at the
Delgany Main River Crossing.
002	Denver Northside Treatment Plant Rocky
Mountain Overflow on the west bank of
the South Platte River, located at
latitude 39°47'50" North, longitude
104°56'05" West, approximately 200 feet
downstream from the Delgany Main River
Crossing.
003	51st and York Street Overflow, on the
east side of the Burlington Ditch,-
located at latitude 39°47'34" North,
longitude 104°57'31" West, approximately
0.2 miles (0.4 kilometers) upstream from
the York Street bridge, across the
Burlington Ditch.
004	Dumb Friend's League Bypass on the east
bank of the South Platte River, located
at latitude 39^41 '40" North, longitude
104°58'45" West, at 1295 South Santa Fe
Drive, approximately 2.5 miles (3 kilometers)

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I /

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yjc)
Permit No. C0-0026620
Page 19 of 19
Point Source	Description and Location
Oil	Alameda Avenue and Kalamath Street.
Discharge is from a storm drain identified
as Denver Health Department index number
S-33-E, on the east bank of the South
Platte River, located at latitude 39°42'37"
North, longitude 104°59'56" West, immediately
upstream from the Alameda Avenue crossing of
the South Platte.
012	Sloans Lake - West Byron Place and Vrain
Street. Discharge is from a storm drain
on the north shore of Sloans Lake at
latitude 39°45'10" North, longitude
105°02'50" West, immediately south of the
above-cited intersection.

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APPENDIX B
UNITED STATES ENVIRONMEN I i_ PROTECTION AGENCY
subject: N. E. Sanitary Sewer Meeting; C-080318	DATE: WAY 0^
FROM: George L. Hartmann, Chief
Operation & Maintenance Section
TO: Files
Met with the following at DWWC offices from 1:30-5:00PM on
January 23, 1975:
Bill Bertram - EPA
Bob Madden	- DWWC
Don Fredricks - DWWC
Cal Ferguson - DWWC
Earl Balkum	- CWQCD
The original meeting was called to discuss the requirement
for and cost of flood protection of the proposed lift station at
the river's edge for the N.E. Sanitary District Sewer Improvements.
After long discussions of the proposed project including the
history of the project and the various cost estimates for the
various phases of the project, the meeting was adjourned.
The city of Denver estimated that, the present grant and grant
increase amendment for C-080318 will eliminate approximately 95-99?;'
of the bypassing at the 51st & York St. junction structure, J.S.fM.
The proposed L.S.#5 and related work will not by themselves eliminate
all bypassing at J.S.H during high rainfall related flows and
will not eliminate the discharge of raw sewage from the approximately
10 homes discharging to the existing 218" x 4'0" brick sewer below
J.S.#4.
EPA Form 1170-6 (Rcy. 6-72)

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The City's flow estimates for the sanitary. flows to J.S.#4
are based on present population and future population estimates
and estimated per capita flows for these areas and from estimated
present and projected industrial flows in the area. An infiltration
and inflow analysis for the area has not been"done since this grant
was made before this was a federal requirement. The design flows
used include however an estimated infiltration flow. Because the
City has not made any detailed flow studies, the' amount of flow which
is reaching J.S.#4 and the amount actually being bypassed at this
time is not known.
The original design of the project involved modifying and
reconstructing the existing J.S.#4 which would prevent the completed
facility from bypassing any flow that reached J.S.M. The original
proposal would also provide a stub out for a 48" gravity sewer
which would approximately follow the existing siphon and would
probably be required for peak flows sometime around 1985.
The present project now with the EPA "will not modify J.S.#4,
hence some bypassing will occur during extreme flows. Because of
leakage around the present bypass gate, some bypassing is probably
occurring now during low flows and will continue to occur after
completion of the project.
The City completed plans and specs for this project and has
also completed plans and specs for the rest of the N.E. Sanitary
Capital Improvements (City Proj. §72-052). The City project #72-052
is the City's answer to complete the abatement of all raw wastes
discharged in the N.E. area, both bypassing and combined, as well
as providing the interceptors, lift stations and force main needed

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to transmit this sewage to L.S. ft5. Attached are the best cost
estimates available from the City for Uiis work.
The City's design report of June 1974 "Engineering Report,
Project 72-052, N.E. Sanitary Capital Improvements" contains the
present and projected service areas, populations, design flows and
proposed facility construction.
The estimated flows to L.S. #5 if the entire project 72-052
is constructed is:
Mi n.	Ave.	Peak
1973	—	12 cfs 32 cfs 64 cfs
2020	—	15 cfs 40 cfs 80 cfs
The anticipated flows from area §3 which is served by L.S. £6
and force main are:


Min.
Ave.
Peak
1973
—
0.1
0.3
1.3
2020
.
0.4
1.5
5.3
Estimated increases in peak flow from 1973: to 2020 for the
entire tributary area is ^54^ = 25% or 0.5%/year. Lift Station #5
is designed with three screw pumps to handle tihie 80 cfs 2020 design
flow.
The City at present plans to construct phase I of 72-052
immediately (C-080318) and to go ahead as soon as possible, with
phase II of 72-052 which is the remainder of tfe'work described above.
The City believes that it is cost effective to not make major
modifications to J.S. #4 of approximately $100,®00 - $200,000 because
when the additional 48" parallel interceptor is required, it will

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be extremely costly to construct this n'ne due to -close proximity
of buildings in the area. Hence the City has opted to construct
a new junction structure J.S. H6 and construct a 48" main from there
to a "new junction structure J.S. §2 on the existing siphons. The
City will also construct a new 60" gravity main from J.S. H2 to
L.S. #5 to enable the 2020 design flows to get to L.S. #5 as the present
siphons are inadequately sized for this flow. . The immediate project
cost differential then between these two concepts is:
Original Proposal	$1,445,000'- L.S.#5 etc.
(Including needed flood	200,000 - J.S.#4 modif.
protection work at
L.S.#5)	1,645,000
New City Design	$1,445,000 - L.S.#5, etc.
113,000- 60" Main
425,000' - J.S.#6 & 48" pipe
1,983,000
Cost Differential =	- $1,645,000 .
338,000 (More for New City Design)
Because there is some concern by the City ©f the capacity of
the siphons between proposed J.S.#2 and L.S.#5, it may be necessary
to build J.S.§2 and the 60" main, in which case the cost differential
is:	$338,000
-119,000 -(60" main & J.S.#2)
219,000
Attached is a breakdown of the N. E. Sanita:ry System Costs provided
by DWWC on 1/23/75.

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The City was told by the EPA and State that they could ask to
have the grant increased so that all of project 72-052 could be
built as C-080218. The EPA also stated that the Ctiy would be
informed informally ASAP as to how the EPA would look upon such
a grant increase
George Hartaann
Attachments

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N. E. SANITARY SYSTEM
Cost Estimates Provided by DWWC 1/23/75
Original Estimate
Original and present EPA grant - To
Completely eliminate bypassing to
River, but would not eliminate
discharges of unsewered area.
Total Cost	Grant Cost
$871,200
$653,400 .
January 23,	1975 Est. for L.S. at
River and minor work in area, will
result in 95-99% elimination of
bypassing	and build flood protection. 1,445,00	1,085,000
January 23, 1975 Est. for L.S. at
river plus all other work to eliminate
any bypassing and to provide service
to raw discharge area.	2,228,000	1,710,000
(Grant increased $1,057,000
over present grant)
Cost Breakdown
(A) L.S. at River and related minor piping and flood projection
(1)	L.S. pumps (3)	-	$154,000
(2).	Construction of L.S.	-	500,000
(3)	L.S. discharge main	-	75*000
(4)	Flood protection	-	25Q„000
(5)	Misc. work, etc.	-	466^000
Total	- $1,445,000
In addition, it may be necessary to modify J.5_#4 in order to eliminate-
most bypassing and to make system work. ($liGffi)r0OO-2OO,000)
(B) Total Project
(1)	L.S. and flood protection, etc.	-	$1,445,000
(2)	60" Interc. and J.S J2	-	113,000
(3)	48" Interce. and J.SJ6 and minor
work at J.SJ4	-	425,000
(4)	14" force main from L.S.#6 to J.S.#4 -	125,000
(5)	L.S.#6	-	120,000
Total	-	$2,228,000

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