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2. DESCRIPTION OF THE SELECTED ALTERNATIVE
2.1 EPA's Decision
EPA's selected alternative for the Mill Creek EIS study area should be
regarded in the light of several important factors:
1. The study area comprises a relatively small portion of the Jefferson
County area not currently served by regional sewers.
2. EPA has recognized the crucial need for relief of unsewered areas
in the Pond Creek watershed. EPA supports the construction of the
West County wastewater treatment plant to service the Pond Creek
watershed.
3. Wastewater management activities carried out in any part of Jeffer-
son County should be part of a feasible, comprehensive program.
4. Unlike most of Jefferson County, subsurface conditions in the Mill
Creek area allow most wastewater management needs in the area to be
satisfied by on-site systems.
EPA has determined that the appropriate action for the Mill Creek area
would be to alleviate the problems caused by malfunctioning commercial septic
tank systems and small wastewater treatment plants by implementing Alternative
7b, as shown in Figure 3. This alternative proposes a limited sewering action
that would serve the Dixie Highway Corridor and at least eighteen of twenty-
six small package plants, while leaving the residential community on septic
tanks. The remaining eight small plants could be dealt with in
one of several ways, such as 1) upgrading to meet water quality requirements,
2) disposing of effluent to seepage pits, subject to the Underground Injection
Control (UIC) program under the Safe Drinking Water Act (SDWA), 3) conveying
wastewater to the existing Black Pond Creek interceptor or 4) conveying waste-
water to the proposed Dixie Highway Interceptor. Other small, existing treat-
ment facilities with surface water discharges (seven plants in the 500 to 2,000
gallons per day range are operated in the study area) could be connected to
the existing Black Pond Creek sewer, to sewers to be constructed under
Alternative 7b, or to groundwater discharge.
It is important to note that EPA's decision relates only to the waste-
water management needs of the Mill Creek study area. Thus, the selected action
represents a decision of federal funding for the area of greatest need for
public sewering in the EIS area. Since on-site systems in the EIS area are
functioning adequately to provide wastewater disposal for most residences, EPA
did not consider funding of more extensive regional sewers to be cost-effective.
EPA recognizes that serving future population with on-site systems
would not be consistent with existing Health Department septic tank regulations.
In this regard, the Federal government is not attempting to preempt local
decision-making. Additionally, EPA is not seeking to limit the flexibility of
local government in accommodating future development in the study area. It
should be noted that, although on-site systems would not be consistent with
certain types of residential and commercial development, substantial sewer
capacity is available at this time in the Black Pond Creek interceptor. EPA's
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selected action does not preclude use of this existing sewer to serve future
developments, nor does it prevent locally funded expansion of the public
sewer system or increased sewer capacity beyond the scope of Alternative 7b.
2.2 Description of the Selected Alternative
Alternative 7b makes use of three types of treatment systems: a
regional system, on-site systems, and possibly a few small-area treatment
plants. Existing unsewered commercial units not along the Dixie Highway
corridor and existing unsewered residental units will continue the use of
on-site systems or connect to existing interceptors. The eight small-area
treatment plants that serve schools have several options available, including
1) upgrading for surface water discharge, 2) disposing in seepage pits, sub-
ject to the UIC program under the SDWA, 3) conveying wastewater to the existing
Black Pond Interceptor, and 4) conveying wastewater to the proposed Dixie
Highway Interceptor. The other 18 treatment plants and commercial units
along the Dixie Highway corridor will be served by the limited regional system
with wastewater being conveyed to the proposed West County Plant for treatment
and discharge to the Ohio River. Future development will be served by on-site
systems or by tying into the existing Black Pond Interceptor at the choice of
local developers and administrators.
2.2.1 On-Site Systems
There are over 20,000 existing on-site systems in the Mill Creek area
serving single-family dwellings, mobile homes, multi-family dwellings, and
non-residential units. Under Alternative 7b, all but approximately 400 non-
residential units will continue the use of on-site systems.
The typical on-site system in Mill Creek consists of a septic tank
and seepage pit. A septic tank is a watertight tank, usually constructed of
concrete, that receives and treats all wastewater from a house or other source.
Residential tank volumes usually range from 3 to 6 m3 (750-1,500 gal), de-
pending on the size of the house and state or local sizing requirements. As
wastewater passes through the septic tank, the heavier solids sink to the
bottom and the lighter particles rise to the surface; partially treated
liquid flows from the tank to the disposal area. Liquid detention time in
the tank is usually two to four days. The solids remaining in the tank under-
go anaerobic decomposition. The septic tank must be pumped out periodically—
usually every 2 to 5 years—to prevent solids from building up and overflowing
the tank into the disposal area, where the solids can clog the soil pores
until the absorption system eventually stops functioning. The septage that
is pumped out of the septic tanks is discharged into the Morris Forman system
for further treatment and disposal.
A seepage pit is a lined, circular pit approximately 1.2 m (4 ft) in
diameter and 6 m (20 ft) or more deep. The bottom of the pit is filled with
gravel or crushed rock to a depth of 0.3 to 0.6 m (1 to 2 ft). Wastewater
is discharged to the pit and seeps through the gravel into the surrounding
soil. The depth of the pit is dependent on the location of suitable soil for
absorption and renovation of the wastewater. In Mill Creek the seepage pits
are extended through the non-porous upper soils of clay and discharge into the
underlying glacial sand and gravel.
Septic tanks are designed to last approximately 40 years. Should
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structural failure of the septic tank occur, sewage could rise to the ground
surface and/or back up into the house. Should failure occur it may be
necessary to replace the septic tank. For houses on 0.1-ha (0.25-ac) lots or
smaller, it may be difficult to get the construction equipment required to
replace the septic tank into the back yard. In this situation it may be
necessary to use an alternate, potentially more expensive means of replacement.
By the year 1995, 4,170 units will be 40 years old. An additional 10,800
units will be 40 years old by the year 2005.
Wastewater management for future growth has been assumed, for cost
estimating purposes, to be provided by on-site systems, or by connection to
the future interceptor sewer system. EPA recognizes that septic tank use
in Jefferson County is constrained by a 1978 Health Department regulation
(Chapter III, Rule 8, of the Sanitary Code of the Louisville and Jefferson
County Board of Health) to lots of 5 ac (2 ha) or more, except on building
lots that existed before June 1, 1978. EPA is not recommending that this
regulation be adjusted, since the rule's enforcement and interpretation are
local prerogatives. If the septic tank regulation, as it is applied to the
Mill Creek area, continues to forbid development with on-site systems, public
or private sewage faciltiies would be required to accommodate future wastewater
management needs.
Management of the on-site system would continue to be the responsibility
of the owner. Responsibilities of the owner include having the septic tank
pumped out every 2 to 5 years and replacing the system should it fail.
2.2.2 Small-Area Treatment Plants
Of the existing 26 treatment plants, 18 are proposed to be served by
the selected alternative. Options available to the remaining 8 plants include
upgrading for surface water discharge, disposing to a seepage pit, or conveying
wastewater to a public sewer. Table 4 lists the NPDES permit number, the
design flow, the liquid and sludge treatment method, and the receiving stream
for each of the 8 remaining plants. The treatment plant locations are shown
on Figure 2. The effluent disposal method will be determined by the treatment
plant owner and will be based on cost, soil suitability, and the ability to
get a discharge permit for the selected method. If the plants are retained
and upgraded, the effluent disposal method is likely to be 1 of 2 alternatives:
surface water or subsurface discharge.
Surface water discharge would require an effluent in conformance with
the standards shown in Table 5. Each of the extended-aeration plants would
require upgrading to produce an effluent suitable for discharge to surface
waters:
1. Plant effluent would be treated by sand filtration.
2. Sand filter effluent would require reaeration to meet the dissolved
oxygen discharge standard.
The treatment facilities at the Wade Shacklette School would require
additional upgrading to extended aeration for the surface water discharge
alternative.
For subsurface effluent disposal, discharges would be subject to the
UIC program under the SDWA; appropriate treatment processes would be determined
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TABLE 4. SMALL WASTEWATER TREATMENT PLANTS IN THE SELECTED ALTERNATIVE
Name
(a)
5. Sanders
Elementary School
9. Eisenhower
Elementary School
11. Pleasure Ridge
Park High School
12. Conway
Middle School
14. Shacklette,
Wade School
22. Kerrick
Elementary School
23. Wellington
Sara Belle
School
25. Johnsontown
Elementary School
NPDES
Permit No.
00027138
00026999
00027120
00027197
00027014
00027090
00027103
00026310
Design Flow
3/d
Treatment Methods
m
28
28
28
57
S£±
7,500
57 15,000
250 65,000
Liquid
Extended
Aeration
Extended
Aeration
Extended
Aeration
Extended
Aeration
57 15,000
30 8,000 Lagoon
Sludge
Hauling
Hauling
Hauling
Hauling
Hauling
Aeration
Receiving Stream
Davis Run Creek
Mill Creek
(600 Trib.)
Mill Creek
(Unnamed Trib.)
Mill Creek
(Unnamed Trib.)
Ohio River
7,500 Extended Hauling Big Run
(Unnamed Trib.)
7,500 Extended Hauling Ohio River
Aeration
15,000 Extended Hauling Ohio River
Aeration
Sources: NPDES Permit information: Louisville and Jefferson County Department of Public Health;
Kentucky Department for Natural Resources and Environmental Protection
(a)
Numbers keyed to plant locations in Figure 2.
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TABLE 5. EFFLUENT LIMITATIONS FOR DISCHARGE TO SMALL STREAMS
IN THE MILL CREEK STUDY AREA
Effluent Characteristics
Biochemical Oxygen
Demand (5-day)
Total Suspended Solids
Fecal Coliform Bacteria,
Number per 100 ml
Ammonia
Dissolved Oxygen
pH
Floating Solids,
Visible Foam
General
Effluent Limitation
Daily Ayr.
Daily Max.
10 mg/L
10 mg/L
20 mg/L
20 mg/L
200
4.0 mg/L
400
8.0 mg/L
6.0 mg/L minimum at any
time
not less than 6 and not
greater than 9 standard
units
No discharge in other than
trace amounts
Shall not cause a visible
sheen on the receiving
water
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for each discharge site. Design criteria established by the Jefferson County
Sanitary Code were used for preliminary seepage pit design.
Under either discharge alternative, three plants will be 30 years old
before the end of the planning period and may need to be replaced:
Kerrick Elementary School
Pleasure Ridge Park High School
Sanders Elementary School
Replacement would probably occur in conjunction with the upgrading of
the plants. Those plants that would continue to discharge to surface waters
would be replaced with extended aeration package treatment plants. Those
plants that would use subsurface effluent disposal and not need to be replaced
or upgraded would continue the use of their existing treatment systems before
discharge to a seepage pit.
Additionally, the option of tying into the existing Black Pond
Interceptor or the proposed Dixie Highway Interceptor and the West County
Treatment Plant are technically plausible (pump station and small-sized force
main) and potentially economically attractive.
2.2.3 Regional Treatment System
The regional system would serve approximately 400 commerical units
along the Dixie Highway corridor and the following 18 package plants (the
numbers in parentheses are keyed to Figure 2):
Valley Village Subdivision (1)
Valley High School (2)
Villa Anna (3)
Beth Haven Baptist Church (4)
Westland Mall (6)
Timothy Hills Subdivision (7)
Eden Apartments (8)
Waverly Hills Apartments (10)
S.W. Jefferson County Government Center (13)
R & W Laundromat (15)
Havalock Subdivision (16)
Silver Palms Swim Club (17)
Cardinal Mobil Home Park (18)
Fordhaven Subdivision (19)
West Springfield Subdivision (20)
Forest Hills Subdivision (21)
River Valley Mobile Home Park (24)
Woodhaven Medical Services (26)
Interceptors will convey the wastewater by gravity to a planned
2.2 m^/s (50 mgd) West County Treatment Plant. The average daily flow
from Mill Creek to the West County Treatment Plant would be 0.13 m^/s
(3 mgd).
Interceptor alignments are shown on Figure 3. Interceptor OR-1, VT-2s
and VV-1 would be constructed as designed by MSD for the 201 plan. The inte*-^
ceptors along Dixie Highway were designed using the design criteria set forth
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in MSD's Design Manual; Tables 6 and 7 show preliminary design data developed
for the Dixie Highway segments. The interceptors size ranges are:
Size Range
Interceptor
in.
cm
DH-1
DH-2
DH-3
DH-4
DH-6
DH-7
DH-8
OR-1
VT-2
VV-1
8-12
10-30
24-27
27-36
8-12
12-21
10-15
10
10
10
20-30
25-76
61-69
69-91
20-30
30-53
25-38
25
25
25
2.3 Project Impacts and Mitigative Measures
2.3.1 Historic Places
Six historic places have been identified as being potentially affected
by the selected alternative (See Section 3.2.6) due to their proximity to the
preliminary interceptor alignments. Historic places can be directly affected
if the interceptor is designed to go through the site. Sites could be af-
fected indirectly by nearby construction activities that could cause struc-
tural damage. Direct impact could be mitigated during the final design of
interceptors by routing interceptors to avoid historic places. Indirect
impacts could be mitigated by modifying construction procedures and/or taking
precautions at the affected site, for example by providing temporary additional
structural support. Documentation of plans to mitigate the impacts to his-
toric sites will be a grant condition that will need to be complied with
before construction is initiated. No construction will take place until
surveys are completed to the satisfaction of the State Archaeologist and
the State Historic Preservation Officer. Should resources be discovered, the
appropriate state office should be contacted for mitigative measures. No
construction will take place until the appropriate state offices are
satisfied with the selected mitigative measures.
2.3.2 Archaeological Sites
Many archaeological sites have been found in the study area and
throughout Jefferson County. Construction activities associated with
interceptor placement and treatment plant construction could uncover addition-
al sites. Such discovery could be considered beneficial if it leads to archae-
ological development and study, for example, or adverse if the site is dis-
turbed or destroyed.
Archaeological surveys will be a grant condition that will need to be
complied with before construction is initiated. Emergency contacts will
also need to be established for emergency discovery of sites during construc-
tion. No construction will take place until surveys are completed to the
satisfaction of the State Archaeologist and the State Historic Preservation
Officer. Should resources be discovered, the appropriate state office should
be contacted for mitigative measures. No construction will take place until
the appropriate state offices are satisfied with the selected mitigative
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TABLE 6. DESIGN DATA FOR THE DIXIE
HIGHWAY INTERCEPTOR
Interceptor
Segment
Flow
(b)(c)
Interceptor Design^
Average
(mgd)
Peak
(mgd)
Diameter
(in.)
Slope
{%)
Length""
(ft.)
DH-1
A
1.23
4.45
27
0.067
5,600
B
1.52
5.33
36
0.046
4,750
DH-2
A
0.03
0.16
8
0.005
1,400
B
0.07
0.34
10
0.28
2,300
C
0.10
0.48
12
0.22
2,050
DH-3
A
0.05
0.26
12
0.22
6,000
B
0.39
1.95
21
0.10
4,500
DH-4
A
0.02
0.09
10
0.28
2,800
B
0.23
1.14
15
0.15
3,650
C
0.10
0.48
10
0.28
2,000
DH-6
-
0.24
1.10
10
0.60
5,500
DH-7
-
0.12
0.59
10
0.24
6,650
DH-8
-
0.08
0.38
10
0.22
6,450
See Table 7 for location of segments.
^ Includes existing treatment plant flows and flows from existing conune^c .
areas shown on MSD's Master Plan drainage maps. Commerical flow estl^
and peak factors as per MSD's Design Manual.
Metric conversions: mgd x 3,790 = m^/d; in. x 2.54 * cm; ft. x 0.305
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TABLE 7. LOCATION OF DIXIE HIGHWAY
INTERCEPTOR SEGMENTS
Location
Interceptor Segment From...
To.
DH-1
DH-2
DH-3
DH-4
DH-6
DH-7
DH-8
A VT-2
B Pages Lane
A Greenwood Road
B Seibel Court
C Paramount Drive
A Lewiston Place
B Lower Hunters Trace Road
A Lewiston Place
B Meyers Lane
C St. Pauls Church Road
Bethany Road
Citation Drive
Alandale Drive
Pages Lane
WH-1 (a)
Seibel Court
Paramount Drive
Pages Lane
Lower Hunters Trace Road
VT-2
Meyers Lane
Lower Hunters Trace Road
Lower Hunters Trace Road
PC-1
PC-1
Bethany Road
Notes: Odd numbered interceptors are along the west side of Dixie
Highway; even numbered interceptors are along the east side
of Dixie Highway.
DH-2
j oins
DH-1
at
Pages Lane.
DH-4
joins
DH-3
at
Lower Hunters Trace Road
DH-7
joins
DH-8
at
Bethany Road
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measures.
2.3.3 Highways
f the preliminary interceptor routes lie in highway corridors;
M°S^ ° h the final design will also route interceptors through
it is likely t a^ ouring final design, contact will be made with the
highway corr ors. ^ jranSportation to coordinate any proposed access to
Kentucky Departmen ctate maintained roads, and to obtain any required
or encroachment on any
permits
2.3.4 Public Health
Removing or upgrading small treatment plant discharges to .<^11
streams would reduce the potential risk of infection from informal recrean
use of streams in the study area. The health risk is posed by possible nal
inadequate disinfection of treatment plant effluent before discharge.
Continued use of subsurface disposal of septic tank effluent by th*
present and future residential population served by septic tanks would
continue the existing impact to groundwater. To mitigate potential healtK
problems, users of private wells should be connected to treated public wa
supplies. At a minimum, private well water should be disinfected prior ?
consumption. Regardless of which alternative is selected, connection to
public water supplies is encouraged because of the time required to IthdI
any alternative. p enJent
2.3.5 Noise
Noise would be created by several aspects of the proposed alternate
Short-term impacts from construction noise during interceptor olacement Ve<
be significant particularly affecting close-quarter businesses along Dix?""
Highway. Neighborhood noise levels would be increased in the short-term C
construction of other interceptors, by the upgrading or dismantline of = y
treatment plants, and by seepage pit construction. To mitigate these aH^11
impacts, project activities should conform to local noise regulations. FSe
2.3.6 Soils
The proposed alternative would have minor local impacts on soils -
the study area Limited erosion and mixing of soil horizons would ocCur *
from constructing the regional interceptor along Dixie Highway and sever*
connect the areas served by the small treatment plants that would be a! to
bandoned. Along Dixie Highway, soils would be exposed as trenches are d
or the interceptor. Connecting sewers from abandoned treatment plants w8
be placed along stream corridors and streets. Good erosion control pr! °ul<*
would mitigate adverse impacts during construction and post-construction^*8
impacts could be mitigated by resurfacing disturbed streets and replant?
vegetation along disturbed stream corridors. Appropriate erosion contr
methods will be identified during final design and Lauded to the co«°i
drawings. 11 tract
2.3.7 Terrestrial Ecolopv
Adverse impacts will result from construction of sewers along 8tl.
cre«un
-*u-
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corridors by disturbing natural vegetation and disrupting wildlife habitat.
These impacts can be mitigated by replacing vegetation, making minor route
changes to avoid large trees, and restricting construction right-of-way to
the minimum necessary for construction equipment. Specific mitigation prac-
tices will be identified during final design and included in the contract
drawings.
Very few wetlands remain in this highly urbanized area. If, during
design, interceptor routes are found to cross wetlands, appropriate permits
will be obtained from the Army Corps of Engineers.
2.4 Construction Grant Priorities in Jefferson County
This EIS demonstrates that the most cost-effective, environmentally sound
action for the Mill Creek area would be to implement Alternative 7b. It is
important to note that the proposed action for the Mill Creek area must be
assigned a priority for implementation in the context of the needs of the
entire portion of Jefferson County. The appropriate forum for assignment of
priority is through a local evaluation process combined with consideration
(for these portions of projects which are either EPA grant eligible or are
dependent on EPA eligible projects) of Kentucky's assignment of priority and
resulting expected fundability. This process should reestablish the extent
and focus of the County sewer expansion program by setting priorities for
program segments clearly based on environmental and public health needs in
light of the latest cost and environmental information, as well as the
availability and timing of funding. For example, there would be little point
in setting a high local priority for projects that the state priority list
showed for either low or no priority.
This procedure should be directed toward establishing priority for
Jefferson County program segments to include, but not limited to:
1. The Mill Creek proposed action,
2. Pond Creek sewering,
3. The West County treatment plant,
4. Morris Forman diversions,
5. County-wide sludge management,
6. North County EIS proposed action, and
7. Floyds Fork wastewater management.
Although the priority of implementing Alternative 7b in the Mill Creek
area will be determined through this process, certain critical public health
and water quality needs are clear. Pond Creek needs have been recognized by
MSD and EPA since 1974 to be extremely urgent. Further, preliminary
evaluations related to the North County EIS have provided extensive evidence
of serious public health problems posed by failing on-site systems.
In placing the Mill Creek area EIS selected alternative in perspective
with Jefferson County's other wastewater management problems, it becomes clear
that other projects such as the West County - Pond Creek System, the North
County project, and Morris Forman system improvements should proceed as
rapidly as possible. The correction of existing surface water discharge
problems and problems associated with the use of on-lot systems by commercial
establishments along Dixie Highway are also high priority. In setting these
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priorities, future options for the Mill Creek area residential on-lot systems
should remain flexible. Certain general criteria for determining when and
under what circumstances the Mill Creek area residential on-lot systems should
receive a higher priority rating would be helpful. These criteria should also
provide a basis for proceeding with the critical correction of water quality
and public health problems occurring elsewhere in the County. The criteria
can address, in general terms, the parameters involved in future decisions
regarding Mill Creek priorities, and the reasons for the higher priorities of
the other, more critical areas of the County.
Typically, the evaluation of site suitability for septic tank use
considers constraining physical conditions such as depth to bedrock,
percolation rates, seasonal high water table, population density, etc. The
general priority criteria that are addressed in this EIS will expand upon
these conventional physical parameters and concentrate on criteria with
specific application to the wastewater problems of Mill Creek and Jefferson
County.
This initial development of priority criteria involves the consideration
of factors that are critical to determining existing priority and for
determining when and under what circumstances a lower priority area should be
reassigned a higher priority. Local and state evaluations should be directed
toward refining these general priority criteria and determining local priority
positions.
The following criteria for determining existing and future priority
positions are proposed:
1. The development of adverse public health impacts from septic tank
failures.
2. The occurrence of significant functional or operational failures of
septic tanks.
3. A rise in groundwater levels that adversely affects septic tank
operation.
A. The establishment of a plan for use of groundwater as a public water
supply source where existing on-lot operations preclude such use.
5. Significant, demonstrable adverse land use impacts caused by
constraints from established wastewater management operations.
Discussion of Criteria
1. The development of adverse public health impacts from septic tank
failures.
The elimination or avoidance of adverse public health impacts is a
critical concern in wastewater management. These impacts could include changes
in water quality, increases in pollution levels, creation of high risk
situations or the aggravation of an existing problem resulting in public
health risks. For the purposes of this study, impacts to public health relate
-3-6-
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primarily to existing and future uses of surface and groundwater resources.
These uses include body contact and consumption.
The quality of Mill Creek area groundwater has been determined by the EIS
Groundwater Program to be influenced by existing septic tank use and not
suitable as an untreated drinking water source. The sampling program showed
some cases of high nitrate levels and elevated bacteria levels. The potential
for public health impacts related to groundwater influenced by septic tanks is,
however, tempered by limited existing and future use of groundwater.
Additionally, since the incidence of system failure in the Mill Creek area is
extremely low, the potential for human contact with failing systems is also
low. Therefore, the existing situation in Mill Creek and the future situation
under the EIS preferred alternative are cases in which public health problems
are not expected to develop. Other areas of the County are, however,
experiencing substantial on-site system failure and therefore exhibit greater
potential for human contact with failing systems and waters impacted by these
systems.
The significance of this criterion in re-establishing priorities can be
determined by relating the characteristics and circumstances of system
failures to the potential for public health impact. This relationship should
consider the rate of septic tank failure, the cause of failure (maintenance
problems, unsuitable soils, high water table, etc.), the nature of failure
(ponding, overflows, backing-up, etc.), the water quality impact, and the use
of the resource being impacted (potential for human contact). By monitoring
these situations and documenting changes in conditions, the redefinition of a
priority may be appropriate.
2. The occurrence of significant functional or operational failures of
septic tanks.
For septic tank systems to be successful, they must be operationally
sound and functional. The failure of an on-site system can be attributable to
site constraints, lack of maintenance or structural failure. In those cases
where significant structural failure has resulted in system failure, the
options include rehabilitation or sewering. In many cases of structural
failure, the site is still suitable for continued system use, however, if
significant numbers of on-site systems are experiencing structural failure,
rehabilitation or replacement may not be feasible because of technical
difficulties, cost or potential public health impacts. These instances should
be analyzed on a case by case basis in order for the significance of this
criterion to be determined.
3. A rise in groundwater levels that adversely affects septic tank
operation.
It has been reported in the past that groundwater levels in Louisville
are rising. This does not seem to be the case in the Mill Creek area despite
the contribution to groundwater from on-site systems. In order for septic
tank systems to be successful, a sufficient zone of subsurface soils between
the disposal unit (lateral field or seepage pit) and the groundwater table is
needed. In recognition of this need, Section 304.406b (6) of the Sanitary
Code of the Louisville and Jefferson County Board of Health requires that
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"whenever, in the course of construction, tfte (seepage) pit bottom penetrates
the subsurface water table, the bottom of the pit shall be filled wit-h r•^
coarse sand to a level at least two feet above the water table " f ean'
the application of this criterion for re-establishing priority';
be appropriate when groundwater levels rise to the point that oLation «?
significant number of septic tank systems are impaired and measure Z *
available to mitigate these operational problems. e not
4. The establishment of a plan for use of groundwater as a m.Kn,
supply source where existing on-lot operations preclude such use "
Most of Jefferson County's water supply needs are met- -u r
Water Company (LWC). At present, the Ohio River is the s l Louisville
water for the LWC, which is permitted by the Kentucky DNPFp%S°UJTuJ°f raw
yearly average of over 200 million gallons per day. in ° t"^raw a
have not been extended, water supply is provided bv dH areas w^ere LWC lines
esample, 300-600 homes (1-2%) in the Mill Creek am° vate water wells. For
water supply. area use P^ate wells for
In the event that groundwater is proposed to be us A
supply source, measures should be taken to minimis _ 88 8 Public water
degradation. In the case of Mill Creek area groundwat qyality
program found that groundwater was being influenced b er' EIS groundwater
use (some elevated nitrate and bacteria levels) anH ^ e*isting septic tank
untreated drinking water source. It was also indi t%n°£ sultable as a*i
public health impacts related to groundwater infliion^ u the Potential for
tempered by limited existing use and future use nf «,*• j septic tai*ks is
to future use, the LWC has indicated that there are °unJwater* With regard
plans to use the groundwater in southwest Jeffer^nr, r° rt or 1°n8-terni
data indicate the Mill Creek area groundwater could Nevertheless,
future with increased wastewater discharges be ur a the
With the application of conventional disinfection *>,aS#a raw water source,
would be expected to be well within established f 5±^ishfed drinking water
criteria. nea finished drinking water
If, however, conditions and policies were to change and the LWC proposed
to use Mill Creek area groundwater, it may be appropriate to minimize the
impact on groundwater quality.
5. Significant, demonstrable adverse land use impacts caused by
constraints from established wastewater management operations.
It is expected that under the EIS selected alternative, future
development can be accommodated by on-site systems and existing sewer lines.
This wastewater management system should allow for existing land use patterns
to continue. If, however, a significant shift in expected development
patterns, trends or types would develop that could not be adequately served by
the preferred alternative, adjustments or modifications to the system
configuration may be appropriate.
-38-
-------
CHAPTER 3
Sewer EIS Study
Review Committee
Holds Meeting
BsHnWMMW PMtwtioa Aamqr oWetefa lacfcnicataaDactaorii-
- - — «-W- Commtiu. it, "-**0,
BnfdmHl wid h« heftr,,* ^ ^
too* H th« •004) MOd jQi.1 ***** "Mul*
^r«jr "'""""'"¦IM.rtU,
Meeting tonight on southwest sewers
By SHELDON SHACC. ' °
..l.aitmlrtwO"
for tM paaiHag ***** tUldy tut waafc "a lot ol
llw lull HT that tm geoersled In a community
—T-— *M«t wkM *• Mn lookUtf at aW-
| J. Mlkutak. paofact offtcar fir tha
J Impact atudr. a "Mdy
"Wllaa-mm ft Uiaaa Hmri ifud »(_
*a §¦» tha Rlvatport induatr? aad T*-nnniaa
ZTL"'"'I** u "•
°*»M fun a i
By SHELDON SHAPES
Cuiw IHMUMHW
Federal environmental official
will be w Jefferson Coaaty tonight to
cttttetW reacUMe an tb* pro-
pond maasive construction or new
jMiary sewerf la iNtt«iA Jeffer*
son County.
The meeting wttl bo at 7:30 p.m. at
Pleasure Ridge Part High School.
*9M1 Greenwood Road-
TM affected irei is in IM MiU
Creek waieraMd wen of DUie High-
way aad south of Sfctvwy — om of
lite ftvvt areaa Ur|Md for mw m*'
er» tMtdtr tM Metropolitan Sewer
District's couacywtM evpanefcon pro-
tram.
Under the plan. about 18,060 of
Marty 30*000 area homeowMn face
a fee of &M0 or mora for collector
Umb to tap into tM tense MSO newer
tnink unaa (bat may be tola,
mental Proles
^ Sewer coMtruc-
UOQ "O"' I**to Mill it's aooa
-il'4°^"''' EPA official*
lea dMaul^i hana ou' book*
gzJIff?"'* taoovatlv*
"a«»«lapoaal nwcbodt wort. Suck
M 'MlWduai bickiftcal nut
are still ¦ utile ctnceroM
S5?s£55
^A,CS"r^e^
~«sr»a3
wwaveiri residents «ll accept a
Waste-disposal methods
discussed at workshop
|y L» w " * -
w t rapid tn»k unai may * £T
Alternatives to sewers being sought iSS
for study in south Jefferson County "*
IT LESUK CLUS —mpiMIIM Sawar Dtttrfct plM to
¦ n» m> Mtld tmn tat tM m Book-up tern
It «M auppoaad tobtl workshop oa M«Ud M raMaaa aMat fUM.
way* ID |M rto of van watar In «0Mh- Sob* rnamMia of * dttiW Mm
mat Jattaraoa County, w* tM Ottcs*- coann*tMwortia«wWltM EPAoa tM
.M o( -WMiMUapoMI (u«ttn<(i altnoot stMy had ho^od to haw muiUacnuxra
«ot o>My w 4lw~"
«s B—o. -— «»• 1—
'M » )¦ cMrfo So»
ura manaai asMa
TM «J M«V*a attmOa* a vofttfec* .
Mraltkt >l Plaaaora Rid* Part Kl»MI M«M m>*0T
So you Jtve »n routtiwett Jefferson
roomy ana know ihcre * a study goms
on io «<** *1 your n^ you thmk
tficrc .ire better wnste-trentment ny»-
(cms nvoitoble (fun sewersJ
Ourma tfte next few months, (hot t*
wftni ihe Aosemment aftency mAkiAft
rtir sewer wudy wii) be exploring.
A no it wants >our ideas.
"Ttiofa petftnp* tde most jmportnni
part or tfttt procem," said Ron Mikutok.
director of the sewer study, for the
Environmental Protection Agency.
"1 con't strew enoufttt the importance
ttuu the community has in this.''
Mikulok, from the EPA's rectonol of-
fice in Aflontn. was in Jefferson County
yesterday to calk with a citizen*' com-
mtftee advHing the government cfurinc
the study.
•ftma into compost. Sewers will b» aua-
icd.
And. he said, there is the option of ^wuS^o^JI
doio* nothing — of .sticking witn seotlc r,-
sterns, the ma»or treatment mSSd adLS »report
now used in the am. ^ ^ sever
tr Hcs
il> meeting w Meeting set on plan
„ , n^inat (tat lur.aaai tt «o«W took m «
MvtnxuMoui viait oomm Is tM araa. AaO Km tit!. 'tlTlaa i*^ ^7 iS"
fmnt oaytaM aMtttaauiytoM lootua* at alwmt- ** * .f!** Tow ~ ""**
kulak soid.
The 13 member* of the citizens' com-
mute* tot* Mtkuiak and two other offi-
cials at yMterday'* meeting that they
haven't gotten aa much reaction from
(heir neignbof* ae they had hoped.
The c»tu*n*' committee alao streawd
thut the study should include mora than
technical information.
"I'm more interested in tM social
aspects of this.'* said committee mem-
ber Francis Eftfdahl. "More than think*
ing about bugs and germs, we want to
mink «boul the puMlc. about eco
ICS."
Most people feet that we re more or
lesa wasting time," Rubin JValker Jr.
said.
"There's rumors that we're going to
get sewer* no matter what That's my
feeling, 100."
EPA has heard that comptan* before'
sad denied tL
After tM July forum, the government
»««.
study shot
The study begun teat November with
a public forum to explain its goabi. The
area being studied is roughly west of
OtKie Highway and south of Shtvely to
vaitey Station.
Since November, however, ihe study
has concentrated mainly on gathering
technical information about conditions
Workshop For Sewer Alternatives. A
week from Tuesday, on July 24, at Plea-
sure Ridge Park High School, EPA will
hold a public workshop to develop sewer
alternatives to the Mill Creek sewer ex-
pansion plan. AH citizens are invited to
attend and to recommend alternative
sewage treatment methods and systems.
The session was planned by the Citizen's
Advisory Committee of local residents,
and to stimulate pauitipation and ideas,
members of the committee have invited
leading developers of sewage treatment
systems to attend and put up displays.
The program is being held to provide in-
put to the environmental impact study
being conducted by EPA. On July 25 at
West port High School in Eastern Jeffer-
to install sewers
^ «n Mill Creek area
*"»>*««ani Jafleiaoa
i,aw<"«1«I tor T-3Q to-
<"«- "tar.
1Mb.
U»a EPA^LSTJ;
*va« 0 pan of u aavt™™.#.
That i
r»eiura» BMMWg -Art m MM* — —
flai| out if tM aeifle fanka mv tacd
x«a« aaaaaM at Mad OM eoomltta*
^ namMr. CkarMa Biaad wattatf o EPA ngeal edmlalaeimtor thai said
M» — dully cairn aMat tm Man EPA WM trrtac to coatm wWtit aitw
»«l» tta rnaaBat iniaa aattwa aemd M rarteeed.
An Oat iwl until altar Maral Bo- Bvi aaM "tMra win M bo attaraa-
vMomanoi TM MW
ciaMa who MM the m anting were Mi* cwdDtttM wanted to have maflitfacw-
era tMre.M aald, bat EPA diaregarded
"""nrtak taM tM maOienca afWHWd
JenersoQ cotutfy aoy mora than I mm mat «sm» nwimlniM are drawn
four ew," said ooa maa. who de> a.*^* >k| wmm^M'
scrtbed Umaetf as a longtime rualrinnf fiW ^
«•- Afti Btad Ml. EPA
TM EPA^oaaond wortaMp ia part wannl oK tM Ml Mat.
of a m«r oa way* to «at nt o» waata ^ ^ .rgmi tMt K
vatar la im Mill Craak lja<>n. aHa la alraatfy daddatf tMt saptftc taak
Mat or DM* Hlfftway a* totidl o» ^ matM*. "Yoam Maa
Aivaiy. EPA atanad mrttaf oa aa a» that all
-nronmaaiaHinpaot atuaaoaat id* tM uuniak
community ratMaratf aro«t oppoaittoa „ "
BPA Had
it
"am M
tJR22L"* ¦ <* Oa aapOc
iSS^mS.^7 «—plaia« torm*
"¦MM >a caaa tM Ma
Sti ^
1*"*" aaaa » • aMMfwM* Me
son County, EPA will hold a scoping SUfSJ S3^3uiH
meeting for the environmental impact £££.«
study being conducted on the North
County sewage treatment plant and sys-
tem. The Homeowners Association had
previously gone to court to force EPA to
conduct these studies. They have agreed
to evaluate all areas excepting the central
portions and th* w»*» *
ia am IM taaa an
tM aapde tula anal worttt* n*L
MawMw o« tM aa^aaeaput oat
•> AS*-i mm
-------
3. ERRATA AND REVISIONS TO THE DRAFT EIS
3.1 Errata
Page Paragraph Line(s)
12 4
5 3 19
17 1 15
17 3 4
18 4 8-10
19 6 2
24 1 1
45 3 5
45 5 3
63 5 14
66 2 10
71 6 1
89 1 6
89 4 3
90 3 2
95 3 9
96 6 2
Corrections
"to enjoin EPA and the Louisville and
Jefferson County Metropolitan Sewer
District (MSP) from further ..."
"... package plants. Alternative 7c. is ..."
"... alternatives that most greatly
facilitate the ..."
"... nitrate levels (above 10 mg-N/L
and ..."
"Nevertheless, data indicated that the
groundwater ... could now, and even in
the future with increased wastewater
discharges, be used as a raw water source!1
(Delete "existing" and "could then.")
"... compared to about $30 million ..."
. renamed the Morris Forman Wastewater
Treatment Plant (WWTP). Along ..."
"... smaller-diameter pipes ..."
"... arrangements may be utilized^"
"... all future dwellings and all
dwellings ..."
"... washing machines, dishwashers).
This ..."
"Costs were developed ..."
"... attractive from the ..."
"... will be considered from the ..."
"... Reliability Class III ..."
"MSD is concerned that ..."
"... wastewaters from the Riverport
complex." (Delete "Industrial.")
-39-
-------
Page
97
97
98
105
106
106
106
107
107
110
119
119
121
122
124
150
152
154
181
195
222
229
230
Paragraph
tine v. a /
4 3
3 2
4 7-8
7 2
5 2
6 2
3 9
2 4
3 3
5 1
4 6
4 3
5 2
4 3
2 4
3 2
3 5-6
(Table 61) 12
(2nd Reference)
(4th Reference)
(Delete "wastewaters from the Rivprpnrr
II V »
complex. ;
"... have been constructed ..."
"... authority from EPA, ..."
"Under Alternative 7b, all but
approximately 400 non-residential ..."
"... tank occur, sewage could ..."
"... except on building lots ..."
"... the remaining WWTP's ..."
(Delete "that")
"... to seepage pits ..." (Delete "a")
"... interceptor 0 and M cost is $1.77/m
($0.54/ft)
"... Highway. However, ..."
"... streams. Siltation could ..."
"... future likelihood of adverse
public ..."
"... system use. However, if ..."
"... nitrates (above 10 mg-N/L)."
"... Mesophytic Forest by Braun (1950)."
"Average velocity 16 km/h (10 mph)"
"... parameters would ..."
"... the use of individual on-site ..."
"... periods represented in Jefferson
County are summarized ..." (Drop "the"
between "in" and "Jefferson.")
Ed Myers, not Meyers
Braun, E.L. 1950 ...
U.S. Army Corps of Engineers (ACE)
1978 ...
-40-
-------
3.2 Revisions
3.2.1 Sewered Areas and Expanded Service Areas
A revised Figure 2 is provided in the Executive Summary.
3.2.2 Unit Cost Estimates for On-Site Systems and Small Treatment Plants
The first page of Table 11 (page 74 of Draft EIS) has been revised
and is provided.
3.2.3 Interceptor Sizes and Costs
Table 21 (page 111 of draft EIS) has been revised and is provided.
3.2.A Southwest Jefferson County Floodwall
Page 129, replace paragraph 3 with the following:
The following description of the development of surface drainage
in the Mill Creek area is excerpted from Hazelet and Erdel (1965):
Historically, the area dealt with in this report
has been poorly drained. When the white man first came
to this area there were no major drainage channels,
rather the area was covered by a number of large ponds.
For instance, the stream we call Black Pond Creek, which
is our 100 Tributary area, was at one time a great, long
pond 500 feet or so in width and three to four miles in
length... Numerous other ponds existed in addition to
this one.
Then, as this area began to develop, the Lower Mill
Creek as we know it today drained an area which included
the area of Shively and what is now referred to as Upper
Mill Creek, above the Henry Watterson Expressway and
east of Dixie Highway. According to the map of 1879, a
connection from Mill Creek to the Ohio River existed at
that time on the present alignment of Garrison Ditch.
In about 1913, the Mill Creek Cutoff was constructed so
that the Upper Mill Creek drained into this Mill Creek
Cutoff and thence into the Ohio River. When the flood-
wall was built in the 1950's, the stream known as Big
Run was rerouted from its connection to Upper Mill Creek
directly into the Mill Creek Cutoff outside the floodwall.
The main channel of Lower Mill Creek was improved and
straightened from its original alignment in about 1927 ...
It now has a good alignment, fairly straight with only
a few curves, and does not wander as would a typical
stream in the flood plains. At the time of these
improvements, easements were obtained throughout most
of the length of Lower Mill Creek.
-41-
-------
TABLE 11. UNIT COST ESTIMATES FOR ON-SITE
SYSTEMS AND SMALL TREATMENT PLANTS
Septic Tanks/Seepage Pits
Single-family dwelling
Multi-family dwelling
and business
Aerobic Tanks
Alternative Toilets
Single-family dwelling
Multi-family dwelling
Polyvinyl Chloride Pipe
1-1/2-inch
2-1/2-inch
3-inch
4-inch
6-inch
Vitrified Clay Pipe, Extra Strength
8-inch
Reinforced Concrete Pipe, Class IV
27-inch (with trench 18-20 ft deep)
30-inch (with trench 18-20 ft deep)
36-inch (with trench 18-20 ft deep)
Reinforced Concrete Pipe, Extra Strength
42-inch (with trench <20 ft deep)
42-inch (with trench >20 ft deep)
Aluminum Pipe, 6-inch
Vitrified Clay Pipe (a)
8-inch (with trench 8-14 ft deep)
8-inch (with trench 14-20 ft deep)
8-inch (with trench 20-30 ft deep)
10-inch (with trench <8 ft deep)
10-inch (with trench 8-14 ft deep)
10-inch (with trench 14-20 ft deep)
10-inch (with trench 20-30 ft deep)
10-inch (with trench > 30 ft deep)
12-inch (with trench 8-14 ft deep)
12-inch (with trench 14-20 ft deep)
12-inch (with trench
15-inch
15-inch
15-inch
15-inch (with trench
Reinforced Concrete Pipe
18-inch (with trench > 20 ft deep)
21-inch (with tTench 8-14 ft deep)
21-inch (with trench 14-20 ft deep)
21-inch (with trench 20-30 ft deep)
21-inch (with trench > 30 ft deep)
>20 ft deep)
(with trench 8-14 ft deep)
(with trench 14-20 ft deep)
(with trench 20-30 ft deep)
> 30 ft deep)
Capital
Cost ($)
1,800
3,600
2,300
1,700
17,000
1.85/ft
2.25/ft
2.55/ft
3.00/ft
4.35/ft
5.60/ft
89.57/ft
99.53/ft
124.41/ft
159.24/ft
184.13/ft
3.55/ft
46.73/ft
51.92/ft
72.69/ft
41.54/ft
46.73/ft
57.11/ft
77.88/ft
98.65/ft
51.92/ft
62.31/ft
83.07/ft
57.11/ft
67.50/ft
88.27/ft
109.03/ft
88.27/ft
83.07/ft
98.65/ft
119.42/ft
145.38/ft
Operations and
Maintenance Cost ($)
40/yr
80/yr
250/yr
110/yr
1100/yr
-42-
-------
TABLE 21. INTERCEPTOR SIZES AND COSTS
(Cost in Thousands of January 1981 Dollars)
Size Eange
Interceptor
in.
cm
Cost
DH-1
27-36
69-91
2,650
DH-2
8-12
20-30
450
DH-3
12-21
30-53
1,210
DH-4
10-15
25-38
670
DH-6
10
25
790
DH-7
10
25
720
DH-8
10
25
620
OR-1
8-12
20-30
240
VT-2
10-30
25-76
1,630
VV-1
24-27
61-69
800
-43-
-------
5.2.5 Significant Agricultural Lands
Page 176, add to the end of paragraph 4:
It should be noted that with the completion of the Southwest
Jefferson County Floodwall the prime farmland in the Mill Creek
study area will no longer be in the 100-year floodplain.
3.2.6 Inventory of Historic Places
Add the following paragraph and Table 45a to Section 5.3.1 after the
subsection on Cultural History, page 195.
Historic Places
The Kentucky Heritage Commission in Frankfort, Kentucky, was
consulted for the locations of cultural and historic sites
in the Mill Creek study area. There are three properties
listed on the National Register of Historic Places, six
properties whose nomination to the National Register has been
approved by the Kentucky Historic Preservation Review Board,
and fifteen properties surveyed but not nominated to the
National Register (Table 45a). None of the sites listed in
the National Register would be affected by any of the alter-
natives. Three of the nominated sites and seven of the
surveyed sites would possibly be affected by one or more
of the regional system alternatives (Table 45a) due to their
proximity to the preliminary interceptor routes. Potential
impacts from construction activities could be mitigated during
final design by routing interceptors away from these sites.
If the final interceptor routes are close to historic sites,
construction acitivities could be modified to mitigate their
impact on the sites.
3.2.7 Legislative/Regulatory Summary
A revised Table 5 is provided.
3.2.8 Locations of Phase II Samples
A revised Figure 18 is provided and retitled, "Monitoring Sites."
3.2.9 MSD's Schedule of Activities for Scenario 3
A revised Figure 5 (Appendix A) is provided.
-44-
-------
TABLE 45a. HISTORIC PLACES IN THE
MILL CREEK EIS STUDY AREA
Sites listed on the National Register of Historic Places
JF 13 Farnsley - Moorman House
10900 Lower River Road
JF 14 Pusey - Aydelotte House
6814 Bethany Lane, Valley Station
JF 25 Lewiston Place
4902 Ranchland
Sites nominated to the National Register
JF 38 Farnsley House
4816 Cane Rum Road
JF 70 Fenley House
5300 Block Raybum Road
JF 72 Jones House
4998 Valley Station Road
JF 75 Waverly Hills Tuberculosis Sanitorium
8101 Dixie Highway (a)
JF 76 Waverly Hills Annex
8101 Dixie Highway (a)
JF 77 Waverly Hills Staff Building
8101 Dixie Highway fa)
Surveyed sites
JF 10 Westpoint Lumber
13501 Dixie Highway
JF 15 Hourse House .
Lower River Road at Ashby Lane I J
JF 19 House
Smith Lane
JF 20 Bethany Methodist Church
11000 Dixie Highway (a)
JF 22 Valley Christian Church
9621 Dixie Highway (b) (c)
JF 24 J.B. Hawes Store , , , »
Dixie Highway at Upper Hunters Trace (a) (c)
-45-
-------
jF 34 J.M. Nicholson House
2417 Lower Hunters Trace
JF 37 House
Dover Road (c)
JF 41 House
Cany Ground Road north ox
Riverside Gardens
JF 43 Schenck House
Crums Lane (c)
JF 44 House
Off Kramers Lane
JF 45 House
3615 Kramers Lane
JF 46 House
4213 Camp Ground Road
JF 71 Valley School
Deering Road and Valley Station Road
JF 74 Jackey Homestead
4105 East Pages Lane (a) (b) (c)
(a) Potentially affected by Alternative 7a, 7b, or 7c.
(b) Potentially affected by the 201 Alternative.
(c) Potentially affected by Alternative 8.
-46-
-------
TABLE 5. LEGISLATIVE/REGULATORY SUMMARY
Legisiation/Regulation
KRS (a) CH 94
KRS CH 107
KRS 224:220 to
224:237
KRS 318:30 and
318:31
815 KAR(b)
20:130 to 20:180
Louisville-Jefferson County
Board of Health Sanitary Code
Ch. 3 Sec. 303.501 to
303.805
Ch. 3 Sec. 304:401 to
304:407
Authority to establish, operate and
maintain sewerage systems
Municipal improvements including:
wastewater treatment systems; Kentuc
Wastewater Revolving Fund; Sewer
Assessment Hardship Fund
Septic tank servicing: licensing;
vehicle tank requirements; disposal
of wastes
On-site sewage disposal systems:
plumbing installation permits;
alternative on-site systems
Sewage systems: materials; methods
of installation; tests and inspections;
commercial septic systems
Wastewater treatment facilities:
industrial facilities classifications:
regulation fee schedule; operation
standards; owner and operator
responsibilities; effluent standards
Individual or home sewage disposal
systems; lot characteristics; allowable
wastes; house sewer standards; grease
trap requirement; septic taHk standards;
subsoil absorption system standards;
privies
(a) KRS--Kentucky Revised Statute
(b) KAR--Kentucky Administrative Regulations
-47-
-------
FIGURE 5 MSD'S SCHEDULE OF ACTIVITIES FOR SCENARIO 3
SJ WEST COUUTV TRECTMENT PL&NT ON UNE APRIL 1988.
^ HCKttYV tOViUT^ T*£.KmEUT ?N-M\T OH UUE SEPTEMBER \990.
-------
PACE NOT
AVAILABLE
DIGITALLY
-------
CHAPTER
4
Residents in Mill Creek drainage area
say they don't need sewer system
EPA Says Some Area
Wells Are Contaminated
By OtOWBIY MOWN
Septic tanks art w.rking floe is
oethweetero Jefferaon County, and the
idetropolttas Sewer District can't be
naiad to build a oewer system that
vOHld work at well, area residents said
Ml
tfce ywtdiH delivered their mes-
¦ft lo the federal Environmental Pro-
eettoo Agency at a public forum on
pact study, eapoctod to be finished 1b
1H
Last eight's discission was supposed
to focus oe alternatives to MSD'i plan:
methods sucb as toilets that make com-
post; individual treatment units at each
nail, oelfbborbood traacmeor
aad frequently dumps raw sewage Into
tbe Ohio River.
He ntd MSD should be required to
get that plant repaired before building •
new plant "I don't want my kits to
have to pay for some more Degllje.ice."
be said.
Ronald J. Mikufak of the EPA region-
Um le E*A'i dsranor. Mbac
CPA i«M»
rs A Few Tips To Make
£ Water Safe To Drink
Well
Well-water report still doesn't answer sewer question
wUtt Mi Mtom County
Mud by Mill Creak
t *m n mm aw Mr m pmmv »•" mt mr ¦
MliMMMpMMKIMMilll- aa ¦ *'
Wastes bring warning to avoid well water nimUl
Overview Of Sewer Situation
In County To Be Conducted
By JOHN C. IONt;
mm* I ESLIE KLLtS
of soutkwenlem Jeff
CoxMy fltoouM stop drtnklnf well
iW lus no< been portfto'. beollli
rials warned ywterdsy
And Hi funis and small children
area skoeld not drlak wel. water
¦w rtrcamataaces, IB' oificlats
M several of ne J3i> families
ana erke fH tkeir water from well
Ikey beHeve tkeir walrr t- «afe to
•TO takr my chancer viih my
- aald Mildred Liven 312*
toad. ~I deal want lo glv
later np. If dty wale-
ckemicils) wont kir'
I doa't kmm why well
Mm- Uvers aald «t» Has live
Tl'imn—n1 Drive for 28 yean and
kad any problem* with tbe water
aae kad worried about ua before?
i now?
"By aw time Ikey (at everybo
sewers eat bere. Ike water Iron
Okie River laat Ron* to be III to
¦tie aald. referring lo a proposol
i in the Mill Creek
Ike area knve
Ms. Rebecca Hanmer, newly
appointed administrator of the
(J.S. Environmental Protection
Agency Region IV has directed
that a new EPA study be con-
ducted of sewer-related pro-
blems in Jefferson County.
The study will be conducted
by a newly assigned study
team from her region. Assign-
ed to the team from the
Region IV EIS branch will be
Robert Cooper. Cooper has
not previously been directly
regarding citizen's problems.
Accoridng to John Howard,
chief of the EIS branch. Atlan-
ta. Ms. Hanmer wants to
become more familiar with the
Southwest Jefferson
residents urge EPA
to keep septic tanks
Morris Forman have dragged
on too long, and there have
been too many expressed
citizen's concerns, she feels.
The new study team will oe
people who
fresh look at
the Morris Forman operati
and the MSD expansion pi
for the purpose of furnishi
Ms. Hanmer a more accurt
overview of sewer-related pi
blems in Jefferson County, <
cording to EPA officials.
•r am
[he problem of Southwest sewage
J.S. report sees pluses and minuses In sewers — and septic tanks
Covatjr xmr
aar again jaft.alffct
sepdc tanks to an
«y»-
i M arC»W»paBiiaM
Mum mm mt ——r —»—oa aflnaded i p>ML^
fee U. S. EnWOO-
ijiiiry at Pi sail re
School to add their
atteraaftvaa
— pcopom ip-
7li l» aai« IMS*.
Several mliliuii cned the prob-
lems of tbe Morris- Forman
Waalsaslsi Treatment Plant servlnj
UtUavUI* and suggaaied that Ike laixe
regioaal tnamaBt plant piupused Is
not toutM* atthar
Doaatt Mte, of 2113 Ratellffe
said-the Moms Ponttan plant
has pi mad to be taatflaaar aad "is
ooo" at any Brno. Be «aa lefermg to
oc,ike -nasi
by numplni of.
warn lam a LoaJarUla i
~Tkey SOU kaneat I
to do wttk tke tlndft." Fowler «e>t
David Warren, of 9211 Plaa«.t
Drive, aid tbe original eotuitrwidt
sewer plaa waa made wkan populanra
luersasss ware pretactM throng* tke
yaar MOO. '
"Since than, we save learned tke
usouiioni plant deal act work.- ud
Qm cakHfMtvf MMag 1
ow populadea Mad to
crease." U said. "!« «Mr warta:»e
deal need you or your ideas any
Sewer Study
Overview Will
Be On TV
byEdStumier
An overview and report of an EnvitOMWV
taJ Impact Statement (EIS) being conducted
by the Emrtronmantal Protection Agency
(CPA) for the MM Creek wee wtt be shown on
local television stations (Ms weekend.
The 30-mtnuie program has been prepared
by EPA officials to bring the public up-to-date
about the study and to inform those that
might not hove heard about It MUalty. Tbe
study started about 14 months ago. accor-
ding to Ron Mikuiek. an EPA official In Atlan-
ta.
Mikulak said local televlalon stations
agreed to broadcast the program this week-
end tn advance of e puhlk forum set for next
Tueed* night at Pleasure Ridge Park High
Schoo*. . .30 p.m.
He said the forum would hear a presenta-
Uon on a portion of the Impact statement
which has looked at alternatives to a multl-
mUllon defter sanitary sewer project for the
Mill Creek area, generally an area along Dixie
Highway to the county Mne.
In a press rets aae. EPA offkdais said the
fonan wtt dlscuas oRarwatlu available for
wastewater management In Southwest
Jefferaon County, to present the results of
the environmental end cost evaluation of
these alternatives, end to get Input from tbe
" Comments that are received at the
meeting will receive consideration In the EIS
dt making process/' the release
& an*> wSJ * •
mm m mmm «mb
m smn h
ESSsrSnu
Presentations of the 30 ndnute television
program g|R be made Dec. 13 en channel 11
at 7:30 aA and channel IS at 3 pjn.: and
Dec. 14 an eannel 3 at 6^0 a.nu. channel
32 at S a*nw and chaanel 41 at 7 JO pjn.
Wkwlai* said he had also tallied with local
aut airing a news spot
-------
4. PUBLIC COMMENTS AND EPA RESPONSES
A.1 Oral Comments
Oral comments on the Draft EIS were received at a public hearing held
on November 17, 1981 at the Pleasure Ridge Park High School Auditorium. This
section contains the transcript of the hearing including introductory state-
ments made by EPA representatives and their consultant, together with EPA's
responses. Table 8 is an index to the oral comments and EPA's responses, and
Table 9 summarizes the general subjects mentioned by each commentor.
-51-
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TABLE 8 . INDEX TO PUBLIC I1LARING COMMENTS ON MILL CREEK DEIS
COMMENT
CODE
PAGE(S)
COMMENTOR
NATURE OF COMMENT
MSD-1. 72 Louisville and Jefferson County
Metropolitan Sewer District
MSD-2. 72-73 Louisville and Jefferson County
Metropolitan Sewer District
MSD-3. 73 Louisville and Jefferson County
Metropolitan Sewer District
MSD-4. 73 Louisville and Jefferson County
Metropolitan Sewer District
MSD-5. 73 Louisville and Jefferson County
Metropolitan Sewer District
MSD-6. 73-74 Louisville and Jefferson County
Metropolitan Sewer District
MSD-7. 74 Louisville and Jefferson County
Metropolitan Sewer District
LJCBH-1. 77 Louisvilie-Jefferson County Board of
Health
LJCBH-2. 78 Louisvilie-Jefferson County Board of
Health
LJCBH-3. 78 Louisville-Jefferson County Board of
Health
Costs for new MSD customers
Financial Impact Analysis assumptions of
rate adjustments
Sewer Assessments
MSD aquisition of treatment plants and sewer
districts
EPA Funding
Further EIS studies
County sewerage priorities
Support for Alternative 7c
EPA funding availability
Support for Alternative 7c
-------
(TABLE
COKMENT
CODE PAGE(S) COMMENTOR
FE-1.
80
Francis Engdahl
LH-1.
81-82
Leo Harrod
CB-1.
83
Carl Brown
CB-2.
83
Carl Brown
CB-3.
84
Carl Brown
EE-1.
84-85
Eleanor Engdahl
CM-1.
85
Mrs. Clyde Mims
JH-
86
James Headon
JH-2.
88
James Headon
WB-1.
89
Walter Braden
KH-1.
90
Ken Heil
EP-1.
91-92
Ed Parker
GP-1.
92-93
George Pendleton
CONT'D)
NATURE OF COMMENT
Preference for on-site systems
Opposition to sewers
Support for Alternative 7b
Nature of the sub-soil in Southwest
Jefferson County
Absence of need for sewers
Support for Alternative 7b
Opposition to sewers
Costs for new MSD customers
Opposition to sewers
EPA funding
Costs for new MSD customers
Untreated wastewater discharges
Sewer assessment charges
-------
TABLE 9 . SUMMARY OF ORAL COMMENTS
1. Louisville and Jefferson County Metropolitan Sewer District
2. Louisvilie-Jefferson County Board of Health
3. Francis Engdahl
4. Leo Harrod
5. Carl Brown
6. Eleanor Engdahl
7. Mrs. Clyde Mims
8. James Heador
9. Walter Braden
10. Ken Heil
11. Ed Parker
12. George Pendleton
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UNITH) STATB» OF AHHRICA
HfVIRORMIHTAL PROTBCTIOB AGEHCT
«
In the Matter of:
Environmental Zaipact statement on
Proposed Waste Matsr Facilities for
the Mill Creek Area of Southwest
Jefferson County, Kentucky. t
Hearing Rook,
Auditorium, Pleasure Ridge Park
High School,
5901 Greenwood Road,
Pleasufe Ridge Park, Kentucky.
Tuesday, Rovenber 17, 1961.
The above-entitled natter caae on for hearing,
I pursuant to notice, at 7:10 P.M.
BEFORE:
AMDRBi ROBWT OREBIE, ESQ., Assistant Regional
Counsel, Bnvlranwmtal Protection Agency,
Region Atlanta, Georgia
|ALSO APPSARIRQ:
Ron Mlkulak, Esq., EX3 Project Officer.
Mike Nllllaas, ESQ., chief of the Kentucky-North
Carolina Construction Or ant Section of the EPA
Water Division, Region I.
1 «»wn nci'Mini'it; h'ihhk
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2
CERTIFICATE
This is to certify thst the following proceedings
before the Environmental protection Agency, United States of
Anerlcs, in the natter of: Draft of EnvLronnentsl Irapsct
Statement on proposed waste., water facilities for the Mill
Creek Area of Southwest Jefferson County, Kentucky, were had
as herein appears, and thst this is Che original transcript
thereof for the files of the Board.
IT
2"
ROTH GENTRY OFFICIAL REPORTER
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INDEX
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.1 MR. JOHN TIERNEY, METROPOLITAN SEWER BISTRICT
* MS. PATRICIA NIGJfllNGALE, JEFFERSON COUNTY
BOARD OF HEALTH
*|HR. FRANCIS LNGDAHL, SOUTHWEST JEFFERSON
COUNTY HONE OWNERS ASSOCIATION
* Leo Harrod, Senior Citizens Group
CARL BROWN, COMMISSIONER
KB. ELEANOR ENGDAHL
Mrs. Clyde Minis
MK. JAMES HEADDEN
MR. WALTER BRA DEN
MR. KEN HEIL
MR. ED PARKER
t®. GEORGE PENDLETON
PAGE
33
35
39
41
43
45
46
47
49
50
51
52
(dim ^nnii r
|r. » \ M muri
in • -.'il »i H' : '• *•'
PROCEEDINGS
HEARING OFFICER BOB OREHME: Good Evening.
Now I call the hearing to order please.
Welcome to the public hearing on the Draft
Environmental Impact Statement on proposed waste water
facilities for the Mill Creek Area of Southwest Jefferson
County,Kentucky.
I'd like to begin this evening by introducing
the hearing panel.
My name is Bob Greene. I'm the Assistant
Regional Counsel for the Environmental Protection Agency,
Region 1.
With Be also frost EPA this evening on my right
is Ron Mlkulak, who is the EIS Project Officer for this
particular project, and on ay left is Mike Williams who is
the Chief of the Kentucky-North Carolina Construction Grant
Section of EPA'n Water Division in Region 4.
I understand there are also several local
officials who are present this evening who are not part of
the hearing panel but are here either to participate In, or
to observe these proceedings.
I'd like to recognise these people at this tlM.
I understand State Senator William Qulnlan Is here, and also
State Representative Elect Bill Lyle.
Thank you gentlemen for attending tonight.
I'MtH lit I'HIIltM. SI l|\»» 1
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The purpose of this evening's hearing Is to
receive public and other agency's comment8 on the waste
water management proposal contained In the Mill Creek Area
Draft Environmental Impact Statement.
Thl» EIS la being prepared on waste water
facilities proposed In the 201 facilities plan prepared for
the Louisville Jefferson County Area by the Rentucklana
Regional Development Agency.
The preparation of this BIS is authorised by
the Clean Water Act and the Rational Bivironmental Policy
Act, NEPA. The Clean Hater Act enables EPA to fund up to
75 percent of the eligible costs for the planning, design
and construction of waste water facilities. The planning
phase of this process results In the preparation of a facili-
ties plan. In this Instance, the Kentucklana Agency was
designed as the local agency responsible for facilities
planning in this area and the Louisville-Jefferson County
Metropolitan Sewer District, MSB, was charged with the res-
ponsibility for implementing the 201 plan proposal.
The Rational environmental Policy Act requires
Federal Agencies to prepare an Btvlronmental Impact State-
ment for major Federal action* significantly affecting the
quality of the human environment. Because of the environ-
mental complexities and water Quality issues Involved In
project, EPA made the decision to prepare an EIS on the
Hi punnv. si.kvii t.
6
201 facilities plan.
Accordingly, In September 1977, the notice of
intent to prepare an EIS was Issued. Pursuant to the guide-
lines of the President's Counsel on Environmental Quality and
the Rules and Regulations of the Environmental Protection
Agency, with regard to preparation of Impact statements,
this public hearing Is being held to receive comments on
the draft of the BIS.
This draft and facilities plan are being dis-
cussed in a public forum to encourage public participation
In the Federal decision making process and to develop public
understanding of Federally funded projects.
In this regard, the draft EIS was made available
to the public and EPA's Office of Federal Activities on
September 18, 1981, and was listed In the Federal Register
on September 25, 1981. The draft EIS comment period will
extend until December 4, 1981. The comments received during
this evening and during the consent period following will
became part of the record.
Before we receive testimony from the floor, Mr.
Mlkulak will provide us with a brief summary of the project,
MR. MIKULAK: Thank you. Oood Evening. My
name is Ron Mltulak, the EIS Project Officer and what I
would like to do this evening before we do receive testimony
from the floor, as Mr. Oreene mentioned, is to provide you
MMIII Itu-Wl I IM. *1 ll\ |I |
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| 7
| with a brief summary of the Mill Creek Area draft environ-
mental impact statement.
What I would like to cover In my remarks this
j evening include the purpose of the EIS, a little bit about
project background, the alternative* that were generated
I during the EIS process, the EIS preferred alternative,
P recommendation* that have come out of the EIS, and finally
j
| the EI«i financial impact analyils.
ft The purpose of the EIS a* I have Indicated on the
J slide is to identify and evaluate waste water management
J alternatives in the Mill Creek Area of Southwe«t Jefferson
! County, and as you all know the Mill Creek Area of Southwest
jJefferson County, Is noted in the yellow area on the slide
before you.
The end product of the EIS process is a determi-
nation of the appropriate Federal role for the funding of
proposed waste water facilities and I stress the word. Federal
role. This is a Federal project that addresses EPA's role
In the funding of facilities and therefore, excuse me, comes
from the Federal perspective. In looking at the coonunity
of the Mill Creek Area, we're looking specifically at that
portion of the community, that residential community that Is
now served by septic tanks, the commercial establishments
that are located primarily along the Dixie Highway corridor
that are served by various forms of on lot systems, the sewerei
i out) in ri'fi rr <. miuiu
8
areas, that are served by small package plants, small treat-
ment plants, and service sewer service to the Louisville-
Jefferson county River Port Authority.
By way of reviewing project background, I would
first like to refer to the Clean Water Act. The focus of
the Clean Water Act was toward Improving the Nation's water*,
specifically under Section 201 of the Clean Water Act, EFA
wa» provided with the authority to fund waste water facil-
ities under the construction grant program. As indicated,
EPA funds are made available for the planning, the design
and the construction of waste water facilities. In order to
meet the mandate of Section 201 of the Clean Water Act, ;>tate«
designate local planning agencies to prepare a 201 facilities
plan. In the case of Louisville, the Kentuckiana Regional
Planning and Development Agency, otherwise known as KIPPA,
was charged with the responsibility for preparing the 201
plan and the Louisville and Jefferson County Metropolitan
Sewer Dl*trlct was charged with Implementing the recommenda-
tions from that plan.
In 197*1, the Water Quality Management Plan was
completed and included in the recommendations for the Mill
Creek Area was that all small sewage treatment plants would
be abandoned and on lot systems, septic tanks, that served
urban areas, would be eliminated. These two sections of the .
jj community were then to be served by a new west county j
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25
sewage treatment plant, that would discharge treated waste
water into the Ohio River.
It might be a little bit difficult for you to
see the details of this map, but on it we've sketched out
the physical configuration; that is, the treatment plant lo-
cation, and the network of interceptor lines that were Includ-
ed In the 201 Plan recommendation. The interceptors are those
lines that are slightly, In slightly heavier bold lettering in
the Interior portion of the study area, might be slightly
difficult for you to see, but on the handout that we have
provided you, we have highlighted those areas in very tough
form so you have an idea of the lines that we are talking
about.
In 1975» EPA and the Kentucky Department for
Natural Resources and Environmental Protection, reviewed the
Louisville 201 Plan and determined It to be substantially
complete. This action paved the way for EPA to commit funds
for the construction and design of several projects within
the 201 study area.
In early 1977, concurrent with the design and
construction of several of the construction projects, EPA
received citizen requests to prepare an environmental state-
ment on this particular project.
In September of 1977, EPA issued what we call a
#otlce of Intent prepare an environmental impact statement
I.HItll III.IMIHI IN'. HM< I
• 1 \ II i:» w
Hi * '.hi r>-nr. '.(Ml' I'm*
10
and subsequent to the issuance of this Notice of intent, we
received numerous comments from local agencies and citizens 1
groups to consider or reconsider the scope of the EIS, and
perhaps expand.
In January of 1978, the 8outhwe«t Jefferson County
Home Owners Association, filed a lawsuit, filed suit in the
U.S. District Count to enjoin EPA and MSD from further imple-
menting the 201 plan, further required that the EIS cover
each subjects as the River Port Industrial Complex, the West
Jefferson County Treatment Plant, and the network of Inter-
ceptor lines that were being constructed in Southwest
Jefferson County.
In February of 1978, we held a public scoping
meeting at the University of Louisville to receive comments
from local agencies and from citizens groups in defining ther
proper scope and Issues to be covered in the EIS. Those
comments were considered and in May of 1978, EPA made the
decision that the preparation of the EIS for the Mill Creek
portion of the West County project In Southwest Jefferson
County did warrant the preparation of an EIS because of
several unresolved issues and significant controversies.
In rounding out a little bit of the project
chronology, I have indicated that the draft EIS was Issued
finally in September of '01, today, there Is a public hear-
S lng on the draft EIS and the final EIS which would respond to
I "I'p in.run IIM. * 1 in h 1
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I 11
the comments that we receive tonight and through the comment
period, Is expected for completion early in 1982.
In stepping back a moment to those days In '77
and '78 when Issues were being raised and scoping meetings
were going on, many issues were raised by cltisens groups.
Many of the issues were not proper or appropriate for the EIS
process but again many of them were.
What I've done Is summarize what might be the
three major Issues that were raised in those days. Included
are that area spptlc tanks, that are working fine and do not
need to be replaced, that sewers through the regional sewer
system would be a costly and unnecessary burden to area hone
owners, and public sewer service should not be provided to
the River Port Inudstrlal Park.
I'd like to go over the existing waste water
management situation in the Mill Creek Area so you all have
a - to put things in perspective, when I start discussing
the alternatives and the preferred alternative.
Because of the unavailability of a centralized
waste water management system In the Mill Creek Area, waste
water management needs were met by a combination of septic
tanks and small package plants. The need for the area was
first met by on lot system# and in the Mill Creek Area,
septic tanks seepage pits system Is the one which prevails
in order to take advantage of the area's fairly unique
I Olll) lll l'OII I l\(. SKIIMI I.
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13
developed a range of alternative! from the no Federal action
alternative to a full regional system; and In developing and
evaluating these alternatives, we've broken the community
Into three population components. Those folks that are
currently served by septic tanks, those folks that are served
by snail package plants and those folks that are actually
future population that are not served by anything right now.
I am going over six or seven alternatives now
and these alternatives are described In a little bit more
detail in Table 1 of your handout, but I an going to go
through It very quickly because this Is Information that
has been put out before and is contained In the draft EIS,
and In fact If anyone has an Interest In reviewing or
receiving a copy of the draft EIS, I have provided several
copies out by the front table so please pick one up as you
leave this evening If you would like one.
But the first alternative I am going to review
right now Is Alternative 2 A. Briefly, it Is one that would
use most of the existing facilities In place; that is, the
Misting septic tanks, future populations would be relying
on additional septic tanks, and we would be using the exist-
ing small sewage treatment plants that are now in place.
The map of Alternative 2 A Is very similar to
the Map of the existing waste water management situation
>
What I showed earlier.
I OKI) HCIMIIU IM. SKHMl l
1U
Alternative 2 B Is very similar to 2 A. About
the only difference Is that wa are looking at expanding some
of the small sewage treatment plants to Include that popula-
tion that would normally be within the treatment plants
natural drainage area. So we are also talking about using
septic tanks for existing population and future population
but expanding the alee of some of the small treatment plants.
This Is shown on the map by the brown colored areas adjacent
to the yellow colored area; the yellow denoting those exist-
ing service areas for the small treatment plants.
Alternative 6 Is basically the 201 plan regional
system and again in that alternative, we are looking at the
connection of existing septic tanks systems and the connection
of existing small treatment plants to the new Vest County
Treatment Plant that is located near the corner of Orel Road
and Lower River Road.
Alternative 7 A, 7 B, and 7 C, and let me take a
moment to explain the difference between the A, B, and C,
variations. Alternative 7 involves a limited regional
systen. The physical configuration or the physical location
of the Interceptors and treatment plant Is the same for
all of the alternatives under Alternative 7. the only differ-
ence being that the interceptors, or the sewer lines for
Alternative 7 C would be larger than those for 7 A or 7 B.
They would be larger because they would be slxed to handle
I.OKI) ItKI'OlI IIV. >1IC\ U K
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future populations.
Alternative 7 A Involves a regional sewer or a
JB limited regional sewer to service the Dixie Highway corridor
4 |J Existing septic tanks would remain on line; that is, they
would not be connected to the sewer3 and we <'ould be looking
at an Increased number of small sevrage treatment plants In
order to accomodate future population growth.
Alternative 7 B, also represents a regional sewer
for the Dixie Highway Corridor, looking at expanded septic
tank use to accomodate future population as well as a
reduced number of small sewage treatment plants, reduced
| because most of the treatment plants, If not all, would be
tied into the regional system and therefore to the West
County Treatment Plant.
Alternative 7 C envisions regional sewers for
the Dixie Highway Corridor, However, the sewers would be
sized as the first phase of the regional system. That
implies that subsequent phases would envision the connection
of the existing septic tank users and future populations to
those facilities.
Again, it might be slightly difficult for you to
see the map of the 7 A, B, and C, as I mentioned before.
I The physical layout Is the same. Roughly, and if you can
'refer to that particular page In your handout, it envisions
an Interceptor line that runs basically the length of Dixie
i oiiii sun in
KMI II KHU I
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i Highway, with a'line that Juts out, as the figure is aligned
right now would Jut out from the bottom of Dixie Highway
> which would actually be east of Dixie Highway to pick up
^ many of the small package plants that are east of Dixie
Highway.
Alternative Number 8 - the first phase of
Alternative Number 8 would be similar to the - a first phase
of the Regional 201 system, the interceptors that would be
proposed or th»t would be envisioned, would be similar to
the 201 Regional System, however, they would be sized and
constructed only to serve the Dixie Highway Corridor and
|j most of the small sewage treatment plants In the area, the
I subsequent phases again, would pick up septic tank users
| and future population.
I
The first phase of Alternative Number 8 is shown
there as a scaled down version of the 201 Regional Sy«tem
and it eould ultimately look like in fact the 201 Regional
I Sy»tem which Is Number 6.
And finally Alternative Number 9 which is termed
no Federal Action alternative. No Federal action does not
imply no action. Indeed, measures would hav« to be taken
still to correct existing water quality and public health
problems, however, these measures would be taken without
Federal assistance, no Federal action. It would Involve
maintaining existing septic tanks and Increasing the number
I OIIII IIKI'uHIINt. >nnn I
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17
of small treatment plants In the area In order to pick up
future population.
Now during the evaluation process, several factors
were determined to be significant in the decision process.
I have listed these as being cost, the first one cost, the
Importance of cost cannot be over-stated, in fact in the EIS
we've tried to look at Federal, Local and Conmunlty costs.
To give you an idea of the magnitude of costs that we are
talking about, the capital costs, or the construction costs
of the Alternatives ranges from roughly $40 Billion dollars,
to $154 Billion dollars.
Public acceptance, number 2. Public acceptance
In this situation is viewed as being closely related to
cost and inconvenience. With increasing costs and increas-
ing inconvenience, resulting in public resistance.
Public Health. Public Health concerns in the
Mill Creek Area relates primarily to the ground and surface
water. It relates to the uses of these waters and to the
potential for human contact with these resources.
Hater quality. With regard to Hater Quality in
the Mill Creek Area, we are concerned with the impact of
waste water disposal practices on both ground and surface
water quality.
Significant impacts are those that are associated
with an action that might adversely affect the existing or
I.OKI> ItKI'OltllN*. M K
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18
potential use of these resources.
And finally, financial lmplentablllty. During
the course of the EIS, several local agencies expressed
concern over the impact of various EIS alternative* on the
ability of MSD to implement the countywide sewer expansion
plan. Rather than go over the evaluation results of these
components, I have highlighted the costs and advantages and
disadvantages of the alternatives with special emphasis on
these categories In Table 2 of the handout which you are free
to go over at your disposal.
What I would like to do now is concentrate on
the preferred alternatives to the draft EIS. In the evalua-
tions that I referred to a moment ago, led to the conclusion
that the Regional System as proposed in the 201 Plan was not
required at this time to correct the water quality and public
health problems of the Mill Creek Area.
Alternative 7 B, therefore, has been selected as
the most cost effective and environmentally sound alternative.
Alternative 7 B proposes limited sewering with sewer service
being provided to the commercial establishments located along
the Dixie Highway Corridor. Sewer service provided to at
least 18, if not all of the small package plants located in
the area.
The residential community that Is now served
by septic tanks would remain on septic tanks. Again, the
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19
I configuration of Alternative 7 B is shown before you.
The critical water quality problems in this area
have been found to be caused by the discharge of inadequately
treated waste water to the local streams by the small package
plants and also the Inability of the on-site systems to
effectively treat waste water for the commercial establish-
Iments along Dixie Highway. Although the unsewered residential
community does Influence the quality of the area ground water,
there does not appear to be significant deterioration of the
ground water to warrant the consideration of this being a
high priority area for the construction of a regional sewer
^ | system.
l " | The recommended action therefore involves the
"'balance between the expenditure of large amounts of public
and private money and the limited impact of continued septic
tank use on the area ground water.
How, the action that is proposed, as the preferred
alternative in the EIS ahotlld be regarded In light of several
' what we call Important factors.
First, the study area comprises a small portion of
Jefferson County, that is not currently served by regional
sewers. There is a demonstrated need to build the West County
Treatment Plant to relieve the crucial situation in the Pond
Creek Drainage area.
Waste water management activities carried out In
I Ollll 111 I'DIt I INI, "I UN II I
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20
any part of Jefferson County should be part of a feasible
comprehensive program, and finally, unlike most of Jefferson
County, the subsurface in the Mill Creek Area allow most waste
water management needs to be satisfied by on-site systems.
The basis for the decision. I'd like to run over
these very quickly. 1 think they provide you with the In-
formation you need to understand the reasons for EPA's de-
| cision of selecting Alternative 7 B,
First, existing ground water has been determined
to be suitable as a treated drinking water source. However,
existing ground waters generally are not suitable as an
untreated drinking water source.
Residential on-lot systems are functional and do
I not constitute a public health hazard. There are no known
plans to use the Mill Creek area ground water as a public
water source. Public water is available in close proximity to
most users of untreated ground water In the area.
The construction Impacts of Seven B are »ignl-
ficantly less than those of a regional system, A limited
regional system provides service to the major waste water
problem areas and the costs of Alternative 7 B are signifi-
cantly lower than a regional system as evidenced by the
difference of $104 million dollars in capital costs and $58
million dollars in present worth cost.
Now, in addition to the physical configuration of
i oiiii in run i IM- *i in i< i
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21
Alternative 7 B, we have also Included several recommenda-
tions In the draft EIS. I'd like to go over those briefly.
First, Its Importantto note that the proposed
action for the Mill Creek Area must be assigned a priority,
for Implementation in the context of the needs in the Jeffer-
son County's overall waste water management plan. In placing
the Mill Creek area draft SIS preferred alternative In per-
spective with these other waste water management problems,
It becomes clear that other projects should proceed as
quickly as possible, and In setting these priorities, future
options for the Mill Creek Area residential on-lot systems,
should Indeed remain flexible.
The factors that do need to be considered In
determining future needs for waste water management plann-
ing as we've Indicated in the draft EIS, Include* the develop-
ment of or a future likelihood of adverse public health
Impact resulting from septic tank failures.
The occurrence of significant functional or
operational failures of septic tanks, rising ground water
levels that could adversely affect septic tank operation.
The establishment of a local plan for use of
ground water as a public water supply source where existing
on-lot operations could preclude .such a use and significant
adverse land use Impacts caused by constraints from the es-
tablished or proposed waste water m&nagemant operations.
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22
Another EIS recommendation concerns well water
use. Because of the low use level of area ground water as
a public ground water supply source and the quality of the
area ground water as determined by the EIS ground water
program, EPA encourages localagencles to extend wherever
possible public water service to those Mill Creek residents
not now served by public water. The estimate is that a
project such as this would cost roughly 1.2 million dollars.
In cases where services cannot be extended, the
ground water quality monitoring program could Include special
emphasis on monitoring areas that would rely on ground water
for public water supply use.
Under any circumstances, that is, no matter what
alternative is finally implemented In this area, private
water supply users should be encouraged to disinfect area
ground water prior to consumption. Where area ground water
is being consumed by Infants, special precautions should be
taken to preclude the long term consumption of ground water
high In nitrates. It Is recommended therefore that area
ground water not he used for infant feeding but either public
water or bottled water be substituted, and private water
supplies being used for infant feeding, should be routinely
checked for nitrates to Insure that the concentrations are
I sufficiently low to avoid adverse health effects.
There is one area of the project that I haven't
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5
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2:
yet covered. That concerns the River Port. As noted
River Port is one of the issues raised by citizens, that
is, sewer service, the provision of sewer service to River
Port.
The interest that EIS has in River Port is not
addressing River Port as an industrial park - not whether
River Port should or should not be constructed, but concern
ourselves with waste water management options, and EPA's
role in providing waste water management for the River Port
Industrial Park.
As most of you are aware, River Port is located
in the area shaded in red on the map and is located in the
Mill Creek BIS study area.
In looking at the waste water management options
available to River Port as we see it, they include that
waste water could be conveyed to MSD as was proposed In the
201 Regional system.
Waste water could be handled by River Port by
a central River Port treatment facility or waste water
could be handled by each Industry that would locate at
River Port.
The various alternatives were evaluated with
respect to cost, technical feasibility, environmental
lapact and EPA funding eligibility.
Without getting into a lot of detail it came
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down to a matter of two factorf,EPA policy and EPA regula-
tions which dictate our actions in River Port.
First, with respect to EPA policy. There Is a
policy on the books. It is called EPA's policy to protect
I environmentally significant agricultural land. River Port
Is located on 1600 acres. Most of this land has been
classified by the Soil Conservation service as environmental'
ly significant agricultural land, even though the lands
have been zoned for industrial use.
Our policy states that we should not contribute
or encourage the irreversible conversion of our nation's
agricultural land to other uses.
Now more importantly concerning funding eligi-
bility and our regulations. EPA's construction grants
regulations state that the costs for waste water facilities
to serve exclusively or almost exclusively industrial flow
is not EPA grant eligible. Thet means EPA cannot provide
funds for those components.
These two factors led us to the decision th1 lt\ III
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25
USD to Implement the overall sewer expansion program for
Jefferson County.
In responding to these concerns, we have ex-
panded and included a financial impact analysis, component
of EIS, that addresses the Impact of several EIS alternative*
on MSD, on MSD customers and on residents of the Mill Creek
area.
Now, in a moment or two I'd like to ask Mr.
David Sheridan of the consulting firm of Gannett, Fleming,
Corddry and Carpenter to elaborate on the results and con-
clusions of the financial Impact analysis. But before I
do that, I'd like to offer a special word of thanks and
appreciation to two groups who are Involved in the EIS.
At the outset of the EIS, some four years ago, we establish-
ed two review groups. A Technical Review Group and a
Citliens Review Group, The Technical Group was composed
primarily of local and state agencies with either an interest
or some involvement in the project at hand.
The Citizens Review Group was composed of
citizens who were on citizens review groups, environmental
groups, general Interest groups, and represented a cross
section of Interest in the community. During the course of
the EIS, we met with these review groups several times,
countless times. I'd like to thank these people who served
on the groups for their assistance, the time and effort that
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they have spent in reviewing materials and talking with us
at the various meetings that we had and for their general
Interest and Involvement in the project.
I am about finished with my brief remarks. I'd
like now to introduce David Sheridan, As I mentioned, he
is with the consulting firm of Gannett, Fleming, Corddry
and Carpenter. During the preparation of the EIS, we con-
tracted with two consultants to assist In the technical
details of the EIS. David represents one of the firms.
The other firm was the consulting firm of Claude Terry and
Associates, who also assisted us. At this time I will turn
it over to you, David.
MR. SHERIDAN: The focus of the financial im-
pact, now, as Ron said, the purpose was to determine the
effects on MSD customers and also specifically the residents
of the Hill Creek Area of a fairly broad spectrum of waste
water management alternatives. We carried this out by
examining the cash flow prospective for MSD to carry out a
broad range of alternatives.
The first cash flow analysis was called Scenario.
One dealt with a full regional system for the Mill Creek area
The regional system would feed to a Vest County treatment
plant sized at 45 million gallons per day and the sequence
of construction in MSD's service area or expansion for MSD
would be to complete the Mill Creek activities, the complete
I OKI) IlKI'OHTIMi >M»\ H I-
b
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27
sewering of Mill Creek and thai go on to the second phase
of the Pond Creek sewering and then go on from there to
North County.
The Second Scenario i» very similar to the first
in that it involves a complete regional system for the Mill
Creek area, but it puts it In a different spot in the se-
quence, Pond Creek sewering proceeding before the Mill Creek
activities and then followed up by North County and then
again the Vest County treatment plant would be of the same
size, 45 million, mgd.
Scenario Three assumes that no public sewers
would be provided in the Mill Creek Area, none whatsoever,
no system other than what would develop there without the
activities of a central agency. A West County treatment
plant in this case would be sized at 30 mgd, at least for
the first phase and the sequence of construction for other
MSD activities would be to complete Pond Creek Phase Two
and then move on to North County and then complete Pond
Creek Phase Three, so you can see that no Mill Creek activit-
ies occur under Scenario Three.
Scenario Four is also a no-public action alterna-
tive for the Mill Creek Area, Here we are testing the effect
of a different size-treatment plant, a 45 mgd treatment plant
with Pond Creek Phase Two North County Phase Three, and North
County Phase Two, following up in the construction sequence.
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28
The Fifth Scenario involve* a limited action in
Mill Creek, again a 45 mgd treatment plant at West county
and the sequence being to complete Pond Creek Phase Two and
then to build the limited sewers described by Alternative 7
A or 7 B In the Mill Creek Area, and then to go on to North
County and back to Pond Creek and North County, to finish
out those systems. This limited Mill Creek Activity would
involve sewers sized only for the current need with no
sewers for future growth that would put the future growth
either on septic tanks or small treatment plants.
And finally, the Sixth Scenario is very similar
to the Fifth except here the Mill Creek activities would have
sewers designed at the outset for picking up all future
growth, that la the sewers would serve the critical need
along the Dixie Highway and then all future growth In the
Mill Creek area would feed to those sewers, but the existing
residences would not be altered.
Bach one of these scenarios Implies a certain
construction activity on a certain schedule and these con-
struction expenditures on the schedule going out into the
1990's were Imposed on a cash flow model developed by MSD
and they produced the results that you will see here.
The first result is to take a look at the Impact
of the various alternatives on MSD service charges. Now,
this is the charge projected for the average residential
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29
user of the system and It is system wide, not Just the Mill
Creek System, and as you can see we have the six scenarios
shown in different colors and about the only thing I can
say about It Is they are all pretty much the >u«, that Is,
that anyone of the six scenarios will produce about the
sane Impact on MSD service charges, for the average resident-
ial customer. There are snail differences among then from
one year to the next but we don't feel that these are signi-
ficant.
Scenario Five la the EIS preferred alternative.
We also examined the other side of the - financ-
ial impact other than the Impact on the user Is the impact
on the agency and that Impact we measured by determining
the bonding requirements that MSD would face under each one
of the alternative*. Now you can see here that this graph
Is not nearly as smooth as the other one but If you would
analyze the total bonding requirements for each of the al-
ternatives they come up to be pretty much the same during
the study period. Neither one of these findings should be
particularly startling because each one of those scenarios,
each one of those six scenarios, has MSD expanding at about
the same rate, whether they are expanding In Pond Creek or
whether they are expanding In Mill Creek or North County,
the, construction is going on at about the same number of
dollars per year.
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31
constructed In 1989 a new residence, and we choose 1989,
because that's the date at which the Mill Creek or the Mill
Creek portion of It MSD system would exist If It were to be
built, we find that the cost projected out to the year 1995
for each one of those alternatives shows that the future
I residence would be most Inexpensively served by septic tanks
and seepage pits and also again, not surprisingly, the public
sewer systems for future residences would be less expensive
than a private or I should*t say private, than would be a
smaller system, simply again because of economy of scale.
So, what we came down to were some conclusions
that I am sure you can feel that I have been leading up to.
First of all, that across the broad range of activities
in the MSD system as a whole In Jefferson County and also
particularly in Mill Creek that these really Is not much of
a difference in financial impact, as reflected in either
revenue raising requirements for MSD or a cost to the user.
But again I stress that that shouldn't be surprising to us
because the construction activities wherever they are occur-
ring are going along at about the same rate under all of the
scenarios.
Secondly, that public sewers are less costly than
the current private system as we project those costs out
into the future.
And finally, that on-site systems consisting of
Mill It ItH'UHTIM. I
32
septic tanks and seepage pits are least expensive for serv-
ing the needs for waste water management in the future
residential units.
So that concludes the finding. The financial
Impact analysis formed an Appendix to the Draft EIS, and I
think a few of the copies are available here, and I'll give
It back to you, Mr. Oreene.
MR. GREHfE: Thank you very much, Ron, and David
I know I certainly benefited by seeing all that kind of
sketched out.
Before we receive comments, I'd like to remind
you to register at the front desk if you haven't already
done so, so that we have a complete attendance list. Also,
if you wish to speak this evening, please Indicate, there's
a place to Indicate that on the little yellow registration
card.
In order that anyone who would like to speak is
given an opportunity to do so, you are requested to limit
your testimony to approximately five minutes. Tf you have a
written ttatement or a prepared text, we would very much like
for you to submit,It, a copy of that to the panel to enable
us to follow your remarks mora closely and also to insure
that your remarks are accurately included in the record.
Members of the hearing panel may ask questions
of the persons presenting oral statements when Its felt
I llllll III I'Oli i im. >1 lit (< I-
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33
necessary to clarify the nature or the substance of the
comments being Bade, however, I would ask that the audience
not ask questions of the people who sake the comments nor
should questions be asked of the hearing panel. The reason
for this is not to foreclose discussion but merely the pur-
pose of this hearing is for us, as the hearing panel, to
receive comments from the Individuals Involved. As we
proceed with the hearing, I'll call on speakers in the order
In which you registered and I think is reflected in the
order of which 1 have the yellow cards. Elected officials
and representatives of Federal, State, and Local agencies,
will however, be called upon first. Before you make your
statement, please identify yourself by name and if appro-
priate, the group or organization that you represent, and
please do go to the podium which is located on the table In
the middle of the room, you know, as you make your comments
to Insure that your comments are recorded on our $ape as
well as the Court reporter's tape.
Would either State Senator Quinlan or State
Representative Elect Lyle, Ilka to make a statement at this
timet
SENATOR QUIHLAH: Not at this time.
MR. GREEKS: All right, sir, are these any other
elected officials whom I didn't recognise earlier who would
like to be recognised or make a statement?
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34
i OK, then, I'll first call upon Mr. John Tlerney
of the Metropolitan Sewer District.
MR. TIERNEY: Thank you.
When I mm a young fellow going to school, they
used to say enuclate and articulate so I will attempt to
61 do so.
71 MSD hai reviewed the Mill Creek Draft EIS con
talnlng EPA'» reconnended alternative plans
To put that alternative plan In perspective, let
look at the bottom line first.
She total capital cost will be approximately
$525 Million dollars, including approximately $50 Million
dollars already expended.
The number of new customers served by the re
coonended plan Is projected to be approximately 46,700.
This would result In capital costs for each new custoner of
almost |11,250. How, what's behind those figures?
The recommended plan assuaea that MSD will be the
agency to implement the program. What other assumptions are
made?
He Bust analyze not only the assumptions but
MSD's capability to perform within those assumptions. The
recommended plan assumes that USD can Increase Its rates to
all customers, present and future, by whatever amount and when
ever It Is necessary to meet the financial needs of the progra
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MSO-1. Response to this comment requires explanation of the origin of
HSD's figures.
The capital cost was derived from comparing total project capital
expenditures through 1995 for the entire MSD expansion program ($496
million) (which Includes the Mill Creek selected alternative) to
capital expenditures associated only with expansion projects currently
under contract (S2I million). Added to this difference Is $50 ailMon
In capital funds already spent, for a total of $525 million. This is
a projected expansion cost for Mill Creek and other areas served or
to be served by MSD.
The number of new customers (46,750) was obtained by subtracting
the number of "equivalent customers" projected for 1995 without the
expansion program (293,218) from the nunfcer projected for 1995 with
the expansion program (339,959). The FY 1982 equivalent customer
base Is 288,298. The phrase "equivalent customers" has a United
relationship to the actual number of users, accounts, or homeowners,
and includes commercial and industrial users. The nunfcer of
equivalent customers is determined by dividing projected revenue by
a service charge per equivalent customer, a charge that is based on a
water-use rate of 6,500 gallons per month.
MSO then divided $525 million by 46,750 to obtain $11,250 In
capital costs per new customer. This result can be misleading for
several reasons.
First, the $11,250 would be a cost per new equivalent customer.
Second, this cost would not be borne entirely by new customers.
Assessments to properties would be made only for collection sewers,
with the costs of other system components paid by all MSD users. In
addition, federal funding would be available for a significant portion
of the project costs.
Several people appear to have interpreted Mr. Tiemey's comments
to mean that new MSD customers would be required to pay $11 ,250 for
connection to the MSD system; this conclusion is erroneous.
MSD-2. MSD rate adjustments were assumed for all alternatives in order
to compare the financial impact of each alternative. Since essentially
similar rate adjustments would be required under any of the alternatives,
the comparison of alternatives is valid regardless of the difficulty
of changing MSD's rates.
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1
HSD-2
2
3
4
R
6
7
A
MSD-3
9
to
II
12
13
14
IS
16
17
MSO-4
16
19
20
21
22
MS 0-5
»
MSD-61 '¦&
35
This assumption overlooks the fact that MSd
cannot unilaterally Increase Its rates or issue revenue
bonds without the approval of both the city and the county.
The coat of the collector sewers Is assumed to
be financed by assessments against all benefited properties
Including properties now served by on-lot disposal systems
except those In a specific geographical area west of Dixie
Highway.
What about the other properties served by on-lot
systems? Mill the sewer benefit that property? Can the
cost be legally assessed In light of IPA's determination
that on-lot disposal systems In other areas of Jefferson
County are acceptable means of waste water disposalT
The financing plan assumes that MSD can acquire
all existing waste water treatment plants without compensa-
tion to the owners. This Issue has not been resolved des-
pite lengthy litigation.
The assumption Is also made that MSD can take
•ver the Okolona Sewer Construction District. This would
require execution of a proposed agreement by the Okolona
Commission.
75 percent of EPA funding is assumed throughout
the lif* of the project until 1995i for all capital costs
except collector sewers. Is this a valid assumption?
SPA concludes that It will not conduct additional
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MSD-3. EPA has not determined that on-lot disposal systems are
acceptable In other areas of Jefferson County. Properties
that were to be served by sewers were assumed to be assessed
for those collectors.
MSD-4. If compensation to treatment plant owners or sewer districts
becomes necessary because of court decisions or special agreements,
then this assuq>t1on would need to be revised. This would not affect
the conclusions of the EIS, because 1} the package plant costs are
likely to be minor tn relation to other costs and 2) the current
analysis would be biased In favor of the regional system, which
replaces the most number of package plants.
MSD-5. Amendments to the Clean tfater Act signed by the President in
December, 1981, will reduce federal funding to 55 percent after
September 30, 1984. The 75-percent assumption was valid at the
time the Financial Impact Analysis was run. Revising this assumption
should not affect the conclusion of this CIS, becuase the current
analysis Is biased In favor of those alternatives with the greatest
construction—e.g., the 201 Plan.
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5 36
I environmental Impact studies in Jefferson County.
I Whit assurances can SPA give that this Mill
I reoccur?
I Obviously, these questionable assumptions,
I coupled with the financial and legal uncertainties in the
I recommended plan must all be satisfactorily resolved before
| that plan can be initiated by anyone.
I MSD 1* merely the designated Management agency
I to implement the sewer program. We believe the entire
I community should decide once and for all whether or n6t it
I wants the sewer expansion program and if so, what that
I program should be. The 201 plan process with public parti-
cipation could address all the issues cited above. Tn fact,
! a revised 201 plan appears to be called for since EPA1b
recommended alternatives, is a distinct deviation from the
201 plan originally approved by this community. That's
all. Thank you, Mr. Greene.
MR! QREHIEj Thank you, Mr. Tlerney.
I'd next like to call on Patricia Nightingale
of the Jefferson County Board of Health.
MS. NIGHTTNOALB: I am Patricia Nightingale,
representing the Louisville-Jefferson County Board of Health.
In 1964, Jefferson County developed a Master
Plan for a county-wide sanitary sewage collection and treat-
ment system. This was done a full eight years before Congrefl!
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MSD-6. EPA's position on the rest of the expanded service area Is
already being Implemented: An EIS is being prepared on the North
County Area, and a negative declaration has been issued for Pond
Creek, where sewer design and construction is underway.
HSD-7. The question of priorities for sewer construction in Jefferson
County is a decision to be made by state and local officials.
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37
passed Public oaw 92-500, the Clean Water Act. This Act set j
the same goals for the nation that Jefferson County had sot
in 1964 of cleaning up it? streams and underground water
and maintaining them in an environmentally acceptable condi-
tion.
Jefferson County welcomed the passage of Public
Law 92-500 and in 1974, presented a Vater Quality Management
Plan, 201 plan, to EPA for consideration. Jefferson County's
plan was accepted by EPA and except for minor changes, the
I
plan was essentially the same as the 19&4 Master Plan.
Jefferson County felt that it was on Its way to
establishing a community wide system that would serve for the
disposal of all residential, coronercial and industrial liquid
waste. The Plan would eliminate or bring under control all
surface and subsurface polluting discharges identified in
Jefferson County. Late in 1977. however, EPA directed that
an Environmental Impact Statement be conducted to determine
the need for (ewers in the Mill Creek Watershed.
Three years and one-half a million dollars later,
iJais E1S reports facts already Known to Jefferson County
participants in the 201 study. That report tells us that
the Dixie Highway Corridor is suffering from numerous mal-
functioning septic tank systems and that raw sewage is
exposed to the atmosphere creating potential serious health
hazards. It also Informs us that the Southwest aquifer is
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38
polluted with nutrients and human pathogens to the extent than
It should no longer be used as a source of untreated drink-
ing water. Further, the report advises that the drinking
of this water nay have serious consequences for Infants due
to the excess nitrate pollution. Ve are advised that surface
streams are in even worse condition than the underground
water, due to the package wastewater treatment plants that
discharge Into this waterhsed.
The report notes that over the next 20 years,
over 75 percent of the septic systems in the Mill Creek
watershed will have outlived their designed life expectancy
and will need to be replaced. The replacement of these
14,000 systems, at an estimated $2,000 each, will cost the
citizens $28 million. The expenditure of these monies will
not improve polluting conditions of this watershed, but will
simply replace existing polluting systems with another pol-
luting system.
Having recognized the pollution problems of the
Mill Creek Waterhsed, EPA has recommended that a construction
alternative be undertaken which does not clean up, or protect
the underground water, but may in fact, continue or even
Increase the pollution of this watershed. The recommendation
I
does not remove all of the package plants discharging into
lntra-county surface water.
The Louisville and Jefferson County Board of
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39
Health has long supported the county-wide sewage collection
and treatment system concept, alternative 8 of the EIS. This
alternative, originally approved by EPA, would eliminate the
very pollution problems documented in the Mill Creek EIS.
The Board, however, recognize* the current adverse economic
conditions of this community and the nation, and, therefore
acknowledges that a compromise position may be necessary.
The alternative recommended by EPA prevents the county from
providing relief In the future when sewers will probably be
needed. This is because an undersized sewer system will be
constructed under alternative 7 B. The Louisville and
Jefferson County Board of Health would urge, therefore that
an attenuated version of alternative 7 C be considered as a
compromise position. This Alternative would limit the
Immediate construction of the collection system to the Dixie
Highway Corridor as proposed in Alternative 7 B. The
attenuated version of Alternative 7 C, however, would pro-
vide sizing of the collection which would allow future
•xtension into developed areas.
It Is inconceivable, with the facts as docu-
mented In the EIS, that EPA could choose an alternative that
dooms the natural resources In Jefferson County to continued
degradation and even recommends further degradation.
An attenuated Alternative 7 C, if implemented,
while maintaining cost figures far lower than those for
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LJCBH-1. EPA does not oppose a local decision to proceed with a sewer
system sized for alternative 7c. Any conmltment of federal funds,
however, would be based on alternative 7b, the most cost-effective
alternative.
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LJCBH-2
LJCBH-3
00
10
alternative 8, would not preclude Jefferson County from com
plying at some time In the future with the mandate from
Congress as set out in Public Law 92-500.
Concerns of Louisville and Jefferson County
Board of Health of Draft Mill Creek EIS recommendation.
One. Will tewer line extensions that are needed
to eliminate all package wastewater treatment plants In the
Mill Creek Watershed be eligible for EPA funding?
Two. With EPA'b recommendation of alternative
7 B, the Louisville and Jefferson County Board of Health
requests EPA to establish another alternative for considera-
'I tion, attenuated 7 C, as presented in the Board of Health's
1 j: response.
il
1 p (Lines 8 through 15 inclusive, is an addendum
of original statement presented by Ms. Nightingale and
were received after the transcript was orignally prepared.)
MR. GREENE: Thank you very much, Ms. Nightingale
Are there anyother representatives of local
agencies that would wish to speak at this time?
(No response)
If not, I'd like to call on Mr. Francis Ehgdahl
as our next speaker.
MR. ENGDAKt: Ladles and gentlemen, X am Francis
Qigdahl, I live at 6229 Bethany Lane in Southweat Jefferson
County and am speaking for the Southwest Home Owners
I unit III I'OII I I\l. -Ml V II i
MM i IM It • '
1.1 MM J.^hl M. < i '
LJCBH-2. Only those plants identified in alternative 7b for connection to
the sewer system would be eligible for funding. These are the only
plants for which connection to the sewer system is cost-effective.
LJCBH-3. EPA does not oppose a local decision to proceed with a sewer
system sized for alternative 7c. Any commitment of federal funds,
however, would be based on alternative 7b, the most cost-effective
al temati ve.
-------
ill
Association, Inc.
Growth is not necessarily good or desirable.
Many times growth creates more problems than it
solves. Before Jefferson County plans a population growth
it needs to address the problems it has now to determine:
1. Do we have adequate facilities for our
present population?
2. When the projected growth of thousands is
added what kind and size of new facilities are needed plus
the costs of such facilities.
Out big problem at the present time is our road
system. We waste time and energy, pollute the air and have
accidents far above the normal rate. When the Riverport
is operational, our problems will Increase. The reasons
Our growth rate is held In check are the roads, dissatis-
faction with the bureaucrata, courts and politicians along
with the Health Department's decision to limit the use of
septic tanks and package treatment plants. The advocates
of regional sewage systems point with pride the population
growth In an area after their systems are operational. The
truth Is that normal growth is hampered by regulations that
limit reasonable development. The bureaucrats must have
their way.
We do not believe that our on site sewage
disposal is as big a polluter as the Metropolitan Sewer
I.OKI) HKI'OHTINi. MltVIM
• .'Mil f X
JO \ MIl.HMjl KC. ullllt | .iw.n
-------
12
Di«triet. The sewer system in Louisville Is antiquated and
will be very expensive to upgrade to minimum standards.
Many of our members believe it Is the need for
more customers to help pay for Louisville's sewer problems
which is behind Metropolitan Sewer Districts desire to take
over our area.
They do not believe MSD wi»hes to help the sub-
urban areas only to make us help pay. They take the attitude
that our areas is where septic tanks work best and yet wish
this area to be the first to be sewered. This way the area
which least needs sewers will have the greatest costs.
There is no objection to have sewer trunk lines
to service the high density commercial zones. We realize
that cm site sewage disposal is limited to low density
population.
We agree that sewer lines are needed for some
areas but for our low density area our on site disposal is
better than the performance of the Metropolitan Sewer
Di»trlct. Thank you.
MR. GREENE: Thank you, Mr. Engdahl.
I'd like next to call on Mr. Leo Harrod.
MR. HARROD: Mr. Charlman, my name is Leo Harrod,
I live at 5035 Terry Road and I represent AARP, a retired
Senior Citizen* Group that meets once a month,
I'm happy to report tonight that our septic
10111) iii PiMiriM. >rit\ icl
VM< UNh t
Hf \ Mil hi. DHHI »'««.«
if."'
Comments noted. Under alternative 7b, only houses already connected
to sewers would be served by the regional system.
-------
43
tanks are working.perfectly.
I have a neighbor here, Mr. Headden, right here
by me, that stopped by most every year and asked me, when
are you going to have your septic tank cleaned out again?
And I said, you Just done it 10 years ago, you
don't want to do It every week, do you? (Laughter)
That's about the rate we've had it deemed out
and I have gone more than that, so, these senior citizens
that I'm representing here with the proposal that has been
made here by MSD, we would be at their mercy, to rai»e the
rates and so forth, according to whatever their needs would
be.
The majority of them would lose their homes.'
That's what itwoild mean to them and surely, we don't want
to put in something out here that would cause people, when
they have reached the age of retirement, that they're going
to lose their homes and would be set out in the cold.
So that'* just about what it would mean to
thousands, not Just four or five, in this area, and X have
noticed that the elected officials downtown are anxious to
get this because it would help them pay off their bonds that
they've already issued, not because we need the sewers, but
becajse they need the revenue, and we are very much opposed,
the people around my neighborhood, and the people that I am
representing here tonight, for any sewers that we don't need
I OKI) Itli'OitllM, ¦- lit \ I "! Hi;. OilJH m-f.h
JWii . tli""
LH-1. Comment noted. Under alternative 7b, only houses already
connected to sewers would be served by the regional system.
-------
LH-1 i
I
00
l-o
1
and something we can't afford.
We still want to keep our homes and live in the
area. Thank you very much.
MR. GREENE: Thank you, Mr. Harrod.
Would you care to give us a copy of your remarks
so we can Include those in the record?
MR. HARROD: I don't have any.
MR. GREENE: I see. You had a copy of the agenda
for tonight. I thought you were reading. Thank you, sir.
At this tine I'd like to recognize Commissioner
Carl Brown, who I understand would also like to make a state-
ment. Comnlssloner Brown.
MR. BROWN: Mr. Greene, Mr. Mikulak, Mr. Williams
I am pleased to be here tonight under these circumstances.
Like many of the people In Southweat Jefferson
County, I have followed this Issue for many years and X
think at the threshhold It has to be remarked that we're
glad you listened. Its apparent that you have, and it means
a lot to me and It means a lot to the people of Southweat
Jefferson County that the feelings, and the emotions, and
the facts, and the logic, and the reasons that have been
presented to the Environmental Protection Agency over the
past several years has been incorporated into this report, anfl
into this recommendation.
As an elected official, as a representative of
I lllili III I'OKl IN<. -I IIMl I
f it HI' ».« ••
Ji M v ' >! 1' • HI ufiM' >«-.i
fi',I ' '/
-------
CB-I
oo CB-2
H5
Southwest Jefferson County, X would like to state for the
record again my support for Alternative labeled 7 B, that
is recommended by the Environmental Protection Agency.
X think the primary reason, and I know that the
remarks I am making now run in cro9s currents with the
remarks other officials who made remarks tonight, and while
1 respect their opinion, 1 beg to differ and 1 do so I think
from a position of information and from a position of reason
The recommendation of the Environmental Protec-
tion Agency does a significant thing and what it does, it
reflects the realities.of our sub-structure, of our sub-soil
It reflects the realities that we have a natural filter
system in Southwest Jefferson County, in the sub-structure
of our land, that is not enjoyed by areas of Okolona, and
areas of North Jefferson County.
The initial approach taken by the one wing of
the Environmental Protection Agency pursuant to the Clean
Water Act was to treat all areas of the county similarly.
That was a mistake.
X think what we've seen tonight Is recognition
of that early mistake - and we all make them - and a report
and a recommendation that allows for the differences in
geology among various regions of the county.
To sum it up - if its not broken, why fix it?
And I think that's what we've been hearing not only tonight
I lIUll KI l'OIUINt. M H\KI
r'tll. i I uh \> I
MK\ MM |t*W 1(1.. limn ¦¦ *
CB-1.
Comment noted.
CB-2. EPA concurs with characterizing the alluvial sub-soil as unique
relative to other parts of Jefferson County. EPA does not concur with
characterizing the aquifer as a "natural filter system." Seepage
pits effectively discharge directly to the sands and gravels of the
alluvial aquifer and although some treatment may occur, the aquifer
should not be considered a "natural filter system."
-------
I ''k
i | but what we have been hearing for years.
[ Its no surprise that to hook on to the sewer
system that's questionable at best, would create severe
economic hardship for the affected residents. But. that's
| not the primary reason not to do It.
The primary reason is as buttressed by the
Intense sutdles of professionals who've looked at It for tl
last several years that the need does not exist. I've
studied the reports. I've rerlewed the recommendations.
Mr. Mlkulak, I've talked to you in Atlanta bout this in
your office. I support what you're doing. I appreciate
what you're doing, and I want to thank you for what you're
doing and I want to thank you far listening to the people
of Southwest Jefferson County,
MR. QREENE: Thank you, Commissioner Brown.
I'd next like to call on Mrs. Eleanor Bngdahl.
MRS. eNGDAHI,: I'm Eleanor Ehgdahl. I live In
Valley Station, Kentucky.
I picked up a magazine last night to thumb
through. I had no idea It had an article on sewage, but,
it has the title, "The modern sewer system outdated and
illogical," so I think perhaps you gentlemen are farther
ahead in your thinking than the MSD who wants to expand
their sewage system and on behalf of the Southwest Jefferson
County Homeowners Association, we thank you for that and
i i.kii iui'iiiu im. Minn i
C8-3. The decision for alternative 7b does not reflect an absolute
conclusion that "the need does not exist." It does reflect a determi-
nation that 7b is the most cost-effective and environmentally sound
alternative for the planning period.
EE-!.
Comment noted.
-------
*»7
EE-1 l
CH-1
CM-1
10 |
11
12
II
I.".
1*
19
20
21
22
23
21
2S
suggesting 7 B.
MR. GREENE: Thank you, Mrs. Engdahl.
Mrs. Clyde Mimn.
MRS MIMS: Thank you.
T don't have any prepared »tatement. I'm Mrs.
Mlms. I'm Ju»t a big mouth from my community of Slyvanla
off Terry Lane. We've kept up what has gone along with
these sewers and we are very much concerned and i-e feel
like we don't need them.
Now, I would like to almost echo what Mr. Leo
Harrod said. I lived on the same property for 25 years.
We built there and we dug our septic tank and we dug our
well. I have our water periodically tested. In 20 years,
I have never had my septic tank pumped. I have no problems
whatsoever, and my water supply according to the Board of
Health, tests perfectly fine. I don't have any need for
a very expensive sewer plan and the biggest part of the
people of our community don't. Things are operating suf-
ficiently and adequately and very possibly my statement
right here might be out of order. I don't know. But, I
Just wanted to state for my community, as a citizen, I have
a big mouth and I don't mind saying so. We don't need them
and we don't want them.
MR. GREENE: Thank you very much. I think as
you probably all know its the big mouth of the community
i <>ni> ti\<; smvn i
! \M \ 11 «t!i1
«¦;. MI'O U"?
Comnent noted.
-------
j 48
that can accomplish some of the best things done in the
J last 10 years or so.
[ OK, Mr. James Headon, is it?
MR. HEADON: I have a question? I wasn't a
person who intended to speak. I wanted to Just sit here
and listen. That's the reason the question mark was on the
thing, but, one thing Jefferson County proposes here, about
18 years ago I bought a house. 1 gave $11,800 for it. Well,
in another four or five years from now, if I live, I'm
going to have that house paid for. But what puzzles me is,
they're talking about $11,000 for each home owner, to put
a sewer in, and Its going to take ne some 20 years to pay
for the house, my grandchildren will never get through pay-
ing for the sewer, to me Its inflationary really. One thing
I noticed among other things, is that they try to run the
people too much, instead of letting the people run them,
they run themselves.
The Government wants to act like we're all
children. We're not all children. Everybody like? to
breathe, and think, and everything for themself. Myself,
I chose to be In the septic tank busine?.-. This is the
reasons I have never came to the meetings as much as T ]
I
want to because I wanted to stay out of it. I didn't want
!
my opinions one way or the other, because the Health De~ j
I
partment here in Louisville does a heck of a ,1ob. I've
I «l(l( III I'OH I IM. M it\II 1
JH-1. $11,000 is not an accurate estimate of a homeowner's assessment
for connecting to a sewer system. Under alternative 7b, no homes on
septic tanks would be connected to the sewer system, so there is no
assessment charge.
-------
49 i
worked with them a lot of occasions. I think the package
treatment plants are doing a pretty good Job. I think that
some of them needs to be cleaned up. I think that there
should be laws passed to nake them do more than what they
do, but the fact that bothers me 1b MSD, when they want a
rate Increase, they go to the Board of Alderman there In
Louisville, and they ask for a rate Increase they get their
rate increase.
Nobody can say anything to them about it because
the Board of Aldermen automatically gave them the rate
Increase.
Now I witnessed.this about a year ago, I guess.
They asked for a $40 a load rate Increase. Well, they raised
it almost 33 percent. We got an attorney and I believe it
was 33 percentthat they raised It. At that the Inflationary
rate was so bad, the President was asking everybody to keep
it at 8 percent, or small figures, but in Louisville, they
decided to raise it 33 percent. But even at 33 percent,
making us to pay to dump our loads, we still can pump septic
tanks and take your septic tank systems cheaper than MSD
can charge a person per month for a sewer, and to me, I
think that sewers are eventually going to be shoved down
our throat whatever, which I think the home owners in this
area have gone against and fbught a good battle, but I think
the polltleans and bureaucrats as they call them, all these
mini Ki i'nmiM, m kmu
l.-Ui. iiMA IKHMM !
HI > Mil lisfit Hi.. | «
MM »llM.
-------
II
150
people who really don't care about the people, they are
there to be seen and think they're above everybody else
in so«cases, but people should be able to think thing?
out for themselves. People In this area don't want sewers.
I I run Into them every day. I pump septic tanks every day.
And the people don't, Just positively don't want It. Like
Mr. H&rrod. I've been living there close to him for 17
years. X think I pumped his septic tank once or something
like that and there's other people that does pump their
septic tank more often than that. There's people that
pump septic tanks every two or three years, but most of the
time the ones that pump septic tanks every two or three years
have got someone working on them that don't know What they're
doing.
But the thing of it is when they run over,aft
least you've Just got one system running over.
When MSD has a spillage in the river, they've
got thousands of gallons; not thousands, but millions of
gallons running over. I can't see the logic behind it.
If somebody could show me the logic, I'd vote for the
sewers. I'll do whatever Is best for the community and
whatever is best for the county and whatever is best for
the country, because I love the country and I love It big,
not because of Just deer hunting because I love deer hunting
too, but that's about all I have to say. I think you'll end
lliitl) IIKIMIIiTIM, m im< t
tWU. HVU ! 1 HH \t t
Comment noted.
-------
51
up shoving It doim our throats eventually but we're going
to kind of let you know we've been here.
MR. GREBIE: Thank you very ouch, Mr. Head on.
Let's see, Walter Brad en.
Ml. BRAD EN: Walter Braden, 10024 Prattle, In
Prairie Village.
Here about three years ago, when all these
things started my wife and I went out to a meeting of this
group. We asked then at that time about Federal aid. There
wasn't any, couldn't have any. It wasn't too long after
that a thing cause up at,a cooaunlty where Federal aid came
up and they got it. If one can get it, why can't others?
That's all I have.
MR. GREENE: Thank you very much for your
consents, Mr. Braden.
Those are all the registration cards that 1
have that have indicated a desire to speak. Is there anyone
else who would like to make a statement?
MR. KHf HEIL: My mm Is Ken Hell. Speaking
on behalf of the Libertarian Party of Kentucky, who speaks
out on government intervention, last night was probably
very ironic when a spill occurred at Standiford Field and
MSD had to flow raw sawage into the Ohio River, for approx-
imately 15 hours as I understand. You know that's a few
million gallons of raw sewage and the MSD is supposed to be
I OIIII Illll'OKTINI. st in It t
i-.jf. itMUi.t.
KM SOI OiBl m, OHIO
KM ln'»7
WB-1. The state determines the priority of projects for receiving federal
sewer funds. The Financial Impact Analysis assumes federal funding
would be available.
-------
I 52
protecting us from environmental damage. Its kind of odd
too, to hear Mr. Tierney's statement that MSD refer* to the
people who use their services as customers. Well, if I were
to have a shoe store and 1 was to go out on the sidewalk and
call people in and tell than, listen, you buy ay shoes or
you go to Jail and pay a fine, they're not customers anymore
Thqr're like slaves or serfs. Yet the MSD «ays they're
their customers.
Mr. Tierney also states that some 46,000 resi-
dents would have to pay a $11,000 sewer charge, if the
Southwest is not included. That goes to show you right
there that Southwest Jefferson County residents would be
paying more than they should pay. They are really subsi-
dizing the rest of the county. Its not fair to the South-
welt. Just because we have good soil out here does not
mean that we should subsidize poor soil somewhere else.
Mr, Tierney also cites certain legal and
financial uncertainties as reasons that this plan should
not be Implemented right now. He also asked you, the EPA,
to dispel these uncertainties right now before you implement
any type cf plan.
Well, what assurances can MSD give u» that
another sewer explosion would not happen again,
MR. GREENE: ThanX you. Yes sir.
MR. PARKER: I am Ed Parker. I am also a member
IDIilJ lll l'iill I |N<. Sl ltMl f
t.'i l.. UMS JtHIUl t
ttt i \"J hi:. I )¦« r
rt(.i u<*~ I
KH-1. J)1,000 is not an accurate estimate of a homeowner's assessment
for connecting to a sewer system. Under alternative 7b, no homes on
septic tanks would be connected to the sewer system, so there is no
assessment charge.
-------
53
of the Home Owners Association. I support Mr. Francis
Sngdahl's statement made earlier this evening on behalf of
the homeowners.
A couple of points I would like to make is in
light of the fact that we have, well, EPA, MSD and Health
Department and thla has been alluded to a couple of times
In other statements and as we see it in the County, MSD
ha* never properly managed the sewer system that It now
controls. It is continually, especially in any kind of a
storm situation, dumping raw sewage into the river.
I've read several reports, I don't have them
with ne this evening, that says the water contamination in
the Ohio River above Louisville is not too bad. But its
bad when you get beyond Louisville, which indicates Louis-
ville, the city of Louisville in particular, Is polluting
the Ohio River. And yet one wonders why the Health De-
partment would be concerned about septic tanks In Southwest
Jefferson County when they are not concerned about the raw
sewage being run through the City of Louisville Into the
Ohio River.
Tou also note that from many reports that we
have received that there are a number of businesses within
the City of Louisville that don't actually run their sewage
through the Treatment plant but run It directly Into the
Ohio River.
i.oito iikpoktiv; sckmu
Wli, T \ I i:kh \l I
ItMNnn^Hl Hf.. OHIO
H'.t \t.T
EP-1. EPA concurs that untreated wastewater discharged directly to the
Ohio River should be considered a health problem. Such discharges are
illegal (all surface water discharges require NPDES permits);
unpermitted discharges should be reported to the Louisville and
Jefferson County Health Department.
-------
54
I would add that that should be considered in
most categories as a health problem.
What I am in essence saying is maybe there
should be some kind of environmental study in the City of
Louisville. That's all.
MR. GREEME: Thank you, Mr. Parker,
Mrs. Yvonne Ramswer? Mrs. Ramswer, did you
want to make a statement?
(No response.)
She apparently doe* not. Is there anyone else
who tould like to speak? Yes? -
MR. PENDLETON: My name is George Pendleton.
I know a lot of the other people who got up here know a
lot more about It than I do.
About eight years ago I lived where they had
sewers and whenever we had a day or two or rain, the sewers
would flood the streets and everything.
Noic.yftten we have rain out here our septic tanks
don't overflow or anything. Our water is Just as clean, if
not cleaner, Nobody gets sick over our water. If our
septic tanks overflow, nobody goes to the hospital about
it.
People have bought the land and have worked
many years, I know my parents and grandparents, they work
all their life to pay for the land and when th ey come out
1(11(1) IU I'tlfll l><. MII\IU
T*\\A IKKMO
\ \oi k<; Ohio :
lint
-------
55
and put In sewers they've got to pay more than what they
paid for the land.
To me, I don't think its right, but thank
you anyhow.
MR. GREENE: All right, thank you, Mr.
Pendleton. Is there anyone else who would like to make
a statement?
(No response.)
Hell, again I'd like to remind you that the
public hearing record will remain open until December 'ith
of 1981. All written comments received will be considered
as part of the record, and should be forwarded to John
Hagan, Acting Chief of the environmental Assessment Branch.
Now, I'll read his address out too, for those
of you who have the handout. Its - the address is at the
bottom of the first page: EPA, Region 4, 3'15 Court land
Street, Atlanta, Georgia, 30365.
I wish to thank each of you for your partici-
pation in the public hearing tonight.
The comments that you have made and what we
have received during this evening and during the comment
period will be carefully considered, and responded to in
the final Environmental Impact Statement.
This final EIS will consist of the Agency's
final decision, a summary of the draft EIS, and any
l.ltltll HKI'OHTINf, -I.HV 11 1
i.-.I'. HMt It.llKUr.
II H MM |1-UI hi tlitUl 1 intiH
GP-1. Under alternative 7b, no homes on septic tanks would be connected
to the sewer system, so there is no assessment charge.
-------
56
pertinent additional information or evaluation* developed
since the publication of the draft, revisions to the draft,
comments received, and EPA's responses to those comments and
the transcript of this hearing.
Those of you who commented tonight or submitted
comments will receive a copy of the final EIS.
I Just want to make this one personal note.
I have always been committed to the principle than ar in-
formed participating citizenry is the best sort of check,
as well as a source of information, for those of us who -
shall we say - are affectionately called bureaucrats.
After all, you know we are charged by law with making certain
decisions and believe it or not, none of us consider our-
selves to be omniscient. We need your Input. We need
your comments. We may not always agree with them, but we
do always consider then.
Again, thank you for your attendance and parti-
cipation in the EIS process.
This hearing is adjourned. Good night.
(Whereupon at 9:15 P.M., Tuesday, November 17,
1981, the hearing in the above entitled matter was closed.)
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-------
4.2 Written Comments
Written comments on the Draft EIS were received through March 1, 1982.
This section contains copies of those letters together with EPA's responses.
Table 10 is an index to the written comments and EPA's responses, and Table
11 summarizes the general subjects mentioned by each commentor.
-95-
-------
TABLE 10. INDEX TO WRITTEN COMMENTS ON MILL CREEK DEIS
COMMENT
CODE
PAGE(S)
COMMENTOR
DATE
NATURE OF COMMENT
SHPO-1.
109
State Historic Preservation Office
10/28/81
Impacts to historic places
SHPO-2.
110
State Historic Preservation Office
10/28/81
Impacts to archaeological resources
COE-1.
111
U.S. Army Corps of Engineers
11/09/81
Southwest Jefferson County Floodwall
COE-2.
111
U.S. Army Corps of Engineers
11/09/81
Flood protection impacts on housing,
population, and land use
COE-3.
111
U.S. Army Corps of Engineers
11/09/81
Flood protection impacts on agriculturi
land
ABS-1.
114
A.B. Schlatter
11/19/81
MSD aquisition of treatment plants
ABS-2.
114
A.B. Schlatter
11/19/81
Details of Alternative 7b
DHH-1.
115
Dorothy H. Hardesty
11/20/81
Support for sewers
DOI-1.
116
U.S. Department of the Interior
11/23/81
Impacts to recreation resources
DOI-2.
116
U.S. Department of the Interior
11/23/81
Impacts to historic and archaeological
resources
DOI-3.
116
U.S. Department of the Interior
11/23/81
Department of the Army permits
DOI-4.
116
U.S. Department of the Interior
11/23/81
Impacts to mineral resources
CDC-1.
117
Centers for Disease Control
11/30/81
Impacts to groundwater
-------
(TABLE 10. CONT'D)
COMMENT
CODE PAGE(S) COMMENTOR DATE NATURE OF COMMENT
CDC-2.
LJCPC-1.
LJCPC-2.
LJCPC-3.
LJCPC-4.
LJCPC-5.
LJCPC-6.
LJCPC-7.
LJCPC-8.
L^pPC-9.
117 Centers for Disease Control
118-119 Louisville and Jefferson County
Planning Commission
119 Lousiville and Jefferson County
Planning Commission
119-120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
120 Louisville and Jefferson County
Planning Commission
11/30/81 Support for Alternative 7c
12/01/81 EPA has undermined the 201 Sewer
Expansion Program
12/01/81 EPA has undermined the 201 Sewer
Expansion Program
12/01/81 Septic tank policy
12/01/81 E1S has added costs
12/01/81 EIS has undermined development planning
12/01/81 Preferred alternative is contrary to
201 Plan
12/01/81 Preferred alternative is contrary to
County Sanitary Code
12/01/81 Preferred alternative is contrary to
the Sanitary Code and the
Comprehensive Plan
12/01/81 Preferred alternative is contrary to
Clean Water Act
-------
(TABLE 10.
COMMENT
CODE
PAGE[S)
COMMENTOR
LJCPC-10.
LJCPC-11.
LJCPC-12.
LJCPC-13.
A-l.
A-2.
JCEPO-1.
JCEPO-2.
JCEPO-3.
JCEPO-4.
JCEPO-5.
121
121
121-122
122
123
123
124
124
125
125
125
Louisville and Jefferson County
Planning Commission
Louisville and Jefferson County
Planning Commission
Louisville and Jefferson County
Planning Commission
Louisville and Jefferson County
Planning Commission
Anonymous
Anonymous
Jefferson County Environmental
Policy Office
Jefferson County Environmental
Policy Office
Jefferson County Environmental
Policy Office
Jefferson County Environmental
Policy Office
Jefferson County Environmental
Policy Office
CONT'D)
DATE NATURE OF COMMENT
12/01/81 EPA decision reflects short-term
cost perspective
12/01/81 EIS has impeded 201 and 208 planning
12/01/81 Supports variation of Alternative 7c
12/01/81 Economic impacts; future development
in Mill Creek
12/01/81 Riverport wastewater treatment
12/01/81 Costs to new customers
12/02/81 EPA decision to prepare an EIS
12/02/81 Costs of sewerage system; time
needed for EIS preparation
12/02/81 Financial impact analysis
12/02/81 EIS process has resulted in
increased costs
12/02/81 EPA's decision does not protect
groundwater
-------
(TABLE 10. CONT'D)
COWENT
CODE
PAGE(S)
C0MMENT0R
DATE
NATURE OF COMMENT
JCEPO-6.
126
Jefferson
Policy
County
Offi ce
Environmental
12/02/81
EPA has "written-off" groundwater
JCEPO-7.
126
Jefferson
Policy
County
Offi ce
Environmental
12/02/81
Septic tank recommendations; ground-
water pollution
JCEPO-8.
126
Jefferson
Policy
County
Office
Environmental
12/02/81
Industrial recovery and expansion
JCEPO-9.
127
Jefferson
Policy
County
Office
Environmental
12/02/81
EIS has impaired the Countys financial
ability to provide sewers
JCEPO-10.
127
Jefferson
Policy
County
Office
Environmental
12/02/81
EIS has impaired stream and ground-
water clean-up
JCEPO-11.
127
Jefferson
Policy
County
Offi ce
Environmental
12/02/81
EIS has devastating effects on future
Mill Creek generations
JCEPO-12.
127
Jefferson
Policy
County
Office
Environmental
12/02/81
EIS has impaired employment
opportunities
JCEPO-13.
127
Jefferson
Policy
County
Office
Environmental
12/02/81
EPA should reconsider its decision or
work to mitigate the effects of
decision
LWV-1.
128-129
The League of Women Voters
12/03/81
EPA's decision threatens groundwater
quality
LWV-2.
129
The League of Women Voters
12/03/81
Supports a selection similar to
Alternative 7c
-------
(TABLE 10.
CONMENT
CODE PAGE(S) COMMENTOR
LWV-3. i29 The League of Women Voters
LWV-4. 129 The League of Women Voters
LWV-5. 129 The League of Women Voters
LWV-6. 129 The League of Women Voters
LWV-7. 129 The League of Women Voters
MSD-1. 131 Louisville and Jefferson County
Metropolitan Sewer District
MSD-2. 131 Louisville and Jefferson County
Metropolitan Sewer District
MSD-3. 131 Louisville and Jefferson County
Metropolitan Sewer District
MSD-4. 131 Louisville and Jefferson County
Metropolitan Sewer District
MSD-5. 131 Louisville and Jefferson County
Metropolitan Sewer District
MSD-6. 1^1 Louisville and Jefferson County
Metropolitan Sewer District
DATE
NATURE OF COMMENT
12/03/81 Fate of small WWTPs under Alternative
7b
12/03/81 Cost of having cleam streams
12/03/81 Cost of stopping groundwater pollution
12/03/81 Worth of natural resources
12/03/81 EPAs recommendation vis-a-vis the
Clean Water Act
12/03/81 EIS was approved before all financial
information was sent to EPA by MSD
12/03/81 Task reports are unavailable
12/03/81 Sewer hook-up costs
12/03/81 Inaccuracy in an EIS figure
12/03/81 Impacts to streams and groundwater
12/03/81 Cost of public water hook-up
-------
(TABLE 10.
COMMENT
CODE PAGE(S) COMMENTOR
MSD-7. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-8. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-9. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-10. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-11. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-12. 132 Louisville and Jefferson County
Metropolitan Sewer District
MSD-13. 133 Louisville and Jefferson County
Metropolitan Sewer District
MSD-14. 133 Louisville and Jefferson County
Metropolitan Sewer District
MSD-15. 133 Louisville and Jefferson County
Metropolitan Sewer District
MSD-16. 133-134 Louisville and Jefferson County
Metropolitan Sewer District
D)
DATE NATURE OF COMMENT
12/03/81 Errata
12/03/81 Errata
12/03/81 Septic tank/seepage pit lifetime
12/03/81 Cost analysis
12/03/81 Erratum
12/03/81 Septic tank reliability
12/03/81 Septic tank reliabiltiy
12/03/81 Erratum
12/03/81 Public acceptance
12/03/81 Opposes sewers not sized for growth
-------
(TABLE 10.
COMMENT
CODE PAGE(S) COMMENTOR
MSD-17. 134 Louisville and Jefferson County
Metropolitan Sewer District
MSD-18. 134 Louisville and Jefferson County
Metropolitan Sewer District
MSD-19. 134 Louisville and Jefferson County
Metropolitan Sewer District
MSD-20. 134 Louisville and Jefferson County
Metropolitan Sewer District
MSD-21. 135 Louisville and Jefferson County
Metropolitan Sewer District
MSD-22. 135 Louisville and Jefferson County
Metropolitan Sewer District
MSD-23. 135 Louisville and Jefferson County
Metropolitan Sewer District
MSD-24. 135 Louisville and Jefferson County
Metropolitan Sewer District
MSD-25. 135 Louisville and Jefferson County
Metropolitan Sewer District
MSD-26. 135 Louisville and Jefferson County
Metropolitan Sewer District
CONT'D)
DATE NATURE OF COMMENT
12/03/81 Errata
12/03/81 Upgrading costs for small WWTP
12/03/81 Errata
12/03/81 Interceptor costs
12/03/81 Affects of sewers not sized for
growth
12/03/81 Cost of public water hook-up
12/03/81 Sewered are difficult and costly to
move once they are in the ground
12/03/81 Erratum
12/03/81 Erratum
12/03/81 Financial Impact Analysis
-------
(TABLE 10. CONT'D)
COMMENT
CODE
PAGE(S)
CONMENTOR
DATE
NATURE OF COMMENT
MSD-27.
KYDOT-1,
CRT-1.
SC-1.
SC-2.
SC-3.
SC-4.
SC-5.
WQAB-1.
WQAB-2.
WQAB-3.
WQAB-4.
WQAB-5.
136
138
139
140
140
140
140
140
141
142
142
142
143
Louisville and Jefferson County
Metropolitan Sewer District
12/03/81 Erratum
Kentucky Department of Transportation 11/02/81
Charles R. Tucker
Sierra Club
Sierra Club
Sierra Club
Sierra Club
Sierra Club
Water Quality Advisory Board
Water Quality Advisory Board
Water Quality Advisory Board
Water Quality Advisory Board
Water Quality Advisory Board
12/03/81
12/07/81
12/07/81
12/07/81
12/07/81
12/07/81
12/04/81
12/04/81
12/04/81
12/04/81
12/04/81
Construction coordination
Supports Altnative 7b
Area is polluted from septic systems
Costs of septic tank replacement
Alternative 7b will not remove all
small WWTPs
Alternative 7b does not provide
sewers for future growth
Alternative 7b is not cost-effective
Groundwater Analysis
Future growth; groundwater modeling
Groundwater modeling
Surface water quality analysis
Surface water quality under the pre-
ferred altenative
-------
(TABLE 10.
COMMENT
CODE PAGE(S) COMMENT
H'QAB-6,
143
Water Quality Advisory Board
CB-1.
CB-2.
DNREP-1.
DNREP-2.
DNREP-3.
DNREP-4.
DNREP-5.
DNREP-6.
144 Carl Brown
144 Carl Brown
146 Kentucky Department for Natural
Resources and Environmental
Protection
146 Kentucky Department for Natural
Resources and Environmental
Protection
147 Kentucky Department for Natural
Resources and Environmental
Protection
147 Kentucky Department for Natural
Resources and Environmental
Protection
147 Kentucky Department for Natural
Resources and Environmental
Protection
148 Kentucky Department for Natural
Resources and Environmental
Protection
CONT'D)
DATE NATURE OF CONMENT
12/04/81 Surface water quality modeling and
sampling
12/09/81 Supports Alternative 7b
12/09/81 Aquifer characteristics
02/23/82 Supports Alterntive 7c
02/23/82 Notes comments of Water Quality
Adivisory Board
02/23/82 Disinfection does not remove nitrates
02/23/82 Groundwater users will not connect to
public water supply
02/23/82 Public health problems remain
02/23/82 Errata
-------
(TABLE 10.
COMMENT
CODE
PAGE(S)
COMMENT
DNREP-7.
148 Kentucky Department for Natural
Resources and Environmental
Protection
DNREP-8.
148 Kentucky Department for Natural
Resources and Environmental
Protection
DNREP-9,
148 Kentucky Department for Natural
Resources and Enivronmental
Protection
DNREP-10.
DNREP-11.
148 Kentucky Department for Natural
Resources and Environmental
Protection
148 Kentucky Department for Natural
Resources and Environmental
Protection
DNREP-12.
DNREP-13.
DNREP-14.
149
149
Kentucky Department for Natural
Resources and Environmental
Protection
Kentucky Department for Natural
Resources and Environmental
Protection
149 Kentucky Department for Natural
Resources and Environmental
Protection
-D)
DATE NATURE OF COMMENT
02/23/82 Small plant discharge limitations
02/23/82 Subsurface discharge may not be
permitted
02/23/82 Primary sludge disposal is not
addressed
02/23/82 Local policy on septic tanks
02/23/82 Erratum
02/23/82 Construction grant priorities
02/23/82 Rising groundwater level
02/23/82 Maintenance of septic tanks
-------
(TABLE 10. CONT'D)
COMMENT
CODE PAGE(S) COMMENT DATE NATURE OF COMMENT
DNREP-15. 149 Kentucky Department for Natural 02/23/82 Impact assessment tables; user
Resources and Environmental charges.
Protection
-------
TABLE 11 .
1.
2.
3.
i
0 4.
1
5.
6.
7.
8.
9.
1C.
State Historic Preservation Office
U.S. Army Corps of Engineers
A.B. Schlatter
Dorothy H. Hardesty
U.S. Department of the Interior
Centers for Disease Control
Louisville and Jefferson County
Planning Commission
Anonymous
Jefferson County Environmental
Policy Office
The League of Women Voters
11.
Louisville and Jefferson County
Metropolitan Sewer District
SUMMARY OF WRITTEN COMMENTS
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-------
12. Kentucky Department of Transportation
13. Charles R. Tucker
( 14. Sierra Club
(-•
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<» 15. Water Quality Advisory Board
16. Carl Brown
17. Kentucky Department for Natural
Resources and Environmental Protection
(TABLE 11. CONT'D)
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fih
HERITAGE
October 28, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
MS Courtland Street, N,E.
Atlanta, Georgia 30365
Dear Mr. Ragan:
The Kentucky State Historic Preservation Office has reviewed the
Draft Environmental Impact Statement for the Mill Creek Area of Jef-
ferson County, Kentucky. Our review Indicates that the Mill Creek
Draft EIS Is not in compliance with the national Environmental Policy
Act of 1969, the National Historic Preservation Act of 1966 and Execu-
tive Order 11593. My comments are as follows.
The Draft EIS does not identify properties listed in or eligible for
listing in the National Register of Historic Places within the study
area. Historic properties currently listed in the Register within the
project study area include the Pusey-Aydelotte House (6814 Bethany Lane),
the Farnsley-Mourman Bouse (10900 Lower River Road), and Lewiston Place
(4902 Ranchland). In addition, the following six properties within the
study area are Included in a Multiple Resource Nomination that has been
approved by the Kentucky Historic Preservation Review Board but has not
yet been approved by the Keeper of the Rational Register: the Famsley
Bouse (4816 Cans Rim Road), the Fenley House (5300 Block Raybura Road),
the Jones House (7998 Valley Station Road), and the Waverly Hills
Tuberculosis Sanitorlum, Annex, and Staff building at 8101 Dixie Highway.
Also within the study area but not Identified in the Dtaft EIS are 19
historic buildings listed In the Survey of Historic Sites in Kentucky.
It cannot be determined from the Draft EIS if any of these properties will
be effected.
O
VO
1
SHPG-1
SHPO-2
The treatment of known or potential archaeological resources within
the study area is also inadequate. Four recorded sites are figured in the
Draft EIS. An informal check with the Office of State Archaeology at the
University of Kentucky indicates that as many as 130 recorded archaeological
sites may lie within the project study area. While a number of these have
been determined eligible or not eligible for listing in the National
Register of Historic Places, most have not been evaluated for their potential
significance.
THE KENTUCKY HERITAGE DIVISION THE STATE HISTORIC PRESERVATION OFFICE FRANKFORT. KENTUCKY 40*0! 502 564-9076
SHPO-1. Conwent incorported in revisions to the draft fl$; see
Section 3.2.6.
-------
ffil
HERITAGE
Mr. John E. Hagan, III
October 28, 1981
Page 2
The Draft EIS states that no known archaeological site will be
effected, but no docuaentation Is provided to support this statement.
The Draft EIS also Indicates that undiscovered sites nay be effected,
but It does not appear that a professional archaeological survey was
conducted to Identify such sites.
In the discussion of Impacts and mltlgatlve Measures for cultural
resources, the Draft EIS suggests that any negative lopacts could be
mitigated by allowing for archaeological Investigations during con-
struction to Identify sites and for further investigation of any dis-
covered sites. This recommendation Is not In compliance with the Advisory
Council's Roles and regulations for the Protection of Historic and Cul-
tural Properties (36 CFR, Part 800).
It Is ay opinion that an archaeological survey should be conducted
by a professional archaeologist to determine if any archaeological sites
listed in or eligible for listing In the National Register of Historic
Places will be effected by the proposed wastewater facilities. If it Is
determined that National Register listed or eligible sites will be effected,
EPA should In consultation with the State Historic Preservation Officer
determine effect and, if necessary, request comments from the Advisory
Council on Historic Preservation. The Final Environmental I^act State-
ment should contain documentation supporting either 1) a determination of
no effect or no adverse effect on cultural and historic properties and a
record of coordination with the State Historic Preservation Office and
Advisory Council, or 2) when adverse effect has been determined, an
executed Menorandum of Agreement or the coaaents of the Advisory Council
and an account of actions to be taken to respond to these comments.
Sincerely,
(Mrs.) Anne Armstrong Thompson
Preservation Director and Deputy
State Historic Preservation Officer frwoNM-< iMf Atf >fAMrik
AAT:TNS/pa
cc: Hr. Don Kllaa
Advisory Council
on Historic Preservation
THE KENTUCKY HERITAGE DIVISION THE STATE HISTORIC PRESERVATION OFFICE
HIWqIIOT rK?Jj"
l'- :;;.'V0 2i0?i ji.
fti u'iin /v n a
FRANKFORT, KENTUCKY 40(101 502 544 8076
Hro-2. A detailed archaeological survey is inappropriate at
this time due to the preliminary nature of the intorcpptnr
routes. Archaeological surveys wi 11 le r.ia-je a const ru-: t ion-
grant condition for specific interceptor routes.
-------
DEPARTMENT OF THE ARMY
LOUISVILLE DISTRICT. CORPS OF ENGINEERS
P.O. BOX 68
LOUISVILLE, KENTUCKY 40201
OKLPD-S
NOV 9 I98t
Mr. John E. B&gaa lit, P.K.
Chief, BIS Branch
BP A, Region IV
345 Courtlaad Street, U.K.
Atlanta, GA 30365
Dear Hr. Hagan:
Thank you for Che opportunity to coaaent oa the Draft Environmental Impact
Stateaent oa the Mill Creek Area which addressea proposed wastewater
facilities for Southwest Jefferson County, Kentucky. He would like to submit
the following eoaaents:
M
I
a. The study area la within the protection of the Southwest Jefferson
County floodwall. Please note tin attached data sheets. More data for the
flood protection works baaed on the sheets could be furnished.
C0E-1 b. Page 1-9, Hydrology and Hater Quality. The history of surface
drainage should be prepared aa per Inclosed history froa "bower Mill Creek
Drainage Study* dated 1965 prepared for Louisville and Jefferson County
Metropolitan Sewer Dlatrlct by Haselet and Erdal,
C0E-1. Comment incorporated 1n revisions to the draft EIS;
see Section 3,2.4.
COE-Z
c. Page 1(7t Paragraph 4.3.5, Bousing and Population. Influence of
|future flood protection on future population should be addressed.
d. Page 117, Paragraph 4.3.6, Land Dae. Influence of the flood hazard on
land use atould be mentioned.
I e. Page 176, Significant Agricultural Land, It should be noted that with
C0E-31 the completion of the flasd protection works now under construction, the prlwe
(farmland discosaed will tie longer be In the 100-year flood plain.
Sincerely,
3 Incl
Ab stated
^\y>
C. E. BASTOURN
Colonel, Corps of Engineers
District Engineer
•—SSS""-•
W; \
COE-2. Land use, housing, and population projections were taken
froia information provided by the Louisville and Jefferson
County Planning ciranrission and HSO, which already assuNS
flood protection in-place.
COE-3. Consent incorporated in revisions to the draft E1S-,
see Section 3.2.5.
Jj£)ibU v; -*<-
"ptGlON W **
-------
SOUTHWEST JEFFERSON CO..KY. F/C 228-2
NJ
I
SOUTHWEST JEFFERSON CO.. KY. F/C 228
CIO*?'
AEMAL VIEW Of PROJECT SITE
J
-------
SOUTHWEST JEFFERSON COUNTY F/C 228-3
SOUTHWEST JEFFERSON COUNTY, KENTUCKY
Condition of Imprommnt, 30 September 1979
LOCATION: In Southwest Jcffenon County, Kentucky, on the left bank of the Ohio Rjver directly downstream
float iMiiailk. Ctatwky.
AUTHORIZATION: The project was authorized by Flood Control Act of August 1968.
PtQItCT FEATURES: The project cousins of 68300 feet of levee, 1,550 feet of conctete wall, four pumping
plants, drainage structures, fm nmabk tknam and other Accessary appurtenances. Top elevation of the protec-
tive works varies from 459-8 to 4SS.Q
The Southwest Jefferson County area Ins a population of S2JU0 residing or Working in the flood area. The line of
protection extends from mite 616.0 uprtrean to mile 628.6 downstream Ohio River. The project affords protec-
tion to 24,100 acres of Southwest Jeftenon County against floods equal to the maximum to record elevation
455.0 in January 1937 with freeboard of three feet.
' MOGIESS: fnglsMTriut and design studies continue. Const met ion of Levee Section 1 was started in October
1973 and is complete Contraction of Levee Section 2 was started in August 1976 and is complete. Construction
t.\ of Levee Section 3 started in February 1979, and Riverport and Lower Mill Creek pumping plants started in June
1 1979.
COST DATA:
Est touted Federal Cost (I979X J54.100.000
Estimated Nonfederal Cast IIW) 9,420,000
Estimated Pn^ect Cost (1979) 63,520,000
Federal Costs to 30 September 1979 13017,108
Federal Net Allotments to 30 September 1979 13^37,473
History
Nistorirally. the area dealt with in this report has
t*t« poorly drained. When the •hit* nan ftrst etat
to this area there sere no aaior drainage channel!.
rather the area trat covered by a auaber of large ponds.
For instance, the (treaa ae call (lack Pond Creek.
•hick is onr 100 Tributary area, mat af one time a
«reat. pond SOO feet or so in width and three ta
four ailes in length. fSee Exhibit 21 far a reproaar-
tlon af an 1179 aap ilitffng this pond' Mnnerous other
ponds existed in audition to this one.
Then, as this area began to deuelop. the loner Mill
Creek ai ae know it today oro inert an area which ia.
c laded the area of Shiweiy and vital is noa referred
to as fpper HHI freeh. above the Henry fatttrsom
Expressway nnd anst af Dixie Highway. According to
the nap of 1179. a connection fron Hill Creek to the
Mil liner existed at that tine on the present aliga-
aent af farrison Pitch. In abont 1913. the Hill
Creek Cntaff nas constructed so that the Upper Dill
Creek drained Into this Mill Creek Cutoff and thence
into the Ohio finer, then the fioodaall nas bailt ia
the 4 MM"*. the stream known as fig Run was rerouted
fron Its connection to Upper Mill Creek directly into
the Mill Creek Cutoff outside the floodwnll. The nain'
channel 0/ loner Mill Creek was improotd and straight-
ened fron its original alignaent in about 1927. as can
be eeen in looking at aerial photographs or the naps.
It see has a good alignaent. fairly straight aith only
a few curves. and does not wander as nould a typical
itream in the flood plaint. At the tine of these in-
proueaents. easenents aere obtained throughout aost
of the length of lower Mill Creek.
-------
A. B. SCHLATTER
7329 St, Andrews Church Road
Louisville, Kentucky 40214
November 19, 1981
John £« Hagan III
Chief of EIS Branch, EPA
345 Courtland St. N. E.
Atlanta, Ga. 30365
I
Dear Siri
I recently read a newspaper article in the Louisville Courier*
Journal concerning the sever extension lines proposed to be built by the
Metropolitan Sewer District (see enclosed copy).
In this article Mr* John Tierney, a spokesman for M.S.D. said the
EPA has aade financial assumptions about the project that may not materialiae.
ARS 1 |^°e these is that H.S.D. will be able to acquire existing, privately-owned
I treatment plants at no cost.
This assumption is of great interest to me, as I am a partial owner
of three sewage treatment plants that may be affected by this expansion. They
ares Fairhaven Sewage Treatment Plant located along Southern Ditch,
fordhaven Plant and Forest Hills Plant located along Big Run.
ABS-2
Would you be so kind as to write and tell me if any or all of these
plants are being considered for abandonment?
It Is very Important to me to know the future plans of EPA and M.S.D.
Please respond.
Yours truly,
Ub,J-3,
A. B. Schlatter
AfiSslc
fmw.;/; • el
I
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'P?
Homeowners
applaud new
sewer plan
ftyjni DETJEN
Ha* Writer
To people living tn southwest Je*
Jersoa Cwmty, ifs * welcome rette^
To 'csinfy sewer offlrtaly if*
.MiUe6 wim qacsttooaMe aannik
iadivcmaqriMnotDdamtl
g.tferpat to gadeffiuuad water sop'
^KaoWectof debate. last Bttw
«*¦ fN UA EpitawMlal Protoc.
fm At»cyVjcal«»-dow» propoaa|
far Wdk| man la Ik. auitkwest-
pert ft ttt.oaatt,
AIM Ttpeoiae attended M
kearlaf at Pleksan Ridge Park
lD0»S?kq°l..aBd a daaeaepoka. Tka
rtsliiiiriiliwlH ka wad by tka EPA
to draw up a' Oaal racooimeadatSoa
Bta| (¦ es^ectedta February.
EPA's Mail version. known aa
HAlteraatt™ 7k," calls tor a limited
¦bw| .*emeifW" lo pay up. |o
OSM tack lokook on W «-
V.Tke 1174 ptaa generated Bam
from koaeowners la VaK
fcr &atloa and.PIeasure Ridge Park
vk» aaid II insbl indid.
Lastalckt EUaor "¦•<»« of tU»
Betkaoy Lane, aid, *Oq bekalf of
Ike CojtkpeK Bobwowmis fiiaod-
tUaaj we ikinl yon Jar suggesting
7k. ¦
tier: Xeeilnfs were eckoed'by
many residents who said tb* EPA
todllaallyllfleaedlowkattkeykad
keen aaytnj all alone.'
for the Metropoiltaa Son Dtatrtct.
nM tke EPA kaa made Itoieartsl ¦»
sumptions akool Ike prefect that
may not materialize.
Some of Ike mmnrttons are that
USD will be able to raise Ik rates
wbea^ver necessary, tfcat EPA's
promise to pay 7» percent of coa-
atractioo costs wM, roaflnnr. and
Mat ITSDwtH keabie.to acqatr* ex-
isting treatment ptaats at me cost.
Tleniey called lor a aew cooipre-
kenstve piaa to determlae sikal klad
of aepers* an aeeded 'at a dap
wkea federal funds are betof skara-
ly reduced.
"We betleva tke aadre —«i-
ty akouM decide" once and for *B
wteEket or «ut tt vasts a severe-
panaloaprocram. aad tf to. what Ike
. Bob Graaae'ef tka EPA Mfks la
Atlanta aald tut e*m tkpafk Jeder
if fkada (or aewen kave keea great-
ly iait badr |ie bellow EPA's fund-
Ja( «f aew aewan wiu rnatlaaii at
dsa( tke Mde Bilk way autamer-
jkl eaaVor- It wo«ild connect is
imalt arvace^reatment piano to tke
system and allow the ana's 17.000
kwnaiiwtiri to continue urfageep-
Ue taaka
O-'Tkat alteimqse. Is a (natty n-
rtsed rerskia it a 1(74 plu lor a
- system tkat mold have re-
Patncia wijswsla. a apotesma^
Coeoty> Health Dtpartaiat, said re-
cent reports ka
-------
Noveaber 20, 1981
Mr. John E. Hagan, III
Chief of BIS Branch
EPA
345 Court land Stmt N.E.
Atlanta, GA 30365
Ui
t
DHH-1
Dear Mr. Bagan:
He want to atatc our need TOR itvtrt. He are a large family
residing at 10006 Horthrldge Court, Louisville, CT 40272.
For yeara we have not been able to do laundry or uae water aa
desired.
Anyone who realdea in our area and says we don't need sewers,
doesn't have a working noee.
Please listen to the RX'i too.
Sincerely,
¦esty
Lfl'.!
DHH-1. Residences In Prairie Village are included in the Pond
Creek service area, which is not part of the EIS study
area. The Pond Creek sewer system is currently under
construction.
ttSEt.'Jl
.... I;-1
l9i!l
-------
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
Southeast Region / Suite 13&4
Richatd B. Russell Ftdttak lulittm
75 Spring Street, S.W / Atlanta, Ga. 30303
ER-81/1985
November 23, 1981
Mr. John E. Hagan, III, P.E.
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Sir:
i
D01-2
Ue have reviewed the draft environmental statement, Mill Creek Area,
Jefferson County, Kentucky, and have the following contents.
The proposed project will not adversely affect any existing, proposed,
or known potential units of the National Park System, or any local
OOI-] recreation areas of our Mandated interest or Jurisdiction. Ue note,
however, on page 113, that school-related recreation resources would be
affected by construction noise and that local noise regulations will be
enforced.
The statement does not Mention coordination with the State Historic
Preservation Officer (SHPO) specifically relating to this project. We
encourage you to contact the SHPO for a determination of significant
cultural resources in the project area. The Kentucky SHPO is
Ms. Anne A. Thompson, Executive Director, Kentucky Heritage Commission,
22nd Floor, Capitol Plaza Tower, Frankfort, Kentucky 40601 (telephone
502/564-6939). Documentation of this coordination should be Included in
the final environmental statement. Also, should any archeological
resources be found during construction, the contact for emergency
discovery Is the Secretary of the Interior, through the Departmental
Consulting Archeologist, Interagency Archeological Services,
Washington, O.C. 20240 (telephone 202/272-3750).
The stateaent should indicate whether or not Department of the Anqy
permits (Section 10 and/or 404) will be required. Information contained
D0I-3 In the stateaent is insufficient to determine the need for such permits
or the likely Impacts of permit related wurk on fish and wildlife re-
sources. Accordingly, these contents do not preclude separate evaluation
and coments on future permits for the project.
(The statement does not contain an inventory of mineral resources.
Cement, stone, sand and gravel, and clays are produced in Jefferson
County. The EIS should include the above information. For completeness,
DOI-4
Section 5.2.1, page 125, should include a description of mineral resources
as a significant natural resource of the affected environment. Section
5.2.2, page 154, should Include an evaluation of the impact on mineral
resources. If the Impact on In-the-ground mineral resources Is con-
sidered minimal, the draft should contain a statement to that effect.
Mention should be made of construction material committed to the
project.
Thank you for the opportunity to content on this statement.
Sincerely,
James H. Lee
Regional Environmental Officer
DOI-1. Comment noted.
D0I-2. Responses to comments from the SHPO are contained in
this section. Requirements for contact for emergency dis-
covery should be included as construction-grant conditions.
001-3. Any necessary permits will be obtained during design,
when interceptor alignments are more precisely determined.
The need for such permits is probably minimal for the
proposed alternative 7b, because much of the interceptor
follows the highway rather than streams and very few wetlands
are still present in this highly urbanized area.
001-4. The relative commitment of mineral resources required
for the construction and placement of an interceptor
system in an urban area is negligible and will have minimal
impact on in-the-ground mineral resources. The installation
of interceptors will also not preclude the future recovery
of mineral resources. The need to avoid specific mineral
deposits, if any, can be assessed during design when spe-
cific interceptor routes are planned.
ENviwi.r
¦ -1.I iUlfH£Nt
D"-" ('Oi 1951
REGION IV ¦ EPA
-------
(404) 262-6649
November 30, 1981
Mr. John E. (lagan, III, P.E.
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 10365
Dear Nr. Bagan:
We have reviewed the Draft Environmental Impact Statement (EIS) for the Mill
Creek Area, Jefferson County, Kentucky. We are responding on behalf of the
Public Health Service.
He are supportive of any effort to provide setters in an area and minimize
the impacts to surface streams and groundwater. However, we do not understand
the method by which this EIS deals with the Impact to the groundwater in the
Mill Creek Aquifer. We believe groundwater is a very valuable resource and
should be protected to the greatest extent possible.
This EIS stated that the potential for public health Impacts related to ground-
water influenced by septic tanks is tempered by the limited existing and future
use of the groundwater. We know that some 600+ families presently use the
) Mill Creek Aquifer for their private water supply. This is not limited use.
Also, it is possible that future needs might dictate Che need for this aquifer
as an alternate water supply.
This document further states that the selection of seepage pit disposal for
the eight remaining amall treatment plants would Increase the impact to ground-
water quality, and it is anticipated that the Mill Creek Area groundwater will
be unacceptable as an untreated drinking water source under this alternative.
In selecting an alternative for this project, groundwater should receive a
portion of the major consideration.
We believe the selected alternative 7b Is not the best alternative to protect
public health now or in the future.
In view of economics and present finances, we would like to see alternative
7c or some variation of this alternative Implemented. Thus far, there has not
been any major health problem associated with contaminated water in the Mill
Creek Area, but we believe It would be wise to mitigate these possibilities
in the future by planning and encouraging efforts to reduce impacts to ground-
"2 water in this area. Failure to do so would be contrary to good public health
practice. Under alternative 7c, Interceptor lines could be constructed large
enough to provide the capacity for feeder lines from future residential
populations to be accommodated and the sewer lines for the Mill Creek Area
could continue on an "as needed" basis or a progressive course.
Page 2 - Mr. John E. Hagan, III, P.E.
Thank you for the opportunity to review this Draft EIS. We would appreciate
receiving a copy of the final document when it is issued.
Sincerely yours,
Frank S. LI sella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
CDC-1. The groundwater did receive considerable attention in
the EIS, as evidenced by the monitoring program. This pro-
gram found that the groundwater is unacceptable as an un-
treated drinking water source, and that those families now
using that water should connect to the public water supply.
This conclusion is applicable to all alternatives, so the
current public health concern with the groundwater is not
a factor favoring one alternative over another. A re-
gional sewer system, for example, could not be completed
for ten or more years, and the only feasible way to protect
groundwater users within that period would be to connect
then to the public water system.
CDC-2. Alternative 7c, as described above, has no greater
public health benefits in the near future than alternative
7b. Only by connecting groundwater users to the public
water system can ioniediate health concerns be mitigated.
Cost-effective wastewater management planning indicates that
there are other areas in Jefferson County, e.g., Pond
Creek, where federal funds for sewers would have more
immediate impacts on public health problems. The selection
of 7b as the most cost-effective alternative does not
prevent local agencies from implementing 7c or any other
alternative. It does, however, limit federal funding
to the extent available under alternative 7b.
-------
900 Fiscal Court Building, Louisville, Kentucky 40202 502-561-6230
2=2/^
2-561-6230
December 1, 1981
Mr. John B. Hagan, III, P. E.
Chief. EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Subjects Draft EIS - Mill Creek Area, Jefferson County, Kentucky
Dear Mr. Hagan:
CO
I
LJCPC-1
Under State enabling legislation, the Louisville and Jefferson
County Planning Conission is charged with the responsibility of
ensuring 'the lost appropriate, economic, desirable and feasible
pattern" of development in Jefferson County. Such is accomplished
through the Comprehensive Plan for Louisville and Jefferson County,
the Comprehensive Plan Manages growth and redevelopment in a
manner that minimizes-adverse impacts on the environment and
that minimises the cost of providing essential facilities and
services that support development.
Experience over more than thirty years has shown the phasing
of essential facilities and services is essential to the orderly,
economical and environmentally sound developnent of the community.
The provision of public setters is a major determinant of orderly
and economic growth in the community. The failure of public
sewers to keep pace with development in the past has resulted in
the proliferation of package treatment plants and septic tanks.
This has resulted in (1) a sprawl land use pattern with the
attendant high cost of ptoviding essential facilities (e.g.,
roads, sewers, waterlines) and services and (2) the serious
water quality problaa* facing all of Jefferson County. Accordingly,
the Comprehensive Plan manages growth and redevelopment in
Jefferson County by ensuring that development occurs in conjunction
with the provision of adequate essential facilities and services.
Because actions by the U. S. Environmental Protection
Agency have delayed the county-wide extension of public sewers
in an orderly and timely manner and the Mill Creek Area Draft
EIS Preferred Alternative 7b will not adequately serve future
-------
LJCPC-I
NO
I
LOCPC-2
development, the ability of the Comprehensive Plan to manage
growth in an orderly and economical Manner has been undermined.
With the entire 201 Sewer Expansion Program in question, local
government has not been able to direct development and the
developer has not been able to make long-ten financial decisions
about sewage treatment systesw. By default, development has
been concentrated in the Interstate 64 corridor eastward from
the Hatterson Expressway where a regional public sewer system
exists or has resulted in the further proliferation of package
treatment plants and septic tanks with greater environmental
degradation and higher long-term costs for sewage disposal.
Today, Jefferson County is farther away from achieving the
goals of the Clean Water Act of 1972, providing an economically
and environmentally acceptable sewage disposal system and
ensuring orderly growth of the oosmranity, than in 1977. Ignoring
the findings of the 201 Waste Treatment Facilities Plan and the
208 Areawide Waste Treatment Management Plan, the U. S. Environmental
Protection Agency in 1977 reversed its 'negative declaration" of
the 201 Plan because septic tanks might be working in a subarea
of Jefferson County, and disregarded the long-term county-wide
consequences of such an action. Subsequent actions by EPA have
placed a cloud over expansion of sewers in the Pond Creek Area
and construction of the West County Sewage Treatment Plant, and
required an EIS to be prepared for the North County Area delaying
sewer expansion there. Regardless of the outcome of the Hill
Creek Area EIS, the time required by the EIS process has resulted
in the long-term county-wide consequences of a more costly
sewage disposal, continued surface and groundwater degradation
and disruption of an orderly and economical pattern of growth
county-wide. In determining the appropriateness of exempting
residential septic tanks in the Mill Creek Area from hooking
into a regional sewer system, BPA has forced the balance of the
residents and all businesses to bear the increased cost of
public sewers and environmental degradation due to delays in
implementing the 201 Plan in the balance of Jefferson County.
Such long-term county-wide consequences have jeopardised the 201
Sewer Expansion Program and achievement of Clean Water Act
goals, and have undermined the community's Oomprehens1ve Plan.
LJCPC-3
ttte long-term county-wide consequences of EPA's 1977
decisions may be a moot point today; however, the potential
long-term county-wide consequences of the Mill Creek Area EIS
decision are not. The Mill Creak Area Draft EIS basically
ignores the long-term county-wide consequences of exempting
existing residential septic tanks from tieing into the regional
system and of implying that future residences in Mill Creek
should also be exempted according to preferred wastewater manage-
ment Alternative 7b. The exemption of existing and future
residences in a subarea of Jefferson County where a regional
system is available could well establish a precedence that could
result in pressure for exemptions in the balance of Jefferson
-2-
LJCPC-1. Alternative 7b is the most cost-effective management
plan to alleviate current water quality problems in the
Hill Creek area. The EIS decision Is not meant to imderalne
local development planning, but rather to focus the use of
federal sewer funds in the most cost-effective manner,
local agencies may 1lement alternative 7c as a local
decision to serve future development, but federal finds will
be available only to the extent available in alternative 7b.
LJCPC-2. Given progress in the construction of the Pond Creek
sewer system, the design of the West County treatment
plant, and the upgrading of the Morris Forman treatment
plant, EPA does not agree that Jefferson County is further
mt*y now than in 1977 from meeting the goals of the Clean
Water Act. The purpose of the Mill Creek EIS was to
examine sore carefully in one area of the county what
system would provide "economically and environmentally
acceptable sewage disposal." The EIS determined that the
environmental needs in this area are not as great as in
other areas and that a more-limited sewer system can in^rove
surface water quality in a cost-effective way. Implementation
of alternative 7b will save considerable federal and local
funds over what would be spent for a full-scale regional
system.
LJCPC-3. EPA's selection of alternative 7b represents a cost-
effective decision for Mill Creek for the planning period.
EPA does not endorse exemptions from a county policy of
abandoning septic tanks and connecting to regional sewers.
-------
LJCPC-3
LJCPC-4
IJCPC-5
NJ
0
1
County. If it can be proven that septic tanks work on a subarea
basis, it is possible to prove that septic tanks work on a case-
by-case basis in the balance of Jefferson County. This raises
the question of the long-term consequence of a challenge to or
abandonment of the mandatory hookup rule for the balance of the
County outside Mill Creek; such may place the financing of the
balance of the 201 Sewer Expansion Program in question. If the
balance of the 201 Sewer Expansion Program is placed in further
jeopardy, residents and businesses of Jefferson County will be
saddled with even higher sewage disposal and environmental
costs. The fact that sewers will not be sized to accommodate
future development under Alternative 7b means that a balanced
pattern of residential and industrial growth will not occur as
envisioned in the Comprehensive Plan. Without an adequate
regional sewer system, major residential and industrial develop-
ment will not locate in the Mill Creek area where jobs are
needed for low to moderate income people in the area and houses
are needed in proximity to jobs to reduce travel distances. The
long-term consequences of the Mill Creek Area EIS decision are
far more serious and broader than the long-term consequences the
County has already had to endure because of the 1977 EPA EIS
reversal. Perpetuation of an imbalanced land use pattern and of
an inability to manage growth in an orderly and economic manner
will result.
The Planning Commission considers preferred Alternative 7b to
be:
LJCPC-6
LJCPC-7
1) contrary to the 201 Sewer Expansion Program adopted by
local elected officials and EPA in 1974,
2) contrary to the County Sanitary Code by exempting present
septic tank owners from hooking up to future public sewers.
LJCPC-8
LJCPC-9
3) contrary to the County Sanitary Code and the Comprehensive
Plan for Louisville and Jefferson County by implying that
future residents may build septic tanks in the Mill Creek
area, by jeopardizing the phasing of essential facilities
and development in the balance of the County and by perpetuating
an imbalanced future land use pattern, and
4) contrary to the Clean Mater Act of 1972 by allowing continued
pollution of the ground water in Mill Creek and by placing
achievement of Clean Hater Act goals for the balance of
Jefferson County in jeopardy.
We would like to point out that the Federal government has
been historically short-sighted in the design and financing of
of facilities, whether roads, sewers, etc., to accommodate
reasonably anticipated future development and that the ultimate
-3-
LJCPC-4. The Will Creek decision does not jeopardize the balance
of the sewering program. Indeed, by freeing funds that nay
have been spent in Mill Creek for more cost-effective use
elsewhere in the county, the overall costs to the county
may be less.
LJCPC-5. Alternative 7b is the most cost-effective management
plan to alleviate current water quality problems in the
Mill Creek area. The EIS decision is not meant to undermine
local development planning, but rather to focus the use of
federal sewer funds in the most cost-effective manner. Local
agencies m^y implement alternative 7c as a local decision
to serve future development, but federal funds will be
available only to the extent available in alternative 7b.
LJCPC-6. Alternative 7b represents a redirection in one area
of the County of the 1974 Mater Quality Management Plan.
It recognizes tnat at this time federal sewer funds can
be spent in a more cost-effective manner in other parts
of the county,
LJCPC-7. Alternative 7b does not exempt present septic tank
owners from hooking up to future sewers nor does it seek to
pre-empt local prerogative in that policy decision.
LJCPC-8. The decision to allow septic tanks or use local funds
to construct sewers for future growth is a local question
not affected by alternative 7b. Indeed, capacity for future
growth is already available in the existing Black Pond inter-
ceptor.
LJCPC-9. EPA does not agree that alternative 7b is contrary
to the goals of the Clean Water Act. That law has always
recognized the need for planning for cost-effective waste-
water management, and alternative 7b meets that need.
-------
LJCPC-10
cost to correct resulting environmental and facility inadequacies
has been far greater than if the facilities had been adequately
designed at the beginning. The preference of EPA for Alternative
7b reflects a short-term cost perspective of the Federal govern-
ment and not the long-term costs of all involved. At the
present time, it is questionable if EPA can even cover its share
of the cost of Alternative 7b.
LJCPC-11
I
V-*
TO
I-*
I
LJCPC-12
He are also concerned that the Federal government has
required local jurisdictions to prepare 201 and 208 plans for
achieving Federal water quality goals under the threat that
Federal financial assistance in public sewer expansion would be
lost; that local jurisdictions prepared such plans in good
faith; that the local jurisdictions provided their share of the
financing to implement the sewer expansion plan; that the Federal
government has become an impediment to implementing the sewer
expansion plan through delays and funding cuts; and that the
Federal government without altering environmental requirements,
appears to be removing itself from any liability after committing
local government to a dead-end program.
In view of the long-range countywide development, environmental
and economic concerns above, we urge that the regional sewer
system in Mill Creek be designed to accommodate reasonably
anticipated future development even if the initially constructed
system is limited to the area to be served in Alternative 7b and
even if EPA will not presently participate in the additional
cost of a larger sized facility. The attenuated version of
Alternative 7c (limited regional system) suggested by the Louisville
and Jefferson County Health Department on November 17th is
consistent with our view point.
We feel that some variation of Alternative 7c according to
the area served has the following advantages over Alternative
7b:
(1) Existing residences in Mill Creek would not receive public
sewers because such would not be built to the area and not
because EPA exempted existing residential septic tanks from
hooking into a regional system. This would avoid the
appearance of exempting residences under the County Sanitary
Code; and thereby, avoid the question that a precedence for
exemption from mandatory hookup may be established jeopardizing
the regional system in the balance of the County.
(2) Enabling future development to tie into the regional system
consistent with the County Sanitary Code and Comprehensive
Plan such that county-wide land development goals and
objectives may be achieved relative to balanced growth and
to the orderly, environmentally sound and economical phasing
of growth with essential facilities throughout the County.
-4-
LJCPC-10. Federal funding of sewer projects under the Clean
Water Act has always been recognized as a short-term effort
to "catch up" in pollution control and not a long-term
commitment to fund future growth. EPA cannot change the
objectives of the Act nor guarantee future funding levels;
responsibility for both rests with the Congress. The State
role in setting priorities for funds will also affect the
level of funds for the Mill Creek area.
LJCPC-11. The sewer-expansion plan for Pond Creek has not been
delayed by.this E1S. The sewer-expansion plan for lill
Creek was found not to be cost-effective, and to that
extent EPA "has become an impediment to implementing the
sewer expansion plan." Such an impediment is clearly
justified by EPA's mandated role to provide cost-effective
planning. Furthermore, the impediment does not prevent
local funding of the sewer-expansion plan.
LJCPC-12. The decision to design for alternative 7c is a local
decision. EPA will provide federal funds only to the
extent that they would be available under 7b.
-------
UCPC-12
Ni
hO
I
LJCPC-13
(3) Enabling the extension of the regional system to handle
existing residential septic tanks should EPA reverse its
decision about continuing to permit ground water pollution
in Mill Creek.
<4) Enabling the extension of the regional system to handle
existing residences should the residences of Hill Creek
change their minds, no matter how remote such seems today.
Yet, avoiding the extension of public sewers to those who
don't want them in Mill Creek.
In conclusion, we do not feel that the majority of the residents
and businessmen of Jefferson County should bear the adverse
economic and environmental costs for a minority in Mill Creek.
Accordingly, we ask that EPA give due consideration to the long-
term county-wide development, economic and environmental consequences
of a decision in the Mill Creek area. That is a decision not
to extend public sewers to existing residences on septic systems
in Mill Creek should not establish a precedence for future
development in Mill Creek and the expansion of sewers in the
balance of Jefferson County.
Sincerely,
ftt-Bo bsrt V. Bowman
g Executive Director
KfB/tb
cc: Planning Commission
David J. Mansen, Chairman, Hater Quality Advisory Board
Bruce K. Lane, Director of Division of Environmental
Health, Department of Public Health of Louisville & Jefferson
County
Jack J. Wilburn, Executive Director, Metropolitan Sewer
District
£Nv1ROK«rMAi,MPAcl mmm
^¦CSEBnnrpnj)
¦¦¦-I'i'W iv ,
LJCPC-13. The financial inpact analysis showed that there was no
adverse economic impact on the rest of Jefferson County from
any of the alternatives. Shifting funds from the Mil J Creek
area to other areas with greater environmental need will
hasten the provision of sewers and provide environmental
benefits for the nest of the county. Future development in
Hill Creek and the future provision of sewers are local
questions.
-------
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-------
Hitch McConntU, County Judge/Executive
JEFFERSON COUNTY ENVIRONMENTAL POLICY OFFICE
Donald J. Ridings, Secretary
400 Old Louisville Trust Building ¦ 208 South Fifth Street • Louisoilk, Kentucky 40202 ¦ (502)531-5941
December 2, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Subjec t:
NJ
JN
JCEP0-1
JCEP0-2
Written Comments Regarding Mill Creek Area
Draft Environmental Impact Statement
Dear Mr. Hagan:
Some 84 months ago, a sewer expansion plan for Jefferson
County, Kentucky was completed under Section 201 of the
Federal Water Pollution Control Act. This Plan was designed
to bring the County's streams and groundwater into compliance
with this federal act.
Some 76 months ago, the Environmental Protection Agency
(EPA) approved this 201 Plan for Jefferson County, stating
that no Environmental Impact Statement (EIS) was required.
Some 50 months ago (26 months later), EPA reversed this
original decision and stated that an EIS was to be prepared
for the Hill Creek, portion of the Jefferson County Plan.
This reversal was made despite the fact that the Kentucky
Attorney General had issued a statement that, in his opinion,
all laws and regulations had been complied with during the
preparation of the Plan, and despite the fact that a court
suit filed by a local group of homeowners requesting an EIS
was ultimately dismissed.
During initial meetings with various local agency
representatives, EPA offered assurances that the community
would not have to pay more for sewers as a result of the EIS.
EPA also stated that the EIS would take between 18 and 24
months to complete.
Some 50 months after EPA announced that an EXS was to
be prepared, a public hearing has been held on the draft
EIS document. This letter regards that document.
JCEP0-1. The opinions of the Kentucky Attorney General are not
binding on EPA, nor does his approval of the 201 planning
process prevent EPA from further study of a small portion
of the 201 study area. The court suit was not dismissed
until one year after the EIS was begun, and part of the suit
was dismissed without prejudice, i.e., it was not "ripe
for adjudication" because the EIS was underway. The suit
could be re-instituted once the EIS is completed.
JCEP0-2. The proposed alternative 7b represents a cost savings
over the original regional sewer system. The duration of the
EIS has been increased by several unforseen events, including
local requests to include the entire County in the EIS and
to prepare a detailed financial impact analysis and the
need to conduct an intensive environmental sampling program.
-------
Mr. John E. Hagan, III, P.E.
December 2, 1981
Page 2
JCEPO-3
Five major points need to be made in response to the
draft Mill Creek Environmental Impact Statement.
First, EPA's financial impact analysis (Appendix A of
the EIS) states as one of its significant findings" that,
"Mill Creek activities had no noticeable affect on either
MSD's (Metropolitan Sewer District's) revenue requirements
or projected MSD customer service charge." This finding
ignores the real facta.
During the 50 months that EPA has taken to prepare the
draft EIS, the construction cost index, as published by the
Engineering Hews Record, has Increased by 40.3%. Any
JCEPO-4
JCEPO-5
suggestion that the financial resources of government, at
any level, or of Jefferson County residents have kept pace
with this index is ludicrous.
At the federal level, the final Carter budget contained
$90 billion for sewer construction grants. Congress is
currently considering legislation to slash this amount to
$24 billion, and recent articles in the local newspaper state
that the federal Office of Management and Budget is now
proposing to cut this amount to $10 billion over 10 years.
Certainly the federal financial picture for sewer construction
has been devastated during this 50 month period.
Changes that have occurred over 50 months in state and
local government finances are no less bleak. Kentucky state
government has cut millions of dollars from its budget.
Local governments in Kentucky now operate under a celling of
4 percent annual revenue Increases.
As with government, personal disposable income has also
failed to keep pace with the inflated cost of sewer construc-
tion over this 50 month period. In fact, recently released
Census Bureau statistics show a decline in the median family
income between 1979 and 1980 of 5.5 percent when adjusted
for inflation.
The draft EIS fails to directly address what constitutes
the real financial impacts of this 50 month delay in Jefferson
County's sewer expansion plan.
Second, the draft EIS recommends that 17,000 residences
retain their septic tanks and seepage pits rather than hook
onto sewers. This Environmental Protection Agency recommenda-
tion protects everything but the environment. It protects
the pocketbooks of residents in the area. It protects EPA's
sewer construction grant monies. It does not protect the
groundwater under Mill Creek, as evidenced by EPA's own
groundwater sampling program.
JCEPO-3. The financial impact analysis concludes that the extent
of construction activities In Hill Creek will have no
noticeable effect on MSD or its customers. Mo analysis has
been made of the effect of the planning activities of the
EIS on the real costs of providing sewer service.
JCEPO-4. EPA does not dispute the fact that construction costs
have inflated over the course of the EIS. Building now
just to avoid inflated costs in the future is seldom, if
ever, good public policy. The EIS was conducted to determine
the most cost-effective wastewater management plan for the
Hill Creek area. The EIS concludes that alternative 7b pro-
vides that cost-effectiveness at a cost much lower than that
of a regional system, in constant, current dollars. Wheth-
er the local governments' financial situation is better or
worse with the later, smaller system 1s moot. The financial
impacts of a 50-month delay are not pertinent to the se-
lection of a cost-effective alternative, because the Impacts
are common to all alternatives in the future--"what is done
is done."
If anything, the recent decreases in personal dispos-
able income and local revenues (1n real dollars) emphasize
the need for cost-effective planning to ensure that limited
public funds are committed to those projects where they do
the most good.
JCEP0-5. The purpose of an EIS is to find cost-effective manage-
ment solutions, i.e., to balance socio-economic costs and
environmental benefits. The Hill Creek EIS concludes that
alternative 7b produces the best balance. Certainly pro-
tecting "the pocketbooks of residents in the area" 1s a
concern to EPA as, presumably, it is to the local govern-
ment. Under alternative 7b, as well as all other alter-
natives, the groundwater 1s usable as a treated drinking
water source.
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Mr. John E. Hagan, III, P.E.
December 2, 1981
Page 3
N3
I
Third, the EPA recommendation appears to be more
political than technical. Consider the facts. EPA spent
thousands of dollars and numerous months to test groundwater
in the Mill Creek area. These tests identified that the
aquifer is polluted by septic tanks and seepage pit3. EPA
JCEPO-6 then decided that polluting the groundwater is not that big
of a deal. It occurs to us that we could have saved thousands
of tax dollars and months of time by not testing the ground-
water, since EPA has ultimately decided to write off the
aquifer anyway.
Fourth, EPA's recoemendation that the septic tanks and
seepage pits be retained in the Mill Creek area offers
credence to the notion expressed by numerous residents that
their septic tanks are "working." Throughout Jefferson
County outside of the Mill Creek area, septic tanks typically
empty into lateral fields. When these lateral fields fail,
sewage effluent often seeps to the surface creating substan-
tial health and aesthetic problems. Unlike the lateral
JCEPO-7 field overflow problems, the seepage pits in Mill Creek dump
the sewage effluent straight into the groundwater where it
cannot be seen or smelled. Unfortunately, the philosophy has
therefore become, out of sight, out of mind. EPA's recommenda-
tion clearly adheres to this philosophy.
The real losers, in the long run, appear to be the
residents in the Mill Creek area. Unlike other pollution
problems, groundwater pollution remains extremely localized.
The current residents and future generations living in Mill
Creek can now look forward to living on top of a polluted
aquifer for years to come.
Fifth, EPA's recosmendation is totally at odds with the
Reagan administration's push for economic and industrial
recovery and expansion. Fifty months ago, federal 201 con-
struction grants could be used to build sewers to serve
JCEPO-8 industrial development. EPA is now suggesting, in a figurative
sense, that a new Ford or Toyota plant located in the Mill
Creek area should be placed on a giant septic tank. While
possibly humorous in concept, the real situation is deadly
serious in terms of current unemployment rates and the
national and local recessions and layoffs.
In stannary, we find the current EPA position on the Mill
Creek EIS as strictly punitive in its effect. It has had and
will have devastating effects on:
JCEPO-6. It Is not clear how this decision could be construed
as being political. The purpose of the groundwater moni-
toring program was to determine the extent of pollution in
the aquifer. The results indicate that the groundwater is
extensively influenced by septic-tank discharges, but it
is still usable as a treated drinking water source. EPA
has neither the authority nor the intention of "writing-
off" the aquifer.
JCEPO-7. The EIS is not a county-wide endorsement for septic
tanks; the EIS selected alternative is the cost-effective
solution for the Mill Creek area.
The overwhelming evidence from public meetings and the
public hearing is that the residents of Mill Creek do not
consider themselves as "losers" with alternative 7b as the
proposed action.
JCEPO-8. The Slack Pond interceptor has capacity that could be
used for an industrial connection, although federal funds
would not be available for that purpose. The local govern-
ment can provide other sewers for industrial users if they
prefer. Insofar as the reconmendations being at odds with
the President's "push for economic and industrial recovery
and expansion," the President's February 1981 Economic
Recovery Program message Included the follotting language
concerning the reform of EPA's construction grants program:
"legislation will concentrate the program on treatment pro-
jects that directly enhance the quality of receiving waters.
Projects, or features of projects, that do not result in
direct environmental improvement, or which focus on future
community growth will have to be built, if At all, without
Federal assistance. Examples of project; that would no
longer be eligible for Federal funding include new inter-
ceptor sewers, the funding of capacity to meet future
population projections, and collection sewer systems that
contribute to urban sprawl and have a marginal impact on
water quality."
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Mr. John E. Hagan, III, P.E.
December 2, 1981
Page 4
II. The County'8 financial ability to sewer Che
remainder of Che CounCy.
!2. The County's efforts to clean up its streams and
groundwater in compliance with the federal Uacer Pollution
Control Act.
lrcim nl 3. Area residencs and future generations in the Mill
|Creek area, in the long run.
JCEPO-12
JCEPO-13
4. The County's efforts to provide employment
opportunities for its citizens who are currently faced with
severe economic times.
We urge EPA to reconsider its current position regarding
Mill Creek. Should the current EPA position stand, we urge
EPA to work with Jefferson County to overcome the punitive
effects of this EIS process. For example, we suggest that
EPA consider accelerated and increased funding levels for
construction of the remainder of the 201 Plan to compensate
for the substantial financial burden that has been placed
on the County during the 50 month preparation time for this
Mill Creek EIS.
Yours truly,
David J. Mansen, Coordinator
through -
Donald J. Ridings, Secretary
DJR:DJM:bmc
County Judge/Executive Mitch McConnell
Commissioners Brown, Malone and Hatson
Senator Walter Dee Huddleston
Senator Wendell Ford
Congressman Gene Snyder
Congressman Ron Mazzoli
Charles R. Jeter, Regional Administrator, EPA Region IV
Secretary Jackie Swigart, Kentucky DNREP
Water Quality Advisory Board Members
Senator Robert T. Stafford
Congressman Toby Moffett
ENVIRONMtNIAl IMPACT STATEMENT
BRANCH
SraEELQE
S DEC 04 1981
Iktoiyju is
REGION IV EPA
$
JCEPO-9.
Results of the FIA do not support this conclusion.
JCEPO-10. The County's efforts to clean up its streams is pro-
ceeding (e.g. Pond Creek interceptor, West County WWTP, the
EPA-MSD agreement on the Morris Forman WWTP).
JCEP0-11. The EIS anticipates no long-term adverse impacts to
area residents.
JCEPO-12. The proposed action does not interfere with local
development planning for the future.
JCEPO-13. EPA does not agree that a "substantial financial
burden" has been placed on Jefferson County nor that the
EIS has "punitive effects". Alternative 7b has the effect
of directing limited federal and locals funds to those
areas where they are needed most, i.e., other areas of
Jefferson County with greater environmental problems.
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11& Swlh £im»| Awn • Loaiwifc. Kaattfcky 4I2M • ftiMM: (M21 MS-UU
JH*$eamee c£ fyifomwi
* DF LOUISVILLE AMD JEFFERSON COUNTY
December 3, 1981
Attention: Mr. John E. Hagan 111, P.E.
Acting Chief, Environmental Assessment Branch
EPA, Region IV
345 Courtland Street U.S.
Atlanta, Georgia 30365
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
MILL CREEK AREA JEFFERSON COUNTY, KENTUCKY
The League of Women Voters of Louisville and Jefferson County
protests EPA's preliminary decision to recommend that Wastewater
Management Alternative 7-B be selected for the Mill Creek Area as
being the optimum oourae of action for our community. Financial
feasibility and cost-benefit analysis may indeed dictate that no
present action be advised for the current on—site systems of the
residential community. With mors severe sewage problems demanding
attention elsewhere in the community, and with the purchasing
power of committed local and federal dollars now severely eroded
by time delays imposed by the B.I.S. process, it would be impru-
dent to recommend mora than a limited course of corrective action
in the Mill Creek Area.
However, prudence would indicate that an option ought to be main-
tained by this conaunity which would allow for some future exten-
sion of a general wastewater collection system in the Mill Creek
area should, for example, rising fround water cause current septic
tank systems to fail. It would seem prudent, also, to maintain
the option of being able to preserve and purify an important
natural resource in our community, the Mill Creek area aquifer,
l\ source of drinking water for 300 to 600 families.
•1
The Louisville League does not take lightly any decision by BPA
which would have the effect of institutionalizing pollution of an
important natural resource of this community. Alternative 7B would
-------
LWV
-1
LWV
-2
LWV
-3
require that pollution remain - and increase - for many decades
beyond the twenty year projection of the Mill Creek EIS. Since
7b would ensure increased pollution to the aquifer from untreated
domestic sewage, EPA's decision to support an unmodified Alternative
7B night make it more difficult to protect the aquifer from in-
dustrial discharges in the future. The aquifer should not be
considered an appropriate perpetual repository for wastes.
The League recommends (1), that EPA specifically explore the financial
feasibility of a limited action plan which would address the most
pressing needs of the area, and secondly would install a large enough
interceptor system. Package treatment plm ts and septic tanks which
are causing underground pollution could thus be replaced, if necessary
The Louisville - Jefferson County Board of Health supports this
position.
We are particularly concerned that 18 of the package treatment
plants slated for removal in 7B,represent only 54.5% if the total
33 package treatment plants- Thus, over half of the 15 plants left
in the area will be larger plants, plants which are designed to
discharge 3,000 to 500,000 gallons per day. Even the smaller plants
have an unhealthful impact on our streams and were never considered
more than a temporary expediency in our community. We are disturbed
by the recommendation that these plants be transformed into permanent
fixtures - however upgraded - with no future hope for their removal.
The Louisville and Jefferson County League of Woman Voters asks that
spa not r-«ifr»qmend any alternatives which would make currant water
pollution permanent, or which would mandate increased pollution.
LWV
^ . Me would like to know what it would cost the community
_^l to reserve for itself an opportunity for clean water
in all surface streams in the Mill Creek Area.
LWV
-5
LWV
-6
LWV
-7
. We would like to know what it would cost to insure a
future opportunity to decrease or to eliminate pollu-
tion in the aquifer.
. Vie would like to know in more exact dollars just how
EPA is defining the worth of our natural resources.
. We are concerned whether EPA's recommendations of
under-sized collectors means that the goals of the
Clean Water Act are now considered to be a local option
available only to those communities able to fund their
own adequate facilities.
Judith Marks, President
Patricia Nightingale, Environmental Quality Committee
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Louisviikr and Juffwson County 400 South Sixth Strict 502 d87 OSOl
Metropolian Sawei District LOuisvilte. Kentucky 4i>i?02
Deceiaber 3, 1981
Mr. John E. Hagan, III, Chief
EXS Branch
EPA Region IV
345 Courtland Street* N.E.
Atlanta, Georgia 30365
Re: Draft Mill Creek E1S
^ Dear Mr. Hagan:
O
I At the Noveaber 17, 1981 Public Hearing on the draft
Mill Creek SIS, EPA vas furnished with a copy ot the
coaaents presented orally by Mr. John Tiemey on
behalf of MSD. Enclosed is a copy of MSD's additional
coaaents.
Yours very truly,
E. M. MyersrP.E.
Assistant Chief Engineer
EMf.PM
Enclosure
cc: Mr. David Hansen (w/encl.)
ENVIRONMENTAL tMHU $!Alfj*tNT
8R*W«
; LViOii
KtUOM IV ti-A
-------
LOUISVILLE AND JEFFERSON COUNTY
METROPOLITAN SEWER DISTRICT
ADDITIONAL COMMENTS ON THE DRAFT MILL CREEK EIS
November 17, 1981
MS 0-1
Approval Page, First Page in EIS
EIS was approved by the Regional Administrator on August 13, 1981, even
though we were still sending the EIS consultant data on the FIA on August 4,
10 and 18, 1981. In fact, the last set of cash flow runs were not sent until
July 30, 1981.
Page ix
MSD-2
The dates listed for the various reports are incorrect. These reports have
been typed in final form (camera ready) but are unavailable (at least not
easily) for review. Only the drafts of each of these reports have been
printed. There are no plans at the present to even print the reports as they
exist now.
HSD-3
MSD-*
Page 1, Last Paragraph, Item 2
One of the concerns of the area residents is "the cost of sewers to area
homeowners would be high ($2,500-$3,000 hook-up plus monthly charge) and
constitutes an unnecessary burden..." The cost is not high for the average
assessment cost, for all MSD assessment projects from September 1976 to June
1981 is only $2,S43 in June 1979 dollars, based on an ENR index of 2984.
Page 5, 1.2.
MSD-5
MSD-6
Reference is made to Figure 2, here and throughout the report, which is
supposed to show the existing small treatment plants; however, it does not
show any. Table 2 also lists 26 small treatment plants but several are not
shown on any figure in the EIS.
Page 16, Table 3
Alternatives 7b and 7c do not list "increased impact to local streams," and
"continual impact to groundwater," as a disadvantage. In fact, "continual
impact to groundwater" is not listed for any of the alternatives which would
allow the continued use of on-site disposal systems.
Page 17, 1.3.3., Third Paragraph
The cost for connecting each house not presently served by LWC has been
estimated to cost from $1,000 to $14,000, with an average cost of $2,000, for
a total of $1.2 million. Who is going to pay? How and by what authority is
anyone going to force residents to hook-up to LWC, even if it is available?
MSD-1. The conclusions drawn In the Financial Impact
Assessment, which was incorporated in the draft EIS, ivere
not changed by the additional Information cited.
MSD-2. Comment noted.
MSD-3. The sentence quoted ends with "since the on-site
systems are functional." The purpose was to characterize
the impact on septic-tank users, not to compare this cost
to average USD assessments.
HSQ-4. Conner*t incorporated in a revised Figure 2; see Section
3.2.1.
MSD-5. Alternatives 7b and 7c do not increase the impact to
local streams. In both alternatives, existing plants will
be removed or upgraded to meet water quality standards and
current levels of impact will be decreased. Because there
is limited potential for public contact with groundwater—
particularly if the EIS neconmendation for connecting all
groundwater users to the public water supply system is
implemented—the influence of on-site systems is considered
minor.
MSO-6. This is a local public health concern that is not in
EPA's jurisdiction.
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Page 45. 3-2.2.. Third Paragraph
USD-7
The word "diameter" is misspelled in the fifth line.
Page 63, 3.3.2.. Fourth Line From Bottom
The word 'dwelling" is misspelled.
Page 66, Penultimate Paragraph
The word "dishwashers" is misspelled.
Page 68. Last Paragraph
The reference to Figure 2 should be changed to Figure 3.
Page 71, Third Line From Bottom
MSD-8
HSD-9
HSD-1C
USD-11
The word "cost" should be plural.
Pafle 74, Table 11
The unit costs for 12-inch VCP pipe are less than the cost of 8-inch VCP.
In addition, costs for 10-inch VCP and 18-inch (with trench 14-20 feet deep)
are missing.
Page 82 and 83, Last Paragraph
The last paragraph on page 82 states that the life expectancy of a septic tank
and seepage pit is 40 years, but the Salvage Value Factor table lists the
estimated lifetime of a seepage pit as 20 years. This is not consistent.
Page 87. Bottom of Page, Last Sentence
This sentence implies that the regional system proposes building sewers on
currently undeveloped land. This is not the case. Sewers may be planned
and sized for future population, but collection sewers built in the future will
be built by lateral extension agreements at no cost to existing MSD customers.
Page 89. First and Fourth Paragraphs
The word "from" is misspelled.
MSD-12
Page 90. Second Paragraph
The CIS states the number of septic tank failures is small in light of the
number of systems in use, and, therefore, these systems should be con-
sidered very reliable. On what basis is this made? The draft Environmental
Inventory Task Report only addresses documented septic tank failures for a
relatively short period of time: 18 months. No real study, statistical or
otherwise, appears to have been done to support the EIS claim.
MS0-7.
See Section 3.1 for corrections.
HSD-8. Comment incorporated 1n revisions to the draft EIS;
see Section 3.2.2.
HSD-9. The "economic" life of a black-construction seepage
pit is considered to be 20 years; i.e., its value depreciates
linearly over 20 years. Realistically, people will not
replace their seepage pits until they fail completely.
There are nany seepage pits In Mill Creek now that are more
than 20 years old and have not been replaced. Replacement of
the septic tank and seepage pit after 40 years has been
assumed in the cost calculations.
MSD-10. The draft EIS cost analyses are based on total costs
of the alternatives, regardless of who pays. Sewer ex-
tensions for future populations are a part of the total
cost under alternatives providing collection capacity for
future growth.
MSD-11. See Section 3.1 for correction.
HSD-12. These systems are considered reliable because there
are many systems that have been operated for many years
with very few surface failures reported.
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Page 90. Second Paragraph
W
u>
I
The last sentence states that septic tanks in the West County area "would be
considered very reliable," but in the last sentence of the penultimate para-
graph, states that "systems reliability problems may be aggravated by the
advancing age of many" septic tanks. On numerous occasions, it is stated
that many septic tanks will be 40 to 50 years old during the planning period
(pages 65, 70, 82). It is also pointed out that "cooperation of owners" is
HSD-13 necessary for a reliable system. It would appear that many things will have
to go right in order to avoid an unreliable system; namely, 1) septic tanks
pumped out every two to five years; 2) those on-site systems needing replace-
ment actually are replaced; 3) enforcement and monitoring by the Health
Department will be tough and expensive; 4) the small wastewater treatment
I plants not relieved by interceptors will have to be upgraded to meet dis-
charge regulations; and 5) cooperation of owners of septic tanks is necessary
for replacement responsibilities and allowing Health Department inspections.
I Page 90, Third Paragraph
The West County Wastewater Treatment Plant is not designed to Reliability
Class I, but to Class III.
Page 92. 3.4.3.. First Paragraph
The public acceptance or non-acceptance of sewers appears totally based on
conjecture, with no factual or statistical sampling of the public. This fact is
MSD-15 admitted in the last sentence of this paragraph, but public acceptance or
non-acceptance is still used as an advantage or disadvantage in the evaluation
alternative process.
Pane 96. Third Paragraph
The word "concerned" is misspelled.
Page 97, Penultimate Paragraph
HSD-14
The word "constructed" is misspelled.
Page 96, Third Paragraph and Last Paragraph
The word "from" is misspelled.
MSD-16
Page 101, 4.1.
This section describes the proposed action of Alternative 7b. The proposed
sewers in this alternative will be designed for expected present flows and not
future population. In addition, residential units, even though the proposed
sewer is directly in front of their houses, would not be required to hook up
to the sewer.
By not sizing the sewers to serve future population, EPA is forcing the
financial burden of parallel sewers or expensive pumping to future populations
and commercial users, making future economic development of the area very
expensive.
HSD-13. Content noted; EPA does not disagree. The success of
any system depends on the cooperation of the owners.
MSD-14. See Section 3.1 for correction.
MSD-15. Although public sentiment was not statistically sanpled,
statements on public acceptance are not sinply "conjecture,"
but represent the overwhelming viewpoint expressed at nuner-
ous public meetings as well as the public hearing.
MSD-16. EPA does not oppose a local decision to proceed with
a sewer system sized for alternative 7c. Any comnitment
of federal funds, however, would be based on alternative
7b, the most cost-effective alternative .
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MS0-16
Not requiring any of the existing residential units lo hook up to the proposed
system does not make sense. For instance, the VT-2 line would relieve seven
smalt treatment plants, but along the May, EPA would still allow approximately
70 residential units to continue polluting the groundwater with their on-site
systems, even the proposed sewer runs directly in front of their house.
Page 105, 4.2.1.. First Paragraph
There must be more than 400 residential units that will continue to use on-
site systems. Either the number or the phrasing of the sentence is incorrect.
MSD-17|Pao
•E-
I
The 9 in the phrase "remaining 9 WWTP's" should be changed to 8.
Page 106, Section 4.2.2.
MSD-19
This section discusses the Preferred Alternative proposed relief of 18 of the
26 small package plants in the area. The remaining 8 would then have to be
upgraded to meet water quality standards or connected by force main to the
Black Pond Interceptor. Were these upgrading costs included in the Cost
Analysis for the Preferred Alternative? If so, which method was used?
Page 107, First Paragraph
The reference to Figure 2 should be changed to Figure 3.
Page 110, First Paragraph
MS0-17
The reference to Figure 2 should be changed to Figure 3.
Page 110, 4.2.3., Third Paragraph, Last Sentence
HSD-2C
The stated interceptor OiM cost of $0.S4/mile must be incorrect,
hole cover cannot be lifted for $0.54/mile.
Page 111, Table 21
A man-
The costs listed in this table are not identified as being construction or
project costs. If only construction costs, they are only slightly lower than
the costs used in the FIA; however, if they are supposed to be project costs,
they are off by 49%. Table 2 costs total $9,040,000, while FIA total project
costs are *13,463,000.
In fact, the real feasibility of building sewers parallel to, and on both sides,
in some cases, of Dixie Highway, does not seem to have been thoroughly
investigated. Existing utilities (water, gas, electrical, etc.) are highly con-
centrated in the right of way, and the maintenance of traffic and local busi-
nesses' ingress and egress would appear to be especially difficult.
MS0-I7. See Section 3.1 for correction.
MSD-18. Upgrading costs were included in the analysis for the
preferred alternative. Upgrading requirements were deter-
mined by discharge option and concomitant treatment level
required, as described in Section 4.2.3 (page 106) and
Section 3.4.1 (page 77) of the draft EIS.
HSD-19. Reference to Figure 2 is correct, but the figure has
been revised; see Section 3.2.1.
MSU-2Q. The costs in Table 21 are total project costs. Some
of the individual costs were not listed as total costs; a
revised Table 21 can be found in Section 3.2.3. The pro-
ject costs referred to do differ in the present worth
analysis and the Financial Impact Analysis because the
assumptions regarding sewer placement in urban areas were
changed after the present worth analysis and before the
Financial Impact Analysis; costs in the latter analysis
reflect the higher-cost assumptions and include additional
consideration of the difficulties of building sewers along
Dixie Highway. The increment is minor in relation to
total alternative costs and does not change the outcome of
the present worth analysis.
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Page 117, 4.3.8.
MSD-21
This section deals with local economy and finances. It states that the pro-
posed system would have a beneficial impact to local economy by increasing
the value of the properly along Dixie, but if the sewers are not sized for
future growth, this future growth will be difficult and costly.
IPaqe 123, Fourth Paragraph, Last Sentence
Conventional water treatment processes will not remove nitrates and excess
MSD-22
quantities of ammonia, and BOO in the groundwater will make disinfection
more difficult and costly. Disinfection will not reduce the reported high
nitrate levels of the local groundwater (also repeated on page 124, 4.5.2.,
third paragraph).
Whether conventional or not, it is likely to be costly and no doubt some of
these residences that are on well water are on it because they cannot afford
to hook up to LWC.
Page 123, Last Paragraph
MSD-23
u>
I
This paragraph seems to indicate that the Preferred Alternative can be mani-
pulated and moved around at will, like indoor plumbing, to accommodate shifts
in development patterns or other trends. Sewer systems are difficult and
costly to move once they are in the ground.
IPaqe 181, Third Paragraph
The word "individual" is misspelled.
(Page 184, Penultimate Paragraph
The reference to Figure 2 should be changed to Figure 3.
I Page 222
"Meyers" is incorrect; it should be Myers.
Financial Impact Analysis - General
MSD-26
This document does not address the financial impact of the EIS on the Mill
Creek area or the community. It merely reports the estimated service charges
which could be expected based on six very specific scenarios of construction
alternatives. In fact, the study does not address: 1) the financial impact to
the community of spending millions of dollars on plans and studies which will
never be used; 2) does not discuss the financial impact of delaying the Master
Plan all these years; 3) does not offer any alternative financing methods to
help reduce service charges or bond requirements; and 4) uses this narrow
based report as its sole response to the EIS's impact on the local economy and
finances.
160-21. EPA does not oppose a local decision to proceed with
a sewer system sized for alternative 7c. Any conrnitment
of federal funds, however, would be based on alternative
7b, the most cost-effective alternative.
MSD-22. The comments on water treatment are correct, but they
do not alter the conclusion that it is less expensive to
connect a relatively few residences to the public water
system than to sewer the entire area. It should also be
reiterated that 1) groundwater users should connect to
public water under any alternative because of the time
frame of inplementing any alternative, and 2) there are no
plans to use this groundwater as a public water supply in
the forseeable future.
HSD-23. The paragraph alludes to maintaining flexibility for
future wastewater management planning. It does not mean
that sewers would be moved.
MSD-24. See Section 3.1 for correction.
MSD-25. Reference to Figure 2 is correct, but Figure 2 has
been revised; see Section 3.2.1.
HSD-26. To the extent that the impacts 1n items 1 and 2 may
have occurred, they represent "sunk costs," i.e., because
they have already occurred, they are the same for all
alternatives and do not affect the selection of any
alternative. The objective of the Financial Impact Analys
was not to preempt local decisions on financing, but to
see if any of the alternatives would have different impacts
on MSD service charge or bond requirements. Assuming that
existing financing arrangements would continue is the only
equitable assumption available.
-------
Financial Impact Analysis
MS0-27
Figure S shows the West County Treatment Plant going on-line in 1994; that
is really the 15 mgd expansion. The plant should be shown as going on-iine
in April 1988.
ECE2/B
u>
O
I
MSD-27. Comment incorporated In revised Figure 5; see Section
3.2.9.
-------
COMMONWt i M ^ .
DEPARTMENT FOR NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
OFFICE OF THE SECRETARY
OFFICE OF SPECIAL PROJECTS
i.Atni*i nui iu»tH
HtANKFUhl MNlUCfcV
PHopa ri .
December 3, 1981
Mr. John E. Hagan III, P.E.
Chief, E.I.S. Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
|L Dear John:
w
-j1 The Kentucky Department for Natural Resources and
' Environmental Protection serves as the State Clearinghouse
for environmental impact statements. Attached are comments
on the Draft Environmental Impact Statement, Mill Creek
Area, Jefferson County, Kentucky, that the Department has
received from other state agenices. These comments are sub-
mitted for your consideration in preparing the final E.I.S.
on this project.
The Division of Water within the Department's Bureau
of Environmental Protection is preparing comments which will
be submitted as soon as possible.
Sincerely,
Rose Marie Carr
Environmental Review Officer
Office of Special Projects
RMC:b8c
Attachment
K
0 / (QQI
rjer'
-------
Commonwealth or Kentucky
Department of Transportation john/ j"
SCCftCTAMY GOVt«MO*l
Frankfomt. Kentucky ao«22
November 2, 1981
Environmental Review
Office of Special Projects
Department for Natural Resources
and Environmental Protection
4th Floor, Capital Plaza Tower
Frankfort, Kentucky 40601
Gentlemen:
Subject: E.l.S. Review 81-17, Jefferson County
Hill Creek Area Wastewater Facilities
. The Kentucky Department of Transportation (KYDOT) is responsible for
i_i controlling both public and private usage of right-of-way of the State road
u> system. Any firm, individual, or governmental agency desiring access to a
State road or desiring to perform any type of work on State right-of-way
must obtain a permit from KYDOT. A contractor performing the work must
have in his possession at all times a copy of the permit, authorization
letter, and detailed drawings of work to be done.
KTDOT encourages the use of private property for placement of utilities
facilities where possible and practical; but we realize that In some instances
highway rights-of-way are the only reasonable places to locate the proposed
utilities. In these cases. Me expect the conscientious efforts of both the
applicant and the contractor to Minimize adverse effects on the roadway and
on the traveling public due to construction of the applicant's project.
KYDOT
-1
Since State maintained roads US 31W, KY 1931, and possibly others, may
be affected by this proposal, any proposed access or encroachment should be
coordinated at the earliest possible stage with Albert V. Lemieux, Highway
General Manager, P. 0. Box 37090, 977 Phillips Lane, Louisville, Kentucky
40233, phone (502) 367-6411.
KYD0T-1. Coordination with KYDOT will occur during design.
Sincerely yours,
Thomas A. Scott, P.E.
Division of Design
TAS:lk
cc: Albert V. Lemieux
-------
L^c..-mbjr 3, 1981
Chart'ss a. Tusker
6305 Gr=jvivl;w uilve
Loulbvills, iCy **3216
I-.r. John c.. IH t.i.
Chief i.I.a. jranch
it-A Region IV
3^5 Courtland otreet, li.i.
Atlanta, Georgia 30365
i>jar kr. Hagan ;
I should like to conm%n3 your office in aeloctln. Kr. flonald
l-.lkulak aa Chairperson of our most recant public hearing held
on iiovenibsr/Tth. ilia manner of direction at thla meeting, aa
wall aa previous on.d was rendered In a alncer tanner with
respect to thoee in audience participation.
The ilome Owners Association, of which 1 am a charter mwDer,
I la In a fair ijo^ition with extensive redsarch to Judge th?
t— merits of our waate water disposal. Our s.ptlc syst^n.s have
work-d In a satisfactory Banner for a number of y^ars, and
I with proper maintenance will continue to serve well. Vie
can not beli ve there la a real need for we who are on a
fixed income (Social Security) to try to obligate our future
by needless s&wera and Indebtedness.
Th-. sandy, gravelly loam that 1b under this portion of .south
W.-3t Jeffaiuon County causes our aeptlc system to perform
perfectly without a costly sum for another plan for waste
water disposal.
We, therefore, endora#- the JB alternative aa offered by your
CRT-1 group for sewering Dixie Highway corridor for commercial
sites, eto, and allowing us in a resiaential neighborhood to
continue the u^e of our on site septic systems.
Respectfully,
(f£~i 11 ij,y^/ -c < L -
Charles a. Tucker
tMv:iiu.\Kir..-.i i'-ii'- .i .ii.t. t';i
|./| [if CUV i,A1
Stt'ffUTE
MFr.iON :v •
CRT-1. Comment noted.
-------
SIERRA CLUB
CUMBERLAND CHAPTER
107 Tanglewood Trail
Louisville, KY 40225
December 7» 19^1
Mr* John E. Hagan 111 P.£.
Acting Chief, Environmental Assessment Branch
EPA Region IV
545 Oourtland Street, N. £.
Atlanta, 3A 50}65
O
Dear Mr. Hagani
The following are cofianenta by the Cumberland Chapter, Sierra Club, to the
Environmental Impact Statement for proposed wastewater facilities in western
Jefferson County, Kentuckyi
The Cumberland Chapter joins with the Louisville and Jefferson County
Board of Health in opposing the SPA'a proposal for a acaled-down sewer plan
for the Hill Creek area because 1
SC-lf 1* The area is now polluted from septio systems.
SC-2| 2. Replacing these will ultimately cost residents $28 million.
SC-3 5* The sealed-down plan (alternative 7b) will not remove all the
snail package plants now discharging into surface waters.
4. The scaled-down plan calls for relatively small-diameter sewer
trunks serving the area immediately adjacent to Dixie Highway,
leaving 17,000 raaidenta dependent on septio tanks.
SC~4 5. Vs are told that alternative 7b calls for sewer trunks of a size
tJiat could not accommodate the inoreased flow when residents now
having septic tanks later realise that their health depends on hooking
up to a municipal treatment aystea»
6. If so, the EPA recommendation, made in the ostensible interest of
cost effectiveness, is not coat-effective because it will prevent
SC-5 residents from making use of an inadequately-sized sewer system,
coat them millions of dollars to replace ineffective septic tanks
with equally ineffective ones, and guarantee a progressive degradation
of our water quality.
For the above reaaons, we recommend that EPA proceed with the original
201 plan.
Sincerely,
Too Westerlln, member
Cumberland Chapter
Executive Committee
SC-1. The EIS documents that the groundwater is not accept-
able as an untreated water source and reconmends that
families now using the groundwater connect to the public
water supply. None of the alternatives, including the
regional sewer, would mitigate this immediate need because
of the time needed to have a sewer system installed and
operating. There are other environmental concerns in
Jefferson County that could be mitigated more effectively
through the use of federal sewer funds.
SC-2. The cost for replacing septic tanks during the planning
period was included in the present worth analysis. In terms
of cost, replacing and maintaining septic tanks is less expensive
than installing and operating a central sewer system.
SC-3. The remaining small treatment plants would have to be
upgraded to meet NPDES limitations.
SC-4. The overwhelming majority (98-99%) of the people in
the study area are served by public water, so their health
is not threatened by septic tank/seepage pit systems.
SC-5. EPA does not concur that the larger-sized system in
alternative 7c is more cost-effective. Local agencies may
implement 7c if they desire, but federal funds will only
be available to the extent that funds would be available
for 7b.
ENViltUl.n"
,UJ DFC 09 1981 ii'i
Hairfqb
REGION IV CI A
-------
WaU'i (futility Advisory Board
m WQAB
2b(X) Hermitage Way
Louisville, Kentucky 40222
(502) 425,-334!"/
December 4, 1981
RE: Mill Creek Draft EIS
Mr. John Hagan, Acting Chief
Environmental Assessment Branch
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
The Hater Quality Advisory Board (WQAB) was designated by the
t Governor of Kentucky and under the EPA 208 Program to advise and
I—• consult with the State and EPA on water quality issues. Enclosed
are the contents and advice of the WQAB on the Mill Creek Draft EIS.
' I. GROUNDWATER
A. The EIS groundwater program made numerous assumptions and
conclusions which are not substantiated by the groundwater
sampling.
1. Appendix B (Page 79) and Figure 33 (Page 80) state
that effluent from seepage pits move vertically to
the middle of the groundwater table and solid rock
level and then directly west to the Ohio River.
Page 79 includes the statement, "Thus, the relative
positions of polluted water under dry and rainfall
conditions cannot be determined without aquifer
modeling."
WQAB Conment: EPA has assumed that effluent waters and
-1 pollutants follow a vertical path directly to the
aquifer and then west to the Ohio River. However,
pollutant sampling for nitrates and fecal coliform
bacteria show that the higher concentrations are
in the shallow wells rather than the medium or deep
wells. Even more probable are clogged soils below
the seepage pits with bacteria-laden solids that
surface in Mill Creek as the Ohio River rises and
the groundwater level rises, polluted seepage that
reaches Mill Creek in dry weather via a more horizon-
tal route, or seepage that pollutes shallow levels of
groundwater.
Kentucky Counties Covered- Heniy • Jefferson ¦ Oldham • Shelby
100% Recycled Pjper
WQAB-1. The general discussion in Appendix B of the Draft EIS
of effluent and groundwater movement was not meant to imply
that effluent moves "vertically to the middle of the
groundwater table and solid rock level and then directly
west to the Ohio River," to quote Mr. Winfrey. The schenatlc
Illustration in Figure 33 may be misleading in this respect.
Rather, the statement is made in the appendix that "efflu-
ent from seepage pits travels toward the groundwater with
a particular vertical velocity." The effluent would also
diffuse horizontally, to some extent, as it moves down
in the aquifer until it reaches the water table; and as
soon as it enters the groundwater, it would be subject to
the natural horizontal velocity component of the ground-
water. Both the vertical and horizontal vectors would
vary with precipitation and infiltration, thus "the relative
positions of polluted water under dry and rainfall condi-
tions cannot be determined without aquifer modelings," as
stated in the appendix.
EPA concurs that nitrate concentrations tend to be
hiqher in the shallow wells than the nedium-depth or deep
wells, as stated on pages 58 and 81 of Appendix B. EPA
does not concur with a similar conclusion for fecal
coliforms. The percentages of positive samples were 32
(41/127), 38 (50/132), and 36 (52/144) for the shallow,
medium-depth, and deep wells, respectively. The median
organism counts of the positive samples were 25 per 100
mL, 23 per 100 mL, and 28 per 100 ml, respectively.
The data available are not sufficient to test-the
hypotheses that bacteria-laden solids from seepage pits
surface in Mill Creek in dry weather via a more horizontal
route. These events do not seem "more probable," however,
because 1) most of the septic tank effluent is discharged
through seepage pits connected directly to the Ohio River
aquifer, 2) vertical movement into the sand-and-gravel
aquifer is hydraulically preferable to horizontal move-
ment through the more-impermeable silts and clay above
the aquifer, and 3) movement of bacteria-laden solids from
the aquifer upward through 10-20 feet of silt and clay to
Mill Creek is highly improbable.
-------
Mr. John Hagan
Page 2
December 4, 1981
WQAB
-2
WQAB
-3
¦>
ro
i
UQM
-<
2. The EIS states the aquifer can handle more seepage
from additional septic tanks and that the groundwater
was found suitable for development as a treated public
water supply.
Comment: Residential growth in the area under alter-
native 7b would add either septic tanks or package
treatment plant increases. Existing groundwater
sampling and the lack of groundwater modeling fail to
provide estimates of future groundwater quality.
B. Recommendations
EPA has provided assumptions of groundwater pollution and
mechanics, but groundwater data do not support the assump-
tions. The WQAB recomenda that groundwater modeling and
additional sampling are performed to determine existing
conditions and project future impacts of selected alterna-
tives.
II. SURFACE HATER QUALITY
A. Mill Creek
1. EPA did not perform water quality or aquatic life
sanpling for Mill Creek surface waters. Vet, the
report concludes that under "normal" conditions the
existing treatment plants would provide low risk
bacterial contamination (Page 18).
Comnant; EPA provided no surface water quality data
in the EIS and utilized aquatic life data from streams
other than Mill Creek. "Normal conditions" for Mill
Creek based upon recent WQAB sampling of the area
streams show that Mill Creek exceeds fecal coliform
standards by 40 times (>200,000 colonies/100 ml),
while the other five major streams were less than the
5,000 colonies/100 ml Kentucky standard. In addition,
a malodorous, black sludge blanket was present from
Orell Road to the Ohio River. Indication of septic
tank seepage reaching Mill Creek and prolonged wet
weather flows also complex the existing package
treatment discharges.
Aquatic life in Mill Creek has not been documented,
and EPA's assumption that the 21 fish found in Beargrass
Creek will parallel those in Mill Creek is a broad assump
tion.
WQAB-2. Comment is accurate—future growth may be served by
septic tanks or by sewers, and modeling of future ground-
water quality was not done.
WQAB-3. EPA believes the analysis was sufficient for the pur-
pose of the EIS. As stated in the draft EIS, however, EPA
encourages the establishment of a local monitoring program
in areas that could not be connected to the public water
supply. The sanpling wells that were installed for the EIS
groundwater program are available if local agencies would
like to maintain them for future sampling.
WQAB-4. WQAB has been represented at technical review committee
meetings throughout the EIS process, but has not submitted
any "recent" water quality data to EPA. EPA has not seen
any data showing an "indication of septic tank seepage
reaching Mill Creek." The data presented in this comment
are consistent with the conclusion of the EIS that water
quality has been degraded by discharges from the 26 existing
package treatment plants. Only one of these plants is
currently designed at treatment levels necessary to protect
the water quality of the intermittent streams.
There are no data on the aquatic biota of Mill Creek.
Since Beargrass Creek and Mill Creek are similar with res-
pect to hydrology, water quality, and surrounding land use,
it is not unreasonable to assume that the species compositio
of the fish coranunities will be similar. Ho data have been
received that contradict this assumption.
-------
Mr. John Hagan
Page 3
December 4, 1981
2. EPA states that the remaining package treatment plants
of alternative 7b will meet standards because of re-
duced total discharges. EPA also states that the 1974
WQMP modeling provides the basis for treatment levels
of retained plants.
Comment: The aodeling in the 1974 WQMP was based upon
the total flow of package treatment plants existing in
1973. A reduction in total flow for the smallest creek
in the area should require that remaining plants meet
even more stringent standards than those recommended
in the 1974 WQMP. EPA is again assuming that no septic
tank seepage will enter Hill Creek, but if it does,
then the lower streamflows will be easily polluted by
even small amounts of seepage.
.c-
u>
I
UQAB
-6
B. Reconmendat ions
EPA should provide surface water quality sampling and
modeling to justify that the selected 7b alternative will
meet water quality standards. Operation and maintenance
requirements for treatment plants and enforcement of NPDES
permits and stream standards should be carefully outlined
by EPA.
III. CONCLUSIONS
The Mill Creek Draft EIS is based upon unsupported assumptions
for groundwater and surface water, and given monitoring data
for groundwater does not support groundwater assumptions. Ground-
water and surface water modeling and further sampling are required
to justify selection of an alternative.
iially.
Andrew J^Winfrey^
Coordinator
cc: WQAB Members
Ms. Jackie Swigart, KDNREP
EWlRONwniM/ I,-;-.' ,
"' MFNhoi,
nrc n v.
, — . - . I
^GIONlV il-A
WQA8-5. Surface water quality will improve under alternative
7b, because pollutant loadings will decrease for two reasons:
1) most small-plant discharges will be eliminated; 2)
those that remain will have to meet strict NPDES limitations.
The 1974 WQMP modeling determined the total allowable
BOD loading from a single discharge for a regional treat-
ment plant at any point on Mill Creek. To determine specific
limits for a plant from this model, the average daily dis-
charge would have to be known. The implication, however,
is that as volume of discharge decreases, the allowable
concentration of pollutant increases.
The effluent limitations shown in Table 7 of the draft
EIS are those contained in previous discharge permits issued
by the Commonwealth of Kentucky. Preliminary modeling done
by the Kentucky Department for Natural Resources and
Environmental Protection in 1981 determined that effluent
limitations for the existing package treatment plants would
range from 10 to 30 mg/L BOD. Since a limitation of 10 mg/L
was assumed for the EIS, the costs for upgrading the treat-
ment plants are a conservative estimate.
Final discharge limitations for individual treatment
plants have not been determined by the EIS. Whatever modeling
is needed to determine these limitations will be done in the
normal process of writing NPDES and state discharge permits.
WQAB-6. Previous modeling from the 1974 WQMP, the 208 Plan, and
Kentucky DNREP is sufficient to show that water quality stand-
ards can be met by alternative 7b. Specific effluent limita-
tions will be determined when a water quality model is run
for establishing NPDES and state permit requirements. These
permits will also contain requirements for effluent monitoring
and reporting. The local health department and KDNREP have
mechanisms for monitoring treatment plants and enforcing
permit conditions.
-------
CARL BROWN
JEFFERSON COUNTY COMMISSIONER
December 9, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
I attended the November 17, 1981, hearing on the
Mill Creek Area Draft Environmental Impact Statement at
Pleasure Ridge Park High School. I have an active, on-
going interest in the subject, both as an individual and
as an elected representative, and felt a sense of relief
at the prospect of real movement in the direction of re-
solving the waste water disposal problems in Southwest
Jefferson County.
It has been months since the public officials
and citizens of this county first learned that there were
plans afoot to re-examine the massive sewer program ori-
ginally proposed for homes and businesses in the Mill
Creek area. While most county and Metropolitan Sewer
District officials favored the first plan, I had to agree
with area homeowners that it was seriously flawed. Among
its many problems were its questionable necessity and its
enormous cost.
II must again join what I am sure is a majority of
the community's residents in welcoming the scaled-down
(7b) version as a superior alternative to its predecessor.
In formulating and presenting a new plan that is both en-
vironmentally sound and cost-effective, your agency has
proven itself responsive to the needs and desires of in-
dividuals in their respective communities.
CB-2
This administrative change of heart represents
federal recognition of the Southwest County's natural en-
vironmental distinctions — an aquifer with adequate fil-
tering capabilities. It also represents recognition of
JEFFERSON COUNTY COURTHOUSE LOUSVIUE, KENTUCKY 4M02 TBLEVBONE (M2)S8I-S8»3
Mr. John E. Hagan, III, P.E.
Page Two
December 10, 1981
the very real financial hardship to homeowners that an in-
descriminate, all-inclusive sewer program would impose.
Your agency has shown itself willing to "take another
look" at a decision when citizens publicize factors de-
serving of additional consideration. The EPA's role in
this kind of cooperation is proof that federal agencies
can address community needs without trampling community
rights.
I realize that we have yet to find a final solu-
tion to Southwest Jefferson County's waste water disposal
problems. However, that process can only be made smoother
if the EPA and the people it serves continue to act in the
same spirit of cooperation that we have recently observed.
Very truly yours,
¦¦
Carl Brown
Jefferson County Commissioner
CB/LAP/ph
cc: Mr. Bob Watson, Editor
The Southwest News
Mr. Ed Stumler, Editor
The Shively Newsweek
CB-1. Comment noted.
CB-2. EPA does not concur that the aquifer has "adequate
filtering capabilities." Seepage pits effectively dis-
charge directly to the sand and gravel aquifer, and
although some treatment may occur, the glacial sands and
gravels should not be perceived as a natural filter.
-------
Commonwealth or Kentucky
Department for Natural Resources ano Environmental Protection
Office of the Secretary
Frankfort. Kentucky 40601
TClCPhDnC (502
February 23, 1982
Mr. John E. Hagan, III, P.E.
Chief, BIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
The Draft Environmental Impact Statement (DEIS) on
the Mill Creek Area in Jefferson County. Kentucky, discussing
proposed wastewater facilities for southwest Jefferson
County has generated substantial concern among various
groups within the county. The Department has thoroughly
reviewed the DEIS and the contents submitted by local
groups. Departmental staff have also met with representa-
tives from Jefferson County to discuss the impact of the
alternative recommended by EPA in the DEIS on the future of
Jefferson County.
The major alternatives that have been discussed by
other comenters are:
Alternative 7a-Limited regional sewer system, existing
septic tank® and increased small wastewater
treatment plants (future development could
connect to existing interceptor system).
Alternative 7b-Limited regional sewer system, expanded
septic tanks and reduced small wastewater
treatment plants (future development could
connect to existing interceptor system).
-------
Mr. John E. Hagan, III
February 23, 1982
Page Two
DNREP-1
ON
I
Alternative 7c-Limited regional sewer system with £ull
capacity and existing septic tanks until
hooked up to regional system.
The alternative tentatively selected by EPA is 7b.
This alternative is unacceptable to the KDNREP because it
encourages increased use of septic tanks that may contribute
to existing pollution problems in the Mill Creek Watershed
and it will result in the construction of a sewer system
without the capacity to handle additional growth in this
area of Jefferson County. The Department endorses the
system described in Alternative 7c. This alternative
addresses the serious problems along the Dixie Highway
Corridor. This recommendation also does not preclude full
implementation of the 201 Regional System at some point in
the future. However, it acknowledges the current economic
limitations to immediate implementation.
Although this recommendation does not address the
problem of continued use of existing septic tanks by residen-
tial occupants in this area of Jefferson County, it does not
encourage increased use of septic tanks as does Alternative
7b. Implementation of the proposed system will also reduce
the potential for increased pollution of the Mill Creek
Basin Aquifer.
DNREP-2
Attached are comments from the Division of Hater on
specific points in the OBIS. The Department would also like
to make note of the comments submitted by the Hater Quality
Advisory Board. These comments seriously challenge the
scientific base of the conclusions in the DEIS and require a
response in the FEIS concerning their merit and their
effect on each alternative.
The Department submits these conments for your con-
sideration in finalizing the EIS on this project and hopes
that the responses to these concerns in the Final EIS will
provide assistance in the resolution of these critical
issues.
JS:kp
Sincerely,
( //
irely,
U-
Jackie Swigart. Secretary
impaci MAUMEirf5eP®rt,Bei?t for Natural Resources
lh BhStlOl and Environmental Protection
Ji MAR 01 1982
ms
SGiiU'El
ION IV EPA
Mr. John E. Hagan, III
February 23, 1982
Page Three
cc: Don Ridings, Secretary, Jefferson County Environmental
Policy Office
T. S. Wallace, Jr., Secretary, Louisville S Jefferson
County Board of Health
Jeff Elseroad, Gannett-Fleming Engineers
Mike Taiai, Acting Commissioner, Bureau of Environ-
mental Protection
John Smither, Director, Division of Hater, KDNREP
Rose Marie Carr, Office of Special Projects, KDNREP
DNREP-1. EPA does not "encourage" increased use of septic tanks;
the disposal of wastewater from future residences is a local
planning issue. The EIS only recognizes that alternative
7b is the most cost-effective solution to solving present
environmental problems. Local agencies may proceed with
alternative 7c if they prefer; however, federal funds will
only be available to the extent they would be for alternative
7b.
DNREP-2. The conments of the Water Quality Advisory Board have
been addressed previously in this section.
-------
DEPARTMENT FOR NATURAL RESOURCES
AND ENVIRONMENTAL PROTECTION
BUREAU OF ENVIRONMENTAL PROTECTION
DIVISION OF HATER
Comments on the DEIS on the
Mill Creek Area in Jefferson County, Kentucky
Pages 17, 20, 122, and 123
DNREP-3
DNREP-4
DNREP-5
The aquifer of the Mill Creek basin is characterized as
not suitable as an untreated drinking water source due to
the detected presence of nitrates and bacteria (Page 17).
On Page 20, paragraph one, the DEIS indicates that the
groundwater would be suitable for consumption with the
application of conventional disinfection. The Division
believes the DEIS should be expanded and revised to indicate
that disinfection only affects bacteria, but does not reduce
the nitrate hazard.
On Page 17, the DEIS indicates that the residents in
300-600 homes using groundwater as s drinking water source
should spend $1,000 to $14,000, with an average of $2,000
per home, to connect to the local public water supply system
{Louisville Hater Company). However, because the local
residents have already strongly objected to a connection fee
of $3,000 for MSD sewers, the Division believes that they
will not approve this proposed expenditure either, thereby
perpetuating the use of the Mill Creek alluvial aquifer as a
water supply source.
On Pages 17 and 20, the DEIS states that local agencies
are to "encourage" connection to the public water supply.
Neither the state nor local agencies have the authority or
the funds to force these connections. Many statements at
public meetings indicated that residents of the area believe
that the source of their longevity and virility is related
to continued use of private water supplies. Additionally,
these residents believe that the Louisville Water Company
supply contains cancer-causing chemicals and, as a result,
fear connecting to it for their drinking water. Recognizing
these attitudes, EPA must be aware that very few, if any, of
these connections will be made. Accordingly, the Division
does not believe that (a) public health issues can be
compromised for purely financial considerations and (b)
selection of an alternative which leaves serious public
health problems for future generations is prudent. The
Division believes that use of the word "encourage* in the
DEIS does not relieve EPA of any responsibility with respect
to future illness. Under the selected alternative, 7b, the
lexisting problem can only become worse.
DNREP-3. EPA agrees that disinfection does not reduce the
nitrate level in drinking water. The E1S groundwater pro-
gram demonstrated that several shallow wells contained
nitrate levels in excess of the drinking water standard.
The average nitrate level of all wells sampled, however,
was 1.5 mg-N/L; well below the 10 mg-N/L standard. (The
average reading for shallow wells was 3.1 mg-N/L, 1.0 mg-N/L
for medium-depth wells and 0.3 mg-N/L for deep wells).
It is therefore expected that Hill Creek area groundwater
would generally not pose a nitrate problem if used as a public
water supply source. The conclusion of the groundwater
study, moreover, is not that groundwater users should try to
treat the groundwater, but that they should discontinue its
use altogether and connect to the public water supply
system.
OWEP-4. Given that the groundwater is unacceptable as an un-
treated drinking water source, it is a local public health
responsibility to encourage groundwater users to connect
to the public water supply or, at least, to apprise them
of the possible consequences of continuing to use the ground-
water. In any event, this argument is not relevant to the
selection of a wastewater management alternative, because
even the regional sewer system would not remove all the
septic tanks for a least ten years.
DNREP-5. Drinking water and public health have traditionally been
local responsibilities. EPA has not seen any data to show
that the public water supply is carcinogenic and has no
reason to believe that it does not provide a suitable alter-
native to the groundwater. EPA does not believe that
large expenditures of sewer funds in the Hill Creek area
are a cost-effective answer to present pollution problems.
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• Page 29
KRS stands for "Kentucky Revised Statutes." The
state's regulations are entitled "Kentucky Administrative
Regulations." The correct citations in the order given in
Table S are as follows:
DNREP-6
KRS CH 94
KRS CH 107
KRS 224.223 to 224.237
KRS 318.310 to 318.330
815 KAR 20:130 to 20:191
Louisville-Jefteraon County Board of Health
Sanitary Code
CH. 3 Sec. 303.501 to 303.805
CH. 3 Sec. 304.401 to 304.407
ONREP-7
•C-
00
I
DNREP-8
ONREP-9
• Page 53
In Table 7, application of blanket limits is not the
usual practice. Some wastewater treatment plants will
require stringent Units, e.g., ammonia treatment, while
other plants will not require such limits.
• Page 55
The Division of Plumbing of the Department of Housing,
Buildings, and Construction is responsible for permitting
discharges from wastewater treatment plants into on-site
disposal systems (disposal wells). The Division of Plumbing
may object to permitting discharges of the size proposed
here. The Division of Hater believes the PEIS should address
the disposition of the sludge created as a result of primary
treatment. Sludge disposition was not covered in the DEIS.
Page 65
DNREP-10
The removal of the septic tank ban is a purely local
decision, and the Division believes that the adoption of an
opposing position by EPA exerts unnecessary pressure on the
Louisville-Jefferson County Board of Health.
• Page 90
IThe West County Wastewater Plan is classified as Class
III reliability.
DNREP-6. Table 5 has been corrected; see Section 3.2.7.
DNREP-7. Throughout the EIS process, the discharge limits for
small treatment plants were considered to be the same for
all plants, because those limits were endorsed by the 1974
Water Quality Management Plan and DNREP. Only within the
past year has DNREP run a preliminary water quality model
for the Mill Creek area to estimate specific limits for
each plant. That analysis showed that the previous
assunption is conservative, i.e., no plant would have to
upgrade its facility for limits more strict than those
assumed. The evaluation of alternatives, therefore, is
not affected.
DNREP-8. The Division of Plumbing has not commented on the DE!
Subsurface discharge is only one alternative; others are
available if one is precluded by local policy.
ONREP-9. The issue of primary sludge disposal is not relevant
to this EIS. Primary sludge will be generated whether ttv
sewage is treated in a small plant or a regional plant.
DNREP-10. EPA agrees that the use of septic tanks in the Mill
Creek area is purely a local decision.
DNREP-11. Correction noted; see Section 3.1.
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DNREP-12
It is the Division's opinion that upgrading small
sewage treatment plants would be a low priority within the
existing federal construction grant priority list system,
and would probably never receive such support.
ONREP-13
• Page 123
Current data indicates that the groundwater level is
increasing due, in part, to lack of use. Since this trend
is expected to continue at the present rate, the Division
believes that the FEIS should identify how long it will
be before seepage pits will fail to function. If this
occurs, the FEIS should also examine what mitigative measures
might be available.
Page 184
DNREP-14
vO
1
The DEIS has identified septic tank failures and
indicated that the failures are related to lack of maintenance.
Yet, the DEIS does not recommend solutions to the problem;
and the recommended alternative (7b) of this DEIS proposes a
significant increase in the same type of system that currently
fails because of poor maintenance. The Division believes
that these positions should be reconsidered in the FEIS.
Pages 204 to 215
DNREP-15
In Tables SO through 58, the scale and weighting are
not described sufficiently for the data to be useful. There
is no projection comparing the cost to the Mill Creek area
residents of sewage hookups (initial fee and user charges)
with septic tank repair and replacement. The FEIS should be
revised to provide this comparative analysis.
DNREP-12. Setting the priorities for construction grants is a
State prerogative. Privately owned plants are not eligible
for federal funds.
DNREP-13. The data indicate rising groundwater levels in downtown
Louisville where pumping for water supply has been largely
discontinued. The data do not indicate that the same is
happening in Mill Creek. Even if such were indicated, it
would not be possible to extrapolate future water levels
that would affect seepage pits. Section 2.4 recognizes,
though, that at some future time this possibility could
affect wastewater management priorities in the Hill Creek
area.
DNREP-14. Septic tank failures are usually due to inadequate pumpii
of septic tank sludge. The majority of septic tank failures
in the Hill Creek area are those serving commercial establish
ments along Dixie Highway. The EIS selected action would
relieve these malfunctioning systems while allowing the
residential on-site systems to remain. Although the bulk
of failing septic tank systems will be eliminated, the
requirement for maintenance af the remaining septic tank
systems will not be eliminated and is viewed as a local
responsibility.
DNREP-15. Impact analysis is not a quantitative science. Tables
50 through 58 do not present data as such, but reflect the
combined judgements of the scientists, engineers, and
planners who evaluated the impact. The tables show whether
an Impact was considered adverse or beneficial and whether
the degree of impact was minor, moderate, or significant.
These latter terms cannot be quantified, but have subjective
sense that was explained In the draft Alternatives Evaluation
Task Report:
Significant impacts may be direct or indirect environ-
mental consequences that violate laws or governmental
standards, policies, or plans, or create unknown risks to
the general environment 0r Injury to individuals and the
community at large.
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Ln
0
1
Moderate impacts are environmental consequences that
are of concern In decision making, but are of less importance
than significant ones.
Minor impacts are those environmental consequences that
do not weigh heavily in the selection of an action.
Costs for operating septic tank systems and for replacing
those systens Mere included in the present worth analysis.
For the entire area, then, the costs of using septic tanks
versus using a sewer system have been compared. For individual
users, the costs for a septic tank system are shown in
Table 11 of the DEIS:
$1,800 capital cost for replacement
$40/year operating cost
The costs for the sewer system are estimated on page
5 of the DEIS as:
$3,000 connection fee
$120/year user charge
The costs are directly compared In Table 17 of the DEIS,
where the annual equivalent cost is $0.85/thousand gallons
for septic tank users and $3.00/thousand gallons for users
of a regional sewer system.
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CHAPTER
5
EPA proposes
drastic cutback
in Dixie sewers
EPA Announces Change In Sewer Project
Officials o* *ha twlrenminm Prpiacltoo dm* Mgfcvoy, to ftedy too recant iHcHinn.
Aysary tfPA, >rtka In Atlanta IM* wMh om- According to «¦ CPA tyofc—m— to At-
dalsr notfftod mntatt o< a tMMM ravWw imUi CPAvt racantty moda doditow not to
(ommMIm thai major rcvMmu in Um pco- axtaito mm to thnmwiii of hawu in Km
poMd MM Cr««k Buia mm profoct am go- Soutliwost Jafforeon CowMjf araa w*t of
tog to ba mada. Dfato Highway badrady mnwrti rnntaattow
A latlar from CPA'a nfloAai idmtalatrator aiada by araa raaliawta Una yoara ago.
Itafracca W. Hawmar uy« CPA official* teava Ttoaa caolawUom, aMcfc ara rmtinad to
schadutod a maaUng for Jyna 24,7O0 p-m.. Ma. Hi
at llto Soutliwost Qovarwnant Cantar, 7219 t«ifc» <
—
coat o< WW plaa haalt«p faaa wa% kMi
aad wmM be aa uaaacaaaaiy kurdaa for low
lacoaia hoMOMMra, Mat a pdk aavw ¦«.
vtea HmM mm ka fnMM lot on RWikm
mduatrialConpta*. aad that tha aaUraK»«,-
laa at 3o«ilWaa< Jaffaraoa Coaarty waa
to Mm M
tuo
pesa* nmraMiMNHMiiM
M nmM tf «a am» *a •» »«• «ot 1*35 nwm?
mm ftasa; —to yto *¦!!?** jwi— mm mu
• mam —* fly , M uejJTS
EPA stand on sewer project worries officios
Ground-water
problems seen
in the future
l a final 4k)-
•y PATMCX HMflNtr M
and CAIKX.YM OATZ
i Thnaa SUM Wiaaia
a«»n>baroK« toraT&SS;atf*MNa WaSar
UN* to wtdaapraad aawar taenia Jr„ »a BoaneCTaata MaodaUoo'i
ttan la aaettwaatanaa. Mack ef too pnaHiai
wa« of Dtade Hl*>ay eaod. _
awv" aau Of>al Pally, a Pamela waoraad
VMM a ladarml Environ menial raaldani «» mm* oa toa
ProtocUoa Afaacr piupaaal not to toa. "I aava Maa MM "
ta*a aavan bum la aaMMatoaa »aa*to Ikat wkaa in kat
wax 01 Olito Riikwar ooaM aavavtMtr nal«libartaaa yaa
Alarming message
m Officials disagree on consequences
of EPA proposal on sewer project
tiailaaai ina Pa«a Oaa |an la a °* *>*f* "* ***" co* " -n nnaiinii nrniama mhh
cMBawa to court. . «rt to ntoaniy mpniVtta
¦« It eaU cooaty aaaaa Hliilr
- "*PAla coanftocadOanlaaaa(f
/o»toa-eoaaflr." detoak piebtoe -r— mi pan»««i
commercial strip. An earlier proposal called tor sewers there aad a county - south- plana then hnuns up mm****
through subdivisions west of Dixie Highway. "iTc^-%'£££%££
But many of the 17,000 homeowners in the area opposed the initial mrya^ttopay oatama.
plan because of $3,500 hookup charges aad because they believe their udge_ Houanbach'a flat can't, be -u at <*** mm.
. ,,t, __ ZAmjmatm. debt by aolidt- bowvnr. and that malm the iiioaagi
sepac tanks are adequate. toapomsdalaow- bom Wwhiqgtoa far mora alaning
Jefferson Countv officials contend that the scatofrdona ptaa could te
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5. LIST OF PREPARERS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Robert B. Howard
Ronald J. Mikulak
Peter T. McGarry
GANNETT FLEMING CORDDRY AND CARPENTER, INC.
Thomas M. Rachford, P.E., Ph.D.
David L. Sheridan, P.E., Ph.D.
Stephen G. De Sesa
Jeff Elseroad
Victor S. Krea
Stuart L. Miner
Frank Swit .
Larry C. Wills
Ronald R. Wright
CLAUDE TERRY & ASSOCIATES, INC.
Claude E. Terry, Ph.D.
Robert J. Hunter
Louise Franklin
James C. Hodges
Thomas C. Mather
Chief, NEPA Compliance
Section
Project Officer
Chief, NC/KY Facilities
Planning Section
Senior Project Manager
Project Manager
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Engineer
Public Participation
Specialist
Environmental Engineer
Project Executive
Project Manager
Environmental Planner
Environmental Scientist
Environmental Scientist
-151-
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