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Home My WebLink About790481.tiff CITY OF NORTHGLENN 10701 Melody Dr., Suite 313 Northglenn, Colorado 80234 ` n' 71/4 Phone (303) 451.8326 February 13, 1979 Mr. Chuck Cunliffe Weld County Department of Planning Services 915 - 10th Street Greeley, CO 80631 Re: SUP-378:78:30 Dear Mr. Cunliffe: Attached is additional information which we have prepared in response to testi- mony given at the February 6, 1979 public hearing before the Weld County Planning Commission. The information is organized into the following subject areas: Tab A: Protection of Water Rights Tab B: Groundwater Monitoring Program Tab C: Property Values Tab D: Geologic Fault Map Tab E: Referral Agency Responses Tab F: EPA Negative Declaration Tab G: Site Selection Tab H: Miscellaneous Comments In addition to this information , we have previously submitted the following technical reports to support our application: 1 . Northglenn Water Management Program, Water Resources and Facilities, Volumes 1 and 2, April , 1977, Wright- McLaughlin Engineers. 2. Northglenn Water Management Program, Wastewater Facilities , Volume 3, April , 1977, Sheaffer and Roland. 3. Northglenn Water Management Program, 201 Wastewater Facilities Plan, Volume 4, November, 1977, Sheaffer and Roland. 4. Northglenn Water Management Program, Air Quality Effects , Volume 5, April , 1978, Sheaffer and Roland. Fe Sdr h ,Q <h FC z. I.. -'ccol1'LW 6cWil7cJtli.` Z 790481 NORTHGLENN & [RICO LAND AND WATER RESOURCES MANAGEMENT PROJECT Mr. Chuck Cunliffe ffe February 13, 1979 Page 2 Companies to Cities 5. The Physical and Economic Effects on the Local Agricultural nothey of Water er Tne Mr fIrrigationroom politanArea, Anderson et al , in the Northern Denver hletrOPtober, 1976. Colorado State University , the Northylenn 6. An Archeological Survey of the Area Affected by Water Management Program, Dr. Dean E. Arnold, 1978. 7. Preliminary Engineering and Soils Investigation for a Proposed Reservoir, Sections 26 and 36, Township 1 North, Range 68 West, Weld County, Colorado, Chen and Associates , Inc. , March 16, 1978. 8. Environmental Appraisal for Northglenn Wastewater Treatment Project, Project Number CO 80416-01 September 29, 1978, U.S. Environmental Protection Agency , Region VIII . 9. Subsurface and Geologic Investigations for a Proposed Reservoir Site, Weld County , Colorado, September 12, 1978, Chen and Associates , Inc. . 10. Letter Report, Chen and Associates , Inc. to Sheaffer and Roland, Inc. , November 24, 1978. of the We request that these technical reports be formally submitted as a part hearing record. Please let us know if we can provide any additional information to assist you in your review of our application. Sincerely, ��• Richard P. Lundahl , Director Land and Water Resources Management Project RPL: ry Attach. -- MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. ATTORNEYS AT LAW 75 MANHATTAN DRIVE-SUITE 1 P.O. BOX 4579 BOULDER,COLORADO 80306 JOHN D.MUSICK,JR. TELEPHONE(303)499-3990 GLENWOOD SPRINGS OFFICE STEPHEN T.WILLIAMSON (COLO) 1-800 332-2140 1011 GRAND AVENUE ALAN E.SCHWARTZ February 13 , 1979 P.O.DRAWER 2030 LOYAL E.LEAVENWORTH GLENWOOD SPRINGS.CO.81601 JOSEPH A.COPE TELEPHONE(303)945-8513 SUE ELLEN HARRISON WILLIAM T.SMITH,JR. KEVIN L.PATRICK Mr. Chuck Cunliffe Assistant Zoning Administrator Department of Planning Services Weld County 915 10th Street Greeley, Co. 80631 RE: City of Northglenn, SUP-378 : 78 : 30 Dear Mr. Cunliffe: As requested by the Planning Commission at its February 6 , 1979 hearing, I am forwarding information concerning the City of Northglenn' s water rights and plan for augmentation for the replacement of water under the Northglenn-FRICO exchange plan. I have attempted to present enough information for the Planning Commission without becoming mired down in details. It is, of course, a fine line, and I hope I have trod it successfully. If not, however, we will of course be able to answer questions at the February 20 hearing. The City ' s consulting water rights engineers will also attend the hearing. Enclosed are a listing of water rights purchased or under contract to Northglenn, a carter budget, a memorandum describing the operation of the plan for augmentation, and schematic diagrams of the plan for augmentation. Very truly yours , MUSICK, WILLIAMSON, SCHWARTZ , LEAV e & C .C. By -I Joseph A. Cope JAC:no encs. cc: Richard P. Lundahl Frank Culkin, Esq. Elton Miller MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. 75 Manhattan Drive - Suite 1 Post Office Box 4579 Boulder, CO 80306 MEMORANDUM TO: Mr. Chuck Cunliffe DATE: February 13, 1979 RE: City of Northglenn Water Rights Water Rights Owned by Northglenn: 8. 5 shares Farmers Highline Canal & Reservoir Company 3 shares Brantner Ditch Company 117. 26 shares Farmers Reservoir & Irrigation Company, -Mugshail Lake Division SvAN V..eAt 12 shares Farmers Reservoir & Irrigation Company, Marshall Lake Division 7 shares Lupton Bottom Ditch Company 143 shares Fulton Irrigating Ditch Company 415. 295 inches Golden City & Ralston Creek Dtich (Church Ditch) 41 shares Wellington Reservoir Company 41 shares Burlington Ditch, Reservoir & Land Company 117 shares Eastlake Water Company Berthoud Canal & Berthoud Tunnel (Berthoud Pass Ditch) - undivided interest - part owner with City of Golden Golden City and Ralston Creek Ditch (Church Ditch) W-113 Northglenn Reservoir W-231 Northglenn Shopping Center Runoff Arapahoe Well No. 7, permit no. 22500-F Memo to Chuck Cunliffe February 13, 1979 Page 2 Water Rights under Contract to Northglenn: 40 inches Lower Clear Creek Ditch Company 8 shares Lower Clear Creek Ditch Company 234 shares Burlington Ditch, Reservoir & Land Co. 216 shares Wellington Reservoir Company 1. 35 c. f. s. Reithman Ditch MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. 75 Manhattan Drive - Suite 1 Post Office Box 4579 Boulder, CO 80306 MEMORANDUM TO: Mr. Chuck Cunliffe DATE: February 13 , 1979 RE: City of Northglenn Replacement Water Budget - 1988 Full Population - Acre-feet per Annum - Preliminary Estimates Subject to Court Approval DROUGHT YEAR NORMAL YEAR Treated Water Requirements Household and commercial 4 , 140 4 , 140 Irrigation (lawns and parks) 3 , 200 2 , 700 Total Water Required 7 , 340 6 , 840 Raw Water Sources (Clear Creek Drainage) Farmers Highline 54 107 Standley Lake- share water 585 819 Church Ditch - inches water 135 389 Berthoud Pass 120 608 Arapahoe Well 47 5 5 Sub-total 899 1, 928 FRICO Exchange 6, 441 4 , 912 Total water supplies 7 , 340 6 , 84G Memorandum February 13, 1979 Page 2 DROUGHT YEAR NORMAL YEAR FRICO Exchange Net Amount Borrowed 6,441 4, 912 10% Bonus 644 500 Reservoir Evaporation 316 236 Payback Requirement 7 ,401 5 ,648 Leplacement Water Sewage - Northglenn 4 ,016 4 , 016 Sewage - Thornton Enclave * 885 885 Storm Runoff - Grange Hall Creek 1,000 747 Tributary Well Field 1,500 -0- Payback Water Available 7, 401 5, 648 Augmentation Water Requirements Grange Hall Creek 1,000 747 Tributary Well Field 1, 500 -0- Diversions to be Augmented 2,500 747 Augmenting Water Rights** Fulton Ditch 171 214 Lupton Bottom Ditch 466 466 Lr_antner Ditch 75 75 Marshall Lake 8 35 Burlington-Wellington 1,380 1, 684 Lower Clear Creek 173 224 _ Reithman Ditch 111 111 Carryover Storage _ 116 -0- Augmentation Rights 2,500 2,809 EXCESS RIGHTS: 2 ,062 *Small areas of Thornton will be connected to the Northglenn system, and small areas of Northglenn will be connected to the Thornton system for operational purposes. ** Estimated consumptive use based on 1954 records of diversions and irrigated acreage. Memorandum February 13, 1979 Page 3 Alternative Water Budget - If Deep Wells are Permitted DROUGHT YEAR NORMAL YEAR Treated Water Requirements Household and commercial 4 ,140 4 ,140 Irrigation (lawns and parks) 3,200 2, 700 Total Water Required 7, 340 6 , 840 Raw Water Sources ( Clear Creek Drainage) Farmers Highline 54 107 Standley Lake - share water 585 819 Church Ditch - inches wL.ter 135 389 Berthoud Pass 120 608 Deep Wells 2 ,300 1, 300 Sub-total 3,194 3 ,223 FRICO Exchange 4 ,146 3,617 Total Water Supplies 7 ,340 6 ,840 FRICO Exchange Net Amount Borrowed 4 ,146 3, 617 10% Bonus 500 500 Reservoir Evaporation 316 236 Payback Requirement 4, 962 4 , 353 Replacement Water Sewage - Northglenn 4 , 016 4 ,016 Sewage - Thornton Enclaves 885 885 Storm Runoff - Grange Hall Creek 61 -0- Tributary Well Field -0- -0- Payback Water Available 4, 962 4 , 353 Memorandum February 13, 1979 Page 4 DROUGHT YEAR NORMAL YEAR Augmentation Water Requirements Grange Hall Creek 61 -0- Tributary Well Field -0- -0- Diversions to be Augmented 61 -0- Augmenting Water Rights 2, 609 2, 809 EXCESS RIGHTS 2,548 2, 809 MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. 75 Manhattan Drive - Suite 1 Post Office Box 4579 Boulder, CO 80306 MEMORANDUM TO: Mr. Chuck Cunliffe DATE: February 13, 1979 RE: Northglenn Plan for Augmentation A plan for augmentation is defined as "a detailed program to increase the supply of water available for beneficial use . . . " C.R.S 1973, § 37-92-103 (9) . The important words are "water available" for use, since we do not intend to introduce new water into the river as by transmountain diversions. The Supreme Court of Colorado has held that water is available for use if the diversion of the water does not take water needed by senior water rights at the time and place needed by them. Northglenn' s plan for augmentation will operate so as to remove water from the South Platte River at two places , Grange Hall Creek and the Tributary Well Field (roughly 100th Avenue and Riverdale Road in Adams County) and put other water into the river at the times and the places it is needed by senior irrigation water rights. For planning purposes, we are assuming that all water diverted from Grange Hall Creek and the Tributary Well Field will be taken out of priority and must be replaced 100% . Compare 5% replacement at the present time by G.A. S.P. and the City of Thornton. The first comparison that can be made is between the present operation of the Thornton system and the future operation of the Northglenn system. At the present time, Thornton diverts approximately 5, 500 acre-feet of water per year, mainly from tributary wells , to serve Northglenn. Approximately 3, 060 acre-feet of sewage is collected from Northglenn and returned to the South Platte River at the Metro Denver plant. Another 200 acre-feet returns as groundwater from irrigation within Northglenn. The loss to the South Platte River is approximately 2, 240 acre-feet per year. When Northglenn disconnects from the Thornton system, the Metro flow will stop, but so will the diversions, and downstream water rights will be benefitted by 2 ,440 acre-feet of water each year. Memo to Mr. Chuck Cunliffe February 13, 1979 Page 2 Next, compare the impact on the FRICO shareholders . In the past, FRICO has allocated all water available to it equally among the shares, after deducting the water lost due to evaporation, ditch shrink, and operational losses. Once released from Standley Lake, water has been beyond control, and excess water in the Bull Canal has occasionally wasted from the canal, resulting in a loss to the FRICO shareholders . Because Northglenn will run 6 , 441 acre-feet through the Northglenn system, returning 7, 085 acre-feet at the Bull Canal Reservoir, the evaporation and canal shrink losses will be less than they have been in the past, making more water available to the FRICO shareholders. Because of the 10% bonus, paid by Northglenn, even more water will be available to the FRICO shareholders . Because of the construction of the Bull Canal Reservoir, FRICO will be able to exercise better control over the water in the Bull Canal , cutting operational losses and making even more water available to the FRICO shareholders. The final comparison is between Northglenn ' s diversions from Grange Hall. Creek and the Tributary Well Field, on one hand, and the augmenting water rights , on tle other. The water rights bought by Northglenn were historically used for irrigation. A large part of the _ water diverted by these water rights was lost through evaporation and transpiration. The rest returned to the South Platte River as ditch seepage, underground return flows, and surface waste runoff . In a normal year, the amount of water diverted by these water rights and then lost by evaporation and transpiration has been greater than the amount that Northglenn will take from Grange Hall Creek and the Tributary Well Field. Northglenn will stop using these water rights for irrigation , which will stop the evaporation and transpiration losses . The amount of water diverted from Grange Hall Creek and the wells will be less than the _ water saved from evaporation and transpiration loss. Some of the excess water in a normal year will be stored for future use. In a dry year, such as 1954 , the historic evaporation and trans- piration losses would be slightly less than Northglenn ' s Grange Hall Creek and well field withdrawals. The stored water will be used in these dry years to balance the budget. Northglenn will not take any credit for the water that was diverted by these water rights and then returned to the stream as ditch seepage, underground return flow and surface waste runoff. That water will be turned back into the river for use by others in accordance with their priorities and needs . Memorandum to Mr. Chuck Cunliffe February 13, 1979 Page 3 In order to protect the ditch companies that Northglenn holds stock in, Northglenn will leave enough water in each ditch to make up for the increased ditch shrink that results from Northglenn turning water back into the river. Depending on the desires of each particular ditch company, this will be done either by leaving all the water in the ditch until it reaches the historic place of use and then turning it back to the river, or by leaving some of the water in the ditch and turning the rest back to the river right at the headgate. In order to make sure that every ditch downstream from Grange Hall Creek and the well field will receive the water at the time and place it is needed, Nortnglenn purposely bought water rights in several ditch companies up and down the river. For example, the Evans No. 2 Ditch is one that could be affected. Northglenn owns water rights in the Lupton Bottom Ditch that can be turned back into the river above the Evans No. 2 headgate. For another exam- ple, the Brighton Ditch might not be directly affected, but its call might affect the Fulton Ditch. Northglenn owns water rights in the Fulton, Burlington, and Reithman Ditches that can be turned back to the riser to satisfy the Fulton Ditch. Some of the downstream water rights that will be affected are storage rights , such as the Riverside and Milton reservoirs. Since Northglenn' s water rights are mainly direct flow rights, which cannot be used directly to augment those storage rights, some of the -- augmentation water will be returned to the river during the winter months. This will be done by two methods: storage releases and groundwater infiltration. By releasing water into infiltration ponds during the summer, Northglenn can rely on the natural delaying effect of the groundwater system to deliver that water to the river, and the downstream storage rights, at the proper time of the year. The listing of water ricrhts, water budget, and schematic diagrams accompanying this memorandum illustrate the details of this plan for augmentation. W U T Z Q • CC6 rn W y a LL H � W ji a f CO .c 412 W w V c u W o- o a'+o y Lo r O�= u: ≥ 2 • 08cu o0 LL • Nyy` °' a� 33 Q a w a G Z w ate O N`a Lrn HO -.6- S S 0. " a U�- z �= 43 QZ 0. CL " ' 8 z L G W H el' e� o Gee o C, .1)H O o� o a LL LL f� O a N Q 0 2 • I Xo O . N • (l o -------- > ------------- -- a`, p Q 8O Z s i � 9m• ; cm c m ti LL:ti" ft u ii d WI 0 _ Z g �db4, 00 2 gN — - H H — 0�o 8 ►- �Y. O O►N w g b0° - �'b o'' z 2~ �� 60 ° to Z O$4 Tr oe O ` Z ≥re wz 2 ' J O O 0 vb Ti o 8 E C�_ a o 2.c a LY 015 0 0 O Q o' 4 Fo 3 �n Z v: z w ` y J G(eLLI e* o�3 o Oee� ii vs Z 9 �D 3 W i W� �2w f1 z tt N U d o 0 U I-- a`>a Z o tg 5 cx ... co C C CL W o w 0 wrr 00 O\ I- I- ..o Z � '. CC w 3 a 33 0 H 1-x — I " I- Z �> Q Q w w gL J 2� 3v I_ o' d w ZUw W "ii\ x .:r,_ /2 D wpr O ~ j Q Gt I I 1.` W W a Q J Z Z W J ii,\CD i t _ H- Cr O OI:N/; i':). Z F G�4� Li.. O .\,v U t�P H Nil - Q g GAP = m W .. I-- = o V 0 a) L. L. o: 6. 3 / 1 G/� M ` U p Z C CI iI= Q N t. J 6.�2 11. I C° p+« u W Z o 0 Ow 0�. OO F 0 Q > ( z .c L.. ono Z 0/ 7.,- W 0 d 2 0 U o CD p / a d Cr Q ✓ J n Ct \17 ≤n 7/ _....s a 3 Z ;, W Cr M4.4 /� 1 V pN Q o 2 \ O t 0 F 0 C Cr \ Cl)CI Z \ Z U O \ a Q o CD ` ICD r Cr I c _> I C I SA MEMORANDUM TO: Northglenn/Weld County Special Use Permit Application FROM: F. Robert McGregor A4(. 1 DATE: February 12, 1979 SUBJECT: Groundwater Monitoring Program The purpose of this memorandum is to describe the groundwater monitoring program for the Bull Canal Reservoir site in Weld County. This program will provide the necessary information to monitor the quantity, if any, directions of movement and quality of seepage water from the Weld County facilities. It is also intended to meet the groundwater monitoring development standard recommended by the Weld County planning staff. Reservoir Seepage The reservoir and lagoons are designed to prevent the loss of any seepage water. The site itself is particularly amenable to this type of a system. The underlying soils and geologic formations by their very nature will restrict any movement of seepage. As a matter of fact, the site is under- lain by more than 550 feet of materials which are normally placed in a two-foot thickness in the bottom of reservoirs to prevent seepage. The natural site conditions are further supplemented by three man-made seepage control devices: 1 ) compacted clay liner, 2) cut-off trench made of com- pacted impervious materials , and 3) an impervious asphalt surface, drain collection system and drainage water recirculating system on the inner surface of the reservoir berm. Each of these man-made seepage control devices are discussed in more detail in the Special Use Permit Applica- tion and its supporting technical documents. Baseline Monitoring Program Each well within a one-half mile radius of the site will be sampled prior to the operation of the proposed facilities. The purpose of this baseline program will be to establish present day groundwater uses and conditions. Each well included in this program will be inventoried to establish the quantities and intended purposes of the groundwater usage. Water levels will be measured and water quality samples will be analyzed for compliance with Colorado and federal standards for agricultural and drinking water uses. Operational Monitoring Program Sixteen monitoring wells will be established to monitor the quantity and quality of groundwater movement in the vicinity of the proposed facilities. The locations of these wells are shown on the attached Figure M. February 12, 1979 • Page 2 Each monitoring well will consist of two inch perforated PVC pipe in a sand and gravel packing. This design allows for the free movement of ground- water into the monitoring well . The five deep holes will be drilled into the Foxhills Sandstone formation at an approximate depth of 700 feet. The shallow holes will be drilled to a depth of approximately 40 feet. The proposed configuration of sixteen wells will permit the detailed monitoring of both shallow and deep groundwater movements. Each monitoring well will be sampled on a monthly basis to determine ground- water levels and groundwater quality. Each water quality sample will be analyzed for total dissolved solids, PH, nitrite nitrogen, nitrate nitrogen and chlorides. The water quality parameters and water level measurements will serve as indicators of any significant change in groundwater quality, quantity and flow direction. If any significant changes are detected, a more detailed sampling program will be undertaken to establish whether or not the Northglenn operations are the cause of the change and to assess the possible adverse effect, if any, of the change on the intended usage of the groundwater prior to the Northglenn operations. Annual reports will be prepared by Northglenn to summarize the results and conclusions of the monitoring program. These reports will be submitted to the Weld County Health Department, Tri-County Health Department and the Water Quality Control Division for their review and comment. Mitigation Program Any possible adverse effects on existing groundwater usage resulting from the operation of the proposed facility will be mitigated by one or more of the following methods: 1) adjustments to the method of operation to reduce seepage losses and/or improve the quality of the seepage water, 2) interception and recirculation of seepage water to the reservoir by barrier wells or other suitable methods , 3) drainage of high groundwater areas to return the ground surface to a condition similar to that which existed prior to the Northglenn operations , 4) replacement of existing wells with a new water source of adequate quality and quantity to serve the present day intended uses of the groundwater. It is anticipated that the quantity and quality of the seepage water will not adversely impact the groundwater resources of the area. if all of the man-made seepage control systems included in the design of the reservoir and treatment lagoons were to fail , the underlying geologic formation will restrict the movement of seepage water to less than 20 feet per year. This slow rate of movement will provide sufficient time for Northglenn to imple- ment the necessary corrective actions to mitigate any adverse effects. e s 0 W i I r b mCr max "----/----1—___ \ } I q g =� cal c , a2oa .330 w� o rs ®■\ma7 y� \�® II) $�/� O a 7„ ,,, , ,, , , //,, , , _ ----ici„ , _. ,„.., , i , . .... ir. , ,, , Th, c „, ... ,,_ J, ... , , i ,, , , a„ +) I W w ® l J 0 z a '- . I 71a - �. Y� l jl �� FE J r s I ;�/1 za -c, 6_ _ W Q N W 2 \L.{ CI Cf) o um I g I a �I ( u NI Vi / a W v � \\ p, t --�.� 11 _' t u. 5— i 5 its c7 \ ! \ \\ \ \ 7 / Ii _ \ 1 t' 1• w / 7 1 1 1 ti v �� i C/ _ OE klarait \— '�rl' (G 029]306 J.Y•6Q )GVOW10 by 3dOb.1 - Ti1 y� (aoaa�om) v er\ � � 1 on PROPERTY VALUES The testimony entered into the record of the Weld County Planning Commission of February 6 , 1979 , by Bill Heide, a real estate broker from Aurora, appears to be both misleading and irrelevant. Mr. Heide stated that land located outside of the arbitrary boundaries he suggested of I-25 on the west, 150th Avenue on the sourth, and one mile east and north of the treatment site would sell for $5,000 per acre in the future, while land within that area would be valued at from $1, 000 to $1,500 per acre. The only way that any land in the area could be valued at $5,000 per acre would be as a result of rezoning in direct viola- tion of the Weld County Comprehensive Plan. In quoting from an appraisal manuel, Mr. Heide said: "Pro- visions for gas, electricity, water, telephone service and storm and sanitary sewers are essential to today ' s standard of living in municipal areas. . . if water and sewer facilities must be in- stalled in the future, the value of the land is reduced. " Mr. Heide' s testimony is not relevant to the property value impact of constructing a wastewater treatment and storage facility in a rural area. His testimony, however, does point to the fact that property values are reduced by inadequate water supply and wastewater treatment. Residents of the Weisner subdivision have reported water shortages and dissatisfaction with their septic disposal systems. These are factors which will adversely im- pact their property values, not imagined nuisances envisioned as a result of erroneous information. Actual experience indicates that property values and tax bases respond more directly to actual and poter.tial development than to construction of a wastewater treatment and storage facil- ity such as Northglenn' s . This has been confirmed by a five- year study of the impacts of the Muskegon system, a copy of which is attached. The Muskegon system is similar to that pro- posed for Northglenn and is over nine times larger than North- . glenn' s. The major conclusion of the fiye-year study is that the increases in property value in areas proximate to the treat- ment and storage lagoons were more rapid than in the remainder of the county. The question of possible odor was raised through testimony presented concerning problems with the Louisville aerated lagoons. Attached is a letter from the City Manager of Louisville describ- ing the cause of the brief period of odor problems which was the basis for the testimony. The Northglenn design includes suf- ficient backup equipment to avoid any difficulties which could arise as a result of equipment failure. Northglenn is also pub- licly committed to maintain an adequate, well-qualified staff to operate its sytem at all times. EXCERPTS FROM: SOCIO-ECONOMIC AND ENVIRONMENTAL IMPACT STUDY OF THE MUSKEGON WASTEWATER MANAGEMENT SYSTEM Land Use and Development Development during the period 1970-1977 was very much influenced by general macroeconomic conditions . Between 1970 and 1972 , a period of high unemployment , low interest rates and a fairly low rate of inflation , the dispersion of Muskegon ' s populace continued even as its total population fell slightly . Table IX-5 shows that fro;. 1970 to 1972 , permits for 2 , 300 new dwelling units were issued in the county while permits for the demolition of 583 units were issued . Discounting the construction of 843 units of publicly funded multi- family units in the central cities , 55 percent of the remaining 1 , 465 permits were issued in the Muskegon area suburbs and 22 per- cent for the outer townships . Virtually all the new housing outside the central cities was single family, the central cities suffered a heavy net drop in their single family '.rousing stocks . The net loss of commerical buildings in the central cities was almost entirely Table IX-5: Building Activity in Areas of Muskegon County, 1970-1973 and 1973-1977 1970-1972 1973-1977 New Demo- Net New Demo- Net Area Units litions Units Units litions Units Muskegon Urban Corea Residential 1 , 174 463 +711 ' 757 1, 016 -259 Single-Family 331 NA 42 NA Multi-Family 843 NA 714 NA Mobile Home 1 Commercial 29 92 -63 84 56 +28 Industrial 8 +8 25 3 +22 Muskegon Suburbsb Residential 812 122 +690 1 , 778 154 +1 , 624 Single-Family 791 1 , 343 Multi-Family 21+ 280 Mobile Home 155 Commercial 61 1 +60 161 13 +148 Industrial 2 0 +2 9 1 +8 White Lake Urban Areac Residential NA NA NA 12 2 +10 Single-Family NA NA NA 12 NA Multi-Family NA NA NA Mobile Home NA NA NA Commercial NA NA NA 8 0 +8 Industrial NA NA NA Outer Townshipsd Residential 322 4 +318 842 8 +834 Single-Family 284 NA 534 NA Multi-Family 4 NA 88 NA Mobile Home 34 NA 220 NA Commercial 22 0 +22 24 0 +24 Industrial 0 0 0 0 0 0 1 aCities of Muskegon and Muskegon Heights. bCities of Norton Shores , Roosevelt Park and North Muskegon, and Village of Fruitport, and Muskegon, Laketon and Fruitport Townships . cCities of Whitehall and Montague dRemaining Villages and Townships , including Moorland and Egelston Twps. Source: Building and Demolition Permit Data , Building Departments and Township Clerks Offices of the local units in Muskegon County. IX-60 replaced in the suburbs; new business were formed in the rural town- ships . New industrial operations located in both inner cities and suburbs, capitalizing on in-place infractructure and other loca- tional advantages . From 1973 to 1977 , the combined influence of national "stagflation" and declining automotive sales caused continued high unemployment , peaking in 1975 . The tightening of credit, sharp increases in buil- ding costs and the decline of the practice of speculative tract building had a powerful local impact . Table IX-5 shows that during the post-WMS period, 3 ,397 permits for new dwelling units were issued in the county, 1, 187 for demolition . The central cities expe- rienced a net loss of 259 units despite the construction of 714 units of publicly assisted housing . Discounting the approximately 800 units of public housing county-wide , about two-thirds of the new units were constructed in suburbs and the other one-third in rural townships. The decentralization of the population brought about new activity centers in the suburbs . Completion of the Muskegon Mall reversed the trend toward declining commerical land use in the central cities . Table IX- 6 , which describes land use changes through 1974 , shows the tendancy of the central cities not to hold their activity centers , losing 169 acres of commerical , industrial and institutional land use . The opening of the Mall restored much of the loss . Even by 1974 , prior to the Mall ' s opening, the percentage loss was small . What the table does not show is that the net stock of residential land declined by 54 acres between 1969 and 1974 . The net increase of 773 acres was attributable to public investments in transport/ communications/utilities . Building activity was strong prior to 1974 as evidenced by the development of 3 , 988 acres outside the two urban areas . This activity was chiefly a function of the subur- banization of the County as indicated by the fact that 81 .6 percent of the increase in built-up land was for housing . IX-61 V' C O) N O) bi I U) 0 N N r1 N I O Ca) O) O rd to .-i r-I 0 0 0 o X O) .C a) I + + + + + ro 'O a U r1 I4 C N d) O) N 4) -I) 0 W C W C •r1 4 V' Co N lf1 M In Wa r-i 0 2J al N > O O -r1 li in N Co O 0 .-i •H •ri 4 .1) G '-I 7 +) O 0 0 4 7 N aaU G+ \ ro 0 co 0 N C 4 0) 0 ro � O) ro i) E C •rl 4 C1 10 a1 r+) co V' 4.0 ri ro 4 0 > O ro en en fT N N V' r-♦ U it .-a •r1 y N N N N r♦ r-I Cr) •H -ri W W C 4 - > C c O 0 U .-I .-I '-i cr W 7 ra • U H N 4 E a) .-1 O 0 S-I a U -� 4) V' W \ J.) C C O) N •ri d) C O N rn I co tc rn .-i rn In 7 4 N Hi U C cn 4 0 N 1•i 0 10 l0 N O rI O r1 c4 a b1 N O) .C on + + + + + + N N -ri Pa C.-) X r0 E E 4 4 .-a 0 f0 +I ro U a a .0 - ° 4) --. c I C') N t) N M N -0 r-1 4 C O W .-I ro ea 0 U .i N r•1 In .-I N W O) C E 4 •.-I 10 N re) .-I rI > O .C a O) 7 O) •r1 0 0 a CO N 1_i •ri .-I 4 CD N 3 .) > Cr) 1 H N • W N O a ID! IT b"' 1i IA O) a r) V' 10 V' r+) N N N O) C .I) .--I >1 I N N )9 I-O al '.0 W 0 •N -H , •.1 N }) N 4) in V' N I-- N O .C 4 0 el N C C N H - - - - - - O+ O 3 - (J 0 7 4 -ri N V' .-I co M N •rl .C r-I C U) •rl O a � . 7 H N lf) C) Cl) W r.f0 0 X t • ° C 0) 1`4+ � 3 a • C C O 7 N .1) 7 0 N O 0 W Di 0 co .V .C 0 I tT 'U 10 N V' in N N V 4 f0 -•i 7 •rl 1) C cO 0) N N V' Co lr) in r-i M O) 0 W 2) 2$ Li -H X f0 0 N .--I VI CO M CO X Z C O C N W H • N W 4 - - - - - - N 0 .0 •r1 C O a) a 7 00 r-I r1 en in lf) r-I 7 - • £ .••1 4 E ry r1 to 0 N ei 0 a ' ri -0 N p' r "-wcp,C CO •rrl 'C N X ft �7 -r1 ro N rn O raw C f0 (X f) C 4 O 1°1 54 0 ro r� CO 0) It C 7 3 r-1 X 0 4) fa t)' 4 .1 0 . o ea C) N •r-IC 0 A 4 to E .C I E 7 O) .C O 'Cf U N C 0 0) .C O) 1 O 21 r0 U CI C A RI N 0 X -WC +i >1 0 C 7 •ri O) 10 C 4 .0 a X N 4 0 ••1 r-1 •r1 r•1 X ..- O ill 7 4 --i 7 o b) .C C ." 0 in A .0 p .C PO X Z0) 3 o r-a - C y) 7 10 ro 0 U7) 0) C Z N W W .4 W ro -H N •� • in `X--- I O) X 3 a o 0 7 o 0 1-i •.I +i N X 11 C C f0 0 C -rf X 4 C 0 O G H < 0 0 I.7 H O .C N N N f0 O) 4 C O •- T t' U 4.-I N >1 O) O) - O) r0 OE) 0 O) H .C) .4 JO-) N O HI CO 3 C .H44 +I 00 JH-i r°C u) E N N 1°4 .0 u) N •r1 4 4) 0 0 7 •H •r1 +I •ri f0 O) 0 0 r-1 7 I11 7 74 < 7 b+E 0 V V U a s V CI 0 E X X 3 O W U . 10 A U t O) W en Cl) IX-62 One of the alternative hypotheses regarding the effect of the WMS on land use was that removing more than 10 , 000 acres from the stock of developable land in Egelston and Moorland Townships as well as the relocation of 195 existing households, would retard the process of suburbanization that had begun in the 1960 ' s . In fact, permits to build 102 units of housing were issued between 1970 and 1972 . Data on demolition were unavailable . Housing construc- tion in Egelston Township, which had experienced some suburban deve- lopment in the 1960 ' s , continued both before and after construction of the WMS . Egelston cumulatively added an average annual 2 . 8 per- cent to its housing stock from 1970 to 1972 and 2 . 5 percent from 1972 through 1977 . In the surburban communities these cumulative average annual rates were the same 2 . 4 percent for both periods . In the rural townships, the rate of housing construction increased from 2 . 0 percent to 2 .5 percent for the pre-and post-WMS periods . It can be concluded that although the WMS consumed 22 . 9 percent of the total area of Egelston and Moorland Townships, development that would have been expected to occur without the system was not deterred by a shortage of land or any nuisance believed to emanate from the WMS. Tax Base One of the hypotheses regarding the WMS was that by improving water quality, property values would increase . An alternative hy- pothesis was that by removing 22 . 9 percent of the land from the tax rolls of Egelston and Moorland Townships , the tax base of these communities would be so eroded as to force the increase of local millages to meet expenses . The relative decline in the value of inner city real estate continued its downward trend relative to the rest of the County following construction of the WMS (see Table IX-7) . The average annual increase in assessed value from 1972 to 1977 (5.10 percent) was significantly lower than the 8 . 97 percent average annual rate IX-63 >t I rn 4) 3U-i a a, V' N r HI In V' X HI Z Orn.C a '.o r) 0 PI r-1 0 0 it r" U C Cr) U I + + + + + + C, •-I (1)• .C cw 43 • N O. 0 •r1 0 }I in co r 0 O a, a v HI 4.) V, up I a) •H N C • •• I-- C I •--I O M N N V' M In a, 1/44 N 3 a, HI Ili O rd ri O O3 0 CO r co M a' o r-I el 0 Si > • • • • • • 1/40 IT HI U W a in rn N r ri V' V' 0 •- U) .-I itl rtl O W >-, ri r--I r-4 N N HI ri O N a C O HI .I-I + + + + + + + + Cn •• CZ a) c co W rd 1i it 3 W a •- > C .C ) C) z Q cUcCO a ri -r1 .-i N > --I a N >I 4-) F N C) 4) CO CO N ,D CO In CO Si - ri C a N N V' 0 r1 r-♦ 0 a O 1/40 i .C W O M V' N 4J HI en N c.0O0 •r1 • r W O, in)a .I E -in 4) HI r rir •- en Si a' a) in C o, 0 0 0 0 a, lD • 0 "i a r in CO 'D 0 0 0 lD .. el ID a a) I —I 44. Cr) o, r1 r O v cr .4 rl•M �N .aI N 1/40 v r v > l ' CO 1/40 a1 en N in in itl CO a CO ,D N .-i in N M a, a in - C > W >, N V' M N O3 co V' M • N 0 a) ri 4-) 4) . W N -rl >1 CO It 3i 10 N CO in V' Cr) In O, HI 1/40 U 4) 4) (.0 a) a) r--I co N M N in a) N a) - it YI < g a N N HI ,D > U) 1/40 N N th a) N -H a co to •. r-i 0 N 3 n C O >1 0 a. N C r ‘t, O a, r- o r a N r ' NIT ri itl a a1 C, V' 1/40 N HI O . . N it .C 4i O M in r-I W CO CC V' rJ a) U) O O 4) a) - N it a' N .C I..I HI - a ro QtCo CI) 0 uo 0 in 0 lP N en a) U) - N F( N W a O N V' in .-Ii V' HI >,a • ,a E-+ CO I r-IN N O lD N HI in In HI C a) r-I • C) ro O rd - C O a •- N la W a) 1i > V' irl CO rI N rl r-I r O 4) CT -V' N 0 W Ill a N V' In ri CO Cl N el Cr N it In M W R( W >1 en O N r) co r1 .-4 a, N 0 4) ri - W C) ri 4) X 2 C r 0 rI ti) it 1 i N r-I N M •--I V' r) r) in 0 -r1 .-i W it CO Cl a) r r r-I r HI M a - • .E C, en W 4-I CC a a r-I .-I cr z C W - C E C .C c m coN r >. C C C v it + b • ro ()lc c .--4.--4W - W a a) N P. bl E . to 0 R '0 a) Z O-I f [O ON In CD 0 C UCO C .C >, >I a) X a) N C 4f .C itl W W 1-I 1-4 X 4-I C 4-I N •• O •C c 3i .Q a c N C) W N O -r1 3 3 b' U .`a .aO 0 •.CC •o o a a t z aa)) 3 in r-a N x $i a W C E-+ -rl •ri .9 HI N HI W N N 0 U) a) C re Si N 4 W W W I (1) X 3 ro a) a) 0 O a O tx - Ix • 2 X 34 C C it O C C a a Z lei r1 ri 4 0 o 00 E• 0 re W W W r-I .en •• IT CO W 4) •-I ri N >r a) 0 - a) 2 2 a) _.. CD d a) CUM 34 (1.1 N a 4J •r1 •r) C •rl 0 . N . U r-I .X X 4) a) al HI O C 4-i 4) O 4) r-I in HI O 3i .0 W W •r1 li 4) a) O U) (r) a HI •r1 4) HI HI Cr) a it a a .C < a rn z Z z o 0 U O E. E. o E. Z Z 3 0 <a 3 U CI X) U ro a) U) IX-64 of inflation (Consumers Price Index, All Prices , National Average) . As seen in Table IX-7 appreciation of property values and there- fore, total real assessed value increased in the remainder of the County between 1973 and 1977 compared to the rates recorded between 1970 and 1972 , and to the rate of inflation. This was most notable in the outer townships, particularly since the housing stock increased more slowly there than in the central cities suburbs . Apparently , demand, intrinsic value and lot sizes in the more rural areas con- tributed to this occurrence . Property values did not appear to respond to measured or per- ceived changes in water quality . Properties with water frontage appreciated more strongly than did other properties comparable in size and improvements . Thus, other locational factors were decisive both before and after inception of the WMS . Unfortunately , these data could not be quantified for sections within cities with frontage on Mona, Muskegon and White Lakes . (Such data were available for the section of the rural townships surrounding the WMS sites. ) There- fore, the effect of waterfront location is marked by aggregate trends within the county' s political jurisdictions . On the other hand, the predominant trend to move into less dense neighborhoods , tended to increase the value of suburban and rural property during the 1973-1977 period. This trend occurred despite the fact it .was during a time when the average annual rate of home building fell . In con- junction with the continued deterioration of inner city property values, the overall effect was that an increasing share of the County ' s total real property value, especially residential , is located in suburbs and rural areas . Consequently, the impact of the WMS site on residential loca- tion preferences, on suburban and rural housing values , and on the trend toward suburban sprawl has been minimal . Thus, potential negative tax base and property value impacts of the WMS did not materialize . IX-65 Assessed values in the band of sections within a 2 mile per- iphery around the main WMS site increased more rapidly than in other sub-groupings of county jurisdictions . The rate of growth also ex- ceeded the aggregate growth rate in assessed values for Egelston plus Moorland Townships. While precise data are unavailable , it is clear that this area contained a significant share of the mobile home and large lot development that occurred in these townships . The average annual rate of increase in this parameter between 1972 and 1977, 24 . 73 percent, significantly exceeded the average annual rate recorded prior to inception of the WMS (1970-1972) of 9 . 27 percent . This occurred despite the fact that the average annual rate of home building in Egelston Township in particular tapered off after 1972 (cumulatively, 2 . 38 percent from 1970 to 1972 and 1 . 33 percent from 1972 through 1977) . Similarly , assessed values rose at an increasing rate in the peripheral belt surrounding the White- hall Township site. The evidence suggests the conclusion that feared nuisances associated with the site proved not to be a deterrent to investors; rather it appears that such locational factors as plen- tiful and inexpensive land and comparatively less restrictive zoning were decisive. Not surprisingly, during the period of high inflation following the 1974 oil boycott , the cost of government increased, causing a rise in the effective millage levied . Table IX-8 shows that in all cases the increase in the effective millage from 1970 to 1972 was far less than the 44 . 85 percent rate of inflation . Despite cut- backs in local services , large increases were experienced in suburbs that committed resources to water and sewer systems (Fruitport Village and Township, Muskegon and Laketon Townships , and the city of Norton Shores) . The equalized real value of inner city property declined , increasing the burden per dollar of value . Outer townships , which did not purchase water or sewer sytems , presumably had to meet the educational and safety demands of their increasing populations . Interestingly, in Egelston and Moorland Townships , the increase IX-66 +1 N el CO O ' c 0 CO) N N C71 O M N N a) CT I U C N c0 c 0 0, 0 c $4 1 N .-I a) .C m + + + + + + a C) •-I A 0 w N a N 10 0 )n In 00 N N r CO C' N l0 )l X c • b .--I .-a o • •ul c• c en F-1 \0 In In CI' C' in 0 •.-I N r on ri r r r- 4-) r o r"1 sr,• • ui • D • LW Ui c Ui c ' u'1 .-.w U [, 0 *or 0 \0 01 'Cr CO 7 r If1 '.o In .•i 'C 01 '-i N I C;) o � -4 c0 0 r{ > '.i ♦.p r-{ en in en l0 N M ..I r V C) NI to W .--I \0 N CO •.i N in r in in N .-i ri N N It 01 N en l0 r"1 \0 e-i N D ..-I N r•I N 01 .-I e-I 01 (- C N N 1/40 e-i ID L-a N N _ 01 I .•I N a) x c rt a) E-i r 0. v1 in 0 '.0 N V N 0 CO N 0 en 1/40 $a >1 rn 7 i) .-I 10 LI1 .4 N .-I o Cl $4 .-I e-i v X a CO ro o • • F-1 )-I N 10 Q a' CO f"1 N • 1i p• N In Cr) en dl N N .-I O >. 0 • O N .1) .-i . 4 In 0 .-i M O en U 7 7 A N o RC F 'd Si N a) >i u t iJ C b 'C .-i •> 0 "' 4 0) $i 7 ra •.I 0 a) 14 cc .i O 'O U N U .0 N v) O 'NO LO 0 Ca . •c C S4 .0 a E O r• v • 'y 7 a 'c u) C C U N co 4) a CO a) C N Ul 0 II H 14 o C . EOa 0x U •• 0 v v a) si wu) c I E • 0 ,-I x x i) a) .'i 3 c .-I Fi •p N u, •.i w N O 7 C O 7 H X Z 3 O 13:: U 7 .0 U)) IX-67 in effective millage was virtually nil. Clearly the level of ser- vices had to be cut back, but the argument that the WMS would impose an increasingly onerous burden on the residents of these townships was not realized. Health One of the hypotheses for study related to the impacts of the WMS is that it would improve health conditions . One indicator of water-related health impact is the incidence of Hepatitis . The spe- cific hypothesis tested was that as a result of diversion of sewage wastes to the land treatment system, the number of reported cases of Hepatitis would be reduced. Infectious hepatitis (Hepatitis A) , is a virus which can be transmitted by water, being very stable in water and resistent to chlorine. ' It has been expected that a land treatment type wastewater system is quite effective in removing and/ or neutralizing pathogenic viruses from wastewater. The evidence available, however, does not allow any a con- clusion to be drawn for Muskegon County' s WMS . Data on cases of infectious hepatitis (type A) as reported by the Muskegon County Health Department from years 1963 to 1977 are presented in Table IX-9. It is generally felt that the number of cases reported, and those requiring medication and/or hospitalization represent only a small fraction of the actual numbers of cases which occur. Al- though a slight decrease in the mean number of cases reported is observed following the inception of the WMS , there is insufficient evidence to show that these cases are associated with a reduction in water borne viruses. First, there was no control over the re- porting of Hepatitis cases to determine why some cases are reported 1Fox, John P . , "Human-Associated Viruses in Water" , in G. Berg et al. (eds . ) , Viruses in Water (Washington, D .C . : Interdisciplinary Books, 1976) , p. 42 . IX-66 C •r141 ++ O CO >, a) to a) 1) trl H en O 0 .-1 r-1 • O C 11 C I N •. ya ,0 10 a r1 N O r-! © O a N .i CU .C .C O I + + + + + 1) . 01 040 (00 --1 O N a b a) O, M 0 C O r-I C N •'� •r1 r-1 ill 0 r w in ri cc roto >, r-, O N 1-1 •. 0 O < N a) ri to N C a) N .i N N N N W O al U N Q C O4 to to c rn CO N c to rt 0, 0) rn -el Q r'1 co ri a) Sa o t` W W C• 01 ri in ri in I b rn 04 + + + + + + + + ; C, 3 r- -4 C -i `O CT a) n1 ns +J to H .-I > 'r-. a) Sa O < U cO OO co a W -r1 2 O >, O 3 N 44 N C' 0 al N 0 N S-1 C' .--I 0 C I G. r-1 34 7 Cl m e 10 N H O E N ni O r1 en ri •. = N w .. ON .CO?..11Q 00 ri N Z CI I N a) N O O as H O 0 H in N H O H O co O to O in N M •r1 "n 01 a) n1 O N c c to r-! C' ri 1-I E • .--I = > N 0 VO N .--1 Ln to H •rl C' Q M r0 >, C' en CO r-I N f'1 r) r•-• t0 • a) O 1) N C' to H co Cl N en en r-- O N S1 re) O N en co en ri Ol .Y N ri co a) 4a in Cd O O. N r-1 N M H C• M M n1 r1 l0 > co O l- r- ri N ri Cn W N Ca 1.1 H v--.4 C• b >1 4 ia4 IA 44 N in 1) ri N 14 0 in C) > N Cr O. W 0 ` • N O O >1-W to N 11 1) C O Cn N al N� Cl 10 O N - en P. CD C O I O .to N • N O U M t1- 1n to N 100 P'. H 14 ro O Sa . . O1 H • N O) N O nl O .C U O • 4-+ • U N N CS t` to P. • a) • O 1/40 0 N Z Ol 4-1 11 ta rl CO h a) H O O O. 0) H 0) a) 'C r-I W u) -C v v 3 c < CO CO r-1 to O O O O O to to O N 4-1 .C rl CO 0 10 N en C' CO O (El N N •r1 C C •r1 CT rI . >y a) CO > Cl CO r-1 Ul lfl to rn cn 1) O 3 U • rn 1) m -r1 L O W 2 H C a) 'O >, N W H CO 10 ,0 M to C) Sa E O 4 044 r-1 i0 N c M O W 0 O 0 ra • u) O us s-4 to N N co co N r a, • 2 C O OZU U .--I tn O . . . . . . . . tO O to (u rn a) co a) O, O N "Cr N O rn N 0 1) . to 01 U) U) C 4) (0 O N c r-1 10 ri 01 .C C a) 1.) E O H 5 ul F, U M -H Ol co O 3 •. 3 a) a) o C E ,n c r- x to y CO Z .—I alr l en r-1 in rl U tl 5 C C r-I a r1 CL Z C1 r° SU E en O Y. O .c tri en 0 1 C 14 4 0 .C +1 O 2CO 2 (1) _ of O A Y 1 15 r0 a) . ) a) 44 O N N U U N C C >+ >1 N $a .Y •rl r-1 . H La U C A A 04 rd H a) 0) £ Z4 ril 3 E N E O n1 O Sa -r1 Sa .C .C b A O b a) to r1 .Q O U .Cu) O O. O. S-4 OO .i a U) C) C Z Sa Sa O O a H 4L P H O O1 to 1) r-1 N >, W CI) ill b .4 ...14 10 4 -I O H C O) a) u) in -H 1) 0 to to 4 4 i X 3 O W 2 2 O • NG -- Sots • P.,____ • I L ,JA: 749 Main Street Louisville, Colorado 80027 666-6565 January 23 , 1979 Mr. Joseph A Cope Musick, Williamson, Schwartz , Leavenworth & Cope, P.C. P.O. Box 4579 Boulder, Colorado 80306 Re: City of Louisville - Waste Water Facility • Dear Jay, This letter is in response to your inquiry concerning operational problems at the waste water facility operated by the City of Louisville. In general, the City has been very pleased with the performance of the plant, especially the absence of odor problems . I have been the City Administrator in Louisville for six years. During that time we have had only two isolated incidents at the plant. The first occurred a couple of years ago when our operator was ill and we had to replace him on a temporary basis. The substitute operator was not as well acquainted with the facility as we would have liked, and consequently we experienced a brief period when there was an odor problem. We received one complaint as a result of this incident. The second incident of any significance occurred during September of 1978 . One of our aerators malfunctioned and a replacement areator had to be ordered from the manufacturer . Unfortunately, it took a period of approximately four weeks for this areator to be received and properly installed. During this period of delay, the plant was not operating as designed and we did experience some odor problems and com- plaints resulted , primarily from the Centaur Village area in the City of Lafayette which is immediately downstream from our plant. The odor problem was limted to an eight day period. We temporarily resolved the problem by operating the balance of the plant 24 hours per day. The types of problems we have experienced at our facility are easily remedied. We now have a greater number of personnel who can properly operate the plant and we have decided to keep one complete backup unit on hand at all times . The plant is now operating properly and our backup unit has already been shipped and will soon be in storage at the city facility. The City has been very happy with the operation of its waste water facility and we have taken great pride in the ab- sence of odor problems. Many people, including numerous state and city officials , have toured our facility and expressed amaze- ment at the almost total lack of odor. We feel that our present procedures will prevent any future problems. Please feel free to contact me if I can provide additional information or assistance. • Very truly your , LEON A. WURL City Administrator LAW: cm MEMORANDUM TO: Weld County Special Use Permit File FROM: F. Robert McGregor DATE: February 12, 1979 SUBJECT: Geologic Fault Map Attached are a geologic fault map and cross section of the proposed treatment facility and reservoir site prepared by Chen and Associates. It should be specifically noted that the site is not underlain by any faults. In addition, the reservoir and treatment lagoons are designed to safely withstand the peak accelerations which could result from a major regional earthquake. i r • ,,f ; . G {, C L -C 0 13 [D 0O N 49 J C CO . m U O O V+- C. I- „-I .� O �+ VC , `y o.,t W O V f II A a E J u % N C UI N Y Y .'0 RI N O.NN O W 0 N V N G J O o T O ru d u t_ m c m G = CO •V C i 0 0.It ` O 30 a l.7 {��. �• 'V C-1 O Y dpE 1.. �Q F rn 2 3 O N ! R Q O3 ` E-1c 7 C - 7 i. 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R , \ NI \ i. i i '1.. . w eLt1 , • •il 11 • 11y e REFERRAL AGENCY RESPONSES The plans for the proposed Northglenn facilities have been submitted to the following review agencies . The comments and/or concerns of these agencies and Northglenn ' s responses are sum- marized as follows : A. WELD COUNTY PLANNING STAFF Recommends approval because plan is consistent with the goals and policies of the County Comprehensive Plan and in compliance with the County Zoning Resolution. Fourteen dev- elopment standards are included with the recommended approval. Northglenn Response : Northglenn agrees to comply with all of the proposed development standards. B. WELD COUNTY HEALTH DEPARTMENT Supports the concept of the proposal with some remaining concerns about local odor problems , groundwater c..iality and sludge disposal. Northglenn Response: The proposed system is designed to eliminate the production of offensive odors and to protect the groundwater quality. Northglenn in- tends to comply with the Colorado Air Pollution Con- trol Commission Regulation No. 2 , which deals with the production of offensive odors. In addition, Northglenn has adopted an ordinance which provides that the operation of the facility will not be im- paired by attempts to save on costs by energy cut- backs or overloading of the system. Special development standards have been imposed on the proposed facilities to identify, monitor and mitigate potential problems with any underground seepage which may result in the contamination of ground water re- sources, as described elsewhere in this report. If any sludge is produced by the facilities, disposal will be in conformance with guidelines established by the Colorado Department of Health. Northglenn presently owns more than 700 acres of land which can be utilized for land application of sludge. A maximum of only ] 75 acres of land will be needed for sludge application when the facilities are operating at their ultimate capacity. The first priority for land application will be parcels totaling 400 acres within the Northglenn city limits. C. WELD COUNTY ENGINEERING DEPARTMENT Does not object to the proposal. Northglenn Response: Further response not required. D. ADAMS COUNTY BOARD OF COMMISSIONERS Does not object to the proposal. Northglenn Response: Further response not required. E. TRI-COUNTY HEALTH DEPARTMENT Recommends approval. Northglenn Response: Further response not required. F. WEST ADAMS SOIL CONSERVATION DISTRICT Recommends approval. Northglenn Response: Further response not required. G. COLORADO GEOLOGICAL SURVEY Recommends approval. Northglenn Response : Further response not required. H. COLORADO DEPARTMENT OF HEALTH Does not object to the proposal. Northglenn will be required to apply for a discharge permit from the Water Quality Control Division. The Division will review the application to protect downstream water uses and for compliance with Colorado and EPA water quality regulations and sludge disposal guidelines . The discharge permit will not be granted until Northglenn demon- strates its ability to protect downstream uses and to comply with applicable regulations. Plans and specifications for the wastewater treatment works must be reviewed by the Water Quality Control Division prior to the start of construction. Northglenn Response : The proposed facilities are de- signed to protect downstream uses and will comply with the water quality limitations imposed by the State of Colorado and the EPA. The plans and specifications for the wastewater treatment facilities were submitted to the Water Quality Control Division on January 12 , 1979 , and are currently under review. I. COLORADO DIVISION OF WATER RESOURCES (STATE ENGINEER) Recommends a delay in the special use permit until adequate replacement water sources have been acquired and a water augmenta- tion plan has been approved by the Water Court. Northglenn must also receive approval of plans and specifications for the reservoir from the Division of Water Resources prior to construction. Northglenn Response: The State Engineer' s concerns with Northglenn' s ability to obtain replacement water sources is unfounded. The City has already acquired replacement water in excess of its drought year requirements at the ultimate design population. More information on these replacement water sources and the manner in which they will be used to protect other water users from injury is described in more detail in a separate section of this report. The adequacy of Northglenn' s augmentation plan will ultimately be decided in the Water Court and further discussion of this matter is not pertinent to the decision to grant the special use permit application. Plans and specifications for the reservoir were completed and filed with the State Engineer on January 12, 1978, and are still under review. J. COLORADO DIVISION OF WILDLIFE Does not object to the proposal. Northglenn Response: Further response not required. K. U. S. ENVIRONMENTAL PROTECTION AGENCY Supports the proposed plan and will provide a construction grant to assist Northglenn in building the proposed facility. EPA' s funding of the project is contingent upon several condi- tions specified in its September 29, 1978 , Negative Declaration. Northglenn Response : Northglenn is in agreement with EPA' s assessment that the project will not have a sig- nificant adverse impact on the environment. Further discussion of EPA' s assessment of the project and its grant conditions are included in a separate section of this report. MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. ATTORNEYS Al LAW 75 MANHATTAN DRIVE---SUITE I P.O. BOX 4579 BOULDER,COLORADO 80306 JOHN D.MUSICK,JR. TELEPHONE(303)499.3990 GLENWOOD SPRINGS OFFICE STEPHEN T.WILLIAMSON (COLO) 1-800 332.2140 1011 GRAND AVENUE ALAN E.SCHWARTZ February 13, 1979 P.O.DRAWER 2030 LOYAL E.LEAVENWORTH GLENWOOD SPRINGS,CO.81601 JOSEPH A.COPE TELEPHONE(303)945-8513 SUE ELLEN HARRISON WILLIAM T.SMITH,JR. KEVIN L.PATRICK Mr. Chuck Cunliffe Assistant Zoning Administrator Weld County 915 10th Street Greeley, Colorado 80631 Re: SUP-378 : 78 : 30 City of Northglenn Dear Mr. Cunliffe: On February 6, 1979 , the City of Northglenn ("Northglenn" ) appeared before the Weld County Planning Commission to request a Special Use Permit ("SUP") for construction in southern Weld County of the treatment portion of a water exchange project with FRICO. At that time, some residents of an Adams County subdivision, which is near the proposed site, submitted a copy of the United States Environmental Protection Agency' s ("EPA" ) "Negative Declaration" and "Environmental Appraisal for Northglenn Wastewater Treatment Project, September 29, 1978 " ("Negative Declaration" ) . As you know, the Planning Commission continued the hearing for two weeks , and subsequent to the meeting of February 6 , the planning staff requested copies of the Negative Declaration for eac.1 commission member. These copies were immediately submitted by Northglenn. Northglenn supports the inclusion of the Negative Declaration in the SUP record. It was not submitted previously by the City simply because it is now out of date. The concerns and conditions raised by EPA in the Negative Declaration have basically been satisfied, and a grant award is expected in the near future. But since the Negative Declaration is now part of the record, Northglenn believes that a certain amount of clarification is in order. Initially, it is important for the Planning Commission to understand just exactly what the Negative Declaration actually represents. Northglenn has applied for construction grant assistance from EPA for the project. Prior to EPA granting such assistance, the National Environmental Policy Act ("NEPA") requires EPA to evaluate the environmental impacts of the project and decide the relative significance of those impacts. If the impacts are insignificant, then EPA can issue a "Negative Declaration" on the project, which is in effect a positive statement that the project is environmentally sound. After a review that lasted approximately seven months, EPA decided to issue a "Negative Declaration" on the Northglenn project, and the conclusion of that document is that the Northglenn project will have an "insignificant impact on the environment. "1/ A review of the Negative Declaration indicates that when it was written, there were certain issues that EPA believed needed add- itional responses, although it should be noted that these concerns were not of sufficient merit to postpone the issuance of the document. Northglenn believes that all these concerns and conditions have now been satisfied. To aid the planning staff and the Planning Commission in its review of the Negative Declaration and the present status of the issues raised therein, Northglenn is submitting the following information attached to this letter for inclusion in the SUP record: 1. Summary of the status of EPA ' s major concerns; 2. Letter dated December 8 , 1978 , from Alan Merson, Regional Administrator, EPA, Region VIII to William Korbitz , Manager, Metropolitan Denver Sewage Disposal District No. 1 ; 3. Letter dated January 29, 1979, from Richard P. Lundahl , City of Northglenn, to Harvey Hormberg, EPA Construction Grant Program; 4 . Letter dated October 20, 1978 , from Richard P. Lundahl. , City of Northglenn to Alan Merson, EPA, with attachments; • 5. Detailed analysis of issues raised in the Negative Declaration. Northglenn believes that this information will assist in any review of the SUP. If there are any further questions , the City staff and its consultants continue to be available to respond. Sincerely, MUSICK, WILLIAMSON, SCHWA1TZ, LEAVENWORTH & COPE, P.C. By gAilitl Sue Ellen Ha rison SEH:raw cc : Mr. Richard P. Lundahl Ms. Shirley Whitten Mr. Robert McGregor Francis Culkins, Esq. 1 Negative Declaration, page 3 MUSICK; AY'ILLIAMSON, SCIIWARTZ, LEAVENWORTH & COPE, P.C. 75 Manhattan Drive • Suite 1 Post Office Box 4579 Boulder, CO 80306 MEMORANDUM TO: Weld County Planning Commission FROM: The City of Northglenn RE: SUP-378 : 78 : 30 Summary of Present Status of Major EPA Negative Declaration Issues The present status of the major issues raised by EPA in • the "Negative Declaration" and "Environmental Appraisal for Northglenn Wastewater Treatment Project, September 29, 1978" , ("Negative Declaration" ) is as follows : 1. Sizing of the System At the time of the issuance of the Negative Declaration , a decision had not been made as to whether Thornton, or some other municipality, would be included in the sewage treatment portion of the Northglenn project. Those decisions have been made, and the project will only be treating Northglenn sewage plus an extremely minor portion of Thornton sewage . The facility is designed for approximately 42 , 000 people, the ultimate size of Northglenn. Northglenn cannot increase the size of the facility. The City is truly locked into the present size due to specific EPA construction grant conditions , proposed contracts with Thornton, the boundaries of their Wastewater Management Agency designation, and the fact that any expansion for a significant number of people will require construction of what would in effect be a whole new project. Anyzsuch expansion, if deemed necessary by Weld County, would be subject to SUP review. 2 . Environmental Impacts of the Northglenn , Nott, Grange Hall Creek, and Brantner Interceptors. The Northglenn interceptor transports wastewater from North- glenn north to the treatment site. The other interceptors are smaller and were planned to exist in the Thornton area. EPA had two concerns about these interceptors : (1) interceptor construction activities affecting a wildlife habitat area (prairie dog villages) ; and (2) possible urban develop= merit as a result of the access to the interceptors . Northglenn has agreed to utilize all resonable measures to mitigate damage to the prairie dogs during construction. EPA is satisfied that the animals will he sufficiently protected. EPA was particularly concerned that these interceptors, by providing access for sewage treatment, would encourage urban development. Such development can create adverse environmental impacts such as : destruction. of prime agricultural land, destruction of wildlife habitats, and an increase in air pollution. Three of the four interceptors (Nott, Grange Hall Creek, and Brantner) are no longer going to be constructed, therefore, they do not pose any problem. Due to the elimination of Thornton from the system, they are no longer necessary. In order to alleviate the remaining concerns about the Northglenn interceptor , EPA has placed strict grant conditions on access to this interceptor. Northglenn has agreed to all of the -2- conditions , and these conditions will therefore become an integral part of the construction grant. In addition, on December 21 , 1978 , Northglenn adopted an ordinance which embodies this agreement. The conditions basically prevent Northglenn from allowing any indirect or direct hook-ups to the interceptor north of 136th Avenue for the area between 120th Avenue and 136th Avenue. Hook-ups may be allowed, on a case-by-case basis , only after both Northglenn and EPA have granted permission to do so . 3. Cost Effectiveness At the time of the issuance of the Negative Declaration, EPA believed that the most cost effective method for treating Northglenn and Thornton ' s sewage was the continued utilization of the Metro Denver sewage treatment plant. Once Thornton was eliminated from the project, the new cost figures now indicate that the most cost effective solution for Northglenn is the proposed Northglenn project. 1/ Any change in the present site will increase the cost of the facility. Such an increase would not only be difficult in light of today ' s fiscal integrity, but may jeopardize the very existence of the project because of the cost effectiveness analysis. 4 . Water Rights The issues concerning water rights are addressed in a separate submittal to the Planning Commission. 5. Ordinance Requirements As a result of the Negative Declaration, Northglenn must adopt various ordinances and resolutions concerning : - the prohibition of connections to the Northglenn interceptor - erosion control -- sewer tap 1 Letter dated December 8 , 1978 , Alan Merson to William Korbitz - water conservation - air quality - Rocky Flats Radiological Emergency Response Plan - industrial cost recovery - sewer use - user charges - pretreatment requirements These ordinances are grant conditions , and at this time, Northglenn believes that all conditions for the Step II and Step III 2/ grant awards have been fulfilled. All remaining ordinances not adopted at this time, must be adopted prior to Step III payment from EPA. 2 Letter dated January 29, 1979, Richard P. Lundahl to - Harvey Hormberg -4- • UNITED STATES ENVIRONMENTAL- PROTECTION AGENCY 4, Pp0�tiGAP REGION VIII 186O LINCOLN STREET , • DENVER.COLORADO 80203 'NOV 1 7 1973 Ref: 8W--1'1P Ms. Shirley Whitten Assistant to the City Manager City of Northglenn 10701 Melody Drive, Suite 313 Northglenn, Colorado £0234 Dear Shirley: Y recently met with my staff to discuss the Northglenn project with them. As a result of that meeting, I wish to inform you of the latest status of your request for Step 2 funding. We have received several comments (see attachments) in response to the Negative Declaration .ire issued at the end of September. The majority of these comments favor EPA proceeding with funding of the Northglenn project. The few adverse comments that we received, in our judgment, do not justify further delays in approving the Northglenn project from an environmental perspective. We intend to respond to the adverse com- ments, but we do not envision these responses delaying the Step 2 grant award. The issue of procurement possibly could delay the Step 2 award for • another month. After extensive discussion, I have decided to abide by my staff's interpretation of our procurement requirements as they apply to your project until further notification from our Was' .ington Office on this issue. We have prepared a request for deviation from those regula- tions so that at least part of your Step 2 funding request will become eligible if the deviation is granted. The deviation is requesting that all costs since October 23, 1978 (15 working days after issuance of the Negative Declaration) be eligible for reimbursement under Step 2. We expect a decision on this request by early December. The question of the level of funding TPA will provide to Northglenn vas discussed in my meeting with the staff. Based on that discussion and the information that has been provided to us, the following decisions have been made. 1. Step 2 and 3 will be based on 75% (plus 10% for innovative and alternative components if available) of all eligible Step 2 and 3 costs for all those components of the project which were iden- tified in the Negative Declaration as being approved. • • `"� .'r.7•.0free • • f' � Ms. Shirley Whitten Page 2 • 2. The precise amount of the Step 2 award is contingent on the out- come of the request for deviation from the regulations that presently is under consideration. If the deviation is denied then a Step 2 award cannot he made. If the deviation is granted then all Step 2 costs incurred since October 23, 1973 are eligible for 75% reimbursement. If prior costs cannot be approved, then only costs- incurred after the Step 2 award will be eligible for reimbursement. 3. The 10% additional funding will apply only to innovative or alter- native components of the project and only if approved by the State. 4. Funding under Steps 2 and 3 will be conditioned to preclude payment for design and construction of the alternative and inno- vative components of the project (i.e., the storage reservoir and nitrification portions) until such time that Northglenn has executed agreements which will assure EPA that the effluent will • . be used for agricultural purposes for the life of the project. Reimbursement for design costs of these components will not be given unless these agreements are in ei.fect prior to completion of.Step 2 design work. Likewise, the cost of constructing these components will not be reimbursed without these agreements being executed prior to completion of Step 3. The range of funding that Northglenn would receive under this condition could be as low as $5,000,000 or as high as $7,000,000 (rounded to the nearest .ini..11ion dollars) assuming a cost for the project of about $9,000,000. • 5. Funding and payments under Step 2 and Step 3 will he contingent upon Northglenn satisfying the various. grant conditions mentioned __ in the Negative Declaration. If you have any questions on the above, or if you desire a meeting on these matters please call Jim Brooks on my staff (837-3961) . _.. S.L??c:erely yours, t i an Regional Administrator Enclosures • cc: W. Ron Schuyler • ms ,z:1G`.,4-, jad UNITED STATES.ENNIii-2G'NMENTAL PROTECTION AGENCY `� PEGP0P+ +c nsre�c lr';OLi. 1DEET • OLOPX'OO 80295 DEC 1978 : ' - •„� . bh-. William D. Korbitz, P:E. , Manager . Metropolitan Denver Sewage Disposal District No. 1 64S0 York Street Denver, Colorado 80 229 • Deal- 1O1(6z: ; Thank you for responding to the Negative Declaration for the North- glenn Wastewater Treatment Facility. As you point out, there remain several problems with the proposed Northglenn project. We recognized the existence of these p. oblerns in the Negative Declaration. 11e, how- ' ever, believe that the Northglenn project has sufficient merit to warrant FB'A's funding of Step 2. Inherent in our decision to proceed with Step 2 is the risk that one or more of the problems surrounding this project may preclude it from being built. We believe that these issues can be satisfactorily resolved and therefore we are willing to take the risk of funding Step 2 prior to resolution of all the problems. We will not make a Step 3 grant offer until these issues are resolved. This decision is based primarily on our perception that agricultural water/wastewater exchange projects must be promoted and implemented in the Denver Metropolitan area in order to meet future domestic and agricultural water supply needs. In addition to meeting these needs the Northglenn project will provide adequate wastewater treatment to accommodate its projected growth at a cost which the latest data shows to be cost effective. It is ap- parent that Thornton will continue to rely on the Metropolitan Sewage Disposal District to treat and dispose of its wastewater. Therefore, __ . subsequent to EPA issuing the Negative Declaration, Northglenn has • evaluated the alternative of constructing a facility to treat only its wastewater flows while allowing Thornton to continue to receive treatment from MDSDD01. The preliminary results of this analysis indicate that the alternative of separate treatment for Northglenn and Thornton is cost effective in comparison to continued treatment of both cojmunitics' wastewater at Metro. Consequently, the question of need for the project has been resolved in our minds. We probably will not be in a position to make a grant offer to Northglenn until the first of the year. We are hopeful that the agreements among all the carar•.unities in the North area which are af- • - 2 - fected by the Yorthglerm project, will be executed prior to making this grant offer. If this does happen :Tony of our mutual concerns will be resolved prior to Step 2 grant We hope that you and the Board agree with us that the Northglenn the bettertmanage theothers available it, water needed resources of therarea.litan area to ere[(ly yours, i Alan Person I egional ildirinistrator cc: Shirley Whitten Ron Schuyler //;1` CITY OFNOItTHGLENN / At _ ' ..: , ,thY v. ,; 10701 Melody Dr., Suite 313 �""� "' ,ti's" � :r' _ NorthClerin, Colorado 80234 Phone (303) 451•£3326 January 29, 1979 • Mr. Harvey Hormberg Construction Grant Program Region VIII • Environmental Protection Agency 1860 Lincoln Street Denver, CO 80203 Dear Mr. Hormberg: Enclosed please find copies of certain ordinances and resolutions recently adopted by the City of Northglenn in compliance with Step II and Step III • grant conditions: 1 . Ordinance Prohibiting Connections to the Northglenn Interceptor: Adopted December 21 , 1D78. 2. Schedule for Adoption for Erosion Control : Adopted . December 21 , 1978. 3. Sewer Tap Ordinance: Adopted December 21 , 1978. 4. Ordinance for Erosion Control of New Developments : Adopted December 21 , 1978. • 5. Schedule for Adoption of Water Conservation Ordinances : Adopted January 18, 1979. * 6. Resolution Concerninj Air Quality: Adopted November 16, 1978. 7. Radiological Emergency Response Plan (RERP) : Waiting EPA guidance until RERP has been prepared by the appropriate authorities. With the exception of the RERP, Northglenn has now completed all conditions for awarding payment of a Step 1 ! grant and award of a Step II ! grant. On December 13, 1978, Sue Ellen Harrison, of Musick, Williamson, Schwartz, Leavenworth & Cope, P.C. , discussed the problems of the RERP with Bill Geise of the EPA. By making adoption of the RERP a condition of Step III award, • • EORTNCLENN & FRUCO AND AND WATER RESOURCES MMlAGEWIT PROJECT Mr. Harvey Hormber'g . January 29, 1979 Page 2 • . Northglenn is faced with an impossible condition due to the incomplete status of the RERP. Mr. Geise indicated that he agreed with our position and that he would discuss other alternatives with Terry Anderson for the RERP. Northglenn has not heard from either Terry Anderson or Mr. Geise -at this time concerning this condition, but the City wishes to reiterate its position that they will adopt the necessary RERP requirements as a Step III payment condition, but cannot do anything with the RERP within the necessary timeframe for Step III award. As all the various conditions have now been fulfilled, Northglenn believes that EPA can now proceed with a Step III award. Due to our present tight timetable of March 1 , Northglenn requests that EPA inform us immediately of any remaining conditions or procedures that are as yet unfulfilled in the Step III award process. We have also enclosed a letter from Dr. Alfred T. Whatley, Chairman of the Colorado Air Pollution Control Commission, and an article from the Rocky Mountain News , wherein Northglenn received - recognition for moving ahead in committing to improve air quality. if you have any questions, pleDse give me a call . Sincerely, Richard P. Lundahl , Di rector Land and Water Resources Management Project RPL: ry • xc: Sue Ellen Harrison, Esq. • H'.l• 'J b S S kt COLORADO DEPARTMENT OF HEALTH 4210 EAST 1iT1I AVENUE • DENVER, COLORADO 80220 • • November 28, 1978 Honorable Alvin B. Thomas, Mayor • • City of Morthglenn • 10701 Melody Drive -- Suite 305 - Northglenn, Colorado 80234 • Dear Mayor Thomas: . On behalf of the Colorado Air Pollution Control Commission I would like to extend our sincere thanks to the City of Northglenn for their submittal at the public hearings recently held on the State Implementation Plan. • The definite commitments which the City of Northglenn has made with respect to specific programs t , reduce air pollution, thus helping to attain • and maintain Federal Ambient Air Quality Standards were certainly helpful to the Commission. You may be interested in knowing that the City of Northglenn was the only local municipality in the Denver Metropolitan area to make sucn specific commitments , and again, for that the Commission is most appreciative. Please extend to members of the City Council our appreciation as well . We look forward to working with you in the future as the Commission engages in additional programs to clear our air. Sincerely, f- ,--- 04/4 ( t,6(d/ Alfred T. Whatley, Ph.D. Chairman ATW:fg . CITY OF NORTIIGLENN 10701 Melody Dr., Suite 313 • Northglenn, Colorado 80234 .r„„ Phone (303) 451.8326 October 20, 1978 Mr. Alan Merson, Regional Administrator United States Environmental Protection Agency Region VIII 1860 Lincoln Street Denver, CO 80255 Re: Northglenn Wastewater Treatment Facility Project No. C-080416-01 (Step II ) Dear Mr. Merson: On September 29, 1978, the U.S. Environmental Protection Agency, Region VIII (''EPA") published for comment its Negative Declaration and Environmental Appraisal on the City of Northglenn 's application for a Step II grant award for Northglenn 's proposed wastewater treatment facility ("Northglenn facility") . Northglenn concurs with EPA' s determination that the environmental effects of the construction and operation of the Northglenn facility have been adequately addressed in EPA' s Overview EIS for the entire Denver region , and that, as a result, no additional EIS need be prepared under Section 102 (2) (C) of the National Environmental Policy Act ("NEPA") . We understand that Northglenn has now met all of the requirements for a Step II grant , and expect that the award will be forth- coming once the period for comment on the Negative Declaration has expired. Northglenn , however, believes that a number of statements and findings con- tained in the £nvironr.antal Appraisal are inaccurate. When these inaccuracies are removed, the Environmental Appraisal provides even stronger support for EPA's determination that an EIS is unnecessary, and further, presents a compelling case for the issuance of the Step II grant award to Northglenn. In this context, Northglenn submits the following specific comments and recommendations: 1 . Page 69: Cost-Effectiveness Analysis. EPA compares the cost of the Northglenn faci l i ty, an innovative/alternative technology project, with the "status quo" traditional technology alternative, identified as combined treatment of the Northglenn and Thornton wastewater at the Metro Denver facility. It: concludes that the Metro Derive-- alternative is the most cost-effective alternative. North- glenn takes issue both with EPA's authority to consider Metro Denver as an alter- native to the Northglenn facility, and with EPA' s cost calculations for that "alternative". First, Northglenn strongly objects to EPA' s selection of Metro Denver as the most cost-effective alternative. The inclusion of Metro Denver as an alternative in the cost effectiveness analysis is not consistent with the treatment works HORTHGLENN & fRICO LAO AO WATER RESOURCES MANAGEMENT PROJECT Mr. Alan Merson - October 20, 197b Page 2 • identified in the Denver Regional Council of Governments (DRCOG) Section 208 Plan. 1 It is also inconsistent with the conditions for facilities siting set forth in EPA' s final action on the 208 EIS.2 As discussed in detail by letter from Worthglcnn's counsel to EPA, the Clean Water Act and EPA's regulations thereunder preclude EPA from considering Metro Denver as an alternative in its cost effectiveness analysis.3 Second, EPA has understated the cost of the Metro Denver alternative by failing to include in its calculations all the costs necessary for Metro Denver to meet applicable technological and water quality-based effluent limitations , as required by EPA's regulations. One of the conditions in the selection of an alternative is that the alternative provide for t4ie attainment of all water quality standards applicable to the receiving water.`4► In calculating the costs of each alternative, EPA must include the costs of compliance with all water quality-based effluent limitations.? The analysis presented in the Environmental Appraisal is in error because it is based upon the existing Metro discharge permit and not upon the water quality standards of the receiving water. The present Metro discharge has ren- dered Thornton' s existing water intakes unusable. Furthermore, the requirements of the existing Metro discharge permit will not attain the existing stream standards since it does not include a limitation on nitrate nitrogen.° ". . . In fact, the water quality for Alternatives 2 and 3 (down- stream from the Metro Denver Sewage Treatment Plant) is such that it should not be considered a viable source of raw water for the City of Thornton. The contaminants that present the greatest problem with respect to treatment are nitrate, nitrite, viruses and dissolved solids. Treatment of this water would require "state of the art" technology which has not been demon- • strated to have the reliability needed for a municipal water system. Even if the processes were reliable, the cost would probably be prohibitive." lDenver Regional Council of Governments Clean Water Plan , Resolution Adopting an Amendment to the Clean Water Plan to Designate Worthglenn as a Management Agency, DRCOG, Dec. 21 , 1977. Letter from Richard P. Lundahl to Alan Merson, Regional Administrator for Region VIII , Sept. 22, 1978. -U.S. Environmental Protection Agency, Region VIII , Denver, Final Action on the Denver Regional Environmental Statement for Wastewater Faci l i tiess and the Clean Water Program (August, 19721) pg. 7. 3Letter from Musick, Williamson et al . , Counsel' for llorthglenn, to Mr. Alan Merson, EPA Regional Administrator for Region VIII , dated August 31 , 1978 (Attachment A) . .40 CFR 35.917-1 (d) (4) , 43 Fed. Reg. 44022, 44060 (Sept. 27, 1978) . 540 CFR Part 35, Appendix A(6) (a) , 43 Fed. Reg. 44022, 44057, (Sept. 27, 197O 6Water Diversion and Treatment Reconnaisance Study for the City of Thornton , Colorado, C11211 Hill , June, 1978. Mr. Alan Verson October 20, 1978 Page 3 There has been some speculation on the part of a few individuals that a cleanup of the Metro effluent will not improve the quality of the South Platte. Northglenn disagrees with this point of view and agrees with EPA's assessment of the situation:7 ". . .EPA is convinced that instream water quality of the South Platte will be improved if Metro Denver constructs and operates a facility that is designed to control ammonia and/or nitrates. . ." Some interests have also speculated that the South Platte Rive- will be downgraded. Such speculation is not appropriate to consider in identifying the cost-effective alternative especially because this kind of speculation is poorly founded. EPA rejected recommendations to downgrade the South Platte as a part of its approval of the Denver 208 Plan.8 ". . .The present water quality assessment appears not to adequately support the Plan's recommended downgradings for the South Platte downstream from Littleton and Clear Creek downstream from Golden. Sufficient documentation '..ill need to be provided to EPA before these downgradings can be approved. The criteria identified under 40 CFR 130. 17(c) (3) (i-iii ) will be used to assess the aJequacy of the documentation. These criteria are: (1 ) the existing designated use is not attainable because of natural background; (2) the exist- ing designated use is not attainable because of irretrievable man induced conditions; and (3) application of effluent limitations for existing sources more stringent than those required pursuant to Section 301 (b) (2) (A) and (B) of the Act in order to attain the existing designated use would result in substantial and widespread adverse economic and social impact. In addition to tests for down- grading, the State must assure that existing instream uses are main- tained (4+0 CFR 130. 17(e) (1) ) . The State of Colorado in its certification of the Denver 208 Plan has also rejected proposals to downgrade the South Platte.9 7EPA Region VIII , Environmental Appraisal for Ilorthglenn Wastewater Treatment Project, September 29, 1978. 8Letter from Alan Merson, Regional Administrator to Honorable Richard 'Lamm, • Governor of Colorado, August 5, 1978. 9Letter from Richard D. Lamm, Governor, to Mr. Alan Merson, Regional Adminis- trator, January 10, 1973. • • Mr. Alan Merson October 20, 1978 • Page 4 Therefore, the cost estimates on page 69 of the Environmental Appraisal must be revised to reflect the cost of compliance with existing stream stan- dards: • a. Present Worth of Northglenn Proposal $21 ,890,90010 (1980 Capital Cost $14,637,400) b. Present Worth Cost of Status Quo Alternative $18,729 ,500 (1980 Capital Cost $9,600,300) The Northglenn proposal is the most cost-effective alternative. EPA regu- lations grant a 15 allowance in the cost effectiveness analysis for alternative technology proposals. Once the 15% allowance is included, the estimated costs of the two alternatives are within 1 .6% of one another. This is an extremely small difference and is well within the margin of error in planning level cost estimates. These factors, in combination with the obvious environmental benefits of open space preservation, air quality enhancement and energy conservation, clearly identify the Northglenn proposal as the cost-effective plan. 2. Page 1_ Reference Documents. The reference document list should be expanded to include "Northglenn Water Management Program, Air Quality Effects , April , 1978, Sheaffer and Roland" and "An Archaeological Survey of tie Area Affected by the Northglenn Water Management Program, 1978, Dr. Dean E. Arnold". These documents provide key information for determining the environmental effects of the Northglenn project, and were submitted to EPA early in the environmental review process. 3. Page 5: Total Water Resource Project. The phrases "year-round• storage" and "pumping large quantities of groundwater" are misleading. The storage reservoir will hold approximately 9 months of wastewater flow. The quantity of groundwater that may be developed from both shallow and deep wells combined under the Northglenn plan is 3370 acre feet in an average year. This is less than 1`G of the water already being pumped each year from these aquifers , and is not "large" from the regional perspective. Also, the effects of the _ shallow well (tributary) pumping on the South Platte flows will be mitigated by senior water rights already purchased by Northglenn. 14. Page 6: Total Project Cost. The statement that the total project cost will probably exceed $50 million is without basis in the record. The cost of the Northglenn water supply and wastewater systems will be substantially less than EPA's estimate. 5. Page 6: Collection System. The phrase "collection system" should be changed to read "interceptor system" in paragralih 3a. 10Cost of Northglenn implementing agricultural reuse proposal with Lower Thornton continuing treatment at Metro Denver. Further documentation of these costs will be provided under separate cover. • Mr; Alan le rson October 20, 1978 Page 5 • 6. Page 15: Sludge Disposal . By letter of September 11 , 1978, from Mr. Richard P. Lundahl to Mr. Alan Merson, Northglenn provided EPA with the details of its sludge management plan, including implementation and a contin- gency plan. 7. Page 16: Table 1 . Northglenn does not agree with the statement in Footnote 1 that the collection system improvements and the purchase of the storage reservoir site are ineligible for EPA funding. 8. Page 26: Table 4. Table 4 must be amended to apply the following discharge limitations to Metro Denver. These limitations must be imposed in order to meet the water quality standards applicable to the present South Platte stream classification (B2) : ROD 5 mg/1 SS 5 mg/1 NH3-i1 1 mg/l NO3-N1 mg/1 P01{-P 8 mg/1 9. Page 27: Groundwater. It should be noted in the second paragraph of this subsection that the estimate of potential yield and storage coefficients are based upon the best available information using formulas established under Colorado law. Northglenn will file an augmentation plan in Colorado Water Court which will mitigate the impacts of groundwater pumping pursuant to Colorado law. 10. Page 67, Second Paragraph. Northglenn disagrees with EPA' s suggestion that the raw water source is a factor to be considered in determining whether or not a wastewater management proposal is "alternative". A proposal does not have to be an agricultural exchange project to be "alternative" or "innovative". 11 . Page 42, Paragraph 2. Attachment B is a report submitted by Sheaffer & Roland, Inc. , entitled, "Northglenn Water Management Program, Waste- water System Effluent Quality", Oct. 16, 1978. This report addresses the remain- ing concerns of EPA on the design of the wastewater facility. 12. Page 81 , Condition 8. Stonehocker Dam is not an integral part of I4orthglenn' s water supply or wastewater disposal plan. Colorado law prohibits the construction of this dam without State Engineer's approval ; therefore, EPA's desire to tie that approval to Step III award is not only unnecessarily restrictive, but could conceivably be very costly if Northglenn decides to delay design of the dam. EPA should maintain flexibility with regard to any grant conditions involving the dam. if you would like further clarification of our comments , please let me know. Sincerely, Richard P. Lundahl , Director Land & Water Resources Management Project 1'lu.�l .,!v, .x„_;111 • U: .)'... . E* fV.Aiti , • LEAVEN\"✓OR I I I & COPE, P.C. ATI ORNLYS Al LAW 75 MANNA I IAN URI\L - SCIII E I P.O. [1O\45]9 BOULDER. COLORADO 80306 JOHN D. MUSICK,JR. TELEPHONE 13031 499.3990 GLENWOOD SPRINGS OFFICE SIEPIIILN I. WIt1IAMSON (COLO) 1.800332,2140 1011 GRAND AVENUE ALAN L SCI I\\ARIL P.O.DRAWER 2030 LOYAL L II A\LNWOR IH GLENWOOD SPRINGS.CO.81601 JOSEPH A. COPE 1 ELEPHONE(303)945.8513 SUE ELLEN HARRISON WILLIAM]. S?1IIII.JR' August 31 , 1978 'ddmnmd V0 &U C onl,. Mr . Alan Merson , Regional Administrator United States Environmental Protection Agency Region VIII 1860 Lincoln Street Denver , CO 80295 Re : 208 Plans and the screening of alternatives for the cost effectiveness analysis Dear Mr. Merson : aresently , there is a disagreement between the City of Northglenn and the Region VIII EPA staff as to whether 208 plans provide the basis for the screening of alternatives in the cost effectiveness analysis . The purpose of this memo is to explain the basis for Northglenn ' s position that the 208 plans do serve this useful function , and that to rule otherwise is clearly contrary to the Clean Water Act and its re- lated regulations. In summary , the cost effectiveness guidelines require alternatives to be screened as to their capability to meet federal , state and local criteria . The 208 Plan is a proper basis for determining such criteria . In addition , EPA cannot fun3 projects which are contrary to the 208 , thus making it a wasteful exercise to evaluate any such alternatives . Appendix A - Cost effectiveness analysis guidelines , 40 CFR §35 , 5 (b) states the following : . . . the identified alternatives shall be systematically screened to define those capable of meeting the applicable federal , state and local criteria. The screening of alternatives represents an extremely important process in the cost effectiveness guidelines , for without legitimate screening the cost evaluations could be endless . Paragraph 5 (b) sets forth what can be considered as the minimum basis for the elimination of unnecessary alternatives - they must be capable of meeting federal , state and local criteria. ATTACHMENT A D1r . Alan Pierson August 31 , 1978 • Page 2 This section of the regulations is not particularly clear on what myriad of requirements could enter into such a deliberation, but there is some rather clear guidance in the federal Clean Water Act and other regulations. Obviously, " federal , state and local criteria" would include water quality standards and effluent limitations . In addition, it appears equally important that such criteria should include 303 (e) and 208 plans . Presently , enormous funds are being expended to develop adequate 208 plans . If the integrity of both the planning process and the construction grants program is to be maintained , then these plans must also guide in the funding process . If these plans can be ignored , then what meaning do they possibly have? In fact, the Clean Water Act requires 208 plans to identify "treat- ment works necessary to meet the anticipated municipal waste treatment needs of the area over a twenty year period" . Section 208 (b) (2) A, 33 U. S.C. §1288 . Thus the plans must , by law, identify alternatives and EPA approval of such plans is concurrence that this requirement has been satisfied . EPA approval also makes these plans enforceable pursuant to federal law. As such, the 208 plans are clearly "federal , state and local criteria" and truly provide the most logical basis for the screening of alternatives in the cost effectiveness analysis . The Clean Water Act of 1977 makes it extremely clear that a grant cannot be approved unless the treatment works covered by that grant are included in a 208 plan . Section 204 (a) states : Before approving grants for any project for any treatment works under §201 (g) (1 ) , the Administrator shall determine - (l ) that such works are included in the applicable aea wide waste treatment management plan developed under §208 of this Act . . . 40 CPR §35 . 925-19 sets forth certain requirements that the Regional Administrator shall determine have been met before awarding grant assistance. At §35 . 925-19 , this determination is as follows : That, pursuant to §208 (d) of the act, after waste treatment management agency has been designated for an area , and a final plan for such area has been approved, the applicant is a designated agency and the treatment works project is in conformity with such plan . Mr . Alan Person August 31 , 1978 Page 3 In addition , the present regulations at §35 . 925-2 , in fact do require conformity with any applicable 303 (e) basin plan .. In obvious recognition of the importance of the 208 process , on June 2 , 1978 , EPA published the following proposed changes to this section : . . . that the project is consistent with any applicable water quality management plan approved under Section 208 or Section 303 (e) of the act ; and that the applicant is a waste water management agency designated in any plan certified by the governor and approved by the Regional • Administrator . (43 FR 24248 ; Environmental Reporter , Current Developments , June 9 , 1978 , Volume 9 , No . 6 , Page 214 ) . It is obvious from the Clean Water Act and the regulations related thereto , that EPA cannot award a grant unless the contract is consistent with the 203 plan. Therefore, the 208 plan becomes the logical basis for establishing the alternatives to be evaluated under the EPA grant process . Time and money spent evaluating a non-208 alternative will be wasted, for EPA is powerless to grant monies for such projects . A related aspect of this analysis concerns EPA ' s ability to issue grants to other wastewater management agencies . Since EPA is unable to award grant money in violation of the 208 plan , they cannot give grants to others for expansion that would include Northglenn . Northglenn is the waste water management agency for the Northglenn area , and therefore Northglenn is the only agency that can receive grant monies to treat Northglenn ' s sewage. Although it has never been articulated by the Region VIII staff, their position may be based on 40 CFR 35 . 917-1 (d) (3 ) . In setting forth the content of a facilities plan , this section includes "an evaluation of improved effluent quality attainable by upgrading the operation and maintenance and efficiency of existing facilities as an alternative or supplement to construction of new facilities" . That section of the regulation must be read in conjunction with the Clean Water Act, Appendix C and the other regulations cited above. It cannot be read in a vacuum. Such an alternative would only be valid for cost effectiveness determinations if it was consistent with the 208 plan. Mr. Alan Merson August 31 , 1978 • Page 4 In addition, it should be noted that the 208 plans are of extreme importance to the State of Colorado in its implementation of the Colorado Water Quality Control Act, CS 1973 , 25-8-101 et seq . The Water Quality Control Division cannot issue NPDES permits which violate 208 plans. C. R. S. 1973 , 25-8-503 ; Regulations of the state discharge permit system; §6 . 1 . 5 (A) . When granting site approvals , the Water Quality Control Commission places enormous emphasis on 208 plans. The "Procedural regulations for site application for sewage treatment works" states at 2 . 2 . 3 : " it is the policy of the commission to carefully review site applications to ensure . . (3) that all sewage facilities are constructed in accordance with the state and federal continuing planning process . . . " Thus it appears that any alternatives evaluated which are inconsistent with the 208 plan could not be built and operated pursuant to state law, and the expenditure of funds on such alternatives would be futile. In conclusion , Northglenn believes that the Clean Water Act and its related regulations ; the inter-action of those federal requirements with state law; and the 208 process itself clearly require the 208 plan to be the basis for the screening of alternatives pursuant to 40 C 'R §35 , Appendix A 5 (b) . EPA has approved the 208 DRCOG Clean Water Plan and therefore that plan should determine the alternatives to be evaluated by Northglenn in the cost effectiveness analysis . Very truly yours , MUSICK, WILLIAMSON , SCHWARTZ , LEAVENWORTH & COPE , P .C. r / By ( / 7 i r t : Sue Ellen Harrison SEH/ln cc : Richard Lundahl Robert McGregor Charlie Murray Lou Maracheau Terry Anderson • • • • ShEAJ Ca RCAANGp • Chicago Washington,D.C. Denver Environmental Planning & Engineering • So!or Energy • Resources Management • October. 16 , 1978 • Mr. Richard P. Lundahl Director of Public Works City of Northglenn 10701 Melody Drive Northglenn, Colorado 80234 • Subject: Northglenn Water Management Program - Wastewater • System Effluent Quality . Dear Mr. Lundahl: The purpose of this letter is to present documentation to demonstrate that the effluent from the storage lagoon of the proposed Northglenn Wastewater System can meet the USEPF\ rs maxi- mum limitation of 30 mg/1 for Biochemical Oxygen Demand (BOD) and Suspended Solids. The layout for the proposed three cell- aerated lagoon and storage reservoir facility is shown on the attached Exhibits A-1, A-2, and A-3. • • Aerated Lagoon Design The process design basis for the three-cell aerated lagoon is discussed as follows: • Cell I -- is a 24-hour rapid mix lagoon designed to permit bacteriological synthesis )f the readily • biodegradable organics. Virtually all of the soluble BOD and readily degradable suspendGa BOD will be syn- thesized in the 24-hour cell. ATTACHMENT B 130 North Franklin Street Chicago, hlinois 6060G (312) 236.010G . .. \. \.••. _ U, j //:, . . . . . . , . ( 2 • Cell II - is a facultative aerated lagoon designed to permit sedimentation of the heavier solids and to facilitate endogenous respiration and stabilization of the synthesized BOD. This cell will have a detention time of 4 days. Algal synthesis together with nitri- fication will be initiated in this cell. Cell III - is designed to facilitate oxidation of the synthesized organics and additional nitrification and algal production. This cell is designed with a detention time of 9 days with tapered aeration to facilitate sedi- mentation of biological and algal solids produced. Storage Reservoir The storage lagoon will act as an additional two-cell solids stabilization and settling lagoon which will further reduce the availability of critical nutrients required for algal synthesis. Effluent from the third aeration cell will be discharged to the deepest portion of the storage reservoir. This portion of the reservoir will be separated from the final • discharge location by a low head wall which will facilitate the further flocculation and sedimentation of algal solids. Facilities having a low level of aeration and mixing would be provided in this portion of the storage lagoon to facilitate algal flocculation and deposition. The operating depth in the deepest part of the reservoir (at the discharge point of the third aerated lagoon) will vary from 49 to 12 feet. In the final outlet portion of the storage reservoir the depth will range from 39 to 2 feet. The most critical time for the increased production of algae will occur during the mid-summer period when the water level in the storage reservoir will be drawn down to its lowest level. How- ever, any possible increase in solids concentration at that time • . will be offset by the irrigation makeup return flows which will dilute the wastewater by a ratio of about 1 :1. These added flows will be relatively low in available nutrients. • Effluent Quality -- It is anticipated that the aerated lagoons should produce an effluent low in alkalinity, nitrogen, phosphorus, and trace • • minerals. The aerated lagoon effluent should have a pH above 9 and contain little biological solids . Ammonia nitrogen will either be stripped by aeration or converted to nitrates, and most of the phosphates and iron will be precipitated at the elevated pH. The aerated lagoon effluent will not support significant algae growths without additional nutrients being added from outside sources. The exact amount of algae production in the reservoir can only be determined in the field after construction. However , the best information currently available indicate that ' the effluent quality should meet current EPA 30/30 effluent criteria. Exhibit B presents a discussion of the biological and chemical process dynamics of the lagoon treatment and storage system prepared by Dr. Ross E. McKinney of the University of Kansas. This discussion presents the theoretical basis for ' the system' s expected abjlity to meet the 30/30 standards. Empiric-il Operat.inc Experience Experience with the operation of three-cell, relatively deep aerated lagoons in Colorado has shown that a properly designed system can achieve a high quality effluent throughout the year. Examples of such systems include Louisville end 1'?-cwt. Design and performance data on these systems are presented in the attached Exhibit C. The facilities are designed as tapered aeration systems with a relatively rapid mix in the first cell followed by successively reduced aeration levels in the suc-- - seeding cells. In some cases the subsequent cells are not aerated. The total detention time for these systems ranges from 30-60 days with a liquid depth from 11 . 5 to 13 feet. Suspended Solids con- centrations in the effluent is below or at 30 mg/1 in virtually all cases. • Performance data are also presented in Exhibit C for a number of relatively deep, multiple--cells lagoon systems in other states. These include: Pawnee, Illinois, Windber, Pennsylvania and Lake Koshkorong, Wisconsin. These systems are ai.i three cell- - lagoons with detention times ranging from 47 to 143 days with depths varying from 7-10 feet. All three systems produce consistently low effluent suspended solids levels. Data for these lagoons on nitrogen and phosphorus indicate that one or the other of the constituents appear to be removed to low residual concentrations in the effluents. ..... . . _., .. .� S r J ..v. .... _. • r . • . n v.. ...1. ✓.. . __ , J . . . . . . i. aV.0 4 Comparison data for two and three-cell lagoons in Colorado indicate that three-cell lagoons achieve much more consistent suspended solids removal performance. * * * * * In our professional opinion, the best available information, as covered in this letter , indicates that the effluent from the proposed Northglenn wastewater treatment and storage facili- ties.will meet the 30/30 standard . Sincerely, • SHEAFFER & ROLAND, INC . 71://r4-2] F. J. Roland, P.E. Vice President �j • W.A. Cowlishaw, P .E. Chief Engineer 3.1„? ))44 7)r. F. R. McGregor , P .E. Regional Vice President. • /ms • Attachments I. ' if\ STORAGE RESERVOIR PUMPING 71STATION WITH CHLORINATION BULL FACILITIES _r�_ I CANAL I : ' r M- il s \ \s f _"--7-4 t _ TT-, '` SCALE IN FEET _ .--. ..i. 0 100 400 800 y-'<-71 .- 1 -..../ /J i / \.\\:\ h h . n STORAGE RESERVOIR �,,,j , N .,:. e\ PROPERTY • ) -----1 S‘A° Qi4 LINE (T Y P.) 50 FT. MIN_ SETTLING FROM EDGE � LAGOONS -^-! . OF :l RM ---,... ......c-,..c.-- 1.--- _, 5730- ii L l • i i o ,-)V 5120_ • SETTLING L�..1_.., __.. pl _.:1.-_-, - I_.4 LAGOONS BASIN j F , f �� ► f � ►r EXISTING • I f. ':•• / o(L 1,I1`, I I ,V O ROAD U j I V I _J ITT 1 '! h . =_ � _-- 1 "- ' .. 7 SO FT. : , --... - -- • • ___ _3\..___. . _-\..,,..„-/I.L7/....__....\. • SHEAFFER AND ROLAND, INC. CITY OF NORTHGLENN, COLORADO ENVIRONMENTAL PLANNING AND ENGINEERING WASTEWATER SYSTEM BASIS OF DESIGN r,,' SOLAR ENERGY • RESOURCES MANAGEMENT PROPOSED WASTEWATER TREATMENT te -a. CHICAGO, ILLINOIS AND STORAGE FACILITIES • • • A-1 w . r • ;_:X:l;C;1I /► - 2 i • f • (� tt 111,‘ .• i\ - N - coil_Gate Valve .)unction I I Il IIii tl ii II ,I it / V Ni— -- I It I \ I,, I J / T7i 1 II 11 fl I I I I Il SIOraqe 11 • I! Ro.ervoir h - ll • I 11 11 • 01.:710VI— k.) C Struc urc3 ------ -.=_-_---,--.-,.-. .__1 I _ 'o.3 —_ _....._ / I1TN I (_) C 0 I1 . N V --. N 7IJL\ _I l_ \_ _ "' \ II - II 200 IC?n - 0 ___?�� _.__ 400 _ ____Q. _ ` _�. _1 {-- • r�,oaa :.-r-_=__ .__.. a- --: ---1 -----2 Inlet Volvo Vault _ — �: seas,aria zt� � Scale. I''= 200' } • SHEAFFER AND ROLAND, INC. CITY OF N0RTHGLENN, COLORADO l ENVIRONMENTAL PLANNING AND ENGINEERING WASTEWATER SYSTEM BASIS OF DESIGN SOLAR ENERGY • RESOURCES MANAGEMENT CHICAGO. ILLINOIS TREATMENT FACILITIES LAYOUT . A-2 5180- - 70 H.W. EL. 5159 60 V 50- /--- — �----. Settling — SI40—~ LW. Basin Storage Reservoir ,\ t l. 5122 30- 2 _ ' --...._ \ ,__, l_=\_\_ ..\\\\\\\\,"\i' .ii,`��Y' 5100 i I }1 I I I I I I 0 400 800 1200 1600 2000 2400 2800 3200 3600 4000 SECTION A--Al Scale: Horz. 1"• 600' Vert. 1"` 60' 5180- 70 Lo ' - 20' Width Of goo C H.W. 60 Roadway (Typ.1 7 50 O _ _ O — (O Storage Aeration Lagoon Reservoir 5140 - J/ Redwood Baffle L FILL %4. �� 20- 10 I510 0- -- �� __ 300 600 900 1200 1500 SECTION S B' Scale : Horz. 1 • 300' Vert. 1".40' 5180 Settling Settling 70— Basin . Lagoon Compacted GO- --- .. — - -1 Berm ITYP) 50-- 5140--- __,_ 30- ' ----- Aeration 20�— `/� Lagoons 10- sloa-�- —} I- i 1--- 0 400 600 • 1200 1000 SECTION C- Cr Scale: Horz. 1"• 400' C� I I Vort. 1"• 40' SHEAFFER AND ROLAND, INC. CITY OF NORTHGLENN, COLORADO ENVIRONMENTAL PLANNING AND ENGINEERING WASTEWATER SYSTEM BASIS OF RESIGN -) SOLAR ENERGY • RESOURCES MANAGEMENT PROPOSED WASTEWATER CHICAGO, ILLINOIS TREATMENT FACILITIES -- SECTIONS r)-ri" A-3 • • ANTICIPATED MICROBIAL 'RESPONSE IN RESERVOIR FOR NORTFIGLENN, COLORADO Prepared by: Ross E. McKinney September 4, 1978 • PURPOSE: The purpose of this report is to examine the potential microbial response within the proposed reservior following a three stage aerated lagoon wastewater treatment system. APPROACH: The basic approach to the problem of anticipated microbial growth lies in an understanding of the fundamental microbiology and biochemistry of biological wastewater treatment and mixed aquatic populations. tt is readily recognized that there are no known ways of predicting with absolute certainty what the exact biological response will be in any body of water. Many different microbial reactions and responses can occur depending upon the specific chemical composition of the water and the environmental factors imposed upon that body of water. It has been known for many years that the growth of most bacteria depends upon a readily degradable .,ource of oreanics. The bacteria can metabolise the organics by oxidizing a portion of the organics to obtain energy to convert the remaining organics into cellular protoplasm. The basic reactions of metabolism are :,imply a set of oxidation-reduction reactions in which something is oxidized to obtain energy while something is reduced to store energy for later use. Dissolved oxygen is widely used by bacteria with carbon dioxide and water as the primary end products of the oxidation reactions and cellular protoplasm representing the reduced end product. The protoplasm formed is an unstable organic material that can be oxidized by the same bacteria or other higher forms of microorganisms. If free dissolved oxygen is not available, the bacteria can use nitrites or nitrates as the oxidants with nitrogen gas baing one of the major end products along with carbon dioxide and water. A highly specialized group of bacteria have the ability to use sulfates as oxidants but hydrogen sulfide is one of the end products. A very few specialized bacteria have the ability to use carbon dioxide but they require an extremely large supply of hydrogen to produce methane and water. Very little methane is produced by the reduction of carbon dioxide but there are bacteria capable of carrying out the reaction. In the absence of dissolved oxygen the bacteria use oxygen containing organic compounds to form more oxidized organics and more reduced organics. The splitting of the organic molecules and the shift to organic acids and Alcohols yields some energy which permits a small amount of bacterial growth. The overall growth of bacteria depends upon the energy available from the oxidation reactions and the nutrients necessary for b cterial protoplasm. The bacterial system approaches the lowest level of energy With time. The organic products of anaerobic metabolism would remain if it were not for a highly specialized group of bacteria which can metabolise the organic end prodcts to methane and carbon dioxide which arc lost from the water phase as — gases. The bacterial reactions proceed from the highest energy level to the lowest energy level , from dissolved oxygen to methane. Bacterial metabolism consists of rapid synthesis and slow endogenous respiration. The synthesis reaction i , .bout 10 times faster than the endogenous respiration reaction, permitting rapid stabilization of organic natter in v4astewater treatment systems vider aerobic conditions. The -- stabilization of the bacterial cells by .•ndegenous respiration occurs slowly; 13-1 but protozoa can utilize the bacteria for food and produce more rapid stabilization of the bacterial protoplasm. There arc some bacteria that utilize inorganic compounds rather than organic compounds. These bacteria are strict aerobes which gain energy from the oxidation of ammonia to nitrites and nitrates. Carbon dioxide is used as the source of carbon for protoplasm. In effect the autotrophic bacteria convert stable, inorganic materials into unstable organic materials in the form of bacterial cells. Other bacteria oxidize hydrogen sulfide to free sulfur and sulfates. A few bacteria can even oxidize hydrogen or ferrous iron to obtain the enrgy needed for synthesis. The nitrifying bacteria are the most important group of the autotrophic bacteria. When organic matter is added to water, the bacteria respond almost Immediately with rapid growth and stabilization of the biodegradable fraction of the organic matter. One of the end products of protein metabolism is the release of ammonia which can be oxidized by the nitrifying bacteria to nitrites and nitrates. Initially, the release of ammonia ties up some of the carbon dioxide formed by metabolism as alkalinity, ammonium bicarbonate. The alkalinity helps keep the pH at the proper level for good metabolism. One of the interesting aspects of nitrification is the fact that nitrification results in significant destruction of alkalinity. Each mg/1 of ammonia nitrogen oxidized results in destruction of 7. 1 mg/1 alkalinity as CaCO . In soft water areas nitrification can destroy almost all of the alkalinity and drop the pH below 6. Even in hard water areas nitrification can produce a significant . drop in alkalinity and reduce the pH. ALGAE The stabilization of. organic matter by bacteria produces a stable effluent as far as bacterial metabolism is concerned. In the presence of light energy the stable nutrients can be metabolised by algae to form algal protoplasm. In effect, the inorganics are converted back into organics which are no longer stable. The algae undergo endogenous respiration the same as bacteria. In the presence of light energy the algae take the end products of endogenous respiration and convert them right back to new algae. The net result is that it appears the algae remain unchanged when actually they are undergoing continuous change. In the dark the algae undergo normal endogenous respiration with the release of nutients. When light • returns, the released nutrients can be metabolised again unless lost from solution during the .dark period. • In natural water the growth of algae is limited by phosphorus; but in polluted water the growth of algae is limited by either nitrogen or carbon. Algal protoplasm has a chemical composition very similar to bacteria and can he represented by the empirical formula , C H 0 U.. Phosphorus is normally 1/5 the nitrogen content. Normal domestic wasieraZcls contain approximately 200 mg/1 BODr, 200 mg/i alkalinity as CaCO3, 20 mg/1 ammonia nitrogen, 15 mg/1 or•ganic)ni trogen and 10 mg/1 phosphorus. It is possible to convert the . SOD to its carbon equivalent and to do the same with the alkalinity. The . -. -SOD has approximately 112 mg/1 carbon while the alkalinity contributes an additional 21r mg/1 for a total of 136 mg/1 carbon. Approximately 2/3 of the 1300 carbon is put into bacterial cells in the synthesis reaction with a • slow release of additional carbon during endogenous respiration. From a practical point of view it is possible to estimate that 2/3 of the carbon related to the BOD would eventually be •Fade available for algal metabolism in the aerated lagoon system where some suspended solids settling will occur. Actuallysome of the carbon dioxide would be lost to the atmosphere in the . B-2 • • aeration cell through stripping at the aerator. The metabolism of protein by bacteria results in the release of ammonia which reacts with the carbon dioxide to produce ammonium bicarbonate alkalinity. Metabolism of 10 mg/1 of organic nitrogen would only tie up 9 mg/1 carbon from the carbon dioxide. With 200 mg/1 alkalinity at pH 7, approximately 10 mg/1 carbon would be retained as carbon dioxide in solution. The release of other minerals tied up by organic acids which were metabolised by the bacteria helps bind the carbon dioxide. Careful analyses would have to be made of the specific system to accurately determine the amount of carbon made available for algal growth. Alkalinity measurements after the synthesis phase of bacterial - growth in a 24 hour aerated lagoon would indicate that the available inorganic carbon is in the range of 48 mg/1 as bicarbonates. The metabolism of bicarbonates by algae results in a pH shift upward with the production of carbonates from the bicarbonates. The carbonates tend to raise the pH to a pont where metabolism ceases. It is estimated that no more than 50 percent of the carbon in the bicarbonate alkalinity is available for metabolism. This means that the 24 mg/1 converted to algal protoplasm would mean approximately 50 mg/1 VSS or S5 mg/1 TSS. If all the carbon could be converted to cell mass , the algal mass would be around 300 mg/l . The expected algal growth should be 1/6 the ultimate potential . Nitrogen is a critical element for both bacteria and algae growth. The metabolism of 200 mg/1 BOD by the bacteria would result in 17 mg/1 nitrogen converted to cellular protein. Approximately 10 mg/1 of the 15 mg/1 organic nitrogen would be released by metabolism with 5 mg/1 remaining unmetaholised. The net balance would require 7 mg/1 of the ammonia nitrogen leaving approximately 13 mg/1 ammonia nitrogen untouched. Endogenous respiration would release additional ammonia in proportion to the rate of endogenous respiration. If 2/3 of the nitrogen were eventually released by endogenous respiration, a total of 23 mg/1 nitrogen would be available for algal growth. At 10 percent nitrogen the maximum potential growth would be 230 rag/1 VSS or about 250 mg/I TSS as algae cells. The 10 mg/I phosphorus represents a potential algal. growth of 500 mg/1 VSS or 550 mg/1 TSS, making phosOorus the least limiting of the three elements. In addition to these elements iron and magnesium are critical trace metals that could also limit the total algal growth potential . Iron is the more sensitive of the two trace nutrients since iron reacts with phosphates to form a ferric hydroxy phosphate precipitate that results in removal of the - essential iron. It is hard to establish iron deficient systems since growth simply ' levels off before it should. It appears from these data that with domestic sewage carbon could --•- easily become the limiting element in the growth of algae. The availability of the carbon is the critical factor in the final analysis. The loss of carbon dioxide during initial metabolism is the hardest factor to evaluate. - In an aerated lagoon the aerator-mixers help to drive off the carbon dioxide since the concentration of carbon dioxide in the air is quite small . The remaining alkalinity and pH are the key parameters for determining the avilable carbon. Recently, it has been shown that nitrification can play an important role in the alkalinity reaction. Nitrification results in the destruction of 7. 1 mg/1 alkalinity as CaCO1 for each mg/I ammonia nitrogen oxidized. If the 13 mg/I excess ammonia nitrogen were oxidized in the first aeration cell , 92 mg/I alkalinity would be destroyed, dropeing the alkalinity from 200 mg/1 to around 110 mg/l . With a pH around 7.8 ai.out 13 mg/1 carbon would be available B-3 • for algal metabolism. The total 'algae mass would be around 30 mg/1 until endogenous respiration released additional carbon dioxide in the second aerated lagoon. Approximately 35 mg/1 carbon would be released from bacterial metabolism in the second aerated lagoon. If the algae were able to obtain all of the carbon released by endogenous respiration the growth could reach 80 mg/1 VSS or 90 mg/1 TSS. The total algal mass leaving the second aeration cell could be as high as 120 mg/1 . Further growth of algae would depend upon additional endogenous respiration of the bacteria or some other source of carbon. With sedimentation of solids in the third aerated lagoon the algae population should show a significant decrease. A very important reaction occurs with the growth of the algae, the pH rises. it should reach well over 9 and might even reach 10. The pH should balance with the relative concentrations of alkalinity forms. As the pH rises, calcium carbonate will be precipitated as will iron and calcium hydroxy phosphate. The removal of iron and phosphate in the third aerated lagoon should be sufficient in itself to prevent further algae growth in the reservior. The effluent from the third aerated lagoon should have around 100 mg/1 alkalinity and a pH above 9.0. During the summer months the nitrogen should be essentially all nitrates if adequate oxygen is supplied. The precipitation of iron and other trace metals should reduce further algae growth to a minimum. The atmosphere will be the primary source of carbon but the rate of transfer will be small , depending primarily upon the degree of mixing at the air-water interface. It has been estimated that 8 mg carbon could be transferred across each meter of water surface per day which could yield approximately 20 mg of TSS/day if adequate light was available and the other nutrients were in excess. Mixing will be an important key to distributing the algae throughout the resrvior volume. Not only will mixing distribute the algae around the reservior, mixing will assist in separation of the algae by contact with the bottom surfaces. • Endogenous respiration of the algae results in a continuous degradation of the algae protoplasm. While the algae reuse the nutrients released by endogenous respiration, approximately 20 percent of the algae mass produced will remain as stable organic suspended solids which will not create an o::ygen demand or release their nutrients. In fact the 20 percent solid fraction will tie up carbon, nit •ogen and phosphorus. The net effect will be that nitrogen and/or phosphorus will become the limiting nutrient in the reservior. The long retention time in the reservior, 9 months should be adequate to provide a reasonable effluent. CONCLUSIONS • It is readily recognized that there is no way to make absolute predictions c}f effluent quality from a three cell aerated lagoon wastewater treatment system followed by 9 months storage. It is anticipated that the aerated lagoon should produce ae effluent low in alkalinity, low in nitrogen and low in phosphorus and trace minerals. The design any operation of the aerated lagoon will determine the effluent quality. A properly designed• and operated system should have a pH above 9 with little carryover of biological solids. Ammonia nitrogen will either be stripped by aeration or converted to nitrates and most of the phosphates and iron will be precipitated at the elevated pH. The aerated lagoon effluent will not support significant algae growths without additional nutrients being added from outside. The exact amount of algae production in the reserviors can only be determined in the field after construction; but the l'c- t information currently available indicates that the effluent quality sh„i:ld be under current EPA effluent criteria. B-4 EXHIBIT C AERATED LAGOON OPERATIONAL EXPERIENCE Treatment of wastewater by aerated lagoon systems has become an accepted technology during the last twenty years. Feedlot wastes , industrial wastes, pulp mill wastes as well as municipal wastewater have been successfully treated by variations of the aerated lagoon process. The design, operation, and performance of these lagoon .systems have varied widely, reflecting not only a diversity of ap- plication but also a lack of consensus on both the theoretical and empirical bases of design and operation for lagoon wastewater treat- ment systems. The fundamental theory of lagoon treatment of wastes is well known and straightforward; the lack of design consensus seems to be based on uncertainties in refinements of theory and design rather than on the _:asics. In the following discussion, case histories of five existing -.eratcd lagoon systems are presented. In each case, the major design parameters of the system along with associated performance data, are presented. A brief discussion of the system' s perform- ance in relation to its design then follows. The case studies presented were clue to (1) their location in climate similar to 1 orthglenn' s; aid (2) the avail.abi_1 :i. Ly of detailed performance and design data. Loui sville, Colorado The Louisville wastewater system consists of si.x lagoons ar-- rang.: d in two sets of series-operated , three cell systems. The first two cells in each series are mec_hanical.ly• aerated with floating surface aerators while the third cell in each series is quiescent. Final effluent is chlorinated prior to discharge. C-1 • The Louisville lagoon system regularly receives two levels of flow depending upon whether flow is diverted into an adjacent batch- operated oxidation ditch. The ditch has a 0. 25 MGD capacity and operates approximately 50 percent of the time. When the ditch is in operation the lagoon system receives less flow into the first two cells of each series. Clarified effluent from the ditch is recombined with lagoon water in the quiescent final cells of the lagoon system for polishing. When the ditch is not in operation, the lagoon system receives full flow. For evaluation purposes , .flows into the lagoon system are averaged to account for diversions to the oxidation ditch. Overall Lagoon System Design flow and detention time 0. 6 MGD at 24. 3 days Average flow and detention time 0. 4 MGD 'at 36. 4 days Total surface area in cells 5. 7 acres ~ Liquid depth 12 feet -- first cell in each series 11. 5 feet - second and third cells in each series Side slopes 3: 1 Aeration Mechanical surface aera- • tors , 30 HP in first cells; 20 HP in second cells Average influent 130D5 loading 3881bs/day at 117 mg/1 Average influent SS loading 620 lbs/day at 186 mg/1 Cells 1_ and 2 (first cell in each series) Liquid volume and average 2. 60 MG and 13. 0 clays pea: detention time cell. Surface dimensions 31.1 ' x 211 ' per cell (1 . 02• acres) Water depth 12 feet • Aeration 1 - 30HP unit in center of cell , operating on the average 12 hours/day intermittently, equivalent to 5. 8 HP/MG and 3. 7 lbs 02/lb DOD • Assumed DOD and SS reduction 75 percent C-2 Cells 3 and 4 (second ccii in each series) . Liquid volume and average •2. 08 MG and 10 .4 days detention time per cell Surface dimensions 189 ' x 189 ' per cell (0. 82 acres) Water depth 11. 5 feet Aeration 1 - 20 HP unit in center of cell operating on the average 12 hours/day in- termittently, equivalent to 4 . 8 HP/MG and 9. 9 lbs 02/lb BOD Assumed BOD and SS reduction 75 percent Cells 5 and 6 (third cell in each series) Liquid volume and average 2. 60 MG and 13 . 0 days .per detention time cell Surface dimensions 211 ' x 211 ' per cell (1. 02 acres) . Water depth 11. 5 feet Aeration Natural air-water surface • - exchange Performance • Effluent was monitored for. SOD5, suspended solids , and pH ac:c.:oxcli.ng to Colorado State Health Department requirements. Data for 1977 is presented below: Inf)uent Influent Effluent Effluent flow BUD SS BOD SS pH flonth (MCD) (mg/1) (mg/1.) (mg/1) (mg/1) (Units) Jan. 0.48 119 162 6.8 7.8 7.3 • Vet). 0.50 - -- 4.0 2.5 7.3 • Mar. 0.90 ].34 159 .3.2 2.2 7.3 • !pr. 0. 52 .. .. —. . • May 0.5 c -- June 0. 58 116 150 J 2 . 2.2 7.4 July 0.56 113 160 1.4 4.2 7.4 Aug. 0.56 . 67 208 2. 5 2.5 7.4 Sept. 0.48 129 241 2.0 6.1 - Oct. 0. 50 124 234 1.0 1.0 7.5 Nov. 0.54 124 183 1.0 1. 0 7.5 Dec. 0.51 123 178 1.0 1.0 7.4 C--3 • • Comments The Louisville system is consistently producing effluent well within secondary standards. Adequate aeration capability (3. 7 and 9. 9 lbs 02/lb DOD5 ensures that the system can accommodate fluctuation in organic loading including spring "solids overturn" typically experienced in lagoons. Low mixing levels and high liquid depth are also major factors in the system' s performance. On a macro level, the mixing level of 5 HP/mG promotes settling of organic wastes and microbial cells to the lagoon bottom where •anverohic processes stabilize these constituents. The intermittent nature of mixing (15 minutes on - 15 minutes off) similarly promotes settling by providing quiescent periods where floculation of solids can take place. In addition the ' use of quiescent third cells in each series seems to promote the growth of attached, submerged forms of filamentous r.lgae and aquatic plants rather than free floating phytoplankton. This has a positive effect on suspended solids concentrations in the effluent. • Niwot, Colorado The Niwot wastewater treatment system consists of three series- operated lagoons. Mechanical aeration is provided in the first cell; the two remaining cells rely on the natural air-water exchange processes. Effluent is discharged without chlorination. • • C-4 Overall Lagoon System Design flow and detention time •- - Average flow and detention time 0. 23 MGD at 60 days Total surface area in cells 4. 6 acres Liquid depth in cells 13 feet:. Side slopes 3: 1 Aeration 1 x 50 HP floating mechani- cal aerator in cell =1 Average influent, BOD- loading 342 lbs/day at 176 mg/1 SS loading 315 lbs/day at 163 mg/1 TKN loading 55 lbs/day at 28 mg/1 P leading 77 lbs/day at 39 mg/1 Cell 41 Liquid volume and average detention time 3. 5 MG and 15 days Approximate surface dimensions 225' x 225 ' (1. 2 acres) Aeration capacity , 1 50 HP unit in center • of cell, 14 . 3 HP/MG = 7. 0 lbs 07/lb BOD DOD, reduction 89 percent SS reduction 80 percent TKN reduction 38 percent P reduction 47 percent Cell 2 1.i.quid volume and average detention time ' 3. 5 MG at 15 days surface dimensions 225' x 225 ' (1. 2 acres) Aeration Natural reaeration only C-5 • Cell 43 Liquid volume and average detention time 7 . 0 MC at 30 clays Surface dimensions 44 ' x 220 ' (2 . 2 acres) Aeration Natural reaeration only BOD reduction (Cells 2 and 3 combined) 66 percent SS reduction (Cells 2 and 3 combined) 47 percent TKN reduction (Cells 2 and 3 combined) 48 percent P reduction (Cells 2 and 3 combined) 22 percent Performance _—�1u- i^c 1ue'—n c:.)or:::l.:on'--c/1 Date 13O13 SS TKN P 338O SS ITN P NH3 6/72 145 39 14 17 5 22 4 9 _ 4 .` 7/72 ].E1 66 12 • 21 4 12 6 14 6 8/72 141 65 11 13 4 14 4 13 4 9/72 146 102 - 24 2 13 -- 10 • 1.0/72 100 94 23 15 4 18 1.7 1F; 1.5 11/72 102 176 8 20 6 ].2 2 0 1 12/72 109 130 - 22 J3 16 -. 9 6.5 1/73 276 283 33 58 1.0 16 13 20 13 2/73 340 400 51 260 E 24 13 28 13 3/73 ' 202 226 47 32 ' 11 34 14 23 14 4/73 195 197 48 33 8 30 13 19 1.J- 5/73 300 373 90 82 5 9 18 24 7 6/73 146 E8 . 14 7 3 1.4 15 19 5 7/73 163 83 )4 7 10 11 35 10 5 • • C-6 • Comments The Niwot system achieves good removals of BOD and sus- pendded solids with highest levels of suspended solids in the effluent during the spring months. Pawnee, Illinois The Pawnee wastewater system utilizes a three cell , series- operated aerated lagoon system. Aeration is provided by a Hinde- type submerged tube diffused air system with a central blower unit. • Aeration is concentrated in a stepped manner with the most aeraL tion occurring in the first cell where organic loading is greatest. Effluent from the three-cell system is passed through a sand fi,.tt. prior to chlorination and .lischarge. Overall Lagoon System Design flow and detention time 0. 5 MGD at 60 . 1 days Average flow and de- tention time 0. 21 MGD at 143. 5 days Total surface area in cells 11. 0 acres Liquid depth in cells 10 feet Side slopes 3:1 aeration • , 24 , 000 lineal feet of sub-- merged perforated tubing • supplied by 2 x 495 cfm blowers and 1 x 495 cfm standby blower Average influent , 13On5 loading 823 lbs/day at 473 mg/1 SS loading 866 lbs/day at 498 mg/1 TKN loading . 89 lbs/day at 51 mg/1 P loading L3 lbs/day at 36 mg/1 C-7 . • Cell 4'l Liquid volume and average detention time 17 MG at 81 . 4 days Surface dimensions 740 ' x 350 ' (5. 9 acres) Aeration 17, 500 feet of submerged tubing at 723 cfm Average BOD5 reduction 97 percent Average SS reduction 92 percent • Cell ''2 Liquid volume and average detention time 8. 5 MG at 40. 8 days Surface dimensions 740 ' x 190 ' (3. 2 acres) Aeration 4 , 500 feet of submerged • tubing at 186 cfm Average BOD,. reduction 62 percent Average SS reduction ?_8 percent Cell g3 Liquid volume and average detention time 4. 3 MG at 20. 4 days Surface dimensions 740 ' x 110 ' (1 . 9 acres) Aeration 2, 000 feet of submerged tubing at 83 cfm Average BOD5 reduction 4 percenc Average SS reduction 12 percent • • C-8 Performance Influent-^n/1 Effluent Prior to Filters and Chlorination-mg/1 Date BOO SS TRN P SOD5 SS TKN NH3 P 3/76 233 178 25 27 4 22 3 < 1 6 4/76 277 236 29 24 4 15 6 C 1 11 5/76 460 371 47 25 C 27 5 < 1 6/76 :70 544 49 31 9 23 5 C 1 7 7/76 452 768 54 35 7 21 5 < ,1 13 8/76 G02 758 39 34 9 132 7 < 1 15 9/76 575 529 64 50 11 16 4 < 1 15 10/76 799 678 80 48 2 11 4 < 1 14 11/76 543 561 74 51 3 13 4 < 1 17 12,E76 554 543 53 42 5 18 5 < 1 20 2/77 395 337 • 56 37 8 1}. 11 5 32 /77 296 417 48 30 19 ) 7 15 6 33 • Coliwients The Pawnee system shows design and operating characteristics similar to those of Louisville except that it is more tapered, with decreasing cell volumes and artificial aeration levels through- out the three-cell system. It is difficult to evaluate the Pawnee , system since it is significantly underloaded hydraulically ; however, it shows a consistent: and satisfactory performance throughout the test period with the exception of a high SS level in August of ?x•976 and somewhat higher than normal nitrogen and phosphorus levels in February and Ma 7ch of 1977. C-9 • • It should be noted that the Pawnee system consistently treats wastewater of very high strength while still meeting DOD5 , SS and NH3 standards. The system' s freeze up problems were a result of an extremely severe winter and could be prevented by the construc- tion of lagoons 15-16 feet deep. Windber, Pennsylvania The Windber wastewater treatment facilities consist of a Series-operated, three-cell aerated lagoon system. Subsurface diffused aeration is provided by a Hinde-tvpc perforated tube net- work in all three cells. Aeration is concentrated in a stepped maimner with highest aeration levels in the first cell where organic loading is greatest. Effluent from the third cell is continuously chlorinated to achieve a 0. 5 mg/I residual concentration . Overall Lagoon System • Design flow and detention time 2 . 0 MCD at 30 days Average flow and dct"mntion time 1. 26 MGD at 47. 6 days Total surface area in cells 20. 6 acres Liquid depth in cells 10 foot: Side slopes 3: 1 Aeration . 1, 200 cfm blower at 9 psi. with 84 , 000 feet of per-- . foratcd ' tubing Average infi':ent, 13OD5 loading , 1, 774 lbs/day at 169 mg/1 SS loading 1, 593 lbs/day at 152 mg/1 TNN loading 240 lbs/day at 23 mg/1 P loading 53 lbs/day at 5 mg/1 • C-10 Cell el Liquid volume and average detention time 22 MG at 17 . 5 days Approximate surface dimen- sions 1, 100 ' x 300 ' (7 . 6 acres ) Aeration capacity 52 , 000 feet of submerged tubing at 743 cfm Average BOD5 reduction 73 percent SS reduction 65 percent overall ( 83 per- cent winter, 47 percent summer) Cell 42 Liquid volume and average detention time 28 MG at 22 . 2 days Approximate surface dimen- sions 1, 240 ' x 3d0 ' (9 . 7 acres) Aeration capacity 28, 000 feet of submerged tubing at 400 cfm, 14 . 3 cfm/MG = 1 . 50 lbs 02/lb BOD5 Average RODS reduction 50 percent SS reduction 79 percent Cell ` 3 • Liquid volume and average detention time 10 MG at 7. 9 days Approximate surface dimen- sions 520 ' x 270 ' (3. 2 acres) Aeration capacity 4 , 000 feet of submerged tubing at 57 cfm, 5. 7 cfm/MG = 0 . 43 lbs 02/lb DOD _ 5 Average BOD5 reduction 0 SS reduction . 7 percent: • C-11' • .. Performance Influent- /1 Effluent (ario: to chlor; ,,tinn)-:q/1 Date Floes BOD SS T?:;: P BOD SS (mcD) 5 $ TENNH3 !' Algae f103/liter) 11/75 0.7 177 186 21.9 4.9 7 2 14 12 < 1 25 12/75 0. 6 203 173 29.5 6.8 14 3 20 17 < 1 < 1 1/76 1.5 152 128 16.7 3.6 21 12 22 22 1 1930 2/76 1.5 220 107 13.2 3.2 41 10 19 18 4 1 314 3/76 1.4 161 124 14.4 3.4 23 20 14 14 4 1 1055 4/76 1.5 155 128 18.4 4.7 15 10 17 17 < 1 91 5/76 1.1 202 166 27. 7 6.4 27 16 25 25 1 901 6/76 1.0 1S2 158 3:.: 8.1 41 18 33 31 3 17 7/76 1 . 4 145 149 25.1 5.4 35 10 34 33 4 17 8/76 1.5 133 170 27.6 6.2 11 12 29 27 3 15 9/76 1. 5 173 177 46.0 6.8 8 8 34 2.7 3 L - 10/76 1. 4 106 151 18.4 4.3 30 4 26 23 1 1 • Comments The Windber system is another tapered three-cell lagoon system that shows consistent performance throughout the test period. Pre- • chlorination BOD5 levels are somewhat high for four of the twelve test months . This is probably due to the aeration levels in the cells which are somewhat lower than those at Pawnee. In addition, the lagoons at Windber are irregularly shaped and some short -circuiting may occur. None- theless, the Windber system provides an effluent which for the most part meets BOD and SS standards prior to chlorination . Chlorinating the effluent reduced these levels to well below effluent standards . • Lake Koshkonong, Wisconsin The Lake Koshkonong system employs a three-cell, series- operated aerated lagoon system for wastewater. treatment. Aera- tion is provided by a Hinde-type submerged diffused aeration system equipped wi4h a central blower unit. Aeration is concen- trated in a stepped manner with concentration in the first cell. Effluent from the third cell is chlorinated prior to discharge. • C-12 • Overall Lagoon System • Design flow and detention time 0. 6 MGD at 22 . 7 days Average flow and detention • time 0 . 25 MGD at 54 . 6 days Total surface area in cells 6. 9 acres Liquid depth 7 feet Side slopes 3: 1 Aeration Iiinde-type diffused aera- tion using 29, 700 feet of submerged tubing and a blower capacity of 425 cfm Average influent, BOD_ loading 177 lbs/day at 85 mg/1 SS loading 22.8 lbs/day at 110 mg/1 TKN loading 32 lbs/day at 15 mg/1 P loading 12 lbs/day at 6 mg/1 . Cel]. yl . • Liquid volume and average detention time 4 . 55 MG at 18 . 2 days Surface dimensions 430 ' x 235 ' (2. 3 acres) Aeration 18 , 000 feet of submerged tubing at 257 cfm air at 9 psi. Average BOD5 reduction 79 percent SS reduction 87 percent C:e J.?. 42 Liquid volume and average detention time 4 . 55 MG at 18 . 2 days Surface dimensions 430 ' x 235 ' (2 . 3 acres) Aeration 7, 500 feet of tubing at 107 cfm air at 9 psi • Average PODS reduction 16 percent SS reduction .-- 26 percent • • C-13 • Cell P3 • Liquid volume and detention time 4 . 55 MG at 18 . 2 days Surface dimensions 930 ' x 23S ' (2. 3 acres) Aeration • 4 , 200 feet of tubing at 60 cfm air at 9 psi Average DOD5 reduction 8 percent SS reduction - 11 percent Performance Date DOD_ SS TKm P ^ D 50D5 SS TY,:: ,Nil3 P • 12/73 89 129 18 5 6 6 10 9 9 1/76 96 115 21 9 7 3 13 12 9 2/76 73 123 18 5 6 3 15 12 5 3/76 37 48 6 3 14 2? 5 4 5 4/76 55 64 11 14 18 24 3 2 12 5/76 71 64 12 5 17 57 5 1 6 6/76 86 100 17 9 10 17 8 5 7 7/76 93 133 18 6 17 27 6 3 6 8/7G 118 183 15 5 17 25 1 3 9/76 11.3 326 16 4 31 33 8 5 4 10/76 1.92 114 10 4 20 11 6 3 4 11/76 87 116 21 9 2 7 9 8 6 • • • • • C-14 MEMORANDUM TO: Weld County Planning Commission FROM: City of Northglenn RE: Update of "Negative Declaration" and "Environmental Appraisal for Northglenn Wastewater Treatment Project (Project No. CO 80416-01, ) September 29, 1978. " DATE: February 13, 1979 The following comments are being submitted in order to update the "Negative Declaration" and "Environmental Appraisal for Northglenn Wastewater Treatment Project, September 29, 1978" ( "Negative Declaration") . The page and paragraph numbers at the beginning of each paragraph refer to the page in the Negative Declaration where the EPA comment appears. 1. p. 3. In order to proceed with Step II funding, the United States Environmental Protection Agency (EPA) must perform an analysis of the environmental impact of the project under the National Environmental Policy Act (NEPA) . EPA indicates that their review of the facility plan and their environmental analysis of the impacts of the project indicate that an environmental impact state- ment is not warranted for the Northglenn project. Therefore, this particular document represents what is referred to as a "Negative Declaration. " The purpose of the Negative Declaration is for public review of the EPA decision that the proposed project will have an "insignificant impact" on the environment. 2. p. 5 , D. , #l. EPA states that the "overall objective" of the project is to manage available water resources as efficiently as possible through the exchange agreement with FRICO. This concept is consistent with EPA objectives under the Clean Water Act and consequently, EPA has supported this project in concept since its inception. 3. p. 6 , D. , #3. EPA notes that all the contracts for receipt of water from Thornton to Northglenn will expire by 1988. It should be noted that many of these contracts in fact expire a number of years sooner. Therefore, Northglenn must plan now for the future • and the City cannot wait until 1988 to decide what it is going to do for water. 4. p. 6,D. , #3 (b) . The Negative Declaration identifies four major interceptors that will be part of the facility plan. This is no longer the case, since Thornton will no longer be part of the system. The only interceptor to be built will be the Northglenn Interceptor. 5. p. 15,D. , #3 (e) . Concern was expressed in the Negative Declaration concerning Northglenn proposals for sludge removal. Since that time, Northglenn has submitted a more detailed plan on how sludge will be handled and removed from the facility. 6. p.24 ,E. , #4 . At the time of the issuance of the Negative Dec- laration, EPA was concerned about whether the proposed facilities could meet state and federP.l suspended solids effluent discharge limitations. Since that time, Northglenn has submitted additional technical information to EPA and has met with EPA officials, and this concern has been alleviated. 7. p. 24 ,E. , #4. EPA briefly discusses the Metro Denver NPDES discharge permit requirements, and Metro' s ability or lack thereof to meet the permit requirements. Recent newspaper articles have indicated that Metro has been in gross violation of its permit. In addition, prior to these recent violations, Metro was not meeting, on a continual basis certain permit limitations and is therefore presently undergoing a Step I plan to determine how best to bring the facility into compliance. • Any discussion of Metro ' s capability to continue to receive Northglenn waste must be viewed in light of the fact that the facility is presently not meeting NPDES permit violations. 8. p. 28,E. , #7. In discussing the facility plan, EPA indicates that the recommendations fr_•om the plan were to have the Northglenn facility serve outlying areas in Adams County. This is no longer the case. 9. p. 41,F. , 1l. The proposed Northglenn facility is consistent with DPCOG population projections for the Northglenn area. In addition, by preserving agricultural land in Weld County, Northglenn believes urban growth will be diminished in that area. 10. p. 42,F. , #2. EPA notes the water quality that will be dis- charged into the Dull Canal from the Northglenn facility will be compatible with the quality of water flowing through that canal. The actual quality of the discharge will be determined by state and federal standards. These standards must consider downstream users. EPA notes that at the time of the Negative Declaration there were still questions about the proposed design. As stated in paragraph #6, this is no longer the case, but in addition, EPA notes that the facility can only be constructed in order to meet the _2_ permit requirements. Therefore EPA does not expect any changes in ' the environmental impacts resulting from design criteria modifications. 11. p.44 ,F. , #2 . EPA is presently requiring certain conditions of all applicants for wastewater grants. These conditions concern various water conservation measures and ordinances. Northglenn has satisfied all of these conditions. In addition, EPA has conditioned the award of a grant for Step III on Northglenn adopting a schedule for the adoption of certain water conservation ordinances that were included in the facility plan. . This condition has now been met. 12. p. 46,F. , #3. EPA notes that they would expect some air quality benefits from the preservation of open space in agriculture that will occur as a result of the Northglenn plan. Northglenn believes that the preservation of agricultural land is extremely important in any discussion of air quality benefits. 13. p. 46, 47,F. , #3. EPA has set forth certain requirements concern- ing the implementation of air pollution measures, the state implementation plan, and a sewer tap program which limits the number of available taps on a basis that is consistent with DRCOG population • forecasts. At this time, Northglenn has adopted all of the proper resolutions and ordinances concerning these requirements for the Step III award. 14. p. 47,F. , #4 . EPA states that " . . .there will be considerable energy saved by implementing Northglenn ' s proposed project" . Therefore, Northglenn has met the EPA energy requirements. 15. p.47,F. , #5. EPA notes that the land application concept of the project is attractive to them. In addition, the Negative Dec- laration states that "if this land were converted to urban use it is estimated that approximately $1, 548, 000. 00 of net agricultural income will be lost annually. " Northglenn believes that it is important to consider the economic implications of losing this land to urban development. EPA explains that they do have a policy to promote the preservation of prime agricultural land, .but as far as their funding is concerned, they want 20 year commitments on agricultural reuse. EPA is looking for a guarantee of 20 years for the application of wastewater to agricultural land. At this point in time, Northglenn has undergone considerable negoti'.tioris with FRICO and has submitted certain proposed language to EPA. Preliminary review from EPA has indicated that this condition will be satisfied. 16. p. 50,F. , #5. EPA notes that the facility does not extend into the South Platte 100 year flood plain and that there will only be a crossing by the interceptor of Big Dry Creek. Since development cannot occur in this area, then there will be no flood plain problems . -3- 17. p. 50,F. , #5. In the area where the prairie dogs exist, EPA will not allow development and is requiring that construction impacts be minimized. Northglenn has agreed to both of these conditions. 18 . p. 61,F. , #5. EPA expressed concern about controlling urban runoff in the Negative Declaration. At this time, Northglenn has adopted the proper ordinances and/or resolutions to satisfy this requirement. 19. p. 62,F. , #6. It is believed that certain components of Northglenn ' s facility will enhance the availability of recreational facilities to the general public. 20. p. 63,F. , #8 . At the time of the issuance of the Negative Declaration, EPA believed that adoption of the Radiological Emergency Response Plan (RERP) was imminent and as a result, Northglenn' s grant was conditioned on the adoption of certain procedures concerning this plan. Unfortunately, this plan has yet to be adopted by the proper state and county authorities and therefore Northglenn was in the situation of attempting to meet an impossible condition. This has been discussed extensively with EPA, and at this time, Northglenn is awaiting response from EPA on whether this condition should become a condition of Step III payment as opposed to Step III award, thus giving Northglenn adequate time to comply. 21. p. 66,G. EPA expressed certain concerns over growth related to the proposed interceptors. The interceptors mentioned, namely Neff, Grange Creek and Brantner will not be built. In addition, EPA required that Northglenn adopt a regulation prohibiting connections to the interceptor north of 136th Avenue. This has been done. 22 . p. 67,G. There are certain requirements set forth in the Denver Regional Environmental Impact Statement that Northglenn must adhere to. These requirements concern air pollution control measures , availability of taps, erosion control and the Radiological Emergency 1esponse Plan for Rocky Flats. It is believed that all of these conditions have been satisfied at this time, with the exception of the RERP, which is explained in paragraph #s20. 23. p. 68, G. EPA raised the issue of whether or not Thornton • wi3.1 be part of the system. As previously stated, it has been determined that Thornton will not be part of they system and the size of the facility has been adjusted accordingly. 24 . p. 68,G. EPA discusses the capacity of the Metro Denver sewage facility as being adequate through 1990. This statement is confusing because, as previously noted, the Metro Denver facility is presently not meeting its NPDES discharge permit. Therefore, immediate upgrading will be necessary. -4- 25. p. 68 , G. EPA has now indicated that the Northglenn Plan, and not Metro Denver, is the most cost effective alternative for treating Northglenn wastewater. 26. p.69,G. As previously discussed at paragraph #5, it appears that EPA' s concern for a commitment to continue applying wastewater to the land may well be alleviated at this time. 27. p. 79,L. At the end of the Negative Declaration, EPA set forth various conditions that must be met by Northglenn concerning the construction grant process. The conditions are as follows : a. p.79,L. , #1. The first condition concerns the eligible costs if Tho3_r..t:on will be part of the system. This is no longer a problem because Thornton will not be part of this system. b. p. 79,L. , #2. EPA is concerned about certain interceptors that will traverse prime agricultural land. As previously stated, certain of these interceptors will not be built, and Northglenn has adopted an ordinance as required by EPA to prohibit connections to the remaining interceptor for the area north of 136th Avenue. The area between 120th and 136th Avenues may receive hook-ups only after EPA and Northglenn approval. c. p. 80, L. , #3. EPA was concerned about flood plains and wildlife habitats. These concerns have been completely taken care of as the interceptor will only traverse the Big Dry Creek 100 year flood plain and will not allow for development in that area. The ordinance referred to in paragraph #27 (b) is also applicable for this concern. d. p. 80,L. , #4. EPA was concerned about whether or not Northglenn had access to sufficient amounts of makeup water for the project. This is explained in detail in the water rights submittal to the - Planning Commission. e. p. 80,L. , #5. This condition also addresses water rights issues and is explained in the water rights submittal. f. p. 80,L. , #6. This item focuses on the FRICO and Thornton agrec:mNuts. All agreements with I•'RICO have been reached and -. • necjcLiations are presently ongoing with Thornton. g. p. 81 ,L. , #7. EPA is concerned that the wastewater will be - applied to the land for 20 years. As previously stated, it is believed that this condition is satisfied at this time. h. p. 81,L. , #8. EPA (and state law) require State Engineer' s approval to proceed with the construction of certain dams within the Northglenn project. Information has been submitted to the appropriate agencies concerning these dams, and Northglenn does not believe that there is any problem in receiving such approvals. -5- • i. p.81 ,L. , #9. The Weld County reviews are the basis for this proceeding. j . p. 81,L. , #10. At the time of the Negative Declaration, EPA was concerned about Northglenn proposals for disposal of sludge. Subsequent to the Negative Declaration, Northglenn has submitted all necessary information concerning the disposal of sludge. k. p. 81,L. , #11. This paragraph concerns the possibility of groundwater pumping and .is addressed in the water rights submittal. 1. p. 82, L. , #12. (1) . This paragraph contains certain air requirements, all of which have been met at this time by Northglenn. m. p. 82,L. , #12 . (2) This condition requires the implementation of a sewer tap program, and as previously stated this has been incorporated into an ordinance by the City of Northglenn. n. p. 82,L. , #12. (3) This condition concerns the schedule for the adoption of erosion control ordinances, such schedule having been submitted to EPA at this time. o. p. 83, L. , #12. (4) This condition concerns the adoption of water conservation ordinances and the schedule for their adoption. Such schedule has been provided, as required, to EPA. p. p. 83,L. , #12. (5) This condition concerns investigating the feasibility of certain bike trails, etc. , associated with the Northglenn interceptor. Such investigation is ongoing at this time. q. p. 83,L. , #12 . (6) This condition concerns the adoption of a notification procedure for the 1ERP. As previously stated, due to the impossible nature of this condition, it is believed that this condition will be modified by EPA. • -6- ,,_ �q"♦1 i f d UNITED STATES ENVIRONMENTAL PROTECTION AGENCY• p1•44 MACC' REGGN vn! 1!60 L NCGLN STAEE' C ENVEF.COLORADO 3025? i€GXI'IVE DECLARATION • TO ALL INIERESIED GOVERNMENT AGENCIES AND PUBLIC GROUPS: As required by guidelines for the preparation of environmental impact statements, an environmental review has been performed on the proposed EPA action below: Project Wastewater Treatment Facility Location Northglenn, Colorado Project Number C 080416-01 (Step 2) Total Cost/EPA Share $685,900 (75% of eligible costs) EPA's share has not been determined due to a number of unanswered ques- tions regarding the eligibility of the project for grant funding. The level of funding is dependent on several factors, the most significant of which is whether Thornton will be a part of the Northglenn system. EPA will make a decision on the level of funding based on the information available at the time of the Step II award. The proposed wastewater treatment facility will be designed for a popu- lation of 72,700; the existing population of the study area is 42,000. The project study area includes floodplains, prime agricultural land, and a wild- life habitat area. The major primary impact of the project will be construction of a 24" interceptor through a wildlife habitat area. A major secondary impact of the proposed project is the possible conversion of prime agricultural land to urban use resulting from the construction of interceptors in the Lower Thornton service area. Another secondary impact is the additional air pol- lution that will result from increased automobile usage associated with the area's growth in population. Another secondary impact is potential ground- water depletion and degradation that would result if Northglenn is success- ful in implementing its proposed groundwater pumping program. The State Engineer's Office has denied 19 of 20 well permits required in order to implement the groundwater pumping program. Northglenn is appealing that decision. Consequently, it is not certain that this part of Northglenn's proposal will be implemented. • An environmental impact appraisal which describes the project and analyzes the impacts in more detail is attached to the Negative Declaration. • r. R ` • l Page 2 The review process indicated that only parts of the facility plan can be appoeved at this time dne to environmental ronsiderations and other fac- tors. These components are: 1. Northglenn Force Main and Pump Station 2. Aerated Lagoon @Veld County Site) 3. Storage Reservoir °Veld County Site) 4. Bull Canal Delivery System 5. Sludge Handling 6. Northglenn Collection System Improvements 7. Stonehocker Reservoir Components of the facility plan which cannot be approved are: 1. Branter Interceptor, Force Main, and Pump Station 2. Riverdale Force Main and Pump Station 3. Nott Interceptor There are two reasons that these items cannot be approved. First, Thornton has not agreed to implement the facility plan and second these interceptors will provide service in areas where prime agricultural lands are located. In addition to the above two items, EPA cannot approve any capacity that would be constructed to convey and/or treat Thornton's wastewater without Thornton entering into an agreement with Northglenn to have their wastewater treated at the Northglenn facility. EPA has awarded Step I funds to Denver Metro to evaluate the alternatives available to Thornton for wastewater treatment. Metro has passed the funds Into Thornton for its use in conducting thin study. The results of this study will not be forthcoming for several weeks. EPA will rely on this study to complete the existing facility plans regarding the ultimate treatment of Thornton's wastewater. A preliminary decision has been made not to prepare an EIS on the North- glenn facility plan. This action is taken on the basis of a careful review • of the engineering report, environmental impact assessment, and other sup- porting data, which are on file in the above office and are available for public scrutiny upon request. Comments supporting or disagreeing with this decision may be submitted for consideration by EPA. After evaluating the comments received, the Agency will make a final decision; however, no administrative action will be taken on the project for at least fifteen (15) working days after release of the Negative Declaration. Alan Merson Regional Administrator • • • Environmental Appraisal for Northglenn Wastewater Treatment Project (Project Number: C080416-01) September 29, 1978 • TABLE OF CONTENTS • A. Project Identifier .. _ . _ 1 „ . B. Reference Documents 1 C. Introduction 3 D. Description of the Project 5 E. Description of the Environment 19 F. Environmental Impacts and Proposed Mitigating Measures 41 G. Significant Issues and EPA's Proposed Action 65 H. Other Alternatives Considered 71 I. Agencies Consulted by EPA • 73 J. Public Participation 75 K. Reasons for Not Preparing an EIS 77 L. Grant Conditions 79 M. Appendix - Mailing List 87 • • .l ENVIRONMENTAL IMPACT APPRAISAL A. PROJECT IDENTIFICATI0N • Applicant: Northglenn Address: 10701 Melody Drive, Suite 313 Northglenn, Colorado 80234 • Project Number: C080416-01 (Step 2) B. REFERENCE DOCUMENT(S) • The following reference document(s) have been utilized by EPA in the environmental review of this project and are considered to be part of the project file: 1. "Predesign Report: Wastewater Management Lower South Platte Service Area", December 1973, CH2M Hill. 2. "Sequel to Predesign Report: Wastewater Management Lower South Platte Service Area", June 1974, CH2M Hill. 3. "Lower South Platte Facility Plan", Volume 1, August 1977, CH2M Hill. 4. "Northglenn Water Management Program, Water Resources and Facili- ties, Volumes 1 and 2, April 1977, Wright-McLaughlin Engineers. 5. "Northglenn Water Management Program, Wastewater Facilities", Volume 3, April 1977, Sheaffer and Roland. 6. "Northglenn Water Management Program, 201 Wastewater Facilities Plan, Volume 4, November 1977, Sheaffer and Roland. 7. "Final Denver Regional Environmental Impact Statement for Waste- water Facilities and the Clean Water Program", Volumes 1 and 2, April 1978, EPA. 8. "Final Action on the Denver Regional Environmental Impacts State- ment for Wastewater Facilities and the Clean Water Program", August 1978, EPA. 9. "The Physical and Economic Effects on the Local Agricultural Econory of Water Transfer from Irrigation Companies to Cities in the Northern Denver Metropolitan Area", Anderson et.al. , NRED, Economic Research Service, USDA; Dept. of Political Science; Dept. of Agronomy, Environmental Resources Center, CSU. _1_ ;} • C. INTRODUCTION Title II of the 1977 Clean Water Act establishes a program to provide Federal. assistance in the development and implementation of .waste treatment management plans and the construction of publically owned treatment works. Federal financing of waste treatment works are implemented in three steps: Step I, facilities plans, Step II, preparation of construction drawings and specifications, and Step III, • construction of treatment works. Northglenn funded Step I without Federal assistance. On September 7, 1977, Northglenn presented copies of their draft facility plan to EPA. The Plan was revised in November 1977. On March 7, 1978 the State of Colorado Water Quality Control Division certified to EPA Northglenn's application for Step II funding. By regulation, EPA cannot award a Step II grant until it has approved a facility plan for the proposed project and performed an analysis of the environmental impacts of the project under the National Environmental Policy Act. EPA has been will working with Northglenn to supplement the facility plan so that it comply with EPA's facility planning requirements. EPA now has suffi- cient information that it can take action on the facility plan. A review of the facility plan and the supplemental information indicates an environmental impact statement is not warranted for this proposed project. EPA regulations require that a public notice in the form of this negative declaration/environmental appraisal be given to explain why EPA considers this proposed action to have an insignificant impact on the environment. The negative declaration/environmental appraisal is circulated for public, State and Federal review, after _ which EPA must make its final decision on whether or not to award the Step II grant. This document is the negative declaration/environmental appraisal for Volume 4 of the Water Management Plan, Northglenn, Colo- rado. In making this determination. EPA relied cn those documents listed previously in this Negative Declaration to supply information relevant to the proposed project. -3- • D. DESCRIPTION OF THE PROJECT 1. Background: Northglenn is proposing to construct a multi-purpose water resource. project consisting of.a .drinking water supply, wastewater treatment and collection system, supplemental deep formation pumping system, and an urban runoff collection system, all in one integrated approach. The project will be located in the northern fringe of the Denver Metropolitan area (see Figures 1 and 2 for a definition of the study area) . EPA is being requested • to participate in the costs of designing and constructing the waste- water treatment portion of the Northglenn water management program. Several factors contributed to Northglenn's decision to proceed with the grater supply/wastewater management program. The major reasons are: • a. Northglenn's need for a sure source of water for its customers through the year 2000. b. Northglenn's desire to improve the water quality of its potable water supply, since Thornton's water supply has experienced nitrite levels exceeding the National Drinking Water Standards. c. FRICO's willingness to enter into an agreement with the City of Northglenn for shared use of FRICO's water. The proposed project has an overall objective to manage the avail- able water resources as efficiently as possible through an exchange agreement with FRICO. This feature is consistent with EPA's objec- tives to give preference to innovative and nonconventienal wastewater treatment technologies. Consequently, in concept, EPA has supported this project since its inception. 2. Total Water Resource Project: Northglenn has entered into a water exchange agreement with the Farmer Reservoir Irrigation Company (FRICO) . This agreement allows Northglenn to utilize up to 7,785 • acre feet of water for municipal use, all of which is appropriated and stored by FRICO in Standley Reservoir. Northglenn is committed to return 110% of the water diverted for municipal use to FRICO whenever it is called. Therefore, in addition to a water treatment plant and a wastewater treatment plant, Northglenn is proposing to construct a year-round storage reservoir, and a plan for replacing any water that is consumed by the City of Northglenn. This plan includes the proposal to collect .and treat the urban runoff in North- glenn, pumping large quantities of groundwater, and obtaining addi- tional water through purchase, etc. Under the agreement, FRICO is under no obligation to provide water to Northglenn until FRICO is assured that all related facilities are constructed and North- -5— glenn has secured approval of its plan for providing make-up water. Northglenn may continue to rely on Thornton for domestic water up to the time when FRICO water is delivered for use by . residents in Northglenn. November of 1980 has been Northglenn's " ' target date for severing its relationship with Thornton for both water supply and wastewater treatment services. The total project cost (excluding OFM) for both water supply and wastewater systems will probably exceed $50 million. To date, cost has not deterred Northglenn's efforts to implement the project. The community, by a 2 to 1 vote, has authorized 31 million dollars of general obligation bonds for use in implementing the water supply/ wastewater program. City officials have been seeking other sources of funds, including EPA construction grants, to make-up the differ- ence between the 31 million and the anticipated cost of 50 million dollars or more. 3. Wastewater Project: Currently, Northglenn's wastewater is conveyed through Thornton to the Metro (MDSDD#1) facility for treatment (see Figure 3) . Thornton has contracts with each property owner (etc.) in Northglenn to provide this service. All of these contracts are scheduled to expire by 1988. Consequently, Northglenn has been negotiating with Thornton, an agreement whereby Northglenn will provide this service to its residents. The facility plan makes the following recommendations for wastewater transport, treatment, and disposal (see Figure 4) . a. Collection System - Once agreement is reached with Thornton, Northglenn will make improvements to the existing collection system to redirect the wastewater flows to the new Northglenn facility. These improvements include sealing off several lines and connecting them to a new interceptor which will convey the wastewater from the City of Northglenn to the treatment site. b. Conveyance System - Four major interceptors were identified in the facility plan as needed to convey wastes from Northglenn and the Lower Thronton service areas. They are: Brantner Force Main (15,500') , Riverdale Force Main (11,000') , Mott Interceptor (12,000') and the Northglenn Force Main (46,900') . Of these the last item is the only interceptor that is absolutely neces- sary to convey only Northglenn's wastewater. The others are designed to provide service to the Lower Thornton service area. • • —6— ) f.•I I • Figure 1 - 201 Facility Planning Area • BOULDER "1 J' A+ � v�j .1 o . �`-47 / REt'4 -�. e�`°f 71AGRICUU LTURAL REUSE Soon•• aoj/��: `l (SERvlcir_ AREA r EARR / fr. Re�, tT WEST!.iil!STEP, \\ °�' BROOMFIELD ;i . \: STANDLEY •_7 .> . ` LAKE F LOWER SOUTH `' PLATTE CLEAR CREEK f» Jtiz 5. CLEAR CREEEK..�... • ''�-.' . DEMYER SOUTH e. \ LAKEWOOD \NERR ��"r SAND CREEK f "" ( ,.....!!!R "Ef ' ••.•�.._...� ''�' `.., CHERRY ` EA LAK LADE ti 4 fIT L» • -- '— aJ CHERRY".CREEK/ ya UTTLETOH/EHGLEC000 GOLDSMITH\ GULCH CHATFIELD RESE¢YDIR I 1 ti • • • • Excerpt from Northglenn Plan, Vol. 4 • • —7— 1 • • FIGURE 2 AGRICULTURAL REUSE SERVICE ARth / • C, :n'� ♦:1]�1 . r� .^! - ..:le' �.Jf�h. iJlrA, al „..„!...„_,;_ __,77.,..._:..._4' �'. r'co . 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'''.'•°""..."/i •./e. ,V:I' 1 ;.. _ N .st,:T?•a` s t P,� "� ! s't,: cc-.j. ,1 :' Y �F s ..ri.eAI.E I!Tr 7 ' �*i-It o..)-� ri +►t,�-••r,,?1 • " TH RNT9N�•iiii;rfkiArri- ": . . ;r,':!..,. . i • 4• 507'. 000 L I ,., , • ,It•Li'i: ,..1•�•'.,j1 t F61,,11r5. .L I ;..1 -,!._ .` +'C�r t _.7r� 1 f 14 ] . pi +`S a Tht.$tl :lil 'I:J ti '� _ ai I' ;�.f.,i.F `'I'let •�-`! •• ��• t +.1�{' t F.::ct'rpt from *7ort:ht;lenni.1•:�I � ir•. {.•y:4. •-`. -ilS41'FLM,M ,C r�l;��l—'i `:. •7• —f ..-i I j !. VJr ka.::J 1�yli= ��o1� . ,' . • ; • • wq*11 `Ir.I i" • ii•' r,\,,,jr t,' + %:i: :•T_» .i,r•.. `�'••• AGFiIf,.tLTURAI. I1EUSE.SERVICE AREA -, ,�iii'fl0I'1'10'4 i'.` I:,}J; j1..;',,\\, • •4 j' .. iil.a%r‘! -- aORTN(ILENN CITY LIMIT rlll, ti I.Ilt,rl°+ :i•• 't t , I 1 _._ + • II. 1•- L'Ir .!I• I, !'rn�I i.:, .', +'I �'� • • ,.. ' t • 'r -- TNORt:TON CITY LIMIT • • I •I IILi. . •,•,1.I,' !I�,,'+;,!ill;iI ;:i .ICI`' ;�' :`:,:x..•.'• Alin 'hY II• • ,1: �1;II.i Ili, t III. ••• l,.`r.. -'�l [ t� II I ..,4,. j' .; • • • • FORCE MAIN 13- ll�hlIff'+itl' ! !I Iltft — •+!aw.` '': I, ',� � r 'I ..ry. I. , I'''''‘. •I.I r 7 i.1:f.• ay I 'I ,'•! ( WASTEWATER TREATMENT PLAIIT 1+ r" + 'I h �.,r�l r" J�:; , r. i I Ilillllll(IIIIIIIII I '_. `I lI -`:1� ._;-_,• IF I _._ GRAVITY INTERCEPTOR ��...,,z_.... ...,_____• . �r......._ ,er • c. Wastewater Treatment - The facility plan is proposing an aerated, three cell lagoon system for treatment prior to storage and discharge. Figure 5 is a diagram of the pro- posed treatment and storage facility. Due to a 30 .mg/i suspended solids 'effluent limitation the lagoon treatment' and storage system design includes provisions to control algae growth. The aerated lagoons will be designed to per- form nitrification. Through the nitrification process the alkalinity of the wastewater will be reduced. The facility design is based on the theory that carbon will be a limiting nutrient at the reduced alkalinity level, therefore limiting algae growth. d. Storage and Disposal - The facility plan recommends a 6000 acre feet reservo r be constricted in Weld County to provide for winter storage of the effluent. The treatment and storage sites are located adjacent to th Bull Canal, approxirmce1y, 11 miles northeast of the intersection of Interstate Highway 25 and Colorado State Highway 7 in Weld County, Colors h . During irrigation season, FRICO has the right to call the water that is in the reservoir. Consequently, discharge rate will fluctuate based on the calls made on the reservoir. The outfall line is being sized to drain the reservoir to a three foot level within a few days. The plan recommends that a three foot mini- mum pool be maintained in the reservoir to prevent nuisance con- ditions from developing. Chlorination of the effluent will occur just prior to discharge from the storage reservoir to the Bull Canal irrigation ditch. e. Sludge Disposal - The facility plan recommends that sludge be removed every two to five years and be injected in the surroundin;; agricultural land. The plan is not explicit on defining the details of how this will be implemented, nor does it identify a contigency for disposing the sludge if agricultural reuse is not implemented. 4. Cost of the Proposed Project: The cost for the combined Northglenn/ Thornton wastewater reuse system are presented in Table 1. • --15-- • ) I , :N Table 1 Costs of Northglenn's Proposed Project System component Cost Annual OM1 Capital Cost (does not include fees) • a. Collection System 846,0001 10,000 Improvements b. Interceptors 6,543,0002 75,000 c. Treatment Facility 2,239,0002 435,000 d. Storage Reservoir 3,775,0002 35,OC0 • e. Reservoir Site 905,0001 - (already purchased) f. Irrigation Delivery 265,0002 25,000 System g. Sludge Handling 400,0002 30,000 Total 14,973,000 610,000 1. Not eligible for EPA funding 2. Includes cost for handling Thornton wastewater flow. Eligibility for EPA funds to be determined at time of grant award. • ..16_ ) FIGURE 5 STORAGE RESERVOIR PUMPING STATION WITH CHLORINATION -N- BULL FACILITIES CANAL • Ai ' - say SCALE IN FEET , f, 0 100 400 B00 JM / "a\ 1J q / 1 `i :' may . i�� STORAGE RESERVOIR f I; 6,000 ACRE FEET fi' a. 1\11' ` ' ; t: PROPERTY }1 51�'° 1 `!LINE (TYP.) ! _�/ a r 50 FT. MIN.. SETTLI:., FROM EDGE LAGOONS t".:`,' OF BERM 5110 f,; j 4� : — i ! . 4- i -- o . __ __ so•�� 'S FV. I 3120 if, ( . .t , 41, i+ : " t» ii j ‘.1-----7;---4"-c,,..---------. — ✓�AERATION SETTLING :;� ',Z!I "Ic, LAGOONS BASIN Y_: .�• FV1 f it ,i ►_- s. �i �1 EXISTING c.._-......... ri, : i./. ROAD ----,----------r---.—> _. >. ,�� It , ��t '" "",, =Jl r it �+ 1 � t k; � i �� M C-5,10 :I. 1 J�� f!,: SO FT. + 4.A „�o sW.'.. . ;:,; 1 ,MIN. 1,1:rt. � • SEE FIGURE VI-3 1 : FOR FURTHER /?o DETAILS G4- 1 SHEAFFER AND ROLAND, INC. CITY OF NORTHGLENN, COLORADO ENVIRONMENTAL PLANNING AND ENGINEERING WAS'(EYJATER SYSTEM BASIS OF DESIGN SOLAR ENERGY • RESOURCES MANAGEMENT PROPOSED WASTEWATER TREATMENT .1' CHICAGO, ILLINOIS AND STORAGE FACILITIES Excerpt from Northglenn Plan, Response Letter -17- • E. DESCRIPTION OF THE ENVIRONMENT 1. General - As shown on Figure 2 Northglenn is surrounded by other incorporated communities. The Thornton areas of Brantner Gulch and Lower Grange Hall Creek are mostly undeveloped, but numerous new subdivisions are under construction or are proposed for con- struction for these two areas. To the North of 120th Avenue open space and agriculture are the primary uses of land. Northglenn • is principally a light commercial and residential community. The study area is adjacent to the Denver metropolis and is located on the northern edge of the urban develop:nnt in the Denver Region. The study area is located in the Big Dry. Creek and Grange Hall Creek drainage basins. The drainage flows are intemittent and they consist only of groundwater seepage, stormwater, and/or in'. ation water. The Denver Regional Council of Governments CM COG) Clean Water Plan reconn ended a secondary contact recrea- tion, agriculture, warm water biota, and wildlife classification for Big Dry Creek. No recommendation was made for Grange Hall Creek or any of the irrigation ditches in the _,rea. The Colorado Water Quality Control Commission considers irrigation ditches as waters of the State which are subject to regulation by the Com- mission, although very few in the State are classified at this time. 2. Irrigation Systems - The Bull Canal and Farmers Highline irriga- tion ditches are the two largest supply canals for agriculture in and around Northglenn and Thornton (see Figure 6) . The Farmers Highline canal is also used as a conveyance system for part of Thornton's water supply as well as for irrigation. Potentially, the combined irrigated acreage for these two systems is approxi- mately 39,000 acres. The Farmer's Reservoir and Irrigation Company (FRICO) , which con- trols the water delivered to the Bull Canal, via Big Dry Creek is one of the largest mutual irrigation companies in the South Platte Basin. It is this company which has an agreement with Northglenn to allow Northglenn first use of 7785 acre feet of water stored in Standley Reservoir. In turn, Northglenn will return 110% of the FRICO water it uses to the Irrigation Company. FRICO maintains storage rights in Standley ^eservoir for 30,000 acre feet of water of which about 70% is owned by farmers and land owners. The remaining 30% is owned by cities and commercial interests. Westminster has storage rights of 12,000 acre feet in addition to FRICO's rights. Westminster and FRICO also have an agreement allowing each entity to store water in each other's storage space if it is not being utilized. However, the agreement precludes each party from mixing its water with the water that is owned and stored by the other party. This practice is referred to as "stacking" water rights. -19- • 4 , Thornton, as part of its severance agreement with Northglenn is seeking an agreement with FRICO for storage rights in Standley Reservoir for about 9500 acre feet of water. Thornton has iden- tified this storage as capacity in excess of what FRICO needs to meet its commitments for irrigation. ... ... .. . . . The principal crops that are grown with FRICO water are corn, alfalfa, and small grains. Depending on the water supply avail- able during a particular year, anywhere from 10,000 to 15,000 acres may be under irrigation using water from FRICO's holdings in Stand- ley Lake. Water delivered under the Highline Canal system is on a run-of- the-river basis and varies yearly with stream flow. Although there is no central storage reservoir for users of Highline water, there are over SO small farmer owned reservoirs or holding ponds that .are served by the Highline system. The City of Westminster has negotiated an exchange agreement with the Farmers' Highline Canal and Reservoir Company. This agreement allows Westmins,.er to use 1 gallon of Highline water for every gallon of efflu,..nt Westminster discharges to the canal. Westmin- ster has constructed a pipeline from its wastewater treatment facil- . ity to the canal in order to implement this agreement. The Farmer's Highline Canal services many speciality farms (e.g. nurseries, greenhouses, truck farms) and provides irrigation water to grow alfalfa, corn, and small grain crops. According to a recent report, only a small fraction of farms could remain in farming without this irrigation water. The area served by this ditch is constantly under pressure to urbanize. 3. Water Supply - Although the project being considered by EPA for funding is a wastewater project, Northglenn s need for the project stems, in part, from its water supply needs. Northglenn is not in isolation when looking into the future and projecting its demand for water versus its available supplies. The communities of West- . minter, Thornton, and Broomfield all face the same problem. As • Table 2 shows these communities have a projected water supply shortage based on the estimated year 2010 demand. • —20— FIGURE 6 AGRICULTURAL IRRIGATION CANA, ' (,` ` et, e4J� " ' _ / o s7�alt______X_,Q 11080 l \ . o,--- !f : w �./r BM 5a5 5aQc r )an¢ o . a V I \ 115381 1 (` sai. •.'s V ( 0 Lr s_ 1 l%36 31 \ _ N7` f1�U� PAS. ..n Iv • c r ,' J — '1� 1 ...I I /� 1Rv • ivt v i �, l G� � - 11 / I , .'? ., In l �_ r- 4 ,(�i'. • ( 7 , ,..,t \ I, O I, , I �.J A n l I '� •I � �` �1, L r c t s ,..t....„,,,, 5445.-040„„ L .. 1 I , .1ii.`tl Jo p 6901 pp S Ai i s �3 a R 4 ' \ --�` M<ic I%22 l (IM 511J?'A Ai cli / —v/ r. \�4 1 v 1- r \ iii.. _ '^4i V u J , ) OW/ ti . �* HH LPL ° , I A ki II 3NT SJJ 1 ) - J BM '_yp < r r'• 'MAyor.-,4,....--.,-;,---4,1,,:a_ /t� „ _ ..-_,, lr;. dd to i :, t` J2 �,s� L— n ;' �I iou' /dS t Goi [[��,,FF,,�� Iry 1 1' ... t� J I - • i ov` N^ .- . I 1 (( Drs. ow 'i \tlwke o ane,t- ��t Nendf r 5 • 1 2i2.a¢e ' Dso {� . .) �� a' ; ,� - \ I i . 5, 11 i0 1`' � Disci I . 1 < 1 111 36 o1I ` elo va,w ti vc I`ll F , T Y5 C it e. ao. �� til'.. (t 7"- rea.�M1 ;,;' i b .,[�J '44 .� a `..'^ 4� , }-S,r`'�'�'lll�� ll6 ! _( ,/4.. SF' , GP .,�.• -,1— sih .h.�r" ' I�....�„� '� 1, �S- Ate, ;,•2 L: I �I 1 — L ,lYT�-1� .e, AV > �-I— I ( - { FPS t t^> "* ^ .' 1 vit1.ine ' �2 ,1 13 ! J \F, i� r' ii "3 h,. r i }( %r`icrhle' I - G��{� J Y" ` 3 14 � I 'MF 11M i9: 1. �� g .. /1--: ,u UCY t��l' \pl nV<' .v......as � ,.\ ,m fir/ �"� `•� , i)I<< i i;olf\ `.:..i LI t „�. i ' T1i0 R'vTITI%, v,v^e✓:; .,ycA�. C y9fF"(f e.' V'43l>ll1i },/ I' �Sh'�r_a-- TR Rt4T°P. - -.*-I ]I `t.,�1 ' 11 �i --` t d `i 17 f I-- /�`..S t 4`; 6 nf�a//iii t3ki -S ? 1 ns T-tirn.:,; nan, \\\I' / 4 bY.l••.f 1 L'- ilb'alituJULL. 3 rtIP I' I Y5•-' C+vl y I erpt from 1;orth6,lenn �ftL -247(i,/,-„,1 ,A l _.17 3 '� ri.'E� _1.11 I `.�, ,-.:,�ti,, i....�.1a.,n, Vol 4 �IL - VIrW n tlai / , a. ,z— V1 {u � �1 hf t t �'itr I', (tt nr , A&i,lfUlTNNAL @ELISE. t 10E AREA w 1 p \2,104.111) Ill f I, ', > x] 1 Mil , J _ I,, „_, }rJe\, � I \ { 1 i{mil --- - NQ ItIQLENN CITY LIMIT 1}}} ))EE 11 l �� 11 wr,: I � `, �llti. i 11 /� 1 F-1;1; {�y� ( �,I44 t { ---- Tfl RUTQN CITY LIY:71T 36; 11 ' If C a r PCTLUTIAL EY,CU M'CE �h I E}liv .k { vi; r i f s ''i {.. >�`"'sl_ 1 , III IZiATILIN CANALS :::::21.2,„ /it t \�vti I Lla,';IL ''j,. { •, V.----L-4.,_ �t y 44\ 1rifl(1c .,tfUu I °', _ . d f . 1 [1 }Ay .. ,p,�ar y J_ .2 , ,lalth,\k 0. .... �+ •Hanna tvp Table 2 ' • Projected Water Supplies and Needs Estimated Supply from Presently Year 2010 Owned and Utilized Water.Rights . - . Demand .. Potential Average Potential Dry Year Yield (ac-ft/yr) Year Yield (ac-ft/yr) Broomfield . 4,720 2,340 14,200 Northglenn/ .. Thornton 12,100 8,980 25,400 Westminster 12,000 5,500 15,300 :Source: "Draft Regional Water Supply," DRCOG, March, 1978 In order to obtain additional water supplies, the City of Thorn- ton initiated cc.adem atjon suits against three mutual irrigation companies (FRICC., Farmers Ilighiine, and Lower Clear Creek) in 1973. Westminster did the same against two of the companies. One of the suits, 7;:ornten against FRICO, was die•missed by the court in 1976. This suit has since then been appealed to the Colorado Supreme Court by Thornton. These cases have not been decided although the Supreme Court has ruled that "home rule" cities have the right to condemn ep.ricultural water rights in order to meet future water supply During th negotiations between the communities of Thornton/West- minster a ,d the farmers, Northglenn has been busy trying to reach a compromi:.e with the farming community regarding joint use of the availab water resource. This compromise is reached between Northg?ela and FRICO on September 2, 1976 and involved each party signing an exchange agreement whereby Northglenn would have right to use up to 7785 acre feet per year of FRICO water for domestic purposes in return for Northglenn promising FRICO 110% of any FRICO water that Northglenn used. This agreement has precipitated a series of events which has cul- minated with the development of proposed agreements between North- glenn, Thornton, Westminster, and FRICO. These agreements, if signed by all parties, would (a) transfer ownership of the water/ wastewater utility i c Northglenn to FRICO; ;.b) give Thornton 9500 acre feet of storage rights in Standley Lake of which 500 acre feet would be given to Westminster; (c) allow Westminster to assume responsibility for operating and maintaining Standley Reservoir; and (d) eliminate the practice of stacking water rights in Standley Lake. The last two agreements are the most controversial and prob- ably will take some time to resolve. • -23- Historically there has been a problem with the quality of the water supplies in the Denver North area. During the spring, Standley • Lake turns over resulting in taste and odor problems in the West- .minster drinking water supply. Westminster believes that this prob- lem is aggravated by Coors discharge to Croke Canal which feeds Standley Lake. On the other hand, Thornton has detected high nitrite __ levels in its water supply. Thornton believes that this prob- lem is traced to its South Platte alluvial well field which is recharged a short distance downstream from Metro Denver's wastewater disposal plant. The water quality problems associated with West- minster's and Thornton's water supplies are not addressed in Volumes 1 through 4 of thy..' Northglenn Water Management Pro' rain Plan. Water quality of C e is : supply apparently has not a significant factcr in Northglenn's decision to implement the selected water supply and wastewater alternatives although it has been cited elsewhere as a reason. 4. Water Quali t t - Presently wastewater from ti'orthg1enn and Thornton and discharged to the South Platte River which is classified for a warm water fishery and secondary contact recrea- tion. The Clean Water Plan recommends that the fishery classifica- tion be.deleted and that the South Platte below Metro's discharge be classified for agriculture, secondary contact recreation, and wildlife. Northglenn proposes to discharge into Bull Canal which is not classified by the State. The State includes irrigation canals as waters of the State which means they are subject to State regula- tion. Irrigation canals probably will be treated under the State's agriculture classification. The criteria that apply to this classification are presented in Table 3. The State's gui- dance on planning and design for land application systems requires a minimum of secondary treatment for all discharges to irrigation ditches that are not controlled by the treatment entity. This requirement is currently being revised to relax the effluent limitation for suspended solids. • The present effluent requirements for discharge to Bull Canal versus discharge to the South Platte River are presented in Table 4. The • consultant has designed the treatment system to meet the criteria in Tables 3 and 4 for discharge into the Bull Canal. EPA has questioned whether the proposed limit for suspended solids can be . met with the proposed design for the treatment works. Metro is presently discharging effluent to meet the DOD and TSS requirements specified in its NPDES permit. Compliance with the ammonia and residual chlorine limitations is based on the avail- ability of EPA construction funds, but under no circumstances will noncompliance extend beyond July, 1983 and only if EPA grants an exception to the present permit compliance schedule of December -24- • • • Table 3 Colorado's Criteria for Agricultural Use • Parameter Criterion • Dissolved Oxygen An effluent shall be regulated to maintain aerobic conditions, and a guideline of 2 mg/1 dissolved .oxygen in an effluent should be maintained, unless demonstrated otherwise. Suspended Solids Suspended solids levels will be controlled by Effluent Limita- tions (i.e. 30 m g/1 for secondary treatment) and Basic Standards. Arsenic :1 mg/i Beryllium .1 mg/1 Cadmium .01 m ;/1 Chromium .1 mg/1 • Copper .2 mg/1 Lead .1 mg/1 Manganese .2 mg/1 Molybdenum .15 mg/1 Nickel .2 mg/1 • Selenium .02 mg/1 Zinc 2.0 mg/1 Cyanide .2 Nitrate (as N) 100.0 mg/1 • Nitrite (as N) 10.0 mg/i Boron • .75 mg/1 Fecal Coliform per 100 ml (Geometric Mean) 1000 -25 • • - • Table 4 Effluent RequivemPnts. for. Existinn Discharge to the South Platte River versus Proposed Discharge to Bull Canal Metro's Existing Discharge Limi- Proposed Dis- ta.tions charge Limita- CO-0026638 tions for Bull Parameter (South Platte)a Canal • BUD 20 30 SS 20 30 I -i3-N 1.5• - NU3-N - - • Cl2 (Total residual. C1) 0.05 0.5 Fecal Coliiorm (#/100 ml) 1000 1000 Dissolved Oxygen 6.4 2.0 a. NPDES Permit requires compliance by December 31, 1979, dependent on the availability of adequate funding. • • • -26- 31, 1979. Metro is presently conducting a Step I study to deter- mine the cost effective alternative to meet this requirement and/or any other requirements that may be imposed in order to protect downstream water supplies. Thornton has during the recent drought noted nitrite levels ex- ceeding national drinking water standards in its distribution system. Thornton has attributed these high levels to Metro's dis- charge, although identification of Metro as the source of this problem has not been verified. Even if Thornton is successful in reaching agreement with FRICO for 9500 acre feet of storage in Standley Lake, it wH11 continue to rely on wells along the South Platte for water -1y during the winter months. Consequently, consideration must be given to protecting Thornton's water supply which the present i•Ietro facil- ity planning study is taking into account. 5. GrouncT ter - ti:rthglenn is underlain by three bedrock aquifers wniai are the Denver, Arapahoe, and Laramie-Fox Hills. The ; aver aquifer is the only one of the three that is defined as tributary • by the State Engineers Office. Data for several wells in the vicinity o, Northglenn indicate that yields are as great as 100 gpm. Since the majority of wells in the Arapahoe formation are being used for domestic purposes the yields average less than 40 gvn. Average yields for Laramie-Fox Hills wells are 75 to 100 gpm. Wright Water Engineers have esti- • mated that a potential yield of 2300 acre feet per year is avail- able for appropriation from these two aquifers below the boundaries of Northglenn. The water quality in the Arapahoe and Laram:_e-Fox Hills aquifers is variable. Table 5 is a stnnnarr of the aiailable water quality data on these aquifers. In general, the water quality of these formations in within the Public Health Services drinking water standards. The piezometric surfaces of the Arapahoe and the Laramie-Fox Hills - aquifers have been declining during the last few decades. For example, the Laramie-Fox Hills aquifer has experienced a decline of 200 to 300 feet during the period of 1960 to 1976 in the vici- nity of Northglenn and Thornton. Similarly, the Arapahoe aquifer has experienced declines of SO to 2.00 feet for the period since 1970 and the aquifer is now at or near crater table ccr.Ji.tions in the Northglenn area. The Laramie-Fox Hills aquifer is still under artesian pressure in this area. Northglenn has indicated that up to 2300 acre feet of water may be pumped from these aquifers during a dry year in order to make up consumptive losses that will be incurred in the Northglenn system. Volumes 1 and 2 of the Northglenn Water Management Plan proposes . —27— • } ;. aa • that this water be pumped from a series of 10 to 20 wells located - -- throughout the city. Northglenn's application to obtain rights to the Arapahoe and Laramie-Fox Hills water is presently before the Water Court. To date, the State Engineer has approved one (1) out of 20 permits requested by Northglenn to construct the neces- sary wells. There is still a legal question "whether a im.uircipailty such as Northglenn is entitled to appropriate groundwater under- lying private property. Because of the uncertainty of obtaining both rights to the water and the well permits, Northglenn is also actively seeking other sources of make-up water. 6. Air Quality - Volume 2 of the "Final Denver Regional Environmental Impact Statement for Wastewater Facilities and the Clean Water Program", presented a surcaary of Denver's air quality for the years 1974 and 1975. The eight-hour standard for carbon monoxide and the one-hour standard for ozone were the two criteria violated most frequently at the six air quality stations located in the metro- politan area. No air quality stations are located directly in Northglenn or Thornton. However, air quality modeling indicates that these problems pervade the entire metropolitan area, includ- ing both Northglenn and Thornton and will conti.iue to be problems sometime into the future. 7. 'emulation Projections - The population projections for the study areas are presented in Table 6. These projections are derived from and are consistent with DRCOG's projections for the area under study. Of the 30,000 people projected increase from 1977 to 2000, about 1/3 would occur within Northglenn's corporate limits, while most of the remainder falls within Thornton's city limits. Some growth will occur outside of both communities in Adams County. The facility plan evaluated the need for wastewater service in these areas and recommended that the proposed North- glenn ITN P serve the outlying areas in Adams County. To date, there is no commitment from Thornton or these other areas to have their wastewater treated at the Northglenn facility. 8. Land Use - The developed portions of Northglenn and Thornton are cTevoied primarily to residential and commercial uses. These . communities provide a labor force for industry, business, and government located located within downtown Denver and Boulder. Of the total study area about half the land is presently used for open space and for agricultural purposes. The majority of this land is located within Thornton's boundaries, or in the unincorporated areas of Adams County. —28— • Table 5 1 SUMMARY OF NON-TRIBUTARY WATER QUALITY Arapahoe Aquifer Range Average (U.S.P.H.S.) Total Dissolved Solids (ppm) 210 - 467 250 - 300 500 Temperature (degrees F.) 61 - 68 65 SAR 14 - 25 18' - 20 pH 7.8 - 8.8 8.4 9.0 Hardness (ppm) 4 - 23 10 Iron (ppm) 0 - 2.5 0.2 - 0. 5 0.3 Calcium (p M) 0.6 - 8.1 2.5 - 3 Sodium (ppm) 79 - 164 100 - 120 Fluoride (ppm) . 0.7 - 2.8 1.5 0.9 - 1.7 Sulfates (ppm) 12 - 123 30 - 50 250 Laramie-Fox Hills Aquifer Total Dissolved Solids (ppm) 440 - 714 600 500 Temperature: (degrees F.) 67 - 77 72 SAR 15 - 50 20 • 30 PH 7.8 - 8.2 8.0 9.0 Hardness (ppm) 3 - 44 10 Iron (ppm) 0.05 -0.11 0.08 0.3 Calcium (ppm) 0.4 - 3.3 1.0 Sodium (ppm) 200 - 294 250 Fluoride (ppm) 1.2 - 3.6 2 0.9 - 1.7 Sulfates (ppm) 2.5 - 7.8 5 250 Excerpt from Northglenn Plan, Volume I -29_ • • TABLE 6 SUMMARY OF POPULATION PROJECTIONS BY MANAGEMENT AREA Population, Year Management Area - 1975 1977 1980 1990 2000 UpDer Grange Hall Creel, Northglenn 29,000 32, 000 35 , 000 42 , 500 42 ,500 Sub Total 29 ,000 32, 000 35 ,000 42 ,500 42 ,500 • Lower Grange Hall Creek Thornton 3,600 5,400 8, 100 12,400 15 ,200 Other • O500 800 1 ,300 1 , 800 2 ,100 Sub Total 4,100 6 ,200 9, 400 14 ,200 17 ,300 Brantner Gulch • Thornton 3, 000 3, 500 4 ,300 7,600 10 , 800 Other 100 300 700 1, 500 2 , 100 Sub Total 3,100 3, 800 5, 000 9 ,100 12 ,900 -- .— TOTAL 36,200 42,000 49 ,400 65,800 72,700 Excerpt from Northglenn Plan, Vol. 4 • -30- • } . • DRCOG has defined an urban service area for the Big Dry Creek Basin which includes much of this open space and agricultural land (see Figure 7) . It is DRCOG's policy to restrict develop- ment to these urban service areas. Given DRCOG's growth policy, their definition of the Big Dry "Creek Service Area, and their population projections for this area, it can be expected that much of these lands will be converted to urban use during the next 20 years. It is EPA's policy, however, not to construct wastewater facilities that will provide service in areas where prime agricultural land is located. It has been estimated•that 18,800 acres of land were converted to urban use from 19-69 to 1975 for an area much larger than the Northglenn/Thornton study area, but which included this area. The relationship of the urban areas to three irrigation service areas is shown in Figure 8. A comparison of Figures 7 and 3 show a great potential for converting agricultural land to Moan use. 9. Economy - Northglenn and Thornton are typical suburban communities. T#ie economy of 'these communities centers on property taxes and sales taxes. Most of the income generated by the communities' work force is derived from sources outside Northglenn and Thornton. Northglenn passed a 31 million dollar general obligation bond issue for the purpose of paying for capital improvements asso- ciated with the.recommendations of Volumes 1 through 4 of the Northglenn Water Resources Management,Plan. In addition to this source of funding, Northglenn expects to receive funds from EPA as well as from other Federal and State sources. ].0. Soils - Of the 23,665 acres of land classif__ed in the FRICO and Fanners Highline Irrigation Service areas (using the Soil Conser- vation Service's Soil Capability Classification System) 15,881 acres fall under Class II or III, both of which are highly suit- able for irrigated agriculture. Table 7 summarizes this infor- mation for these two irrigation service areas. Figure 9 shows where prime agricultural lands are located in the DRCOG planning region. It is assumed that these percentages characterize the soil types in the facility planning study area as far as suita- bility for agricultural use. Based on the Soil Conservation Service's rating and some additional criteria, PRCOG attempted to defi:e where prime agricultural lands are _Located in the five county Denver metropolitan area. Figure 9 graphically depicts where these lands are located. Based on a comparison of Figures 7 and 9, it appears that the unincorporated areas in Adams County east of Thornton is the only area where prime • -31- . • agricultural lands overlap with the DRCOG service area boundary. • However, DRCOG's Regional Development Policies (RDP) numbered 1 and 35 would allow development in this area in that RDP 35 applies only to non-urban areas which are defined as areas outside of an . - . . .. ... —urban service area. Despite DRCOG's policy P l i owing dpvp1 npment in this area, EPA is required by regulation to evaluate other alternatives which will encourage the preservation of agricultural lands. 11. _Proposed Storage Reservoir and Treatment Lagoon Site - A separate Study investigated the suit. b .a ity QI the proposed site foe the storage reservoir. This study characterized the site's topography as generally flat to gentle (l to 7 ) slopes. The site is presently being cultivated. Coal mining has occurred during the past 100 years in the area, but no known coal mines exist in the JT=c di.ate vicinity of the proposed site. The proposed site overlays the southern border of the Boulder-Weld County coalfield. The site also overlays the Sprindle and Wattenburg oil and gas field. No sand and gravel deposits were detected during the field investigations of the proposed site.• - The geology is sandstone occurring in Milliken, Fox Hills, Laramie, and Arapahoe Formations, ranging in depths from 6 feet to 600 or — more feet. Soils include up to one foot of topsoil underlain with claystone and clayey sand. The Laramie-Fox Hills aquifer occurs at a depth of 600 feet and is approximately 100 feet in thickness in the vicinity of the pro- posed site. • • • • • -32- a)I _ i. 1, . 1• _!. •1`, ' . • ':7' '..-1,il.Tri-••• •i ..1,:., _J...I : . s• . ........ I. I : •r r i • S 1 '_ I• AGURE 7 ` iI I • I /p I , e. _ Faciiitlea Service Areas . : }J• I t•`9�• '1d:t t'',4�•'. . .• :„a�;, iii,.. NOTE:fAC0.1TYSNOWN5ERVICEAREA9fORA0ENC!E9 1 • 1 . 1 � 155_i. -:-.1 : Fp t NOT ON THE•MAP Y'OIRD SE COMPARABLE t::,1_,-1-1:,1•:.: �' h ,4 t !.;7• TO THEIR EX!STIN3 SERVICE AREA. • I I.4,./i,,,Ii.7'1 I t `7 . `; r .. 4 .1.,.^ ''d II' I •:.Y• V C.-1,- . 1,1 1�' 1 ,j I. irl -�: ' . :6RIE.. 1 ••1 ..I. I , 1 l • . \ '•• 1/'•(; r .t I f •• I 5551• • a •Ir • 1B, 1' ,LAF/.YE.V.E 1 .I' .1 1 l ., j. •. ` 1• • ?_. • . . . .. . `fin •').it•;1,; • tc :;',, . i • M:. • 1 I 1 •L. •f . y 't. •.• • ` 3••-'- ••• ' . . ••ti.rti .4•-•1•'',-a../,- :t''.-; t• .r+. T,• •` '•.,:.:... • • •._ • :� •l. '� •.„�+. sa P�+ i,` .44,gNiOM • ;#/.,:;•"*".;,'"! �,... •• _. ..., . 1 • • •.... , . •li1 •! COW `•• `�. ..L�' ti i;:_ r . y•) • • •-.. - .'-i •. W •' I .•fit, y f `� —,. .4..Iw••••��• '. `•• !'tx.!. .1#- .'vr •``'f' t+'�•,f ;: ems ' , �.J�� • 'Li`� �,. _• � .• - 4,w..id s . • ••• ..1-,•••••'!,•.!••e"...!:••'•".".•72174%1.: -•i• (+y _SOUTN_ADAMS,COUNTY Ni 1. ♦' ` tom..` • ,'• -15•3001'1 '�!tr1.�g1 tf•i: ...• • �- , �i —.yh, ; _ , , 5-I•,a. '`-T'• ;• .�e'i'• • :_ X11.I....•• .. �_, K'•- _•+' 3\)t �. �, .-•--a---'--: • •t-frl., - . -I -I i _.!; _�'-*'•FJT251MOu8�. w-- - `+,i _ -s• J -('�.l _ ff• ••••:.1 r?'� �dJ7lt"L'AKE1Y000 �_i`: ,t'}•'_- /•..•t l ._re '- Y .\_f�`- - may,` ..,,,y .. •I ::•��,('��.J r _,....._,,..son„.:__.- -\_1 L14 •`. �'�i.. II ♦ ,1. '�. �. :'�/� ' :g.":::-s. ..,p�NYER HOi�TH�!PE. \-�`.a'`i. �Gl• AN1i'CREEK `� 1.4 • $ x ▪ • / ' _11 '• ' `-Lac..... ``5555. ` } • .i.---14-1 , .--71.55•: •1•,.�. J± ?: I. —I:. a -4-\ '+-4.- .. .� \t`w •tiJ l�r '' • • 54�Nvil /J 1 Ali.:'...;;;;,-,-'-'•' '`,:b.•' I i _/I r• 1. �1 .i • Y' `�!l•.' •`5' '1 , +�•r.,.r ,.a: I. ( :1 ' F,,,, •...•.. :•,':1 •,r t*;S .* y I.: 1:j k:11.-::'...:: >:, 755`5. r l , 1. • I *T' },, ;'�-]••,w; \ v , ,M• • • -..I -1 • {c;t 1 • . i I ::.,:' 1 •Y-1 I t ti1 • F ti •,'SR�• ••\� vk.�: 1 1 1 i • /'+1 1 .r• r �l :-•r 1 • 11{ i•1(1t ,�" z : ) " .{ t� 1 51•.55 ,;• • I. 1 t i •I �i:• I -1'i�l J `55 5 5 • • •` f ` y. r i .! 1 ; • 1 , 1.'il e ti..., ,.. ...i.. .._:::/.: .i f i'!-1.:.1-7.t. ,. ,.1 f!\ , ,i• \tit), 1 i i -,,:-.. ' -' ' 7 . —I . . : • -.. .. ? l'.,-/I �^ it , I .1 ;. . ,•C•. I I 'l _ 5 1; D. `'�. '�\ ! .. ...7i 55:55. �:_�� i I _ I Excerpt from Clean Water Plan 1 33— ; • 1 • Ro9W )dw • 0 Figure 8 ,},./_,Irrigation Service Areas with City �r• i . s'r Boundaries and Urbanized ,,i'" °i�:'' Aroas:January,1974 - t.t;.gend ._--z.i. / ": r4.Vr-a Formers r'2escvoirr,ndIrrig:.tionCo. �-.'•.1.. '.: I.— 'Z '�'.'. (S1nndiky Lzkn Division) s ./:L___(:•-"'' .-• — Farmers'High Linn_ L.inelund tt t•^:L}�. -i•--:• •-1 p74 I�r2 Lower Cie et Cret I:Ditch Co. ce`%`�"' •f _ ';._ r ?= - - a ADANIS co [•:23 llrbunircd Arc r,1.-: ,.v."t':'-_ -- ^--- City Boundary .-- '''j` } -.:7:7ii.it.%-:1 0 1 7 e - 4 /11 SROOMFi eft t" • I Qnc*..., e: =!.--..7.7'""'"'•"=:'''''''''''''—f..7..7.'.'i.Z2-n._""'S ';i `... .'-.-....1 L.- ▪ •... ....... l.,r e»« , ,Eiji ' _ f :*\4-:-!111-::7-:-; • / ...:.:„..:::1,I t-out.Dr R soCO -1-77-f— . <,,o.4-:--'1:=-, =- - _' • r-••-ter,,�;.-t-.'� r .i t5- ..f t "1 ` i�- i 1 L'.. I T----",1_1 1 •C1`>;/ttr..:t•aZ je i NOPT :3LENN • ' e.F., L.,i 6 i .- - 9� 3„-'.---1.-. ._ FE:.=RAL:•• 1• mil[_.^. ! •7'r•• 7 i i7!S I,• ;:eer.Aiy `• - -' rrEit'ti7S rritC 1 t' Lett. /F. :• r -ti�t;; :: r-----.. :,il . t-rt------- ---e:_ -::-.1.-:i1:11 . : - L=.'-1.--i-... - _ e tom` ,''... •F CDntrI:-.ReE i ._ "� :i AftYACi t• • •* CITY i r•-�•-+ a:,' ! �.�..�. 1 Ire., rf L'.._.,i It A°': _ r`° —y i . -j •• i r j CENvE..COQ .! —_. t Tss •; era ,\ r-1 ems•,• c0.. • OI i; =t.,. WHEAT F:IDOE ui DEN cR i` GOLDEN 1 j. I I .� �-' % c9 r of • �' • 1 'B LAKEWOOO -i`� i 1 tt AU SC A ta, r .1.r ! •Fl71Ve �-1 _ 1 F17OW • • AIL ‘ ra flow �' rintl,.v Excerpt from CSU Report by Anderson, et.al. —35— _ 4 , .-‘, ." • te...1.2%..i..' . ) %'Itati ' 10 1101 1 �2 - VI VI I cok + 2� asa Q . !' v ii ...:„......--..,'".......• Sk,.14,t-1\31.2:1VA-' ,...' .7"..::1 i'!, ;:9 0 40. ill 1 y y gr O "" ks.,.._,..e.:,72/TrAi.:-5-..."*. 4Icciacu-il!.....4,ii I/ '.. ,/. O 1 �-y t O re ra �j O 34 •- ,may ~ ' .. • .;^. f ! = f --j - 11 Ql cji i XI, i ` � 1`-mil ill 1{ r Y .: e r i 4S ` J1,.. .tt - f/ i ....ef k..;r6 t 2 , ....; •` t i ;1 , fir-:; . -:• _ ! .1, a • ftbE3r._ --•- -------• —3 7— • Table 7 • • SCS Soil Capability Classification: Irrigated Cropland in the Farmer's Reservoir and Irrigation Company, Stanley Lake Division and the Farmer Highline Canal and Reservoir Company as of 1970. SCS Class Acres Percent II 12713 53.7% III 6653 28.2% IV 3010 12.7% V 406 1. 1% VI • 310 1.3% VII 573 2.4% 23665 100.0% Class I - Soils in Class 1 have few limitations that restrict their use. Class II - Soils in• Class 2 have some limitations that reduce the choice of plants or require moderate conservation practices. Class III - Soils in Class 3 have severe limitations that reduce choice of plants or require special conservation practices, or both. Class IV - Soils in Class 4 have very severe limitations that restrict the choice of plants, require very careful management, or both. Class V - Soils in Class 5 have little or no erosion hazard, but have other limitations impractical to remove that limit their use largely to posture, range, woodland, or wildlife food and cover, Class VI - Soils in Class 6 have severe limitations that make them generally unsuited to cultivation and limit their use largely to posture or range, woodland, or wildlife food and cover. • Class VII - Soils in Class 7 have very severe limitations that make them unsuited to cultivation and that restrict their use largely to grazing, woodland or wildlife. Class VIII - .moils and landforms in Class R have limitations that preclude their use for commerical plant production and. restrict their use to recrea- tion, wildlife, or water supply, or to esthetic purposes. Source: Report by Anderson, et. al. • -39- • • F. ENVIRO ! is AL IMPACTS AND PROPOSED MITIGATING MEASURES The facility plan evaluated six (6) general environmental issues in terms of what impacts can be. expected with and without the project. • They are: growth, water, air, energy, agricultural preservation, and environmentally sensitive areas. In addition to these issues the facility plan identified more site specific impacts related to the location of facilities (i.e. the interceptor, treatment lagoon, storage reservoir, and. urban runoff collection reservoir) . The results of this and EPA's evaluation are presented below. 1. Growth - Growth is the co►m'iion denominator for discussing impacts for the other five environmental issues. Without.,grewth and assuming no increase in per capita demand for goods end services, there probably would not be 'any increase in the demand placed on the available air, water, lend and energy resources. Zero growth is not and be not a _.. iiey within the timefrw e of this plan- - ning pa-dcd, as is evid.n_.'d by the facil7-r.; plan's project .;;n for an increase of 30,000 people between now and the year 2000. • Northglenn and Thornton are implementing plans to r,:.ov ide eFsen- tial services for their expected increase of 10,000 and 20,000 people respectively. Similarly, both communities are developing new ways to manage growth in order to minimize the impacts that this growth will have on the urban and natural environments. • These measures will be discussed in the sections below. EPA has established a policy of funding wastewater facilities in the Denver metropolitan region which are designed consistent with • DRCOG's population projections. The proposed Northglenn facility meets this criterion. EPA will not, however, be able to fund capa- city for the Lower Thornton Service Area without an executed agree- ment stipulating that this area's wastewater will be treated at the Northglenn facility. EPA has taken the position that once con- struction begins on the wastewater treatment facility, no increase in funds will be forthcoming to construct capacity for treatment of flows from the Lower Thornton Service Area. • 2. Water - Surface water quality, water supply, and water rights in the State of Colorado are all interrelated and this is especially true when discussing Northglenn's Water Management Program. The Clean Water Plan concluded that achievement of EPA's 1933 • water quality goals are not attainable for the South Platte River below Metro Denver's discharge. E 'A is not convinced the documenta- tion presented in the Clean Water Plan supports this conclusion. -41 • - •• . . . .. The Northglenn facility plan claims that withdrawal of their waste- water from the Metro facility and substituting discharge of a secon- dary treated effluent to Bull Canal will improve the overall water quality of the Denver Region. This claim cannot be reasonably sub- stantiafecl""'since the quantity of wastewater flows being diverted are minor compared to the total Metro wastewater discharge and — stream flows in the South Platte River. EPA is convinced that in- stream water quality of the South Platte will be improved, if Den- ver Metro constructs and operates a facility that is designed to control ammonia nitrogen and/or nitrates. As far as the water quality in Bull Canal is concerned, the projected discharge quality will be compatible with the quality of irrigation water flowing through the Canal. — EPA's questions about the proposed design of the wastewater treat- ment facility have not been resolved. However, regainlinss of the — alternative treatment technology that is finally selccte the facility that will be cons tr eted will be designed to ,: _t appli- cablerequirements. Consequently, e .. cable discharge PA does net expect vi change in the environmental impacts resultin'; from a resolution of the questions dealing with design of the facility. The effect of the proposed project on water supply will be positive • once the FRICO/ orthglenn agreement is implemented and Northglenn begins to use Standley Lake water. Implementation of the discharge agreement will result in immediately adding 6125 acre feet of water supply for domestic use (FRICO's commitment based on the dry year demand for 35,000 people) . Thornton has stated that the Northglenn severance will free 10,000 taps which is more than adequate to satisfy the projected growth in the Lower Thornton Service Area. The addition of this water, however, will not enable Thornton to abandon its South Platte alluvial wells. This is true even if Thornton is successful in obtaining 9590 acre feet of storage in — Standley Lake, because the right to storage does not include any right to use FRICO water. Consequently, implementation of the FR1CO/Northglenn exchange agreement will not solve Thornton's _ water supply problems. Northglenn will attempt to solve the taste and odor problems of Standley Lake through the design and construction of its new water treatment plant. • Due to legal difficulties which Northglenn has encountered in ob- taining non-tributary water, the water rights for the make-up water . for the project have not been identified. It is unclear at this point what procedure Northglenn will take in obtaining water rigs-ts. Northglenn could take the option of preparing an overall plan of augmentation for the development of its water supply. The augmenta- tion plan would include a description of the water rights which will be used in the plan including historic use, diversion records, water decrees and priorities, and proof of ownership. The plan would be - -42- • . • • developed in order to insure that as Northglenn develops the water supply there will not be injury to any vested water right or decreed conditional water right. State laws which regulate water use pro- ._ _. . vide for administrative and judicial review of augmentation plans in order to protect water users. Northglenn has also indicated that until their own water rights are obtained they may. take the option of using the water which is presently supplied by Thornton for their system. It is not clear if this proposed action would fall under the court ruling which permitted municipalities to change their wastewater discharge • point to a location downstrea.► when this change caused injury to water users. If Northglt, ciecta to go with. this option EPA will require a legal ops re^;:z-:J ing this issue. It is not clear if there would be i njuries td .water ueers if this option ' is followed, thus environmental or eeoemic impacts caused by these potential injuries have not been analyze d. EPA w.t?l require Nor l wl.enn to dcmonstrr:t.e that it has acquired all the necessary make up wa• it needs to • } :he exchange :c.r � . .:,. l�:i •�,:t� ^tee project and has made provisions to pay al] cos s associated with them prior to award of a Step III grant and initiation of con- Structicn. 'At the time this negative declaration was written, no decisions were made on the quantity of groundwater (shallcw or deep) to be pumped by Northglenn. Therefore, it is difficult for EPA to assess the impacts of the proposed project on the groundwater quality and quantity. EPA believes that if the full scale ground- water pumping program (3000 acre feet in a dry year versus 2700 acre feet in an average year) were implemented the groundwater impact could be significant. Northglenn did provide an estimated drawdown that could be expected in the Arapahoe aquifer if it were pupped at a rate of 1300 acre feet per year for a 100 years. Two cases were evaluated, the first for an average permeability of 20 gallons per day per gquare foot and the second for an average permeability of 50 gpd/ft•-. The results of this analysis are presented in Table 8. Table 8 represents the drawdown that is expected from Northglenn's proposed groundwater pumping program only. The aggregate effect of all groundwater pumping, existing and proposed, from these aquifers is not known. The information presented in Table S is based on . the assumption that the aquifer will yield water equivalent to -20 percent of its total vplume as the aquifer dewaters. It shout u be emphasized that the value of the specific yield of 20% is an estimate. There is a possibility•that the actual specific yield in the Northglenn area could be less than the estimated value which would increase the impacts due to pumping. An analysis was not done for the Laramie-Fox Hills aquifer since Northglenn would pump from this aquifer only during a dry year. -43- . Since the shallow wells are tributary to the South Platte, any pumping from these wells will require Northglenn to acquire the rights to this water. Pumping from wells tributary to the South Platte will probably reduce stream flows. The effect on ground- water quality or in-stream water quality was not evaluated. uc ed on the relatively low proposed maximum quantity of 1440 acre feet — per year, EPA does not expect any detectable changes in the sur- face or the groundwater quality. EPA will recommend to the State Engineer that additional studies be conducted to better define the average storage coefficient of the Arapahoe and Laramie-Fox Hills aquifers p=ier to approving any more well permits. EPA expects -that a better analysis of the potential impacts of the proposed groundwater pumping pro- gram could be made once this study is completed. As part of EPA's final action on the Denver Regional Environs ental Impact Statement, EPA is requiring applicants for construction grants to comply with the following provisions to promote water conservation in Metropolitan Denver. "Prior to making a grant for design of a wastewater facility the grant applicant must demonstrate (in conjunction with the appro- priate local jurisdictions) that: a. The feasibility and cost effectiveness of metering and pric- ing incentives have been studied and steps taken to implement these measures where cost effective. b. Building codes have been evaluated to incorporate, where - feasible, water saving devices in plumbing systems on new construction or major remodeling and a program instituted to encourage voluntary retrofit of such devices by property owners. c. The design capacity on other features of the wastewater treat- _ ment facility reflect the projected reduction in wastewater flows. d. Wherever the dry weather wastewater base flow (excluding in- dustrial flows) to be used for planning a treatment works exceeds 70 gallons/capita/day, the applicant plan and imple- ment a water conservation program and use the reduction in wastewater flow as the measure of design capacity for new treatment facilities. As a guide, a 15 percent reduction in wastewater flow may be expected from the implementation of an in-house water conservation program." - The facility plan included copies of several draft ordinances which are designed to ensure that water is conserved once Northglenn assumes responsibility for water treatment and distribution. EPA is satisificd with the provisions of these ordinances as meeting • the requirements of a and b above. EPA will condition Northglcnn's - grant award to require adoption of these ordinances. -44- ) • . . -Table 8 Drawdown (feet) in the Arapahoe Aquifer Due to Northglenn's Withdrawal of 1300 acre feet per year Case 1: Permeability = 20 gpd/ft2 T.e Distance to Nort%lenn (miles) (yrs) 2 - 4 - -- 5 - - 8 1O ' 20 71- 5 0 0 0 0 0 0 10 .25 0 0 0 0 0 20 2.2 0 0 0 0 0 40 8.1 .25 .03 0 0 0 60 14.0 1.0 . 20 0 0 0 100 23.9 3.6 1.2 0 0 0 • Case 2: Permeability = 50 gpd/ft2 Time Distance to orthglenn (miles) (12-s) 2 4 S 8 10 20 1 0 0 0 0 0 0 5 .23 0 0 0 0 0 10 1.42 .01 0 0 0 0 20 4.37 .23 .04 0 0 0 40 9.14 1.42 .49 0 0 0 60 12.62 2.91 1.31 .05 0 0 100 17.59 5.72 3.21 .35 0.10 0 • Excerpt from North?3enn Plan, Resrorse Letter _45— • The facility plan used 90 gallons per day per capita as the basis for design. Records of water consumption for Thornton and North- . glean indicate that dry weather in-house use in 1977 was 62 gallons per capita. This figure is within EPA's .criteria of 70 gpcd to be used for designing treatment works. Thus requirements c and d above are satisfied. 3. Air - The proposed project may have the effect of delaying the conversion of agricultural land to urban uses in the FRICO service • area. By keeping agricultural land in production, the facility plan claims oxygen producing vegetation will promote cleaner air in this part of the Denver Region. The exact difference in .air quality is not predictable but EPA would expect some air quality benefits benefits from preserving open space and agriculture within and adjacent to the metropolitan area. Some of these benefits will be offset `.;t the conversion of agricultural land to urban use — in the Lower Thuruton erea. EPA, in an attempt to promote better air quality through the im- plementation of its program.s requires the following of all its applicants for wastewater construction grants in the Denver Region. "EPA believes that funds be made available only where reasonable actions are being taken to deal with the air quality impacts of growth. Accordingly, EPA will require: _ a. A commitment from the elected policy body of the local govern- ments which are to be served by the proposed wastewater treat- ment facility, to: — • (1) Implement air pollution control measures considered rea- sonable for their area. The s.ir quali.t ~rogram adopted — by the City of Westminster is an (txampie. (2) Participate in the process established by the State of Colorado and the Denver Regional Council of Govern- — ment:s to revise the Denver eat:arnt of the State Air Quality Implementation Plan. (3) Support the implementation of the Denver element of the State Air Quality Implement on Plan once approved by EPA. • b. Design wastewater facilites based en DRCCG population pro- jections (or as revised during thy: State Air Quality Imple- • mentation Process) with capacity increases staged in accor- dance with the April 25, 1978, regulations (43 FR 17697) pertaining to grants for construction of wastewater treatment works. • -46- • c. The grant applicant (in conjunction with local jurisdictions) to develop and implement a sewer tap program which annually determines the number of taps available for new residential development and which is consistent with the DRCOG popula- • . tion forecasts for 1980, 1990, and 2000. d. Development which will be served by. the additional capacity to be within the adopted regional urban service area boundaries and contiguous to existing development as stated in DRCOG's Regional Plan Policies. EPA may require evidence that local governments within the service area are pla rioting contiguous development thr ct:4.l: � �.��inf actions, bui:]s��.r,.�* permit approvals • and tap allocations." • EPA has discussed these require-::ents with Northglenn and they have already taken mea.smes cons'st: n4 with these requi.rc„.cr:ts or are committed to c r:moly with the above requirements. EPA intends ends to condition its Step II and III grants based on compliance with these provisions. 4. Energy - EPA has adopted the following policy regarding energy conservation for EPA funded projects in the Denver Metropolitan area. "As a requirement for receivin a grant for planning or design of any wastewater treatr::.nt works, the considera- tion of solar energy and energy conservation technology and techniques must be demonstrated by showing that energy requirements, particularly for natural gas, have been reduced as much as possible." Supplemental material to the N'crthglenn facility plan provide a detailed analysis of the energy requiie^ients for several alter- native:, considered in the Plan.. This information is summarized in Table 9. This analysis indicates that there will be consider- - able energy saved by implementing N'crthg].enn's proposed project. Consequently, EPA is satisfied that the proposed project meets the above requirement. • S. Land Use/Agricultural Land/Environmentally Sensitive Areas - A feature that;ia.s made the proposed project attractive-f om EPA's perspective is land application of the wastewater effluent. The facility plan claims that a direct result of the exchange progru:.r will be the maintenance of 16,000 acres of land in agricultural production. If this land were converted to urban use it is esti- mated that approximately $1,543,000 of net agricultural income will be lost annually. • -97- Table 9 Energy Consumption (megawatt hours/year) Alternative Energy Consumed 1. Northglenn Agricultural 11 ,653 Reuse Plan 2. Metro Denver Alternatives a. Status Quo1 14,37S - b. Modified Status Quo2 32,342 c. Protect Downstream Water Supplies 20, 764 d. Meet 1983 Goals 4.'0,901 1. Meets existing discharge permit requirements. 2. Meets existing discharge permit requirements, but assumes successful implementation of Adims County sludge plan. -48- } • • • • EPA has a policy of promoting the preservation of prime agricultural lands. EPA is using its construction grant funds as a means to • implement this policy by encouraging the use of these funds for constructing land application projects. EPA regulations and the Clean Water Act provide for 85% funding of_land application projects in addition to giving a 15% preference to these types of projects in the cost effectiveness analysis. EPA has developed some requirements for ensuring that land appli- cation projects continue to operate as a land treatment scheme throughout the twenty year planning period. In general, EPA requires assurances that the applicant can control disposition of its effluent such that land application of the effluent is guaranteed for tfitienty. years. Therefore, EPA is requiring all land treatment.epplicaaa. to develop long term reuse. agreements with the recipients of the wastewater, or as an option, to pur- chase sufficient land where the of lnent can be land replied either under the manag+emc: t of the applicant or t pro r se with another open-note r..' R ^ metthis t: q a ei;,^: 1%`.', ''�Ci �;Trth,lc:�::' has not ,':'.:iL�].I'£tiiCilt and EPA, therefore, will condition the grant award to require these agreeients, prior to making a Step III gaaiit and the initi- ation of construction. Without these agreements, the Northglenn project will not meet the definition of an "alternative" techno- logy. • The agricultural area that is most s'.sceptible to urban develop- ment and which is located within the DRCOG Big Dry Creek Urban Service Area are those lands covered ;•y the Farmers Highline and Lower Clear Creek irrigation service areas. There are no prime agricultural lands located within the urban service area for North- glenn. Thornton and Adams County are both encouraging development to occur in these prime agricultural areas and the Northglenn project, if constructed as proposed, would extend service for waste- water treatmen;, into these areas. For EPA to fund the extension of interceptors into these prime agricultural areas is contrary to EPA regulations and policies. The facility plan has not demonstrated to EPA's satisfaction that wastewater treatment service is urgently needed in these areas, nor has the applicant evaluated the feasi- ' bility of implementing individual systems or cluster systems as a means of providing this service. Consequently, EPA will not fund those.portions of the proposed project which extend service into the areas described above until such time as a full range of • alternatives is evaluated and assurances are made which will pro- tect agriculture in these areas. Of tte other 13 categories of environmentally sensitive areas identi- fied by DRCOG in their report, "Specification of Environmentally Sig- • nificant Areas in the Denver Region," only S have potential for con- flict with the proposed project: that is, floodplains, shrink-swell soils, wildlife habitat areas, coal resources, and oil and natural gas fields (see Figures 10 - 14). -49- • •:) DRCOG's Regional Development Policy number 23 regarding flood plains states: "Development should not occur within the limits of the 100 year flood plain nor should any filling in of the floodplain that would reduce its flood carrying capacity. Parks, recreation and '• • -open space uses are encouraged in floodplain areas." All the 103 year floodplains within the study area occur in Adams County and at this time, EPA does not have copies of Adams County's develop- ment policies and regulations as they apply to floodplains. The facility plan did not conduct a floodplain analysis. However, it appears to EPA that the proposed project will not extend into the South Platte River 100 year floodplain. The only component of the proposed project which will encroach the 100 year floodplain is the Northglenn interceptor where it crosses Big Dry Creek. This area is presently used for agricultural purposes and EPA intends to require Northglenn to p,ohibit any connections to the interceptor outside the urban service area which includes the Biz Dry Creek floodplain. Therefore, EPA does not expect any new 'development to occur in the Big Dry Creek floodplain. The facility pl.:n recognizes that shrink-swell soils exist in the vicinity of the site for the treatment lagoon and storage reservoir. The design phase will address any problems that could be encountered with construction of these facilities. The applicant has analyzed the suitability of these soils for the intended uses and has con- cluded that no major problems will be encountered. The Northglenn interceptor will cross a designated wildlife area (see Figure 12) . The impact of constructing the interceptor across this wildlife area was not evaluated in the facility plan. DRCOG's . Regional Development Policy numbered 29 addresses this problem as follows: REP 29 - Development in significant wildlife habitat areas etreas of very high density and production) should occur only after an evaluation of the site has been made by the Colorado . Division of Wildlife and it is determined that the impact on wildlife habitat is not adverse or the adverse impact is miti- gated. EPA has contacted the Division of wildlife and has discussed the project with them. The area in question is not a habitat for any known threatened or endangered species. Rather it is a habitat for • numerous communities of prairie dos with densities as high as 700 animals per square mile. Development in the vicinity of these habitats would be a more serious impact than actual construction of the interceptor through the area. Prairie dogs are fairly tolerant to human activities and are known to exist in the midst of urban developments. Despite this, EPA will condition the grant to preclude development from occurring in this area and also to minimize construction impacts. -50- 4 f is ,-t°- . . at [ • I a a a' • v Al O P4 ti .• Zw O o°. 1. c al 7,'I w cL O .., z U .. • ...I .Q.. 0t:• O 3 wa �:�•— mss. I I 4J ..."'"••••*"" ...N.......--.......,, ! —. 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It? .__ W La c O 0 `LJ 0 S 0—.. �yy VI VI O '. L- �9. -✓ .. Q 4 .. 7 . -.- O; N ,n 3 i fs y /^ Ln o CD al 0 I Py... . ,. - Y. & ei Ize o O. 1 W Q� N . f� a a ¢ p - of O (� U Y: O O O o a ¢ n 3 .! o zr7c- °,7 O1 ° @ C 3 al ei S.1) C-.,, r,> . 1 r1 'r t r i pry 4h / rte- �._`- 4 /.-/ — 1 .�... f i• t- F • c t ..-.;.................-t- e .'1 t4,..fn- tam. rba,r.: .<..wrta - .4,.......,,,........-,....t......,,.......,-- -•.. r (_, ,- - `I ; P \ , 4 r let ..ems -59- • • A report by Chen and Associates concluded that construction of the proposed reservoir and treatment lagoons will not interfere with development of the oil and gas resource lying beneath the proposed site. If this is true then no conflict exists with DRCOG's policy numbered 32 or any of EPA's policies. Regarding .the coal resources that underlie the proposed site, the same report concluded that the coal is "uneconomical to mine because of the depth below ground surface, thin coal beds, and lack of lateral- continuity of these • coal beds." Consequently, the proposed project is consistent with DRCOG's RDP #31 and EPA policies. A separate archaeological and culture]. evaluation of the pr r osed project was orde1"taken :s part of t.le facility plan, e fo?to 'i' g d • excerpt presents the conciusion of this study. "On February 28 and March 1st, Dr. Jean E. Arnold conducted an archaeelozical eua"•'v of tho proposed site. The survey -include ; two proposed - :.kn` .:C:•. i '!iS ' .thin the city o . NorthEO.en'., a proposed es... .oir lccete mill':: north of Ncn:i.h letn, and a tApelne b`.ti;ee:o one of the ouml irg stetions cnd the ervoir fell owing_i1" first the Union i'aC:7.:._c Railror d Lacks, ails then York Recd. This survey was c7-1 ried out in conjunction with other studies to provide an environ- mental assessment of the project area. A site file search in the Office of the State Archaeologist, and a literature search revealed that there were no archaeological sites in any of the areas affected by the project. During the course of a walking .survey of the project area, one isolated arti- fact (a chopper-scrapi ar) was found and only one archaeological site (SAM66) was located. This site consisted of a dump/mi.dden • of the recent period probably dating to 1900 - 1940 A.D. A copy of the OSAC Survey report for the site is attached. Neither of these cultural resources are important nor signifi- cent enough to recommend further investigation within the pro- ject arer.. Therefore, there are no known significant archaeo- logical sites nor cultural resources in the survey area that would be destroyed or adversely affected by the proposed pro- ject." The final land .use .issue considered in this negative declaration is one related to the control of urban runoff (nonpoint sources of water pollution) . The final action on the Denver Regional Envircn- menta7. Impact Statement nukes the following requirement: "Prior to granting funds for construction or expansion of wastewater facilities, the general purpose governments within the proposed service area must show progress, in the form of ordinances adopted or recent efforts taken, towards imple- menting the nonpoint source controls recommended by the Clean • Water Plan." -61- • , EPA will make this a condition of the grant award. Since Thornton and Adams County will probably not be the beneficiaries of EPA funds at this time, EPA will not require that they satisfy the above requirement. . , 6. Enhancement of Recreation Opportunities - The Clean Water Act specifies that EPA shall not make grants from funds authorized • • after September 30, 1978 unless the grant applicant has analyzed the potential recreation and open space opportunities associated with the proposed treatment works. The Northglenn project has many aspects: ;,hich will .i 1preve recreational opportunities that are available to the residents of Northglenn. The most notable is .the proposed Stonehocker reservoir which will include recrea- tion facilities for biking, picnicking, and hiking. There May be _ opportunity to use all or part of the Northglenn interceotor right of way as a bike trail, etc. EPA will suggest to Narthgle:1n that this opportunity be explored. Otherwise the applicant has evaluated the compatibility of ':-`1c: proposed project with other existing, plan- ned, and proposed recreation facilties and has integrated the wastewater project with these plans. 7. Other Site Related Impacts - a. Stanley Reservoir: Although the reservoir is not a component of the wastewater project there has been some concern about the structural soundness of the dam and the potential for failure resulting from implementation of Northglenn's and Thornton's proposed water supply projects. Many new develop- ments have located in the valley below the reservoir and dam which would be endangered if the dam failed. It is EPA'e understanding that Northglenn and Thornton are not • seeking new storage capacity (rights) in Standley Reservoir. Rather both communities will be utilizing water that is al- ready in storage or storage capacity that is not presently being utilized. It is also EPA's understanding that the State Engineer's Office will not allow storage in the upper part of the reservoir until certain improvements are made. Since the proposed project will not affect the reservoir and dare, and because available operating capacity exists in the reservoir, EPA believes that this issue should not delay design and con- struction of the Northglenn successive use project. b. Stonehocker Reservoir (Stormwater Retention Reservoir): The urban runoff from Northglenn will be collected and stored in Stonehocker Reservoir located on Grange. Hall Creek. Northglenn proposes to construct the reservoir for recreation purposes in addition to using the runoff from shopping center parking • lots as a source of make-up water. -62- • • domestic wells in the area. 'A more detailed analysis of this relationship is presently underway. Northglenn will be design- ing an early warning monitoring system to detect potential prob- lems that may result from sludge disposal and/or reuse of the wastewater for agricultural production. Based on available information no problems are expected. 8. Rocky Flats Emergency Evacuation Plan: In the Denver Regional • Final. Environmental Impact Statement, EPA identified an area of concern where new or .existing housing is located near the Rocky Flats �)1.h�tt vm i v :e'is'.ng plane. EPA- . � Ihc.. Szncc. is £Ui2(a iIrl water tr�c;teet. ...i.;.:.nl.:a ehat could serve these areas, 10A, oped...'„_. p01,.e -.._ _ ...:l with this problem. These e e re: a. If EPA detciaine that a wastewater facility p.eopos.sd for EPA funding will .s a hr.fir. • . nt .• i n t.. ;r:y G .:lC.�....:. �.. ..:::::;s is xv�;1;. ci '�:: "Area o: Concei.i:" d:;_.;. 'e:i. by. .tj: : Coleyee Dep e .�n`. Health Guidence dai i NovZper I7Z for the US AYC Rocky Pats Plan c, Jefferson Col=y, as amended) and appropriate mitigating J:;•'';.t' tires have not been carried eut according to existing state statutes, EPA will condition the grant of Federal funds to prohibit sewerage service to that development. b. Pending recon endi:tions of the Rocky Flats Monitoring Committee on notification, EPA will require grantees (in conjunction with appropriate local govert:ental entities) to develop a notifica- tion mechanism (e.g. notification ordinance) for notifying exist- ing and prospective homeowners in the vicinity of the Rocky Flats Plant of the provisions of the State Radiological Emergency Re- sponse Plan and their role in carrying out prescribed protective actions. (Vicinity can be defined as the Category III and II areas, Rocky Flats Radiological Emergency Response Plan.) Since Northglenn does not lie within the ,'.Area of Concern" defined by the Colorado Department of Health, there is no problem with the general eligiblity of the planned developable areas. Northglenn does lie partially within the Category area II defined by the Rocky Flats .Moni,tor.ing= Ccmrmittee. EPA will require before Step III funding can be approved fcr this project, that the City of North- glenn take positive steps to adopt a City Ordinance or some suit- able mee•.hanism to notify existing and prospective homeowners in the Category II areas concerning the Emergency Response Plan for Rocky Flats. —63— • G. SIGNIFICANT ISSUES AND EPA'S PROPOSED ACTION Several issues have surfaced during EPA's review of the Northglenn Water Management Plan and Northglenn's Step II grant request. These issues are highlighted in this Section to facilitate the reader's understanding of potential problems with the project and to learn how EPA intends to confront and/or resolve these problems. The narra- tive that follows provides additional detail and background informa- tion on the proposed project. Issue 1: Growth and development in the north part of the !, nv-er region the r'.:sul:ed in abellt 18,000 ?cr.ee of tural 1F4:... 7 . rie ras Co;my to be converted tou:'i. !T se for the 6 year priod ef 1969-1975. The NorthNorthiyi facility ":n p7..71jec -row-c! to occur n h,.. a �.z_ in fir,.;..... :► agri•.'::J.tural areas and prime i- cuituf ;1 a e :i. • Implementation of North..-l's -oposal will immediately free 10,000 tans for d�:relolmenr. t.i.t.;`2Z T :Drntcn w.rcie all this :gricul- tural land is locate :. Al). cf the j:reposedinterceptors will tra- verse prime agricultural lands except for the Nott interceptor. EPA has endorsed DRCOG's Regional. Development olicies Numbered 23 through 41 as found in the Council's "Draft Regional Growth and Development Plan for the Denver Region" (DRCOG, July 1977) . Policy number 35 states: "Development should not be permitted in presently identified areas of prime agricultural soils which are located in the non-urban areas of the Denver Region". In addition to the DRCOG policy, EPA regulations published in April 25, 197E place the following restrictions on EPA's funding of interceptors: "An interceptor may be provided in the initial stage to phase out or eliminate existing point source discharges and to • accommodate flows from existing habitations. Unless neces- sary to meet those objectives, interceptors should not be extended into environmentally sensitive areas, prime agri- cultural lands and other undeveloped areas (density Ices than one household per two acres) . Where extension of an interceptor through such areas would be necessary to inter- conn^ct two or more con-iunities, the grantee shall reassess the need for the interceptor through further consideration of alternative wastewater treatment systems, analyze primary and secondary environmental impacts of the interceptor, and provide for appropriate mitigating measures such as re-routing the pipe to minimize adverse impacts or restricting connections to the pipe. Conditions to ensure implementation of mitigating -65- • II • measures shall be included in NPDES permits when new permits are issued to the affected treatment facilities in those cases where the measures are required to protect the treatment facili- ties against overloading." • EPA proposes the following actions in response to the above requirements: 1. EPA will not fund the Nott, Grange Creek and Brantner Interceptors until such time that "alternative" waste- water disposal systems (i.e. , individual or cluster systems) are investigated, and the impact of the pro- posed interceptors upon agricultural lands is fully evaluated. 2. EPA will provide funding for the Northglenn interceptor north of the Big Dry Creek servile: area provided tha Northglem adapts a regulation prohibiting direct or indirect (through pump stations) connections to the inter- ceptor in.the section from 136th Avenue north to the treat- ment lagoon in Veld County. : • Issue 2: Northglenn's proposal to pump groundwater from the Arapahoe and Laramie-Fox Hills aquifers may have irre- versible long term environmental consequences. — Part of Northglenn's agreement with the Farmer's Reservoir and Irrigation Company (FRIC0) is for Northglenn to have the right of first _ use for up to 7,785 acre feet of FRICO's water as long as Northglenn returns to FRICO ].100 of the water that it uses. 'Typically, a city experiences 30-40% consumptive losses. Consequently, Northglenn needs to replace the water it consumptively uses and augment whatever FRICO water is used by 10%. Volume 2 of the Northglenn Water Management Program identified that almost half of the make-up water would be derived from groundwater sources, the majority being pumped from the Arapahoe formation. The status of the Northglenn proposal to pump large quantities of water from the Arapahoe formation is uncertain. The State Engineer has approved only 1 out of the 20 well permits requested by Northglenn. Even if all permits were approved, there is a chance that a class action suit would be filed on behalf of private well owners in the vicinity ( f Northglenn. Because of these factors, and others, North- glenn has been actively pursuing alternative sources of make-up water. EPA, in its comments on the Northglenn facility plan, identified as the major potential environmental problem the depletion of the groundwater resource in the Arapahoe and Laramie-Fox Hills aquifers. -66- • EPA requested and Northglenn has provided some additional information on the impacts associated with the proposed groundwater pumping scheme. Given the fact that other sources of water are available, EPA has chosen to delay a more thorough analysis of these impacts until such time it is certain Northglenn will implement the ground- water pumping program or a similar proposal. EPA could fund construction of the wastewater treatment facility prior to a final determination being made on whether the Arapahoe and Laramie-Fox Hills aquifers will be used as a major source of make-up water. EPA understands that Northglenn or its residents can continue to rely on Thornton for its water supply until such time the HUCu water becomes availzu le and that Northgl.: .,n n:_;; be able to discharge Thornton water to Lnl Canal. This ::ay affect whether the pr'c'jec is considered an agricultueal exchencc project • and hens:: would be defined as an "alternative" technology- (see Issue 6) . .J' .'.•.,'A funds.. a cQm'.v:l...._ 't.! teeetent c'••C:. discharge st':•:.:r•mf :::):1 will rely on the St:.te En ine ;e to cve uate ';orchgle :n's assessment of ianp;'.ts of the pre posed greendwater pumping program. If ':11A iS an gY a. ch age project, .PA will require further s of c: 'iCilltL r 1. e;Y.�t-, o EPAr rti .^. ail;�i:�:' � r the groundwater pepping programprogrmn if it is still an integral part of the project. and constitutes a significant portion of the make-up water. Issue 3: The "Denver Regional Environmental Impact •1.tatemcnt for Wastewater Facilities and. the Clean 11a.ter Program" has identified several requirements with which Northglenn will need to comply. There are four items which are identified in the Overview EIS for which a response from Northglenn is still needed. These action items are: a. Northglenn needs to demonstrate the City Council's commitment to (1) implement reasonable air pollution control measures; (2) participate in the development of the Denver element of the State Air Quality Implementation Plan and (a) once ap- proved by EPA, support implementation of the Denver element of the State Air Quality Implementation Plan. At a minimum, the City Council needs to pass a resolution which identifies their commitment to improving Denver's air quality. b. Northglenn needs to develop a sewer tap program which annually determines the number of taps available for new residential development and which is consistent with the DRCOG population forecast for 1980, 1990, and 2000. -67- • } • c. Northglenn needs to demonstrate the consistency of its erosion • control program with the recommendations contained in the URCOG Clean dater Plan. • ._ .-- d. .. ivorthgienn'must-take-steps to-adopt a•City Ordinance or sunie suitable mechanism to notify existing and prospective home- owners in the Category II areas around the Rocky Flats plant, • of the Emergency Response Plan for Rocky Flats. Northglenn.has assured EPA it will comply with these requirements. EPA will require action on the above items as a precondition to re- ceiving a Step III award. • • Issue 4: Northglenn is proposing to d.eshn and construct ;. facility to treat both Northglenn's and Thornton's 1•rast:wace_' flows. Thornton has not mace a commiti: :nt to have its wastewater treated at the Nor;:hOeiul facility. Resolution of this problem wi.i I affect the proposed. project's eligibility and - correspondingly, EPA's funding. North;lenn is seeking EPA funding to design and construct a 7.2 million gallons per day (mgd) wastewater treatment facility. Of this amount, 3.2 mgd is being reserved for Thornton's wastewater flows. EPA has discussed this matter with Thornton's staff and the information gleaned from them indicates that Thornton is in the process of exploring alternatives for treatment of their wastewater, but no decisions have been made on which alternative they will select. The 1977 Clean Water Act and EPA's regulations promulgated in accordance with this Act, prohibit EPA from .fundi_.ig excessive reserve capacity in a facility. By. funding the proposed project at the size requested, EPA coult. be in violation of the Law and its own regulations. Therefore, EPA has decided to limit its level of funding to those costs for a facility designed to treat only Northglenn's wastewater. EPA is • willing to adjust its grant amount to include Thornton's flows if an agreement is executed between Northglenn and Thornton any time prior to EPA awarding a grant for construction (Step III). After a grant is awarded for construction EPA will not make any adjustments to that grant to include capacity for Thornton. Issue 5: ;.2A has funded capacity in the Metropolitan Denver Sewage Disposal District #1 facility through 1990, a percentage of which is capacity for Northglenn's and Thornton's exist- ing and future flows. The facility plan indicates that continued treatment at Metro Denver's facility is the cost effective alternative to treat Northglenn's and Thornton's wastes. EPA's level of funding in the proposed Northglenn project will be affected by this analysis. The Lower South Platte Plan evaluated a "status quo" alternative - for continued treatment of Northglenn's and Thornton's wastewater at the Metro facility. The cost effectiveness analysis of this alterna- tive accounts for existing capacity in the Metro facility to treat Northglenn's wastewater through 1990. The•Northglenn. Water Management Plan evaluated several alternatives, but did not include an evaluation of the status quo alternative. A direct comparison of the two was not possible due to the different assumptions made in each plan. EPA requested and received a consistent analysis of these two alternatives. The results of that analysis .follow: a. Peuse•,: Worth C.;c tY c.' :.�.: Nort'!g1enn Proposal $.22,.253,070 (1.;38:►--C i.t 1 C:'wt. $:r:,,:;01,80 ) b. Present Werth Cost of Status Quo Altn native $l5,828,..t;Q • (Capital C.c.s Given t:.h r. .t 1`' T ._ is .. with n ,J(;;.,.Sit'Il on i:';:.e much i; C't" the 1\D'.'I:t2g)r-:vi '.)roJ• !? .......... 3 :. ..`.- is ost :ecent regulatioris :my pro- hibit EtA ro.:t ...: :thi¢ an/ p7%:j that are not th,1 most cost effec- tive alternative. • The 1977 Clean Water Act includes specific language encouraging the reuse, reclamation, and recycling of wastewater. Congress man- dated that these types of projects would be eligible Zor 85 funding and allowed. a 15% preference in the cost effectiveness analysis for these projects. IPA has not p.thlished any regulations which specif'j bow to treat "innovative" and "alternative" projects which exceed the 15% allowance. This determination will occur just prior to the Step II grant award. Issue 6: EPA has a requirement that all land treatment applicants demonstrate control over the ultimate disposition of their effluent to guarantee long term (minim 20 years) reuse/ successive use of the effluent. Northglenn has not yet met this requirement. EPA requires that land .application types of projects continue to operate as a land treatment scheme throughout the twenty year planning period. Therefore, EPA is cxrtcctin? land treatment applicants to pro- . vide assurances which will satisfy this reouiremen::. • Without these assurances, EPA will not accept thc project as an "alternative" tech- nology wh .41i could affect the level of EPA funding. • • -69- .) ,I . + • In an urban setting where farmers have the advantage of being able to sell their land for development purposes, it becomes increas- ingly difficult to negotiate long term agreements with individual farmers or groups of farmers who will commit the use of the land for • ttgricul urai purposes fur the next sweaty years. horthgienn has sug- gested that these types of assurances can be accomplished through an agreement with the Farmers Reservoir and Irrigation Company. At a minimum, EPA expects the agreement to address how Northglenn will be able to provide land application.for its effluent for the pro- ject life. EPA will evaluate the sufficiency of this agreement once • it is developed. Northglenn night continue to use Thornton's water until the issues surroulicling the use of FR.tCO's water are resolved. If this will be the case, there will arise a water rights problem regarding a chan';c3 in the point of discharge. EPA will condition the Step II grant award in :his situation to require No thglenn. to provide a. le;al opinion s:ga.rdi': + .J Noithgler!n's ::ig `.o discharge. water purchas , frei Thor. e,.., `t from 12 t- -! to Cool. Should ilia for rights difficulties prohibit the project from _'.unc- t.ioni.ng, EPA reserves its usual right to recover filnds due to the inability of the grantee to build and operate the facility as proposed. • • • • —70— • • • 5 H. OTHER ALTERNATIVES CONSIDERED • Between the Northglenn Wastewater Facilities Plan and the Lower South Platte Facility Plan, a total of 21 alternatives to treat North- . .. - . • glenn's and Lower Thornton's wastewater were evaluated. Most of these . • alternatives involved treatment of Northglenn's and Lower Thornton's wastewater at the Metro, Westminster, or Brighton facilities or some combination thereof. The Lower South Platte Facility Plan recommended that wastewater flows in these two service areas be treated in the Big Dry Creek Basin at the City of 4's'e.. _m nsrc' ' ?lent-Nei-is:..-13y because of the oIrdortunties . Northglenn successively l'•` e the effluent �.'.w �iin 'i: )i !r:. ii:•.iii;.e. b.', 1:i. . T'e I\ort h Tl.c.'nn Sinn eealuaeed c'r.a t: .. i,. ' c; al). ei- eheb involye.j construction. of: a new .. eac'_:r'ne .__., '.._i;i'i at ea neer !.:';c;.•4:i.en rather tJu'.n using existing facilities suci,.. a:. s •t .....er s or .:et.rO s. A prel_.,'_1.:'.: i f s:evening of, .:u . . Let ntives eliminated ell thole thee: !i:.''.'. too cc.. ,.l'%. _'k'\. . . !owed this _ f o.'m;'ti.on eed cc;:,- Ci.IPjed that the c:0ei: l': . t.rc ..nn . ^:.i the S5' ._ ,:mi.:i 4er facility .:I about erinal to ... cost of .CC'•i';'L...31�. �.t: theproposed ..... -. ii:.:rl j'� r l M ` alint' ` g rats does J-'i CI..�.7.t} 1,Ie 'C,_�UT�, a S3.II�P,.S.t? Zile C �31xI_;.lia.....O:I dG � not appear to have any advantages over a two p' �t:gurat .on fen the Big Dry yc��ia, con:figuration a Creek Basin; Biased on EPA's review, continued treatment at the Metro facility is the least cost pollution control alternative for the North- glenn end Lower Thornton service areas. The Metro alternative does not have the same benefits as the Northglenn proposal. These benefits include (1) an improved water supply (quantity and quality) ; (2) formation of a city/farmer alliance over the use of water in the basin; (3) develop- • iient of agreements with farmers which will be a positive factor toward the preservation of agricultural land; end (4) a reduction in the amount of energy consumed in the disposal of Northglenn's and Thornton's wastewater. Nonmonetary costs associated with the proposed Northglenn project which are not associated with continued treatment at Metro are: (1) encroachment on an established wildlife habitat area; and (2) poten- tial groundwater depletion and degradation. Both alternatives would probably have the effect of accelerating the conversion of agricultural land to urban use in the Lower Thornton service area and parts of Adams County. The Northglenn Plan evaluated the feasibility of phasing the con- struction of facilities and recommehded. tPrat the 'Northglenn interceptor be paralleled by another 24" line in 1990. Phased construction of the __ . treatment lagoon storage reservoir and other interceptors was not cost effective. • •-71- • • • I. AGENCIES CONSULTED BY EPA 1. Metropolitan Denver Sewage Disposal District #1: EPA requested cost information for. the status quo alternatives evaluated by NDSDDI1. 'This information was provided to EPA. 2. Thornton: EPA requested status of Thornton's plans for waste- . water treatment disposal. Thornton indicated that studies have been initiated and an alternative will not be selected for several months. EPA also requested copies of the draft agreements which Thornton initiated with Northglenn and FRICO regarding ownership of the water and wastewater utilities. 3.. Denver Regional Coueci) of rover. ;..mts: EPA inqu)ved. 'lbout the of i.r ,T'.'''.) $ :\':, a...ct..l ';3•:: 1 -1and iE: l.w rs..sli. .� Regional I.'s:vcicrr •nt 'ol�i.j^s. was .J,...;ed that :Lc 21- 1-‘,-.1 t! f":4 moo-n!7. •.'•i+:I,:'.''' i_:!c .c`1 i.l.ec .,o a i- L:illfii--al �... 'S wi 3 t 1".t`s �L:': ._.. .; o_ to these rr l.ii '.es nd t;:L. ..:.�� ,'.:i :: _;?? �; the polic-'':.:,, sented in the drift "::: 7.C .. : l ui and Development Pl u'i" has not changed si.gnificn.;i:iy. 4. Colorado Division of Wildlife: EPA requested comments from the Division about Northglenn's proposal to construct an interceptor through an identified wildlife habitat area. The area was iden- tified as a high density prairie dog habitat. EPA was advised that prairie dogs are not endangered or threatened species in Colorado, but that special precautions should be followed in con- structing the proposed Northglenn interceptor through this area. EPA believes that the proposed routing along York Street will mini- mize the impacts of construction on the prairie dog habitat. EPA will condition the grant to require that no new taps be allowed to connect to the interceptor through this a-:ea. 5. State Engineer's Office: EPA solicited more details from the State Engineer's Office on their A-95 comment and also on Northglenn's proposal to use Thornton water if FRICO water is not available. The State advised EPA on the type of information it should request from Northglenn and also had questions on Northglenn's ability to implement the project using the water supply sources which arc proposed. - ' 1 —73 • • • Jl PUBLIC PARTICIPATION • 1. Public Hearings: a. September 19, 1977, held at 11801 Comiiiunity• Drive; Northglenn Community Center, Northglenn, Colorado. Twelve people other than those directly associated with the project attended the hearing. All the comments received at this meeting are pre- sented in Appendix J of the Final Facilities Plan. These comments are summarized under 3 below. b October 31, 3.977, held at. 118C1 Cca :iunity D'ri • Co:,eer, Northglenn, Colored°. Ei.ti1`, persons avtend.'.d :.h.. .i arieg and only two, Cary Pe of n � 1'' . 1.`._.. r< e .►�,etr i. �iL ,X01-: �.��. �� 7 �r $ District, ev t[' " 'ir. • . :eer Cejo'.. ed �JL L•�1� Sc we":� i1J..�.l.�•l\.�., -t�. ... r....ri: • � to the �' ect cirt':�.^ i.:or rea::en . i ": :''.?(_'1... net Ynr•.. ..:.e . The ma jol; Sara. oS. l._.. .rrn .__ ,:e a r,.d by :.Lion 1•ciaee .V .s.t _y Thornton l the ].n't r -L;�..,.^'7.?�. . .j_; :'.')i: ?' . ..i;:;'"i';: .i..l' ILti eed. .::or :( i uver resneeeiD3Ty (-)a• ... n:. O . N: :hgh:.i.l�':i i}.:.titewal.er. Mr. P:'' '' o ...: :._. =i A_ e.' �':f' :i:.i is �ssu;' -.l.l ing Me 7 o's respenSL 1i_ ' for treat;.1::it of NoetngJ: . t'. wastewater. ' 2. A-95 Comments: The only adverse comment received by EPA on the proposed project was from Jeris Danielson of the State Engineer's Office. Mr. Danielson questioned whether the project can be im- plemented at this time due to the uncertainties surrounding the sources of make-up water. This cont rn is addressed in this Envi- ronmental Appraisal and a course of action is recommended which satisfies EPA. EPA is interested in the State Engineer's opinion on this matter. 3. Other Comments: Appendix J of the Facility Plan presents the written comments received on the August draft of the Plan. e. Numerous letters were received by Northglenn in support of the project. Numerous other letters were received by Northglenn commenting on conflict between the Lower South Platte Facility Plan and Nort:hglenn's proposal. The majority of responses were favorable in support of the project. • • • ..7g� • ' 1 / ' I K. REASONS FOR NOT PREPARING AN EIS • Criteria for preparing an Environmental Impact Statement (EIS) are presented in Sections 6.200 and 6. 510 of 40 CFR Part 6 of EPA's regulations governing the preparation of EIS's. In general, if a proposed project has significant environmental effects or is the subject of controversy, EPA is instructed to prepare an EIS on that project. The reasons why EPA believes that an EIS is not warranted for this project are: 1. EPA recently corn l..eeed en Overview KIS for the entire Denver Mort:.' '.C.11n pre' ..:t t,, 191-: secc� : 'v c. ::ct::; of - . Region. ' � ,4.ddre 'sed in t1nit c.. C. :it: . i:.. ure ¶... i, thin t.'• it . ._- ?t: , ._,"1;:_.;. . . 1.1 .J:'_ ,Xr :e l'c `t ^ .�'.�:1 of (r3;•ice:-� �ir� �:�':i; .. C."` .. ..: . . .': .. - .• ' the -..j � � t 4, r- _i i . - .l:_c newt c fail csv;ng the .�cia- • pl .'s recc• ndatione to con- is nGt. approving 3. EPA . : ` , in the Lowe_ Thornton sere. , e e arca. Cense- stl�uc:t interceptors. ,.._ . Ruently; EPA believes that the proposed actionwill not ac e e- rate the rate of conversion of agricultural land to t=-ban since the most susceptable areas are located in the Lower lnornton area. 4. The State Engineer's Office is cognizant of the potential problems with groundwater pumping in the Arapahoe and the Larr.nll.e-Fox Hills aquifers. This is evidenced by their rejecting 19 cue of 20 well permits applied for by Northglenn. EPA believes that the State Engineer's Engineer's Office will evaluate Northgl e:i:1's assessment of the envi- ronmental impe-ts of ti;e proposed groundwater pumping scheme prior to approving t:esc permits. Also, since other sources of make-up water are available to Northglenn at a minimum additional cost and since Northglenn is actively pursuing these other alternative water sources, EPA believes that a smaller scale groundwater program is more likely to be implemented. EPA will be recommending to the State Engineer's Office that additional hydrologic studies be con- ducted to determine what is the average storage coefficient of the two aquifers and that the impacts be reassessed based on this infor- mation prior to approval of any more well permits in the Northglenn fire:i.. 5. The :•a st e: e ter .treetmen:'. project, although a part of the te cal. iiatei resources progra=m, is not deeendeIlt on implementation of the FR1CO exchange agreement before it can become operational. North- -_ glenn expects to contract with Thornton for water until such time that FRICO water is diverted to the Northglenn system. -77- • • p . • 6. The institutional and utility ownership problems appear to be — nearing resolution. 7. Altnough' Nortnglenn will not solve all of its water supply prob- lems with implementation of the proposed project, it will result in a better quality water supply for the residents of Northglenn. 8. The proposed project is being designed consistently with regional population forecasts and thus will not stimulate growth beyond what t is rea oncbly expected for the Northglenn and Thornton urban st:rvicc a.co . • • • • • • • —78— L. GRANT CONDITIONS The following conditions will be placed on the Northglenn grant award in an attempt to mitigate the unresolved problems which have • been identified in this Environmental Appraisal. 1. Problem: Thornton has not decided whether it will be part of the Northgfenn wastewater treatment system. Condition(s) : Costs incurred during the design of the treatment works shall be eligible only for those items directly related to the design of facilities for Nor.thg) n i. Costs incurred during design which d'__.'sct].y relate o yee i:r .:?„x ::rpr�c.'. -y f r r.tcr 1,: .. . � .. ' , :•^--"•:i t:;1-., t: flews :e c eliC• it';.:;C outside '�'� .�:::.'..' .::}):;':, :Feie::. ; ')Liii..i;':i l t,.i1F%C::lI'�.:-S {.•:l.::i. n(.!-s. be :o.. iblc: ... �' ,i: _ �:.. eeder `:l.., l:ir::.::" of i.:. s pent wit!01.',. an e:re�ce.':'.,. .'-I .,.:,•.V' c:., i:. y:::l:ul�. iii`::. - .::: is ('0 r;� o: r , r':'.. s�o �.F Y yip....-. ai` s e t r'e_T .:i.c:i to e'! .- i'e. .p r, .•) aCh 2Y(7, J.i)e.i+1.'rd l:u ;! O 7for , re I:I•:::I� ,i:iti _ ';`t e: e '�' '� : l .1 t':7!'• C:iF2$l.. ..�.S.'r, .li}:yc.�: t:� not rela.t2d. to .::::.i°i. J �''c:..-:S.-.:•eee wee .en is :ti;!,...t�- �::t.ein's year 200 i , •.r;. 'c not he el : ?.e t:it agreement prior to initieeing construct.::Loa of the t,eatment works. 2. Problem: Interceptors arc being proposed in the Lower Thornton service area which will traveree- and pre:ride waste.:titer service in areas defined as prime agricultural land. Condition(.) : flPA will not participate in the design and construe- FrEFTBrantir Gulch and Grange Creek interceptors without a more detailed analysis of their ].impacts on agriculture in the areas they are intended. to serve and appropriate u.easures ere taken to mitigate these impacts. Such measures sha:.l include, but not be limited to: (a) exploring alternatives other than central collection and treatment as a means to providing service to those areas; and (b) adopting regulations which would preclude deve).op- ment from occurring on specific parcels of land which are pre- sently used for agricultural production and which are defined as prime agricultural land.. udditio}:re�:+y, the Grantee shall not receive final payment under- Step II or be awarded a Step III • grant until such ti le that the tl-re,:.te has passed an appropriate regulation which will pcohi.bit direct or indirect (through pump station) connections to the Northgie.nn Interceptor for the Section located north of the fi`Y Dry Creek [hi"'21 Service Area as current'.'/ defined in LRCOG's Regional Growth text Development Plan (generally north of 136th Avenue) . • —79— • ll 3. Problem: The Northglenn interceptor will traverse the Big Dry • Creek 100 year floodplain and a designated wildlife habitat area which may result in urban encroachment into these areas. Condition(s) : The Grantee shall not receive final payment under Step 11 or be awarded a Step III grant until such time tnat the - Grantee has passed an appropriate regulation which will prohibit direct or indirect (through pump station) connections to the Northglenn Interceptor (the interceptor conveying wastewater from _ the City of'Northglenn to the treatment site) for the section that will be located outside Northglenn's incorporated boundaries as currently defined (generally north of 120th Avenue and including the area known as East Lake) . Exceptions to this condition, sub- ject to EPA approval, will need to be .negotiated on a case by case basis for the area between 12GLii and 1-36th Avenues. 4. Problem_ : Northglenn has represented its project as a land appli- Gation ("alternative method of treatment") project. To be able to implement the project as planned, Northglenn must obtain make- up water (consumptive use plus 10 percent) . Condition(s) : If the project is to be considered an "alternative method of Ereatment", the Grantee must provide assurances satis- factory to EPA that it has acquired or it reasonably can acquire all the necessary make-up water, prior to receiving a Step III award. . S. Problem: The project may use a water supply which may involve • water rights issues and which may impede implementation of the project as planned. Conditions) : If the project to be implemented involves water lliti—,ssues (e.g. , a change in the point of diversion or a change in the point of discharge) , then the Grantee shall provide EPA with a legal opinion which demonstrates to the satisfaction of EPA that the project can be implemented. This assurance will be needed prior to receiving a Step III award. Any costs incurred due to resolution of problems with water rights and which are not identified in the legal opinion will not be reimbursable under this grant. 6. Problem: Northglenn, to date, has not negotiated an agreement(s) with7'l iornton and/or FRICO which will assure EPA that Northglenn has sewage to treat and that the project will be implemented. Condition(s): The Grantee shall, provide EPA with a copy of the executed agreements which demonstrate that Northglenn will have sewage to treat once the facility becomes operational. These agreements must prove to be satisfactory prior to the Grantee receiving final payment under Step II and receiving a Step III award. -80- • AJ . 7. Problem: In order to be considered an "alternative" project, North- glenn needs to assure EPA that the final disposition of Northglenn's effluent will be for land application. .. • • Condition(3) : The Grantee shall provide EPA with assurances to the satisfaction of EPA that the effluent will be applied on the land for the life of the project (20 years) . 8. Problem: Northglenn needs to obtain clearance from the State 2giineer's Office regarding approval to proceed with construction • of the storage reservoir dam and Stonehocker dam. Cond.it:ion(e.) The Granteehel: pee-v de hPA with. he Stale iiiiees_' clearance a ). :S n- the l'.anl...e to pio.E'e i. i on Strucl.:ion of the neepoeed _ ..en:T e. :;. , . o3 a ..and z. nneeociwr TCSCYVO%.?' pri . o :)...i.ng a Step III award. t• 9. Problem: 1%10. Con ty i; .. i ,. i t .. . . eiles for t e p -oposc d treat_+::.;t ieenen i. :: ::tore:. reservoir. voir. Condition(:,) :he Grantee shall provide EPA with a copy of i;eld County's review and approval of the proposed project prior to • . receiving a Step III award. 10. Problem: Northglenn hes not p•ovided EPA with a detailed proposal .or the disposal of sludge. No contingency plan has been developed in case the proposal cannot be implemented due to EPA restrictions or lack of interest frc:n private land owners in the vicinity of the treatment site. Condition(s) : The Grantee shall submit to TPA for approval a I:eC/ili.tor i program and a contingency plan which will detect poten- tial problems with the use of sludge on pr iiate agricultural lands and which will provide another means of disposal if the Grantee is precluded from disposing the sludge on private agricultural lands. The Grantee shall not re::ei.ve fina]. Step II p?y,nent until both the monitoring program and the contingency plan are approved by EPA. 11. Problem: The proposed project may require large quantities of water to be pumped from the Arapahoe and Lera::ie-Fox Hill aquifers which • may result in significant adverse groundwater impacts. The quan.- • titles of water that will, be p'. ,:pe 1 end the impacts of this. pumping have not been fully determined. . • _81- • • Condition(s) : If the Grantee has developed a firm plan to pump• significant (i.e., greater than 500 acre feet per year) amounts of groundwater from either the Arapahoe or Laramie-Fox Hills aquifers, the Grantee shall provide to EPA a reassessment of the expected ' impacts based on a restudy of the aquifer's-storage-coefficien and the amounts of water to be developed. The Grantee shall also provide evidence that the State Engineer has approved well permits which will allow the proposed development to occur. 12. Problem: As -c1.oscri.hcd share, there are several potential problems Vain i e pro j cc;twhich may prevent it from being irpleraented. - Condition(s) : if the project can not be implemented due to legal, i:ia'lar:c 3 c11, or other problems, i72 A reserves the right to recover all funds expended on the project under this or any future grants. In response to the actions taken by EPA in the "Denver Regional Environmental Impact Statement for Wastewater Facilities and the Clean . Water Program," EPA will also place the following conditions on the Step II grant offer to Northglenn. 1. The Grantee shall before January 1, 1979, provide EPA with a reso- • lution(s) passed by the general purpose government(s) to be served _ by the proposed project (i.e. , Northglenn and possibly Thornton and Adams County) which demonstrates the governing body's commitment to (a) implement reasonable air pollution control measures; (b) parti- cipate in the development of the Denver element of the State Air Quality Implementation Plan and (c) once approved by EPA, support implementation of the Denver element of the State Air Quality Implementation ?'lan. Failure to comply with this condition may result in EPA stopping payment under the provisions of this grant. EPA will not award a Step III grant until this condition is satisfied. 2. The Grantee shall develop and implement a sewer tap program which annually determines the number of taps available for new residential development and which is consistent with the DRCOG population fore- casts for 1980, 1990, and 200O as presented in Northglenn's facility plan. EPA will not award a Step III grant until such time that a satisfactory sewer tap program has been provided to EPA. • 3. The G-antee shall provide to EPA a schedule which identifies when the Grantee will consider for adoption erosion control ordinances and regulations. EPA will not make any payments under this grant • until such time the schedule is submitted to EPA. EPA also will not award a Step III grant until such time that the Grantee has acted favorably on provisions to control erosion resulting from new development. This condition applies to all general governments which will receive wastewater service from Northglenn (e.g. Thorn- ton and Adams County if they decide to use the Northglenn system) . -82- 4. The Grantee shall adopt the municipal water conservation ordinances or similar ordinances as presented in Appendix F of the facility plan and shall provide EPA with a schedule for when these ordinances will be considered. EPA will not award a Step III grant until such • - - time that a schedule is provided. Payments under Step III will be conditioned on the Grantee taking favorable action on these ordi- nances. S. The Grantee shall, as part of Step II design, investigate the feasi- bility of using the corridor for the Northglenn interceptor as a bike path, trail, etc. EPA shall be provided with the r;sul-s of tb-j S ,,,'theC span a i - _ ti, 1./1 , ti �. ill. • -83- MEMORANDUM TO: Weld County Special Use Permit File FROM: F. Robert McGregor l�C. DATE: February 12, 1979 ll( SUBJECT: Site Selection A number of factors were considered in determining the recommended location for the aerated lagoons and storage reservoir. Included in our evaluation were two basic alternatives involving the aerated lagoons. The first option was to locate the lagoons in Northglenn and the second was to place them adjacent to the reservoir at the Bull Canal Site. Our recommendation to locate the aerated lagoons and the reservoir together at the Bull Canal Site was based on the following factors : 1 . Since the storage reservoir is an integral part of the treatment process, there will be more effective quality control and flexibility of operation with the lagoons and reservoir at one location. This will also facilitate monitoring and control of the water quality by the Farmers Reservoir and Irrigation Company as required under the FRICO- Northglenn agreement. 2. By having both the lagoons and reservoir within Weld County, the County will have total jurisdiction over the treatment and storage facilities through the County Health Officer. This will assist the County staff in implementing an effective program for monitoring the system performance. 3. There are significant construction cost as well as operating and maintenance cost savings by locating the lagoons and reservoir together. Two separate maintenance facilities would be required, and additional operating personnel would be needed if the facilities were placed at separate locations. 4. When dewatering of one of the sets of aerated lagoons is necessary for scheduled maintenance, the lagoon water can be discharged directly to the reservoir if the lagoons are adjacent. However, if the lagoons were located in Northglenn, this water would need to be pumped to the reservoir, thereby placing an added burden on the operations of Pumping Station A and would require a larger force main. 5. The proposed plan is a cost-effective solution for sharing of urban and agricultural water supplies. Alternative solu- tions will be more costly and would increase construction costs by $1 ,700,000 and may jeopardize an EPA grant of $7,900,000. Memorandum February 12, 1979 Page 2 6. The proposed facilities are designed to perform in a manner which will not create any nuisance conditions . Nonetheless , possible nuisances may be imagined by poorly informed people. Thus, obtaining site approval for a treatment facility in a rural area which will also receive the benefits of the facility is a prudent course of action. 7. Northglenn is totally surrounded by other cities. Each parcel of land in Northglenn is committed to urban use. Locating the treatment facilities in Northglenn will displace the urban uses and will increase the pressures toward urban sprawl and additional losses of prime agricultural land. MUSICK, WILLIAMSON, SCHWARTZ, LEAVENWORTH & COPE, P.C. 75 Manhattan Drive - Suite I Yost Office Box 4579 Boulder, CO 80306 MEMORANDUM February 12, 1979 TO: Shirley Whitten L � FROM: Sue Ellen Harrison 1�14i RE: Alfred Nehring ' s Testimony at the Weld County Hearing You may recall that at the special use permit hearing for Weld County, a Mr. Alfred Nehring testified concerning contacts he had with the State Engineer' s office. He lives in Weisner Subdivision and apparently his well has gone dry. He claimed that the State Engineer' s office told him that he would have to go down over 900 feet to dig a well because of possible pollution from the Northglenn reservoir. Our office called Reiner Haubold at the State Engineer ' s office to try and verify this comment. Mr. Haubold is the person who talked to Nehring and Haubold believes that he did not say what Nehring attributes to the State Engineer' s office. Haubold says that the State Engineer' s office has absolutely no problem concerning pollution of the Arapahoe aquifer, or any aquifer for that matter, by the Northglenn sewage treatment plant. Haubold did Nehring that he would have to dig a well that was probably nearly 900 feet because in that area he would have to go down to the Laramie-Foxhills in order to get water. In addition, the well would have to be dug to the bottom of the aquifer to afford the best assurance against it running dry. Memo to Shirley Whitten February 12, 1979 Page Two Somehow Mr. Nehring got this all twisted around but the State Engineer' s office does not have any pollution concerns with the Northglenn facility. Sue Ellen Harrison SEH:raw cc: Robert McGregor NORTHGLENN WATER MANAGEMENT PROGRAM , max$ P a� .4x44ry`yn*� \ ` • ,. `4d. V u 9 4 .Y 1,...„, , rt • .4, • t` �1 ..t4x .Stir• `•'� .:1•-•.', -rd-' rte.•,' , ..-': yA i SNARING WATER -1 IL: A"` NQRTNG{.ENN ' '•'r ®? :'Fs«hd Al r• CARES -v ., A. 'Ry e AY}u f I' PY `11 • • •.al A� 1� 7 % /V" ?�. M1et,.qPo, ry 0 Ifs I yy ' . $ ,o-tl',0p �'L . ' '''',1 s 'B p1p5 Summary NORTHGLENN, COLORADO ee. CITY OF NORTHGLENN tie it SHARING WATER 10701 Melody Dr., Suite 313 NORTHGLENN Northglenn, Colorado 80234 Phone (303) 451.8326 NORTHGLENN WATER MANAGEMENT PROGRAM "Among material resources , the greatest, unquestionably, is the land. Study how a society uses its land , and you will come to pretty reliable conclusions as to what its future will be. " That message from SMALL IS BEAUTIFUL has a special relevance for those of us in the arid west. For unless our water resources are conserved and shared, the quality of our lives will wither like the land. Although the water problem has been with us for a long time, the critical nature of the problem was not perceived until 1973 when Thornton commenced an action for the condemnation of agricultural water rights. Unfortunately, this "solution" to the water problem creates more problems than it solves; we simply cannot afford to meet municipal needs at the cost of drying up our nation's farms. If our society as a whole is to enjoy continued prosperity, than a new spirit of harmony must prevail between our rural and urban communities. This new spirit is reflected in the Northglenn Water Management Program. By substituting cooperation for condemnation, Northglenn has designed a system capable of satisfying municipal water demands while keeping agri- cultural land in production. The system offers both fiscal responsibility and environmental soundness, and reflects an understanding that the rural and urban sectors of our society are naturally - and inextricably - linked. Governor Richard Lamm has called the Northglenn Water Management Program "the most creative and innovative thinking I have seen in my ten years NORTHGLENN & FRICO LAND AND WATER RESOURCES MANAGEMENT PROJECT of politics . " What kind of a system could prompt such an accolade? The answer is one that is based on common sense , and adheres to nature' s own cycle. The essence of the proposed system can be described as follows : 1 . Water which has been legally appropriated by the individual share- holders of the Farmers Reservoir and Irrigation Company (FRICO) - and which has historically been used for the irrigation of crops - will be di- verted from its place of storage in Standley Lake and transmitted by pipeline to Northglenn. 2. The City will treat this water and then deliver it to Northglenn citizens for municipal use. 3. Following municipal use, the City will collect the waste-water, treat it , store it, and then return it to the FRICO irrigation system for agricultural use. The water returned to the farmers will be of a quality approved by FRICO, and will surpass all water quality standards prescribed by state and federal law. 4. The total quantity of water which is diverted to Northglenn from Standley Lake will be returned to the farmers . That amount of water which is consumed within Northglenn (approx. 20' of the total water diverted) will be made up to the farmers by water rights which Northglenn presently owns or will acquire for that express purpose. 5. In return for the privilege of using the farmers ' water, Northglenn has agreed to provide FRICO annually with an additional quantity of water equal to 10% of the total amount of water diverted to the City. This can he characterized as "interest" on FRICO' s "loan" of water to the City, and amounts -2- to a fraction of what it would otherwise cost the City to purchase all of the water rights necessary to satisfy municipal demands. Projections show that under the Northglenn Program the farmers will get substantially more water in a dry year period. Even in a normal water year, the farmers will have more water for irrigation because of water management. By integrating water, sewer, and urban drainage planning with recrea- tion, open-space, and agricultural planning, Northglenn has adopted a comprehensive approach to the management of its land and water resources. This comprehensive approach not only saves water, but has transformed a seeming liability into a distinct asset: through the recycling of waste-water, potential pollutants take on measurable value in the production of agricultural products . It is precisely this kind of forward thinking which moved Senator Gary Hart to comment, "With water predicted to be in scarce supply, programs like this will be a necessity. Northalenn' s work in pioneering this should serve as an example for all communities on prudent use of our limited water resources . " In addition to serving as a model of rural -urban cooperation , the Northglenn-FRICO partnership offers some significant advantages to Northglenn citizens: 1 . With its fixed population and boundaries , Northglenn has a unique opportunity to take positive, innovative steps. The City has decided to act, rather than react. 2. Under the proposed independent system, Northglenn -3- will be firmly in control of its own destiny, and political responsibility will flow to and from its own citizens. This will ensure the operation and maintenance of a facility which is responsive to the needs and desires of Northglenn citizens. 3. Rather than continuing to "pay rent" to Thornton , the proposed system allows Northglenn citizens to develop a financial equity in a system of their own. 4. According to the Metropolitan Water Requirements and Resources Report 1975 - 2010, Thornton is incapable of supplying the water demands within its service area. Thornton presently has a dry year deficiency of 5 ,130 acre-feet, with a whopping 30,600 acre-foot deficit forecast for the year 2010. 5. According to Thornton's own financial projections for 1976-1985, substantial utility rate hikes will be required in the next five (5) years. 6. An independent. Northglenn system will mean an end to the present disparity in tap fees. Presently, Northglenn users pay twice the amount which Thornton users pay for water and sewer taps. 7. Northglenn is currently bearing a major share of the cost of Thornton's ambitious growth policies. Having determined to stabilize its own growth at approximately 42,500 persons, Northglenn should not be forced to help finance further growth in Thornton. -4- We, the Northglenn City Council , are acutely aware of the water crisis which confronts us. But by making it our policy to respect the ties which naturally bind our rural and urban communities -- and letting that policy dictate solutions to our problems, rather than vice versa -- the crisis can be averted, and the continued prosperity of our society assured. CITY OF,NORTHGLENN /— / Alvin . Thomas, Mayor Mary Ellen Kette1 r _ H ro d T. Hodges, Mayor ro Tem / 9detirt iliarry_ // T�A tit _C !,-,.•i -eic-} �' r Donald E. Burback Ellwood E. Curtis Robert W. Moderhak, II ( James P. Dawson , Jr. j60-4 M. lia*J44,14 hn M. Hutchins -5- The President Jimmy Carter calls it a "vista" of the future." Northglenn Colorado Governor Richard Lamm Calls it "The most Water innovative, creative thinking 1 have seen in my 10 years of Management politics." System Bureaucrats call it "difficult to implement." Croplands Farmers Standley Lake Bull Canal Storage Northglenn Lagoon Q Q Treatment Wastewater OO Water Collection Cells Treatment 4Ph. _-�• Pumps Plant Urban Rijn" • Lawn Irri. Return Slonehocker Terminal Flows • Reservoir • �I Reservoir Deep Wells • Shallow Wells • Emergency Supply NOTHING IS AS POWERFUL AS AN IDEA WHOSE TIME HAS COME A DARING MODEL FOR THE WEST WATER WILL BE: BORROWED — USED — TREATED — The Northglenn plan is designed to satisfy municipal demands while keeping agricultural land in production. The system will divert water owned by the Farmers Reservoir and Irrigation Company to Northglenn, where it will be treated and delivered for domestic use. RETURNED — afterward, the nutrient-enriched water will be treated, stored, and returned to the farmers for irrigation of croplands. RECYCLED For information contact: Mayor Alvin B.Thomas, or Project Director, Richard P. Lundahl, 10701 Melody Drive, Suite 313, Northglenn, Colorado 80234 (303) 451-8326 Flowing down from the high country, the waters of Clear Creek are presently diverted and stored by FRICO in Standlev Lake, some 25 miles west of Denver. When the irrigation season arrives each sprina, the water in Standley Lake is released into the Bull Canal , and winds its way to the farms of the individual FRICO shareholders. Under the terms of the agreement reached between Northglenn and FRICO, a portion of the water from Standley Lake will no longer flow directly to the farmers ; rather, the water will be piped first to Northglenn for municipal use, and then recycled to the farmers for agricultural use. Nortnolenn' s current population of 32 ,000 will require the annual diversion of approximately 6,125 acre-feet of water; the maximum projected population of 42 ,500 will ultimately require the diversion of 7 ,785 acre-feet of water annually. The map on the preceding page illustrates the lull circle the water will follow. While certainly there are technical and legal obstacles to be overcome in constructing a project of this magnitude, a look at the map reveals how simple and natural the system really is . The essential ingredients of the plan are as follows : A. Raw water delivery system. Conveyance of the raw water from Standley Lake to the Northglenn treatment plant will be via a 7.5 mile , 36-inch diameter pipeline. The water will be metered as it leaves the dam in order to record the exact amount of water diverted. The pipeline will he capable of delivering a sufficient quantity of water to meet peak daily demands , anticipating the maximum population of 42 ,500. A reserve pipeline, originating from the South Platte well field , will also be constructed -6- to ensure the delivery of essential water supplies should the primary line be rendered inoperative. B. Water treatment. Prior to being introduced into the municipal system, the water from Standley Lake will undergo thorough treatment in a conventional plant to be located near the Northwest corner of the City. Water quality standards set by the Colorado Department of Health and the federal Safe Drinking Water Act will be met, and even surpassed, by the proposed treatment facilities. C. Treated water storage. Following treatment, the water will be stored in municipal reservoirs. It is essential that adequate storage be provided in order to ensure the availability of water for peak use periods and fire protection. Elevated storage is required to provide adequate pressure to all areas of the City with a minimum of pumping, and to minimize the treatment plant design capacity. D. Treated water delivery system. The existing City water lines were designed to move treated water from east to west. The Northglenn water management program includes a water treatment plant located on the west side of the City. This will require the installation of 8.5 miles of new water transmission pipelines to maintain adequate pressure throughout the City. E. Make-up water supply. Northglenn' s agreement with FRICO requires that the total quantity of water borrowed from Standley Lake be returned to the farmers. Since approximately 20% of the water borrowed will be lost to the system in the course of municipal use, that amount of water will -7- have to be made up to the farmers from various independent water sources. As previously mentioned, the City is also obligated to provide the farmers with a bonus of 10% of the total amount of water borrowed in any given year. Thus, while Northglenn is acquiring 100% of its water supply at a fraction of its value, it is incumbent upon the City to develop a dependable supply of replacement water. The question of make-up water has been fully explored by the City; extensive engineering and legal analysis has confirmed the City's ability to meet its contractual commitments to the farmers at a substantial savings to its own citizens. The following sources of water will be relied upon by the City for the purpose of replacement: 1 . Deep, non-tributary wells. Approximately 2300 acre-feet of high quality water can be produced annually from wells drilled into the Arapahoe and Laramie-Fox Hills aquifers . Water from the deep aquifers will be an integral part of Northglenn' s municipal supply; it can be safely introduced into the system after a simple chlorination process is performed at the well site. A contract has been awarded for the first Arapahoe well , and drilling will be completed in May of 1977. Water from the Laramie-Fox Hills aouifer will be drawn upon only during dry years , as required to meet the commitments of the water management program. 2. South Platte wells. Alluvial well fields located east on 104th Avenue, approximately one mile west of the South Platte River, will be another major contributor to Northglenn' s replacement water inventory. Approximately 1400 acre-feet of water can be -3- generated from these wells annually for use by the City. Current plans call for the drilling of six shallow wells. After a modicum of treatment, this water can either be integrated into the municipal system or delivered to the farmers for agricultural use. Present Plans call for this water to be transmitted by pipeline to the Northglenn Reservoir, where it will await the farmers ' call . 3. Urban storm runoff. This is a water resource which until very recently has been a wasting asset. Flood control planning can eliminate the harmful consequences of storm flows , and state- of-the-art technology can transform storm runoff into water suitable for open-space irrigation. An additional benefit to be derived from the capture and management of urban storm runoff will be the water quality enhancement of the South Platte River. The Northglenn Reservoir, an earth-filled dam with a designed capacity of 500 acre-feet, will be constructed by the City for the purpose of storing and treating this water, as well as the water derived from the South Platte wells. 4. Urban Irrigation Return Flow. The utilization of urban irrigation return flow as a water resource is consistent with Northglenn's water conservation policies. This is water recovered through nature's deep percolation process, as well as through the collection of excess runoff in the Northglenn Reservoir. 5. Northglenn Irrigation Sub-System. Substantial savings will result -9- from irrigating the City' s public lawns and open space with water derived from the South Platte wells. Irrigation water can serve these municipal purposes fully as well as potable water - and can do so at half the cost. The irrigation water will be of sufficient quality to ensure the continued and undiminished enjoyment of Northglenn's abundant recreational and aesthetic opportunities. In order to integrate each of the above-described water sources into the Northglenn water management plan, and in order to ensure the plan 's successful implementation, the City's water attorneys , Vranesh and Musick , will submit a Plan of Augmentation to the Water Court for its approval . F. Wastewater management. The success of the Northglenn water management program lies in the fact that it is a full-cycle system; by returning treated sewage effluent to the land, the cycle which began with Clear Creek water is started anew. By recognizing that pollutants are simply resources out of place, Northglenn has transformed a seeming liability into a distinct asset -- once again demonstrating that cooperation between the rural and urban communities can produce substantial savings for both. The wastewater management components of the system include all of the facilities required to collect, convey, and store the City' s sanitary waste, as well as ample facilities for the storage of irrigation water during the winter months. Essentially, the system will operate as follows : 1 . Wastewater conveyance and treatment. Wastewater will be conveyed through existing sewer lines to a central pumping station with a capacity of 9.6 million gallons per day. From there the water -10- will be transmitted by pipeline to a treatment facility located adjacent to the winter storage reservoir. Although the choice of an optimum reservoir site is still the subject of geotechnical investigation, the most preferred sites are located in the southern part of Weld County, adjacent to the FRICO irrigation canal . These sites are preferred because of their isolation from population centers , their proximity to the lands to be irrigated, and their relatively low acquisition costs. As shown in the table below, a level of treatment better than normal sec- ondary quality will be provided by the aerated lagoons and storage reservoir combined treatment system, which will ensure the removal of harmful bacterio- logical organisms and suspended organic and inorganic solids. State-of-the- art technology can effectively eliminate both aesthetic objections and the health hazards that are posed to man and livestock. The resulting water quality will surpass all applicable health standards , and will be perfectly suited for agricultural purposes. TABLE I COMPARISON OF UNTREATED NORTHGLENN SANITARY WASTEWATER WITH FINAL TREATED EFFLUENT Aerated Renovated water Untreated Lagoon Discharged From Parameters Units Wastewater Effluent Storage Lagoon BOD5 1 mg/1 175 40 10 Suspended Solids mg/1 175 52 25 Nitrogen mg/1 30 25 20 Phosphorus mg/1 7 6 5 Fecal Coliform Organisms #/100m1 1 ,000,000 200,000 200 'BOD5 is quantity of biochemical oxygen demanding organics. -11- 2. Wastewater storage. Following treatment, the water will be retained in the winter storage reservoir until such time as it is required by the farmers. With a designed capacity of 3300 acre-feet, the reservoir is capable of storing Northglenn's sanitary wastewater flows for the nine month period running from September through May. This reservoir will also serve an additional treatment function by providing further opportunity for stabili- zation and aeration. Site selection for the reservoir will assure the water' s availability to the farmers at a moment' s notice. G. Quality of wastewater for agricultural use: Environmental concerns. Application of treated municipal wastewater to agricultural land raises questions about the effects of possible toxic substances and pathogens potentially present in the wastewater. The fact that Northglenn is principally a residential community makes it highly unlikely that significant quantities of toxic substances will be found in the wastewater. Laboratory analyses of Northglenn' s effluent ha'4e also confirmed that heavy metals are not present in any significant amounts. A strong industrial waste control ordinance, coupled with a continuous monitoring program to detect possible toxic substances , will be implemented to prevent the occurrence of health related problems in the future. Past experience with land application of municipal wastewater in the United States has shown that with proper Pretreatment and disinfection , the health hazards posed by wastewater irrigation can be effectively eliminated. Experi- ments performed by the U. S. Department of Agriculture, and years of operating experience on farms around the world, reveal no ill effects to livestock from -12- ingesting treated wastewater. The same encouraging results have been demonstrated with respect to the crops grown with treated effluent. The insignificant amounts of toxic substances identified in Northglenn' s effluent indicates that there is very little basis for concern about the accumulation of toxic substances in soils or crops. However, in order to ensure that problems do not arise in the future, continuous monitoring of water quality, crops , and soils will be carried out. H. Regional benefits of reuse. Benefits from the Northglenn reuse program accrue to urban and agricultural interests alike. The principal urban benefits are an inexpensive supply of high quality water and substantially reduced waste- water treatment costs. Principal agricultural benefits include the conservation of precious irrigation water supplies and the added nutrient value of the treated effluent. Of course, the most significant benefit is shared by farmers and city-dwellers alike: in an age of soaring populations and shrinking food supplies , essential agricultural land will be preserved in production. By providing an alternative to the condemnation of agricultural water, millions of dollars worth of direct and indirect costs have been avoided by Northglenn. Condemnation or direct acquisition of a water supply for a city Northglenn' s size would cost between $6,000,000 and $9,000,000. Coupled with the loss of farm investments , jobs and crop incomes , the costs of condemnation would be staggering. The ripple effect from these losses would have a devas- tating impact on the urban economy as well . But when cooperation is substituted for condemnation, the continued vitality of our rural -urban economy is assured. Clean water is another dividend to be reaped from the project. Low-cost -13- secondary treatment of wastewater, followed by land application , guarantees that 1985 Federal water quality goals will be met at a substantial savings over the cost of conventional treatment methods. In fact, the Northglenn reuse concept was recently encouraged by the Denver Regional Council of Governments as a cost-effective and environmentally sound way to meet the nation' s clean water goals. I . Financial Considerations. It is fundamental that a city should control its water and sewer service if it is to have control of its own destiny. The provision of water and sewer service to the citizens is a primary municipal function under the constitution and laws of this state. The discharge of this responsibility becomes crucial when it is apparent that presently available supplies of water fall short of existing demands in dry years, and when the future is threatened by commitments to expansion. Nevertheless, any decision to pursue a different course must be accompanied by consideration of the costs involved. To establish a functioning water and sewer utility, Northglenn would have to construct transmission lines, reservoirs, a water treatment plant, wells, and a secondary sewage treatment facility. The city would also have to pay for operation , maintenance and bond retirement. All of these costs will be paid from the revenues of the system. After completion of a pre-design study, the citizens of Northglenn will be asked to authorize the issuance of bonds to finance the proposed project. The total cost of constructing the proposed water supply and sewage disposal system has been estimated at thirty-one million dollars. The cost to pay off the bonds and the annual operation and maintenance costs -14- have been included in the estimated annual cost of the system. The Northglenn Water Management Program has been designed to provide adequate water and sewer service to the ultimate City population of 42 ,500 people. Some money could be saved by phasing construction, but with the high inflation rates in the country it is in the best interest of the City to build the facilities needed for future conditions in the initial construction phase. Also, because it takes a minimum of three years to plan, design and build a utility system, the City would be starting the expansion design within a year after starting operation. 1 . Cost per household under the Northqlenn Program. The total cost to implement the Northglenn Water Management Program is $31 ,000,000 and the system will be fully operational by November, 1980. The project will be financed by General Obligation Bonds backed by the revenues of the utility system. Debt service will be $2,660,000 per year based on 25-year bonds and a 7 per cent annual interest rate. The water facilities annual operation and maintenance costs will be $874,000 and the wastewater facilities operation and maintenance costs will be $216,000 per year. The total annual cost for the Northglenn Water Management Program will be $3,750,000. Based on the current number of taps , the total cost per house- hold per year will be $375. As more taps are sold, the cost per household will drop because of connection fee revenues (tap fees) , and because there are more taps to absorb the debt service cost and the fixed operation -15- and maintenance costs. 2. Cost per household under the Thornton system. The total water and sewer cost for the average Northglenn household under the Thornton system is presently $220 per year. However, because of Thornton' s offer of $21 ,000,000 for water rights of the three agricultural ditch companies they have filed condemnation actions against and because of the increased sewerage treatment costs to be expected when Northglenn sewerage is pumped over to the Westminster Big Dry Creek plant, the estimated average cost for water and sewer service will be $387 per household per year. In addition to the above costs under the Thornton system, the treatment of urban runoff as required by Federal law will cost Northglenn residents between 15 and 40 dollars per person per year. This means that the total cost for water and sewer service plus treatment of urban runoff under the Thornton system will range between $444 and $539 per household per year. It is clear that it is in the best interest of the Citizens of Northglenn to implement the Northglenn Water Management Program which will provide fully adequate water and sewer service plus meet the requirements of Federal law with respect to treatment of urban runoff at a total annual cost of $375 per household per year. When the bonds are paid off, because this system will be adequate for all future needs , the annual charge for debt service of $2,660,000 can be dropped resulting in a savings of $181 per household per year. -16- WYOMING COLORADO a J a WELD 4(<' THOMPSON 4 SO 0�G fro? vTy Fj w z -J OTANDLEY LAKE 4NORTHGLENN • U • Uhl ADAMS 1 CLEAR CREEK I DENVER NORTH NORTHGLENN PROXIMITY MAP MAP SCALE: I" 38 MI . EXHIBIT NO 1 CONCLUSION The pioneers who settled the West, like the Indians who came before them, brought a very special ethic to the land. They didn 't conquer the land so much as they made peace with it. They harvested nature's bounty, and placed it to their best advantage--but they respected it, they took care of it, and they didn 't waste any of it. Above all else, they recognized the need to cooperate with one another if they were going to build their homes in this new land. We are no less pioneers today than our forefathers of one hundred years ago. If anything, the challenge of saving the West is greater than that of winning it. With millions of Americans calling this land home today, and with the demands on our limited environment growing daily, the land ethic of the pioneers remains as vital as ever. There is enough water to satisfy our agricultural , domestic, recreational , and aesthetic needs--provided it is allocated wisely. If it takes the harsh reality of a drought in 1977 for us to appreciate the importance of conserving and sharing our water resources , then so be it. It's not a lesson too late for the learning. -17- N. Z 0 c u, h z §- N L 0 0 a m W w a a to a I" (nce LL w 1- 0 00 a J w 0 Y- �/� 5 0 CO I- 3 5. VJ N " = � z r = Y - OJ VJ - "' G F-- U w C...5 U- O Z r F- w w w Z z J cc Z U z 0 w fn G J O J w z Z Z F- J r F- M 0 w w J ¢ F- w V- U _ w w r ¢ w z w a w W w — F- 1- /n K Z ] 0 C0 0 J 2 _ = 3 3 z ca.� z o� co F- o O X CC 0 = W ill Z _ �' w Z I— Q o = CC J S LU V O O F- �I I Z Q5 - L U s w dI= - y° =\ 6 yw. 3 i I. -' rii(s dd 60 3''',3z �\ LLociAJi W �Z W J/J67 �,�I`1 0 `E z (,�j Q way _ Jea/j� -- _ J A NQ J J � N r� Z m Z ',\Z_____ ..<V. a 1` 3r tai U � j0 -\( W' w%1-'5 ` d a` _ 3zo z Er, ,..„.c..._ H O W o ///�.../ \' I 1 V� W F 7--- Q F WU L. ‘, ,,,,,,\ _ \\%,-...,in) SL 1 pnl8 le�apa3 ,/ Ll * a Z • O 8 \ a O 2 '� �j_l 00 swvav ` ---r PnIS Uepl/a4S • NOSU3J3f -- ki3OlOO8 b �\ __ OO J U w7,5 4) O y. Y U Q 111 d ` I )+ 8 \ ' j/ L C J 111--- J r___..- /f • 1: 1 Et O' 45 \'`I..,_\.\ ? U U \L✓^Vf w „4J ^ J LL J MEMORANDUM OF LAW TO: The Weld County Planning Commission FROM: Francis K. Culkin and Ellen C. Cross SUBJECT: Northglenn's Water Augmentation Plan I. FACTS Concern was expressed at the February 6, 1979 planning commission hearing about the Northglenn's ability to replace the water under the Northglenn- FRICO exchange plan. Mr. Joseph Cope, attorney for Northglenn, attempted to respond to opposition by the Consolidated Ditches Company of District No. 2. Consolidated Ditches Company is opposed to the water augmentation plan because Northglenn has not shown that the water purchased from other sources will be replaced. Consolidated Ditches Company, along with Adolph Coors Company, City of Westminster, the City of Thornton, the State of Colorado, the City of Denver, the City of Aurora, and the Colorado Water Conservation District have all filed statements of opposition to Northglenn's application for deep water well permits and/or Northglenn's application for water storage rights. Northglenn's deep well permit applications were denied by the State Engineers Office. The deep well permit denial is currently being appealed by Northglenn in the Water Court. Additionally, the issue of Northglenn's water storage rights application must still be decided by the Water Court in Greeley. II. LAW Frequently, municipalities acquire a water supply by purchasing water rights= previsouly used for agricultural purposes. Such rights may be devoted to municipal use, provided that no other water rights are injured by the change. Green v. Chaffee Ditch Co. 150 Colo. 91, 3F1 P.2d FF5 (1962). The Constitution of the State of Colorado, Article XVI, 86 sets forth the priortiy of appropriation of water rights : Diverting unappropriated water — priority preferred uses. The right to divert the unappropriated waters of any natural stream to beneficial uses shall never be denied. Priority of appropriation shall give the better right of as between those using the water for the same purpose; but when the waters of any natural stream are not sufficient for the service of all those desiring the use of the same, those using the water for domestic purposes shall have the preference over those claiming for any other purpose, and those using the water for agricultural purposes shall have preference over those using the same for manufacturing purposes. The term "domestic purpose" does not encompass all municipal water uses. Municipal water uses include fire protection, street sprinkling, parks and lawn watering and supply to homes and apartments. The Colorado Constitution does not mention a category of "municipal" use, and the extent to which various municipal uses fall within "domestic" purposes has not been resolved. Municipal systems also frequently supply commercial and even industrial users. See, Denver v. STariff, 105 Colo. 193, 96 P.2d 836 (1939) ; Denver v. Brown, 56 Colo. 216, 138 P.44 (1913). A breakdown of the Denver system water deliveries is as follows: residential - 52.1%, industry - 11.4%, government agencies (including park irrigation) - 7.6%, and about 6.0% losses in the system. Colorado Springs v. Bender, 148 Colo. 458, 366, P.2d 552, laid out the priniciples intended to protect senior water rights: Fundamental among the principles applicable here is the rule that a junior appropriator may not direct the water to which he is entitled by any method or means , the result of which will be to diminish or interfere with the rights of a senior appropriator to full use of his appropriation. (emphasis added). Also see an opinion by the Colorado Supreme Court, published in Colorado Lawyer, Vol. 6, October , 1978, p. 1873 in a case entitled A-B Cattle Co. , et al. v. U.S. , decied August 21, 1978. This case emphasized the principle that all appropraitors whether junior or senior, are entitled to rely upon the continuation of stream conditions as they existed at the time the appropriation was made and cited Farmers Highline Canal and Resevoir Co. v. City of Golden, 129 Colo. 575, 272 P.2d 629 (1954); Comstock v. Ramsey, 55 Colo. 244, 133 P.1107 (1913); Vogel v. Minnesota Canal Co. , 47 Colo. 534, 107 P. 1108 (1410). -2- The Colorado Supreme Court in A-B Cattle Co. v. U.S. , su ra further stated: Persons seeking exchange in water rights which will injuriously affect other rights, therefore, must propose the imposition of conditions to prevent such injury or be denied the right to make the change. City of Brighton v. Boulder Left Hand Ditch Co. , Colo. 1182 (1977) ; Farmer's Highline Canal and P.2d v City City o— f Golden, supra. III. ARGUMENT Mr. Joseph Cope, upon request by the Weld County Planning Commission, forwarded information concerning the City of Northglenn's water rights and plan for augmentation under the Northglenn-FRICO exchange plan. The memorandum submitted by Mr. Cope lists the water rights owned by Northglenn. It also describes Northglenn's treated water requirements and a proposed replacement water plan. The City of Northglenn's treated water requirements are divided into the following two categories: (1) Household and commercial and (2) Irrigation (lawns and parks). There is no indication what percentage of the water will be used for household (domestic) and commercial (manufacturing) . The breakdown on the Denver water use suggests that more than one third of the water used by a city would go to commercial and industrial uses. Commercial and industrial uses have not been classifies as "domestic purposes" (see II. Law supra) In the same vein, irrigation of lawns and parks has not been classifies as a "domestic purpose"; Northglenn estimates that approximately 43.5% of their treated water requirements will be allocated to the irrigation of lawns and parks. The "domestic use" protected by the Colorado Constitution is such use as the riparian owner has at common law to take water for himself, his family or his stock, and the like. Montrose Canal Co. v. Loutsenhizer Ditch Co. , 23 Colo. 233, 48 P. 532 (1896) ; Black v. Taylor, 128 Colo. 449, 264 P.2d 502 (1953). It may therefore be argued that approximately 80% of Northglenn's water requirements are not allocated to domestic use. The agricultural use to which the water rights purchased -3- by Northglenn have traditionally been applied has priority. If the Water Court decides that the prior appropriators may be injured the application by the City of Northglenn will not be granted and Northglenn will not be able to replace the water under the Northglenn-FRICO exchange plan. Although Northglenn owns water rights in 15 different water companys, ditch companys and reservoirs the memorandum submitted by Mr. Cope only discusses replacing diverted water from Grange Hall Creek and the Tributary Well Field. No mention is made of the following tributaries which could be adversely affected: Clear Creek, Ralston Creek, Leyden Creek, Big Dry Creek, Little Dry Creek and their tributaries in Jefferson County. Neither is Standley Lake replacement water mentioned. A further look at Northglenn's replacement scheme reveals many unanswered questions. For example the memorandum states: "(T)he Brighton Ditch might not be directly affected, but its call might affect the Fulton Ditch. Northglenn owns water rights in the Fulton, Burlington, and Reithman Ditches that can be turned back to the river to satisfy the Fulton Ditch." If the water rights in the Burlington and Reithman ditches are used to replace water from the Fulton ditch what water will be used to replace water in the Burlington and Reithman Ditches? IV. CONCLUSION There are many questions as to Northglenn's right to use the water purchased to fulfill Northglenn's water requirements and the Northglenn- FRICO exchange plan. The memorandum submitted by Mr. Cope to the Weld County Planning Commission gives no assurance that the Northglenn-FRICO exchange water requirements will be met. Finally, there are no assurances in the memorandum that the Water Court in Greeley will grant either the appeal of the denial of deep well permits or Northglenn's application for water storage rights. A denial by the Water Court will preclude Northglenn from fulfilling the requirements of the Northglenn-FRICO exchange plan. Respectfully submitted, Ellen C. Cross 1/8678 Francis K. Culkin #2969 Ellen C. Cross #2969 720 So. Colorado Blvd. Suite 962 Denver, Colorado 80222 759-3495 -4- rot '1 77/lQ)ne °sip `�ff�9�`9 `m 4a8 "a .:� MEMORANDUM OF LAW S'� �� \19,2S C)! l£UOt TO: The Weld County Planning Commission FROM: Francis K. Culkin and Ellen C. Cross, acting as attorneys for the inhabitants of Weisner Subdivision SUBJECT: Relevant facts regarding the proposed Northglenn sewage system, developed since the February 6, 1979 meeting of the Weld County Planning Commission The following information has been developed by the inhabitants of Weisner Subdivision regarding the proposed Northglenn sewage system since the February 6, 1979 meeting of the Weld County Planning Commission. This memorandum is in part a response to the answer filed by Northglenn since the February 6 , 1979 meeting. In the interest of brevity, this memorandum will not attempt to refute Northglenn's position on a point by point basis. It is divided into four areas : 1. The Muskegon sewage treatment plant. The Muskegon plant has a history of odor problems. Furthermore, the layout of the plant is such that the plant's neighbors directly abut cornfields rather than the sewage lagoons. 2. Plan 14 of the Denver Metropolitan Sewage District would provide more recycled water in a more efficient manner. 3• It will not be possible to monitor viruses released into the ditchwater from the Northglenn sewage treatment plant. 4. Standard texts in real estate appraisal indicate that property values diminish when the property is subject to foul odors. 1. THE MUSKEGON SEWAGE TREATMENT PLANT HAS A HISTORY OF ODOR PROBLEMS. FURTHERMORE, THE LAYOUT OF THE PLANT IS SUCH THAT THE PLANT'S NEIGHBORS DIRECTLY ABUT CORNFIELDS RATHER THAN THE SEWAGE LAGOONS. Northglenn has presented the Muskegon sewage Treatment plant as a model system. Northglenn has indicated to the Planning Commission that the Muskegon plant is of a similar design to the proposed Northglenn system. It has been the position of Northglenn's engineers that the Muskegon plant has no odor and that the Muskegon plant has had a positive effect on the property values in the areas surrounding the plant. Enclosed please find a paper entitled, "Muskegon County Water Wastewater Management System". This paper was prepared by Y.A. Demirjian, Ph.D. at the request of the United States Environmental Protection Agency. The paper indicates several things about the Muskegon project. First, is that the Muskegon plant differs in a major design factor from the proposed Northglenn system. The Muskegon plant is a complete system. The final stage in the treatment of wastewater is to spray the water onto cornfields owned by the Muskegon project. These cornfields surround the sewage lagoons where the wastewater is originally treated. Run-off water from these fields is collected through a system of underground culverts and directed away from the system. A majority of the land in the Muskegon system is thus used for corn farming rather than for sewage lagoons. The implications of these design differences are substantial. First, residential property contiguous to the Muskegon plant, if any, is exposed to a cornfield rather than to a sewage treatment lagoon. The corn farm owned by the Muskegon project acts as an effective buffer, regarding both foul odors and visually unpleasant features of the plant. The Muskegon plant uses recycled water only on land owned by the Muskegon plant. This, of course, allows for extremely tight control of any problems that might develop with the quality of the waste water used in the irrigation system. Such control is not available when thetreated waste water is released into an irrigation ditch. It should be noted at this point that a local power company has an option on land contiguous to the Muskegon project for the construction of a nuclear power plant. If the wastewater plant is located in a densely populated area, as indicated by Northglenn, it is unlikely that the construction of a nuclear power plant would be a conceivable use of the land. The Muskegon project has suffered from cracking of the walls of the storage lagoons. Such cracking, if it occurred in the Northglenn project, would allow seepage which would poison the wells of the inhabitants of Weisner -2- Subdivision. Such an occurence would be of considerably more import in water short Colorado than it would be in the wet climate of Muskegon. Finally, contrary to the Northglenn presentation, the Muskegon plant has suffered from odor problems, as Dr. Demirian's report states : Every treatment system has an odor problem to one degree or another. The Muskegon system is no different. County investigation into this problem was undertaken in late 1973. At the time, it was discovered that the odor was attributable to reduced organic and inorganic forms of sulphur. This statement of Muskegon's odor problem is of particular import when viewed in conjunction with the massive number of signatures on record with the commission indicating that the inhabitants of Louisville,Colorado have suffered substantially from the odor problems of a system similar to that of Muskegon. 2. PLAN 14 OF THE DENVER METROPOLITAN SEWAGE DISTRICT WOULD PROVIDE MORE RECYCLED WATER IN A MORE EFFICIENT MANNER. The problem of keeping land in farm use is of great concern to the Weld County Planning Commission. Due to the arid climate of Colorado, a major factorin maintaining farm use of the land is assuring an adequate supply of water for the farmer. Recycling has been proposed as an answer to this continuing problem in Colorado. There are several doubts about the legality of recycling from the viewpoint of Colorado water law. There are also considerable doubts about the practical effect of recycling upon the water supply of farmers not involved in the Northglenn system. If these difficulties are ignored and it is assumed that recycling is the most effective way to maintain land in agricultural use, the Northglenn system is still not the best system from the viewpoint of Weld County. The Denver Metropolitan Sewage District has developed a plan for recycling. This plan would treat the wastewater of Northglenn, Thornton, Broomfield, and Westminster in the Big Dry Creek treatment facility. Water used in this system would be returned to the farmers after use. Clearly, the volume of recycled water would be much greater in the proposed Metro Denver System than in the Northglenn system. Such a plan would also avoid a proliferation -3- of wastewater treatment plants throughout the Denver area. Finally, it would avoid the use of Weld County real estate to treat wastewater and sewage developed in Adams County. 3. IT WILL NOT BE POSSIBLE TO MONITOR VIRUSES RELEASED INTO THE DITCHWATER FROM THE NORTHGLENN SEWAGE TREATMENT PLANT. Both the inhabitants of Weisner Subdivision and the municipality of Frederick have expressed great concern over the quality of the water flowing into the irrigation ditches from the proposed Northglenn facility. In his regard, the inhabitants of Weisner Subdivision would ask the planning commission to take into consideration the attached pamphlet entitled, "Wastewater". It is a pamphlet prepared by Charles Downs of Michigan State University. It is a pamphlet advocating a recycling method such as that proposed by Northglenn. The Downs pamphlet states the following with regard to viral activity: Unfortunately, viral activity, the most important and most controversial water quality measurement, cannot be routinely tested with any degree of accuracy. Many questions of viral contamination in a system such as Michigan State University's - and in other water or sewage systems - remain essentially unanswered, because there are no quick, standardized tests that would permit technicians to detect viruses as readily as they now detect disease causing bacteria. Viruses have been found not only in sewage plant effluence, but in chlorinated drinking water. It thus appears that it is virtually impossible to monitor the presence of deadly viruses that might emanate from an incomplete functioning of the sewage treatment facility. This would be a danger not only to inhabitants of Weisner Subdivision, but also to the inhabitants of the municipalities of Frederick, Firestone, and Dacona directly downstream from the proposed project. 4. STANDARD TEXTS IN REAL ESTATE APPRAISAL INDICATE THAT PROPERTY VALUES DIMINISH WHEN THE PROPERTY IS SUBJECT TO FOUL ODORS. Northglenn takes the position that the property values will not be lessened by the construction of the sewage treatment plant. The record before this commission indicates that the inhabitants of Louisville feel strongly that odor is a problem with the Louisville facility. -4- Dr. Demirjian's report offered with this memorandum indicates that odor has been a serious problem with the Muskegon sewage treatment project. In light of these facts, the residents of Weisner Subdivision ask the board to consider the following statement from The Appraisal of Real Estate. This standard text for a real estate appraisal was prepared by the American Institute of Real Estate Appraisers, and it is used by appraisers throughout the United States. The text states as follows : The invasion of a residential neighborhood by commercial or industrial usages generally constitutes a depreciating factor. . .exposure to odors, dust, and noise from commercial or manufacturing enterprises limits a neighborhood's desirability. (p. 95) This analysis is confirmed by the experience of Mr. Anderson, an inhabitant of Weisner Subdivision, who testified on February 6, 1979 that two separate real estate deals for his home had fallen through when the presence of the sewage project became known to the buyers. It is also confirmed by the experience of Mr. Seiberg, who testified at the February 6, 1979 hearing that he had been experiencing great difficulties in attempting to sell his home in Weisner Subdivision. His testimony was supplemented by Mr. Heide, his real estate agent, who stated that he had been unsuccessful in finding; a buyer for the property. Mr. Heide further testified on February 6, 1979 that his general experience had been that property in the vicinity of a sewage treatment plant has less value, both as regards appreciation and as regards current value. CONCLUSION In light of the aforementioned factors, the inhabitants of Weisner Subdivision, acting through their attorneys, Francis K. Culkin and Ellen C. Cross, request the planning commision to recommend that a special use permit for the Northglenn project be denied. Ellen C. Cross , No. 8678 rancis K. ulkin, No. 2969 720 So. Colorado Blvd. , Suite 962 720 so. Colorado Blvd. , Suite 962 Denver, Colorado 80222 Denver, Colorado 80222 759-3495 759-3495 -5- ATTACHMENTS A. A portion of Y. A. Demirjian's analysis of the Muskegon County waste water management system. B. A portion of the proposal prepared by the Metro Denver Sewage District, No. 1, comparing their recycling plan with Northglenn's recycling plan. C. A portion of Wastewater T A Biological Approach, prepared by Michigan State University / i I ! / Al / i 446 Addition of supplemental fertilizer seemed to have resulted favorably at the 2 . 5 inch and 4 .0 inch effluent application rates; however, at the 1 .0 inch application rate fertilizer appeared to have been detri- mental. Generally the higher application rate of effluent resulted in higher yield. This was most likely due to the increase in nutrients which the effluent supplied (see table 9) . 5. Engineering and Operations As can be expected, for a system of this size and comp exi y, certain operational problems have been identified during the initial irrigation season. These are the following: a. Dike damage . b. Failures in the pressure pipe distribution system to the irrigation machines . c. , Failures in the underground electrical cables to the irrigation rigs. d. Odor Investigation and/or corrective action has been undertaken in all of the problem areas . A brief discussion of each of these follows : Dike Damage In the early spring of 1974 , during ice cover break-up in east storage lagoon, some damage was incurred to the soil cement lining of some sections of the northeast wall during high windstorms. This could be attributed to several factors . One factor could he the extreme high water levels in the lagoons at that time. Another factor could be that this particular section of the dike wall was one of the first sections to be constructed and construction difficulties in either mixing, quantities or application of the soil cement material. Inves- tigation into the problem is continuing and further observations are required. The dike lining could have been constructed with stronger mixtures and material, but the cost would have been unbearable . Total damaged area was probably less than 10% of the dike area . After the level of the east lagoon was lowered the damage was repaired. The 1975 winter does not show any major dike damages; there are a few patches which will be repaired during the irrigation season as the water level subsides. There will be normal dike maintenance repairs each year; it is expected from an 11 to 12 mile long dike . 49 Pressure Pipe Distribution System During the irrigation season, there was a high frequency of sleeve and pressure pipe breaks in the underground distribution system to the irrigation machines . There is no consistency in the pipeline breaks . Valves were installed to prevent high surge pressures during start up and shut down; this did seem to help some but did not correct the problem completely . Among many possibilities the pipe could have been damaged, in either transportation or installation, specifications, and manufac- turing are also being checked. Investigation into this problem is con- tinuing . Most repairs have been undertaken as the leaks are discovered. At the present time there are no broken pipes; there may be one pipe leak, but it will be repaired in April. Electrical Cables At the present time about 16 rigs are inoperable due to electrical cable faults . These faults could be caused by pin holes on the cables; it is under investigation how these pin holes showed up; there could be other causes for these faults such as holes, lightening, arching, etc. This problem is still not well defined and the study of this problem is con- tinuing. Repairs to damaged sections are currently being done, by splicing and replacement. Odor Every treatment system has an odor problem to one degree or another. The Muskegon system is no different. County investigation into this problem was undertaken in late 1973. At that time it was discovered that the odor was attributable to reduced organic and inorganic forms of sulfur. Corrective action was taken and the odor was reduced by about 90%. The remaining 10% may be objectionable to some. It is intermittant which could be attributable to the industrial activity. Work is continuing on this problem with the goal being the first odor free treatment system! i 29 VI . MONITORING LAND TREATMENT OF WASTEWATER Generally, conventional wastewater treatment plant operations include collection of wastewater, physical and biological treatment, disinfec- tion and discharge into the receiving surface water. The conventional system operates continuously, every day of the year and discharges con- tinuously. In these operations monitoring of the wastewater is done before, during, and after the treatment to assure the quality of the discharged water meets the regulatory agencies discharge standards . Land treatment of wastewater designs are (or should be) environmentally *4closed systems. Like the conventional system the liquid waste is collected, transmitted, treated or pretreated, disinfected and dis- charged. But the most important difference in comparing the land treatment and the conventional system is that after the biological treatment (pretreatment) and before the discharge into the surface water, storage and living filter processes are taking place; thus, the pretreatment is done continuously, but the discharge is done sea- sonally. The process of renovating water by land treatment systems requires much more involvement and considerations than conventional treatment, the difference is management. The involvement required is extensive monitoring programs of all facets of land treatment . Data obtained from these programs are the key to the management decisions. Monitoring the complex renovation process is essential for establishing safeguards against possible pollution of soil, groundwater and surface waters and air. Environmentally sound designed systems, poorly managed, could do a great injustice to the system. Therefore, management considerations are as important as the design criteria. The monitoring of the Muskegon system is designed to take into account the influent, biological treat- ment (pretreatment) , storage, post chlorination, post irrigation (drained) , lagoon seepage, groundwater, surface water, residential wells, soil and crop characteristics. The monitoring program should take into consideration the measurement of parameters that are important from the public health aspect, federal, state and local government ordinances and recommendations. The program also includes the agro- nomical practice and energy conservation considerations1l A r--/, # 13 Wastewater Storage and Return to Bull Canal • • • A 3, 300-acre-foot storage reservoir for effluent storage during the nonirrigation season ■ Irrigation pump station to return the stored effluent to the Bull • Canal for irrigation • These facilities are shown on Figure 10-1 along with the general alignments • • and locations of the various elements, as proposed in the predesign report. Figure 10-1 also shows how the City of Northglenn is totally surrounded by the Cities of Thornton (north, east and south) , Westminster (west) and Federal Heights (small section in southwest corner) . From this figure it is clear that the City is "landlocked by other incorporated communities" and that the ultimate population can therefore be determined with accuracy and certainty, as stated in the predesign report. Population projections were used in the predesign to size all required facility elements, and therefore the proposed system should be satisfactory for the foreseeable future, with the exception of equipment replacement and normal maintenance improvements. The proposed Northglenn concept has great merit and can conceivably be a one-time construc- tion program for the City that should serve the ultimate development level . However, Figures 4-4 and 7-1 in this Lower South Platte Facility Plan report shows Northglenn as a part of the Thornton service area (Service Area I) , and, in fact, the City of Northglenn contributes the majority of the popula- tion in that service area at this time. The Northglenn system, therefore, is in direct conflict with Alternative 14, which has been recommended in Chapter 8. The management plans basically have the same wastewater management concept, hut their facility configurations, service area boundaries, and institutional arrangements differ . The rest of this chapter compares the two plans and offers possible compromises for integrating the plans. Appendix O contains communications from the City of Northglenn concerning its proposed reus system in relation to the Lower South Platte Facility Plan. COMPARISON WITH ALTERNATIVE 14 l lie proposed facility locations and the exchange system for Alternative } • were shown on Figures 7-1 and 8-8, respectively. The wastewater facilities • for both Alternative 14 (from Figure 7-1 ) and the Northglenn system (from Figure 10-1 ) are located on Figure 10-2 to show where the configurations differ. As can be seen from Figure 10-2, the basic differences are as follows: • Different service areas, although they overlap o Different collection points and pump station locations • Different wastewater treatment facilities Alternative 14 provides wastewater management for a larger service area which could easily he adapted to include the additional Northglenn area proposed in the Northglenn plan. The proposed pump stations both have a high total dynamic head (TDII) to force the wastewater to the treatment locations. The Northglenn pump station is around 300 feet, and the pump station for Alternative 14 is approximately 500 feet . Both systems would therefore require special design considerations. 10- 3 • G,. I 1' ' I I I The exchange system arrangements are different for the two plans. The exchange ! i *,441. system in Alternative 14 is the Thornton reuse proposal discussed in Chapters 7 I rl and 8. Thornton already owns water for exchange purposes, while the City of I + V !'1 Northglenn must develop additional water supplies to augment the water lost ";l ° u,'` through consumptive loss plus the 10 percent supplement as already explained, On the other hand, Northglenn has already consumated a contract with FRICO !l for the loan and return of water, while Thornton has not. However, the if result of both exchange systems is that the wastewater essentially receives ! 17',"i4;„4; t advanced wastewater treatment prior to return to the river system. Both is systems effectively develop additional water supplies for domestic use without ., i '",. condemning agricultural waters, although it should be recognized that the '! r s;� , City of Northglenn is also developing new water for the area from deep wells, F Nil South Platte aquifers and urban runoff. Both systems provide for coo rative i 4 t arrangements between the rural and urban communities, thereby im oving the •Il ll ' 6' overall management for the waters of the State. \, i) r r ' POTENTIAL FACILITY LOCATION COMPROMISES 'e�, 1t \,,,t \ Ili tof To implement a reuse management plan for Service Area I, institutional issues .I5 r ,; regarding possible arrangements between the Cities of Thornton, Northglenri, i t 11 t Westminster, and Broomfield must be resolved . These issues are discussed in l li ::+k,. Chapter 11 but cannot be settled within the scope of this Facility Plan. 4 Final implementation arrangements must be agreed upon by the cities involved ;" 941 through actions by regulatory agencies such as the Colorado Water Quality ,,1! i +s Control Commission, the Environmental Protection Agency and the Denver Regional IIII z Council of Governments. This Facility Plan can only suggest possible compromise 'i It,. solutions for locating the physical components of a reuse plan for this f.tt northern area of the Lower South Platte Basin. :, s ti, The following compromise solutions identify possible facility locations and e �i service area designations. Because the Big Dry Creek Plant has already been ' joy 4r designated as a regional facility, it may be logical to maintain this plant I;',,;4 ;a� ' as the treatment facility for the northern areas. However, consideration of 4.14 alternate plant sites has been suggested by the City of Northglenn. An ti, ;I alternate location may not be feasible given the numerous factors involved in «M4 developing and constructing a plant, such as permits, land acquisition, site l;1 1 considerations and the time constraint of having the plant operational by �? M 1981 . The possible compromise solutions are as follows: {t x` 1 . Implement Alternative 14 but include the area of Northglenn outside ; the service area shown on Figure 7- 1 . Also, the wastewater flows from the Cities of Northglenn and Thornton could be monitored separately. This plan is shown on Figure 10-3. ',�',. � E t a 2 . Implement a modified Alternate"ve 14 where the Cities of Northglenn Lft a and Thornton are separated into two service areas with both dischar9 li' ,°t ing to the Big Dry Creek Plant, as shown on Figure 10-4. i I ! I„ . r 3. Implement Alternative 114 as described in the first compromise t solution above, but discharge the flows to a treatment facility at ;'ti some downstream location, as shown on Figure 10-5. ' . 1 10-4 , t Pic; w ` 1tliC"""' flk6f�'uyY4YflE'YiMKIVi:A'.+4w'1WMta`MA"fY++�xlnnys,Wt+r.' ✓ aW+o.0 34.MetlM .ufMYii.n..+4M✓ .. .. .........:..mv .. -. These three compromise solutions indicate the potential for combining the two conflicting reuse systems into one improved management plan. Furthermore, these solutions are not the only possible compromises. SUMMARY Alternative 14 and the Northglenn system are based on the same wastewater reuse concepts involving an exchange for agricultural water . However, their physical configurations and institutional arrangements differ, although potential compromises are possible and have been identified . At this time, it appears that Alternative 14 as presently conceived is a better plan for the following reasons: Alternative 14 provides a more uniform and orderly approach to wastewater management for the northern sections of the Denver metropolitan area . o Alternative 14 avoids the proliferation of treatment facilities. N Na The City of Thornton already owns a considerable amount of water than can he exchanged with any of the available irrigation ditches in the area . Development of new water supplies is therefore not a problem until late in the planning period . • The Northglenn water management program can be easily adapted to the physical system of Alternative Tfwhile at the same time preserv- ing the City's desire to own and operate its own utility system. • Alternative 14 eliminates four small pump stations throughout the service area and replaces them with a single, more efficient pump sta ion. Possible institutional arrangements for implementing these reuse management systems are discussed in the next chapter. It is anticipated that some type of a compromise will eventually emerge from all the review procedures and the outcome of the Big Dry Creek Facility Plan. 10-5 A. T7- AC , /„/ tA / , e...._ _ . . . • Conditions Monitored Closely clearly the absence of viruses in systems such as MSU's before biological recycling finds full acceptance by WQMP rctiearchen arc confident that they are gaining regulatory health agencies, sound data from their experiments because conditions in both the Iencstrial and aquatic systems are regularly Many Aspects Researched monitored. This capability was part of the original WQMP is more than a project to determine the most planning, which provided for 41 drift wells, 14 shallow immediately effective methods of recycling wastewater by rock wells and four deep rock wells strategically positioned biological processes. A thorough attempt is being made to -- throughout the study area and designed to guard against understand the total ecological impact For example, even 5 accidental contamination. before WQMP was built, the ground and surface water in Composite samples of the raw, primary and secondary the area was studied so that there would be a good data • plant are taken at the East Lansing sewage treatment hale with which to compare all subsequent findings. plant every day. Similarly, samplesare collected daily Similarly, the flora and fauna of the area were carefully limn the influent of each lake and the final effluent from catalogued and arc now regularly monitored so changes Lake Four. In addition, the wells and lake sediments and that take place as a result of biological recycling will be the aquatic plants are sampled periodically. More than 50 observed and recorded. chemical, physical and biological variables are monitored Of interest particular is the possible growth in numbers as these samples are analyzed. The ultimate outcome of of Aedes Icul a , the mosquito species that is the major this data collection program, which was devised by MSU carrier of California encephalitis. This species prefers to water chemist Dr. Frank M. D'Itri, is a comprehensive lay its eggs in stumps, holes along tree trunks and in view of the dynamics of both the aquatic and terrestrial various human artifacts that collect water—tin cans, tires, systems. Abnormalities trends in water or biological and so on. MSU entomologists are concerned that the quality can readily be noted. heavy spray irrigation at the site might provide a good ecological niche for the encephalitis carrier. They have nfo most controversial viral activity, the most important and evidence that another Michigan site for spray irrigation has aspect of water quality already experienced an increase in Aedes trisenatus. measurement, cannot yet be routinely testecLvvigi any Spray irrigation might also provide an optimal degree tofo accuracy. Many i s of viral co or sewage environment for midges. These arc small, mosquito-like in'a system r such as MSU's—and in other water or sewage insects that plague lakes and sewage lagoons in California quit . remain essentially unanswered because there am • much of the year hut have not been an important problem ='k �' no quick, standardized ire tests that would permit technicians in Michigan due to its cooler summers. However, because ' to detect viruses as readily as they now detect midges reproduce so well in shallow ponds, there is disease-causing bacteria. Viruses have been found not only concern that widespread adoption of biological recycling in sewage plant effluents but in chlorinated drinking water. Might lead to a great increase in the Michigan midge the problem is that, while it can sometimes be determined population. Entomologists are studying the potential that a virus is present, it is extremely difficult to he certain problem. The focus of study is not just on insects, but also that virus ie not present in any given water sample. So, on insect predators and other life forms, for example, the and even though conventional sewage treatment and water bird population. At any given time, 20 or more discrete • supplies are not ordinarily checked for vtrtses, public health authorities tend to be concerned that biological Crops nourished by wastewater spray irrigation are recycling night not eliminate all disease-causing viruses. 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Opponent' s presentation. 6. Applicant' s rebuttal. 7. Opponent' s rebuttal. 8. Discussion by Commissioners. Reasons for action. 9. Vote. The Board would like to lay a few ground rules which will hope- fully allow for an orderly hearing of this application for a Special Use Permit for wastewater treatment and storage facilities . The Colorado Supreme Court has ruled that individual land use decisions in Colorado are "quasi-judicial" , rather than legislative, proceedings. This means that the Commissioners are acting as impar- tial judges in hearing such matters. However, the process remains relatively informal. This is not a trial. Our duty as your Commis- sioners is to hold a hearing which is fundamentally fair to all sides of the issue, and then to decide the matter on the basis of the evi- dence presented to us at this hearing. We have endeavored to remain impartial in this matter, so that we can make a decision on the basis of the evidence. I would now ask the Commissioners to briefly disclose any con- flicts that they may have in relation to this case. Thank you. This hearing today is solely on the question of the issuance of a Special Use Permit. The Board of County Commissioners shall consider the following in making their determination in approving or denying a Special Use Permit: Compatibility w±.th the surrounding area, harmony with the character of the neighborhood and existing agricultural uses, need for the proposed use, its effect upon the immediate area, its effect on future development of the area and the health, safety and welfare of the inhabitants of the area and the County. Water augmentation plans are not relevant to this hearing. We ask that all persons testifying come to the microphone so that your statements will be on the record. We ask that persons in the audience please refrain from making comments during the proceedings . The order of business will be as follows : First, the appli- cant's representatives will present the applicant ' s case. The comments of the Planning Commission will then be read by the Planning staff. Next, the representatives for the opponents will present their position. -1- The applicant will have an opportunity for rebuttal. The opposition may then respond to the rebuttal. The Board of County Commissioners will reserve the right to ask questions of any witnesses or of the Planning staff and to refer to legal counsel. The Commissioners will then discuss the matter and take action. If there are no questions of objections, we will proceed on this basis . Is the City of Northglenn ready to proceed? -2- 5OO ' 1 '` � ' / ' V J 1 VVV ( { r� 5100� / 1 14 ,r ., 113 7/ i / 1 ^ 1 3/4 r____Nli I I 4v 2 /23 • / 2Y 4 • ..i. $ /i. SIYrwi V I -- 1? . w La i/ [W...e�.v) iMiw. 4/1" I � \ _ 27 255 II ll 6 So 34 9.3P r 35 _ 3 � 37$ 6 3 o ii AI Hello