(COMMENT: What did Pipedream have to say about the old vitrified clay pipes that deposit their sewage in old Manhole 13's chamber, as well as the old VCP pipes west of Manhole 13 into which it travels (and which William T. West testified were fixed with defective liner that reduced, instead of increased, the flow)? In my opinion, the computer should have come up with advice such as: Put this in your pipe and smoke it! WSP)

C. MODELING SPECIFICATIONS:

3. Modeling Criteria

b. Design Storm Event:"...Using a 60-minute storm event, five storm intensity levels were selected for further marginal cost analyses. They are 1-, 5-, 10-, 50- and 100-year storms.

"...The current (1994) SSO policy in EPA Region VI allows for a 5-year "level of protection", before an overflow is allowed. Most EPA regions have generally agreed that the concept of a "specified design storm event" is acceptable for sizing sanitary relief sewers.

"For example, a 5-year, 60-minute storm event represents a rainfall intensity of 2.2 inches/hour for the Springfield area... a storm event that has a 20% probability of occurring in any given year. Additionally, this represents a sewer system improvement project that would allow one overflow event to occur during a five year period. This date a (sic) taken from the rainfall intensity/duration curves, Technical Paper 40, as published by the Soil Conservation Service of the U. S. Department of Agriculture:

c. Pipe Roughness Coefficient

1. Deposition: Manhole inspections of the system in every basin indicated accumulation in pipe inverts.

2. Roots: ...root intrusion at leaking and open joints was common.

3. Offset Joints: For sewer systems older than 20 to 30 years, offset and separated joints were frequently observed... some offsets exceeding 25% of the diameter. ..."

e. Modeling Results

"... Results of the model indicates wide-spread relief sewer requirements in every basin..."

A. INTRODUCTION:

"...to meet the EPA requirements for reduced wet-weather overflows and bypasses, an evaluation of the costs associated with storage and secondary treatment was conducted... it was difficult to determine the actual peak projected flow rates at the City's two treatment facilities for specific rainfall criteria based on detailed flow information representing only 4.7% of the system.

"Rather, results of the five basins were used to "project" systemwide impacts of I/I reduction at the two facilities. To simplify the treatment analyses, we combined the facilities to develop a composite look at capability of the current facilities to manage and process peak wet- weather induced wastewater flows... We, therefore, recommend that 100% of the collection system be included ultimately in the survey."

(COMMENT: The recommendation was implemented; findings appear in the next section, Recross-Examination--Vl. WSP)

C. STORAGE/TREATMENT REGULATORY REQUIREMENTS

"Under Section 301 of the Clean Water Act, all cities and municipal authorities are prohibited from discharging untreated wastewater into the waters of the United States. Both controlled and uncontrolled discharges are prohibited, including those overflows and bypasses which are caused by excessive I/I due to high intensity, long duration storm events. In addition, federal regulations (40 CFR 122.41 <1> <6>) requires that all such discharge which may endanger health or the environment must be reported to EPA."

(COMMENT: I have reported the endangerment to health and the environment in the SASS area to the EPA, not as a representative of SASS but as a homeowner/member and, therefore, a private party. WSP)

A. METHODOLOGY AND CRITERIA

"... It is impossible for the City to remove all of the sources of I/I in the collection system. Likewise, it is cost-prohibitive for the City to add sufficient relief sewer, storage and treatment capacity to contain a significant rainfall event such as a 10-year storm..."

G. MARGINAL COST ANALYSIS

"...It was determined that a 1-year storm event would be used to identify the cost- effective level of I/I elimination. This would represent a storm event having a statistical probability of occurring at least one time each year...

"...Additional analysis was required to identify the design storm event that would provide the maximum benefit for the city...

"...the final recommendations will, if implemented, provide protection against surcharge for a 5-year, 60-minute storm event after 50% of the total I/I has been removed. This is consistent with the 5-year program being promulgated by EPA in the proposed Sanitary Sewer Overflow Policy."

(COMMENT: Is this a legal way a municipality is allowed to "cut corners" by doing minimum-quality repair work to satisfy a maximum-quality standard which has a built-in margin of expectation that a guaranteed percentage of failure will occur? In other words, what less-refined persons often call a "half-assed job"?

SASS members should discuss this question, because you and your family may be next to follow in my tracks. If the answer to my conjecture should prove to be yes, then many years and millions of dollars have been spent by the City of Springfield rehabilitating a sewer system that never will work right because it was not designed to function at maximum efficiency from the start.

If that is not a major boondoggle, as well as tragedy for those who are harmed, injured or killed by the fungus among us, I don't know what is! WSP)

In July, Springfield receives notice of pending $75 million federal lawsuit and negotiations to settle begin.