EPA 910/9-82-088
&ER&
United States
Environmental Protection
Agency
Water
Region 10
1200 6th Ave.
Seattle, WA 98101

January. 1982
EPA-10-1 D-Coeur d'Alene-Kootenai-WWTW-81
Environmental      Final
Impact Statement

Wastewater Treatment
Facilities for the City of
Coeur d'Alene, Idaho

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           U.S.  ENVIRONMENTAL  PROTECTION  AGENCY

                                 REGION  X

/>>  ^^  'T                    1200  SIXTH AVENUE

          |              SEATTLE, WASHINGTON 98101
                               February 12, 1982
  REPLY TO
      OF:   M/s  443
  TO:  All  Interested  Agencies,  Public  Groups and Citizens

  Enclosed  for your  review and comment  is  the Final  Environmental  Impact
  Statement (EIS)  for  wastewater treatment facilities for the City of
  Coeur d'Alene,  Idaho."

  This EIS  was prepared  in compliance with the National  Environmental
  Policy Act and  implementing Agency regulations  (40 CFR Part 6,
  November  6, 1979).   Availability  of the  EIS will  be announced in the
  Federal Register on  February 12,  1982, beginning  a 30-day comment period
  which will close on  March 15,  1982.   This agency  will  take no administra-
  tive action on  this  project until the close of  the comment period.

  We will appreciate your  review of this document and any comments you
  may have.  Please  send all comments to Norma Young, M/S 443 at  the
  above address.
                                               Chicago, !L  6060^-3590

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                FINAL
   ENVIRONMENTAL IMPACT STATEMENT

    CITY OF COEUR D'ALENE, IDAHO
     WASTEWATER FACILITIES PLAN
      EPA PROJECT NO. C-16-0300
            Prepared By:

U. S. Environmental Protection Agency
              Region 10
     Seattle, Washington  98101
   With Technical Assistance From:

   Jones & Stokes Associates, Inc.
            2321 P Street
    Sacramento, California  95816
                       Responsible Official:
                            R. Spencer
                       Regional Administrator

                         January 12, 1982	
                       Date


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                            PREFACE
      On  January  16,  1981,  the  U.  S.  Environmental  Protection
 Agency  (EPA)  released  for  public  review and  comment a  Draft
 Environmental Impact Statement (EIS) which evaluated the en-
 vironmental  impacts  of construction  of  the proposed improve-
 ments to the Coeur d'Alene sewage treatment  system.  EPA has
 prepared this Final  EIS to respond to the comments received
 and  to present EPA's recommended  action on the  City of
 Coeur d'Alene's  application for further grant assistance on
 the  project.

      Improvements to the City's wastewater treatment system
 are  needed to upgrade  effluent quality  and expand  service
 to City  residents and  to residents of adjacent  urbanizing
 unincorporated areas.   The wastewater facilities plan  for the
 upgrade  of the system  was  prepared by Brown  and Caldwell,
 with the assistance  of Meckel  Engineering and Surveying.  The
 Draft EIS was prepared concurrently with the City's  Facilities
 Plan in  order to avoid unnecessary delay.

      The Draft EIS evaluated four alternatives, the  "no  action"
 alternative  and  three  "build"  alternatives.  Early planning
 involved the  screening of  a large number of  alternatives.
 Among the alternatives considered was a regionalization  alter-
 native for joint treatment with the City of  Post Falls.   EPA
 requested that this  alternative be investigated because  of
 the  proximity of the two cities on the Spokane  River and  the
 timing of the planning efforts.   Extremely high interceptor
 costs were predicted,  however, and the  joint treatment alter-
 native was eliminated.  With the  aid of a local Citizens  Advisory
 Committee, three action  alternatives were selected  for detailed
 evaluation.   The "no action" alternative served as a baseline
 for  comparison but was not  acceptable because the  sewage  treat-
 ment  plant would continue  to suffer occasional  hydraulic  overloads
 and  violations of the  City's National Pollutant Discharge
 Elimination System permit  (NPDES)   suspended  solids  limits.
 The  three remaining action  alternatives evaluated were:   up_g_rade
 of the existing treatment plant (Alternative B); construction
 of a  new plant at a site downstream from the existing plant
 (Alternative  E);  and upgrade of the existing plant  (without
 expansion) and construction of a  second treatment facility
 1-2 miles north of the City  (Alternative G).

     The preferred alternative identified by the City and
 the Citizens Advisory Committee was Alternative E,  construction
of a new plant on a new downstream site.  This selection was
reported in the Draft EIS.   Although EPA agrees that Alternative E
would provide a number of beneficial impacts, it would  cost

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$3 million more to construct and operate a new plant than
to upgrade the existing facility.  Rehabilitation of equipment
at the present plant and expansion of plant capacity will
greatly improve effluent quality and will reduce potential
contamination of the Rathdrum Prairie aquifer.  In addition,
Alternative B is environmentally acceptable and the most cost-
effective alternative.  EPA does not consider that the benefits
of building a new plant are sufficient to warrant expenditure
of an additional $3 million to solve existing problems.  EPA,
therefore, recommends implementation of Alternative B and
has so indicated to the City.  With the prospect of a reduced
amount of available federal grant funds, the City and Citizens
Advisory Committee have agreed that upgrade of the existing
plant is acceptable, and the City has applied for funds to
design and build a new clarifier on the existing site.

     As discussed in the Draft EIS, the wastewater facilities
plan indicates that future development is planned on Blackwell
Island.  Growth is also projected in the general vicinity
of Nettleton Gulch.  Both of these areas lie in a designated
floodplain, and 15 acres of wetland are located on Blackwell
Island.  The wastewater facilities plan includes capacity
that could be utilized for developments on the Island.  While
EPA will not participate in financing the interceptor connection
to Blackwell Island, the award of funds would provide treatment
plant capacity for this development.

     EPA regulations implementing Section 201 of the Clean
Water Aci restrict federal grants where capacity would be
utilized for development of environmentally sensitive lands.
Inasmuch as sewage treatment capacity for eventual extension
of sewage service to Blackwell Island is included in the proposed
interceptor system, EPA will require the City to take action
as necessary to assure that no_wetlands^pr^flopdplains will
be impacted in violation of federal protection policies as
a result of expanding the City's wastewater treatment capacity.
This can be accomplished by assessing the extent of the environ-
mentally sensitive areas on Blackwell Island and by requiring
environmental assessments for any proposed developments that
would adversely affect these areas.  EPA grant awards for
design and construction of the wastewater facilities will
require the City's assurance that these areas will be afforded
proper consideration and/or protection.  The City, in fulfilling
this requirement, should coordinate its activities with the
U. S. Corps of Engineers, U. S. Fish and Wildlife, the Idaho
Department of Fish and Game, the Department of Health and Welfare
and EPA.

     A final decision on the award of a Clean Water Act Section
201 construction grant to the City of Coeur d'Alene for design
and construction of the selected alternative will not be made
by the EPA Regional Administrator until the close of the 30-day
comment period on this Final EIS.
                              11

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                      TABLE OF CONTENTS
PREFACE                                                   i

EXECUTIVE SUMMARY                                         1
     Project Need                                         1
     Project Funding                                      1
     Alternative Selected by the City of Coeur d'Alene    2
     Environmental Impacts of the Selected Alternative    7
     EPA1s Recommended Action                            11
     Coordination                                        11

CHAPTER 1 - LETTERS OF COMMENT ON THE DRAFT EIS AND
            EPA RESPONSES                                13

CHAPTER 2 - ORAL TESTIMONY ON THE DRAFT EIS AND EPA
            RESPONSES                                    37

BIBLIOGRAPHY                                             81

LIST OF REPORT PREPARERS                                 83

ACRONYMS AND ABBREVIATIONS                               85

APPENDICES
     Appendix A - Draft EIS Distribution List            87
     Appendix B - Cultural Resources Correspondence      91

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                      EXECUTIVE SUMMARY
 ( ) Draft Environmental Impact Statement
 (x) Final Environmental Impact Statement
    Type of Action:  Administrative


                        Project Need

     The City of Coeur d'Alene, Idaho wastewater treatment
system provides secondary treatment and discharge to the
SpoR'arie River.  The treatment plant is currently judged to
be at its effective capacity.  Occasional hydraulic overloading
and the deteriorated condition of some of the treatment units
have led to violations of the City's National Pollutant Dis-
charge Elimination System (NPDES)* permit effluent limitations.
This in turn has resulted in issuance of an EPA compliance
order and has stimulated the Coeur d'Alene City Council to
place a temporary moratorium on new sewer hookups, pending
improvements in the wastewater facilities.  In addition, pro-
posed new discharge requirements for Coeur d'Alene specify
an improved level of treatment to reduce discharge of pollutants
to the Spokane River.


                       Project Funding

     In order to improve its wastewater treatment capabilities,
Coeur d'Alene contracted with Brown and Caldwell of Seattle
and Meckel Engineering and Surveying of Coeur d'Alene to prepare
a Step I wastewater facilities plan.  The EPA administers
grant funds for such planning efforts under Section 201 of
the Federal Clean Water Act.  The planning, design and construc-
tion of facilities improvements can receive up to 75 percent
federal and 15 percent state funding.

     EPA issued a Step I planning grant of $158,088 to Coeur
d'Alene in May 1979.  Before additional funds for design and
construction of a selected project can be awarded, EPA is
required to complete an environmental review of potential
impacts of the project.  This review must meet the requirements
of the National Environmental Policy Act (NEPA).   In addition,
the Safe Drinking Water Act requires that federal agencies
ensure that any action taken does not lead directly or indirectly
to contamination that would create a significant health hazard
in a "sole source aquifer".

     To comply with these requirements, EPA has prepared a
Draft and this Final EIS to evaluate the consequences of the
* A list of acronyms and abbreviations is included on Page 85.
                               I

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construction of Coour d'Alcno's proposed long-term wastewater
treatment solution.  Prior to issuing this Final EIS, EPA
issued a Finding of No Significant Impact (FNSI) for Coeur
d'Alene's proposed interim facilities improvements.  Issuance
of the FNSI has allowed Coeur d'Alene to apply for fiscal
year 1981 grant funds prior to completion of this Final EIS
on the 20-year facility plan.

     The State of Idaho priority list for financial assistance
included $830,000 in fiscal year 1981 for Coeur d'Alene interim
project design and construction (Steps II and III).  It is
estimated that an additional $2,625,000 in federal and $525,000
in state funds will be sought by the City to complete the
first stage of its wastewater facilities project.  The availa-
bility of these funds is unknown,  as fiscal year 1982 grant
funds have not yet been determined.  The local share of Stage 1
funding is expected to be approximately $456,000 (expressed
in 1981 dollars [Brown and Caldwell 1981]).


      Alternative Selected by the City of Coeur d'Alene

     Coeur d'Alene has selected Alternative Bl as its preferred
option.  This includes a staged upgrading and expanding of
wastewater facilities at the existing treatment plant site
adjacent to the Spokane River.  It is a modification of the
Alternative B described in the Draft EIS.  Rather than expand-
ing the plant to the east, across the Burlington Northern
railway tracks, all new' facilities would be constructed on
the existing City wastewater treatment plant property.  This
revised Alternative B was developed subsequent to issuance
of the Draft EIS, in response to reduced levels of federal
and state funding and less stringent effluent quality require-
ments .

     The proposed project has been divided into two stages.
The first would enlarge and upgrade the facility to a 4.2
million gallons per day (mgd) capacity.  The second stage
would expand the plant to a 6.0 mgd capacity.  Because of
funding limitations, the first stage has now been broken into
two phases.  The first phase, entitled "Interim Improvements",
will increase plant capacity to 3.0 mgd.                      >.


Interim Improvements - Phase 1 of Stage 1                      \j

     The issuance of a FNSI by EPA will allow Coeur d'Alene
to use $830,000 in fiscal year 1981 grant funds to increase
its wastewater clarifier capacity.  This segment of the treatment
system is currently at capacity.  The interim improvements
will include construction of a secondary sedimentation tank
immediately north of the existing trickling filter at the

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Coeur d'Alene plant site.  New on-site piping will be added
to connect the clarifier with the outfall.  If sufficient
funds are available, the plant's chlorination equipment will
also be improved.  The clarifier capacity is needed to consis-
tently meet NPDES waste discharge limitations and allow a
lifting of the sewer system hookup ban.  Plant capacity will
be increased to 3.0 mgd.

     All wastewater will continue to receive biological
secondary treatment and will be discharged to the Spokane
River through the existing outfall.  Sludge will be disposed
of at the presently used location.

Phase 2 of Stage 1

     In the second phase of Stage 1, treatment capacity will
be expanded to 4_. 2 mgd.  This is expected to provide sufficient
capacity through 19^92.  Additional secondary sedimentation
capacity will be added and a variety of other on-site modifi-
cations are planned.  Dechlorination and phosphorus removal
capabilities will be added on the existing plant site.  When
the NPDES permit is rewritten for Coeur d'Alene it is antici-
pated" that eighty-five percent phosphorus removal will be required
on a seasonal basis (April 1 to October 31).  Dechlorination
will occur year round.  The existing trickling filter will
be improved by adding additional rock media; this will increase
waste oxidation capabilities without requiring additional space.
Figure 1 diagrams the preliminary site layout of Alternative Bl
and Table 1 includes the preliminary design criteria.

     The timing of second phase construction is unknown at
present, but if federal and state grant funds are made
available, design could start in 1982.  Total Stage 1 costs
are estimated at $4,090,000 (Brown and Caldwell 1981).
     In Stage 2, clarification capacity will again be increased
by adding a third secondary sedimentation tank.  The trickling
filter will be increased in height and converted to a synthetic
media filter tower to keep the plant's space requirements to a
minimum.  Chlorination and sludge digestion capabilities will
also be increased in Stage 2,. (See Table 1) .  No change in
sludge or wastewater disposal mode is expected.

     After all Stage 2 modifications are complete, the Coeur
d'Alene plant will have a 6.0 mgd capacity.  This is expected
to provide service to the City through the year 2002.  The
Stage 2 cost is estimated at  $6,129,000; the total project
cost is $10,689,000  (Brown and Caldwell 1981).

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CONSTRUCT 2-72'
DIAMETER
SECONDARY
SEDIMENTATION
TANKS WS 2137
INCREASE MEDIA
HEIGHT TO 8 5 FT
ADD 7 5 FT PLASTIC
MEDIA FUTURE
REHAB DIGESTER


DEMOLISH
2 DIGESTERS
FUTURE
  OUTFALL
                                                                  CHLORINE TANK
                                                                  CHLORINE
                                                                  OPERATIONS
                                                                  FUTURE 3rd
                                                                  SECONDARY
                                                                  SEDIMENTATION
                                                                  TANK
DISTRIBUTION.
SLUDGE PUMPING
                                                                  FUTURE TFSC
                                                                  CONTACT
                                                                  CHANNELS
FUTURE
SLUDGE
PUMP
STATION
                                                                  FUTURE TFSC PUMP
                                                                  AND RECIRCULATION
                                                                  STATION
FUTURE PRIMARY
SEDIMENTATION
TANK
DEMOLISH EXISTING
PREAERATION
.TANK FUTURE
                      NEW THICKENER
         SOURCE:  BROWN  &  CALDWELL,  1931
          FIGURE    1.    ALTERNATIVE
          B-1--SITE   LAYOUT

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        Table 1.  Recommended  Plan—Preliminary
                  Design  Criteria
Design basis
INFLUENT
Flow, mgd
BOD, mg/1
SS, mg/1
MECHANICALLY CLEANED BAR SCREEN
Velocity, ft/sec
GRIT REMOVAL TANKS
Detention time, min
Grit pumps
PRIMARY SEDIMENTATION TANKS
Overflow rate, gal/ft2/day ADWF
TRICKLING FILTER RECIRCULATION PUMPS
Number
TRICKLING FILTER CARBONACEOUS OXIDATION
Number ,
BOD/1,000 ft
Diameter, ft
Depth (ft) /media
SOLIDS CONTACT CHAMBER
Number
Detention time, min
SECONDARY CLARIFIERS
Number j
Overflow rate, gal/ft /day
CHLORINE CONTACT
Number
Detention time, hr
ANAEROBIC DIGESTERS (Alum sludge included)
Number ,
Loading, Ib VSS/1,000 ft /day
Hydraulic detention time, days
BELT FILTER PRESS
Number
Feed rate, gpm at 3 percent solids
First stage

4.2
215
215
1
1.8
1
20
1
1
950

2

1
35
165
7/rock

1
10

3
550

3
1

3
0.04
33

1
125
Second stage

6.0
215
215
1
1.8
1
20
1
1
780

2

1
20
165
18/synthetic

1
10

4
550

4
1

5
0.04
30

1
125
Source:  Brown and Caldwell 1981

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Sewer System Extensions

     The sewer system improvements and extensions described
in the facilities plan are to be implemented independently
of wastewater treatment facility improvements.  Brown and
Caldwell has divided the work into two groups:  near-term
projects and long-term projects.  The near-term projects
seek to connect existing urbanized areas relying on septic
tanks; this includes the high school and the county fairgrounds.
The long-term projects will be constructed as local growth
patterns require.  No specifc construction time frame has
been developed; Brown and Caldwell (1981) suggests that a
schedule for the near-term projects be developed by the Panhandle
Health District.

     The near-term collection system improvements are estimated
to cost $1,916,000; the long-term projects will cost a total
of $3,263,000  (Brown and Caldwell 1981).  These improvements
will be financed through formation of local utility improvement
districts.  The amount of federal and state grant support
available for interceptor construction is unknown.


Rationale for Selection of Alternative Bl

     Chapter 10 of the wastewater facilities plan (Brown
and Caldwell 1981)  presents an evaluation of the three primary
alternatives considered by the City of Coeur d'Alene.   Cost
criteria, performance criteria and environmental criteria
are discussed in this alternatives evaluation.  Alternative
B is described as the least costly and least energy intensive
of the three options.  Its total present worth cost is approx-
imately $3 million lower than Alternative E (relocation of the
plant downstream) and $4.3 million lower than Alternative G
(seasonal land disposal north of Coeur d'Alene).

     Of the two Alternative B sub-options identified in the
facilities plan, Alternative B2 has a lower capital cost -
$8.8 million compared to the $10.2 million of Alternative Bl.
In terms of operation and maintenance costs,  however,  Bl
is lower than B2 - $245,000 annually for secondary treatment
compared to $325,000 annually (Brown and Caldwell 1981).

     The remainder of the alternatives evaluation showed
Alternative Bl with favorable ratings for reliability,  and
protection of surface and groundwater, sensitive areas,  terres-
trial habitat, and recreational use.   It did not rank  as high
in terms of reclamation potential,  cultural resource and
air quality protection,  and aesthetics.

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     In the final facilities plan evaluation, Alternative E
was identified as the environmentally preferable alternative
because it would remove the treatment plant  from an urbanizing
area and provide room for future expansion.  Due to funding
limitations, however, Alternative Bl was selected as the
preferred alternative due to its low cost and its ability
to be staged.  The environmental benefits of E were not con-
sidered sufficient to warrant the extra cost.
      Environmental Impacts of the Selected Alternative
Impacts to the Spokane River

     Construction of wastewater facilities improvements under
Alternative Bl will eliminate the occasional discharge of
wastewater that fails to meet the effluent limits of Coeur
d'Alene's NPDES permit.  This will be accomplished by increasing
the amount of trickling filter media and the amount of clarifier
capacity at the plant.  As flows through the plant increase
from about 2 mgd to 6 mgd, however, the added biochemical
oxygen demand (BOD)  and ammonia loads entering the river
could aggravate the low dissolved oxygen (DO) conditions
that exist in summer months just upstream from Post Falls
Dam.  This may eventually lead to added treatment requirements,
but this is unknown at present.  The gradual increase in
waste nutrients added to the river  (nitrogen and phosphorus)
may also stimulate an increase in algal production below
the Coeur d'Alene outfall.

     Heavy metals and other toxins present in small concentra-
tions in the wastewater will be discharged in increasing amounts
as flows through the plant increase."  These constituents
may affect egg and larval stages of fish downstream from
the outfall.  Existing levels of zinc and copper in the Spokane
River"already exceed EPA recommended criteria for protection
of freshwater biota, but impacts on the local fishery are
undocumented.

     Persons drawing domestic water supplies from the Spokane
River downstream from the Coeur d'Alene outfall will face
an increasing health risk from the increasing waste discharges.
There are an estimated T64 residences being supplied drinking
water from the river in a 12-mile stretch below the Coeur
d'Alene outfall.   The NPDES permit disinfection requirements
and monitoring of effluent quality will help to reduce the
risk of contaminating the domestic water supplies.

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Impacts to the Rathdrum Prairie Aquifer

     The construction of added wastewater treatment capacity
will allow Coeur d'Alene to gradually hook up septic tanks
that are now contributing to Rathdrum Prairie Aquifer contami-
nations.  Over the 20-year planning period, 5,000 existing
residents are expected to be converted from septic tank use
to collection system hookups.  This is a major benefit of
the wastewater facilities proposal, as the Rathdrum Prairie
Aquifer has been designated a "sole source" aquifer under
the Federal Safe Drinking Water Act.

     The increasing waste flows accommodated by Alternative Bl
will in turn generate greater volumes of sewage sludge.  A
300 percent increase is anticipated by 1995.  This sludge
will be mechanically dewatered at the plant site and trucked
to the existing disposal site at the Coeur d'Alene landfill.
This disposal site is over the aquifer and therefore poses
a long-term threat to groundwater quality and public health.
Migration of leachate from the sludge disposal site is possible
due to the coarse nature of the substrate in the vicinity
of the landfill.  Sludge leachate characteristically contains
high levels of nitrates and also may contain significant
amounts of heavy metals.


Land Use Conflicts

     Expansion of wastewater facilities at the existing treatment
plant site will aggravate existing land use conflicts between
the treatment facilities and adjacent residential and institu-
tional uses.  Odor and aesthetic complaints are occasionally
voiced by North Idaho College and residents to the southeast
of the plant.  The college would like to expand to the north,
closer to the plant, and condominium and commercial development
is planned for vacant land north and east of the plant.  Therefore,
odor and aesthetic complaints are likely to increase as the
treatment facilities expand and urbanization of surrounding
land continues.
Impacts, on Archeological Resources

     The land adjacent to the Spokane River in the vicinity
of the proposed treatment plant expansion was once the site
of a major Coeur d'Alene Indian village.  While the exact
boundaries of the settlement are not known, the general area
has been designated Site 10-KA-48 in state archeological
site survey records.  An analysis of the Alternative Bl
expansion site conducted by the University of Idaho Laboratory
of Anthropology, however, concluded that no significant cultural
materials would be affected by plant construction.  (See
relevant correspondence in Appendix B.)

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Cost

     Alternative B was the lowest cost alternative  (other
than "no action") analyzed in the Coeur d'Alene facilities
plan.  The revised final analysis of Alternative Bl, contained
in Chapter 10 of the facilities plan  (Brown and Caldwell 1981),
lists the present worth of the project as $12,200,000.  This
does not include construction of interceptor extensions.  The
initial phase of construction is expected to cost $1,060,000
with $830,000 coming from federal grant funds.  The entire
first stage of the project, expanding the plant to  4.2 mgd,
will cost $4,560,000 with $456,000 coming from local funds
 (costs listed in 1981 dollars).  This assumes 75 percent federal
and 15 percent state grant support will be available for most
elements of the first stage  (Brown and Caldwell 1981).  These
costs are slightly higher than would be the case if Stage 1
could be constructed in a single phase.  Construction mobiliza-
tion and start-up inefficiencies make a two-phase Stage 1 more
costly.

     User fees within the Coeur d'Alene wastewater  service
area are expected to increase from approximately $4.50 per
month to $6.50 per month to finance the first stage  (4.2 mgd
facility) of the project (Brown and Caldwell 1981).

     Financing of interceptor extensions under Alternative Bi
will probably come primarily from local funds.  While EPA
rules allow for funding of some interceptors, they are currently
of a lower priority than treatment facilities.  The present
shortage of grant funds makes the EPA financing of interceptors
unlikely in the near future.   Near-term interceptor construction
is estimated to cost $1,900,000.  The long-term interceptor
projects will cost another $3,200,000 (Brown and Caldwell 1981).
These improvements will probably be financed through formation
of local utility improvement districts.  Persons served by
the interceptors will therefore pay for the service.


Major Growth Implications

     The additional wastewater capacity at the Coeur d'Alene
treatment plant will indirectly support the development of
an estimated 2,300 urban acres in the Coeur d'Alene area by
the year 2005.  If development proceeds as currently indicated
by the Coeur d'Alene general  plan,  this will include 440 acres
of prime agricultural land.   It is also expected to serve
development of Blackwell Island; this lowland area across
the river from the treatment  plant is within the designated
100-year floodplain of the Spokane River and contains natural
wetland areas.  It is also part of archeological Site 10-KA-48,
which may be eligible for inclusion on the National Register
of Historic Places.

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     The addition of 2,300 urban acres in the Coeur d'Alene
area will increase the amount of urban runoff percolating
into the surface over the Rathdrum Prairie Aquifer.  This
has the potential for affecting the quality of drinking water
supplies extracted from the aquifer in the area.


Impact Mitigation Measures

     Many of the impacts listed above will be reduced in severity
or eliminated if planned mitigation measures are implemented.
The surface water quality impacts associated with increasing
volumes of wastewater discharged to the river will be reduced
by the addition of phosphorus removal processes in the second
phase of project construction.  In addition, water quality
monitoring requirements of Coeur d'Alene's NPDES permit will
reduce the chance of undetected contamination of downstream
water supplies due to inadequate wastewater treatment *

     Mechanical dewatering of sludge at the treatment plant
site will reduce the chances that leachate from the sludge
drying beds near the Coeur d'Alene landfill will adversely
affect aquifer water quality.  EPA recommends that a regular
groundwater quality monitoring program be established at the
sludge disposal site if it continues as the principal sludge
drying area for Coeur d'Alene.

     Land use conflicts at the treatment plant site have been
reduced somewhat by modifying Alternative B so that only city-
owned property is needed for facilities expansion.   This will
avoid direct competition for sg>ace between different land
use proposals.  Aesthetics complaints could be reduced by
planting a vegetative buffer between the plant and adjacent
properties.

     Project cost impacts have been minimized by selecting
the least costly alternative.
                            10

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                  EPA's Recommended Action

     EPA concurs with the City of Coeur d'Alene that Alterna-
tive Bl is the preferred wastewater management plan.  It is
the most cost-effective alternative and is environmentally
acceptable.  EPA does not consider that the benefits of building
a new treatment plant (Alternative E)  are sufficient to warrant
expenditure of an additional $3 million to solve existing
water quality problems.

     In order to facilitate the earliest possible remedying
of discharge permit violations, EPA has issued a Finding of
No Significant Impact (FNSI) for the proposed interim project
improvements.  This has allowed EPA and the State of Idaho
to award $830,000 in assigned grant funds to Coeur d'Alene
to begin treatment plant improvements.  Before additional
grant awards for design and construction of facilities can
proceed, however, review of this Final EIS must be completed
and a Record of Decision must be issued.  In addition, further
action on grant requests are contingent on the City's efforts
to assure that extension of a wastewater interceptor to Blackwell
Island  (proposed in the facilities plan) will be assessed
and that the City will take action to assure that no wetlands
or floodplains will be impacted in violations of federal protection
policies as a result of this interceptor extension.


                        Coordination

     Since initiation of this EIS in June 1979, there has
been an EIS scoping meeting (June 4, 1979 in Coeur d'Alene)
and numerous meetings of the facilities plan Citizens Advisory
Committee, which EPA regularly attended.  In addition, there
has been frequent EPA contact with local and state agencies
and private citizens.  These efforts sought to identify environ-
mental issues related to the wastewater facilities plan and
to collect background environmental data for use in preparation
of the EIS.

     The Draft EIS was distributed for public review on
January 16, 1981.  A public hearing was held on the draft
document on February 18, 1981 in Coeur d'Alene, and the official
comment period extended to March 15, 1981.  All written and
oral comments received on the Draft EIS have been responded
to in this Final EIS.  Persons wishing to comment on the Final
EIS should submit their material to Ms. Norma Young, M/S 443,
U. S. Environmental Protection Agency, Region 10, 1200 Sixth Avenue
                              11

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Seattle, Washington, 98101 no later than March 15, 1982.
All comments received prior to that date will be considered
by EPA before action is taken on Clean Water Section 20JL_
requests from the City of Coeur d'Alene.  After close "of
the comment period, the EPA Regional Administrator will make
a final decision on funding of the proposed project in a
Record of Decision.  A list of persons receiving the Draft
EIS is included at the back of this Final EIS.
                              12

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                          Chapter 1
                  LETTERS OF COMMENT ON THE
                 DRAFT EIS AND EPA RESPONSES
                        Introduction

     The Coeur d'Alene facilities plan Draft EIS was available
for public review from January 16, 1981 to March 2, 1981.
During this 'period, EPA, Region 10 in Seattle, Washington
received nine letters of comment on the document (see listing
below).  The letters are presented on the following pages.
Each comment that has been marked and numbered in the left
hand margin has received a response, which can be found imme-
diately following the comment letter.


            Table 2.  Agencies Submitting Written
                  Comments on the Draft EIS
Federal Agencies

Advisory Council on Historic Preservation

U. S. Department of Agriculture, Soil Conservation Service-
  Boise Office

U. S. Department of the Army, Corps of Engineers-Seattle
  District Office

U. S. Department of Housing and Urban Development-Seattle
  Office

U. S. Department of Housing and Urban Development-Portland
  Office

U. S. Department of the Interior, Office of the Secretary-
  Pacific Northwest Region


State Agencies

Idaho Department of Fish and Game-Region 1

Idaho Department of Health and Welfare,  Division of Environment-
  Boise Office

Idaho Division of Economic and Community Affairs-Boise Office


                              13

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Advisory
Council On
Historic
Preservation
1522 K Street, NW                     Reply to:           Lake Plaza South, Suite 616
Washington. DC 20005                                   44 Union Boulevard
                                                   Lakewood, CO 80228


January  26, 1981

Ms. Norma  Young M/S 443
Environmental Evaluation Branch
U.S.  Environmental Protection Agency
1200  Sixth Avenue
Seattle, Washington  98101

Dear  Ms. Young:

The Council has reviewed your draft environmental impact statement  for Waste-
water Treatment Facilities for the City of Coeur d'Alene, Idaho, circulated
for comment pursuant to Section 102(2)(c) of the National Environmental Policy
Act.  We note that the undertaking may affect archeological properties which
the Idaho  State Historic Preservation Officer deems eligible for inclusion in
the National Register of Historic Places.  Circulation of a draft environmental
impact statement, however, does not fulfill your agency's responsibilities
under Section 106 of the National Historic Preservation Act of  1966 (16 U.S.C.
Sec.  470f, as amended, 90 Stat. 1320).

Prior to the approval of the expenditure of any Federal funds or prior to the
granting of any license, permit, or other approval for an undertaking, Federal
agencies must afford the Council an opportunity to comment on the effect of the
undertaking on properties included in or eligible for inclusion in  the National
Register of Historic Places in accordance with the Council's regulations, "Pro-
tection of Historic and Cultural Properties" (36 CFR Part 800). Until these
requirements are met, the Council considers the draft environmental statement
incomplete in its treatment of historical, archeological, architectural, and
cultural resources.  You should obtain the Council's substantive comments
through  the process outlined in 36 CFR Sec. 800.9 if an alternative is
chosen which will affect these archeological properties.  These comments
should then be incorporated into any subsequent documents prepared  to meet
requirements under the National Environmental Policy Act.  Brit Allan Storey
may be contacted at (303) 234-4946 for further assistance.
Sincerely,
o
Louis  S. Wall
Chief, Western Division
    of  Project Review
                                   14

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                Response to Comments From the
          Advisory Council on Historic Preservation

1.    The University of Idaho Laboratory of Anthropology has
     conducted a thorough investigation of the area that
     will be affected by Coeur d'Alene's proposed wastewater
     improvements (Alternative Bl)  and determined that no
     cultural resources on or eligible for inclusion on
     the National Register of Historic Places would be
     adversely affected by the project.   The Idaho State
     Historic Preservation Office has subsequently issued
     a letter indicating the planned improvements to the
     City's treatment facility will have no effect on sig-
     nificant archeological or historic properties.   Letters
     to this effect are included  in Appendix B.
                              15

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United States
Department of
Agriculture
                     Soil
                     Conservation
                     Service
Room 345
304 North  8th Street
Boise,  Idaho 83702
                                                March 3, 1981
Norma Young M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington  98101

Dear Ms. Young:

Thank you  for the opportunity to review  and comment on the  Draft Environmental
Impact  Statement for Wastewater Treatment  Facilities for  the  City of Coeur
d'Alene, Idaho.  There  are  no comments forthcoming from our office at this
time.
Si
Amos  I.  Garrison, Jr.
State  Conservationist
                                                                                   1981
                                                                      ENVHttftKNTM.
                                                                              BRANCH
 The Soil Conservation Service
 is an agency ol the
 Department ot Agriculture
                                          16
                                     SCS-AS-1
                                     10-79

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                        DEPARTMENT OF THE ARMY
                      SEATTLE  DISTRICT. CORPS OF  ENGINEERS
                                 P.O.  BOX C-3755
                           SEATTLE. WASHINGTON 98124
NPSEN-PL-ER                                                       6FEB1931
Ms. Norm Young  M/S 443
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington  98101
Dear Ms. Young:

We have reviewed the draft environmental impact statement for Wastewater
Treatment Facilities for the City of Coeur d'Alene, Idaho, with respect
to the U.S. Army Corps of Engineers' areas of responsibility for flood
control, navigation, and regulatory functions.  We have the following
comments:

    a.  Development in the flood plain should be avoided.  If there
is no practicable alternative, development should be constructed to
avoid serious damage or health hazards during a 100-year flood, as
stated, but should also be designed to avoid aggravation of flooding to
other property.

    b.  Page 23, line 2.  The sentence on Section 404 requirements
should read as follows:  A Section 404 permit would be required for
placing fill material in the river in conjunction with the pipeline
installation unless the work is authorized by a nationwide permit.  Any
other type of filling in the river or on adjacent wetlands would require
a Section 404 permit.

    c.  Tables and references to heavy metals should identify the
parameters as either dissolved or total concentrations; for example,
.245 mg/1 dissolved zinc or .245 mg/1 total zinc.

    d.  Page 53, first paragraph.  Zinc is identified as exceeding
Redbook and Fisheries Society criterion, although there appears to be
no detrimental impact to aquatic organisms.  This raises a question
regarding the applicability of the criterion to any and all ecosystems
and to its validity in general.  Because of this question, should zinc
be described as a metal of concern,  or treated according to existing
conditions?                                                     r=~
                                      17

-------
NPSEN-PL-ER
Ms. Norma Young
Thank you  for  the  opportunity to review this statement.   If  you have
any questions,  please  contact Dr. Steven F. Dice, telephone  (206)
764-3624,  of my staff.

                                         Sincerely,
                                                KNUTSON, P.L
                                         Ant Gaat, Engineering Division
                                       18

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                Response to Comments From the
                U. S. Army Corps of Engineers

1.   Before EPA will make grant awards for wastewater faci-
     lities construction in the 100-year floodplain of the
     Spokane River, the City of Coeur d'Alene must make
     written assurances that any new or renovated structures
     are either expendable (in cost-effective terms)  or are
     adequately protected by elevation, diking or similar
     physical means.  Any improvements over $10,000 in value
     must be covered by flood insurance both during and
     after construction.  This insurance must be acquired
     prior to issuance of a Step III grant.

2.   The Draft EIS should be revised to reflect this state-
     ment on Section 404 permit requirements of the Army
     Corps of Engineers.

3.   All heavy metals, including zinc, are reported as total
     concentrations.

4.   The apparent contradiction between productive fish
     populations and zinc concentrations which exceed water
     quality criteria can be explained by one of three
     factors or a combination thereof.  These factors are:
     1)  reported zinc concentrations are not in a form toxic
     to fish,  2)  indigenous fish species have adapted to
     high zinc levels, or 3)  laboratory tests used to develop
     water quality criteria are not applicable to field popu-
     lations.   EPA responds to the third assertion by stating
     that laboratory toxicity tests are useful predictors
     of what will happen in field situations (Federal Register
     45, 231,  November 28,  1980).   In what is probably the
     most extensive comparison available of laboratory and
     field data (Geckler et al.  1976) it was found that
     effects observed in laboratory exposures were also
     observed in field exposures.   However, avoidance,  which
     was not studied in laboratory exposures,  was observed
     in the field exposures.

     There is  some validty  to the first assertion that total
     zinc concentrations in the  Spokane River are not in
     a  form toxic to fish.   Zinc was reported as "total
     recoverable zinc" which, consists of both dissolved and
     suspended fractions.   As a  general rule,  if a substance
     is not dissolved, it is  not biologically or toxicologically
     available.   In many situations the dissolved fraction
     comprises the majority of the "total  recoverable zinc"
     measured.   USGS has recently begun to report zinc  con-
     centrations  in the Spokane  River as both total recover-
     able and  dissolved.  The dissolved fraction comprises
     anywhere  from 22 percent to 100 percent of  the total
     recoverable  zinc with  most  values exceeding 60 percent.


                              19

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The assertion that indigenous fish have acclimated to
existing conditions is in all likelihood valid.  However,
the apparent lack of reduced fish productivity is not
based on hard scientific data but more on general ob-
servations of fish catches and the absence of large
die-offs.  It is possible that subtle changes in be-
havior and physiology may be occurring but are going
undetected.

Bioassay studies on Spokane River fish are obviously
preferable to single factor criteria for all water
courses, but until such studies are conducted and resul-
tant criteria formulated, zinc should still be identified
as a metal of concern.
                         20

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                   DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                  REGIONAL OFFICE
                        ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
                               SEATTLE, WASHINGTON 98101
                                 January  28, 1981


REGION X                                                            IN REPLY REFER TO:

                                                                    IOC
       Ms.  Norma Young
       Environmental Evaluation Branch
       U.S.  Environmental Protection Agency
       1200 Sixth Avenue, M/S 443
       Seattle,  Washington  98101

       Dear Ms.  Young:

       Subject:   Draft Environmental Impact Statement
                 Wastewater Treatment Facilities for the
                 City of Coeur d'Alene, Idaho

       We have reviewed your statement submitted with  your  January 5, 1981
       letter.

       Since our Portland Area Office has jurisdiction over HUD programs in
       Idaho, they have also reviewed the statement and their comments are
       attached.

       We certainly support economic as well as physical  growth on a planned
       basis and that are consistent with locally developed comprehensive
       plans.  However,  we believe environmental impacts  including secondary
       impacts should be addressed at the time growth  inducing projects such
       as wastewater treatment plants or expansion of  such  plants  are proposed.
       We further believe that EPA by doing so would make the compliance of
       follow-up projects with environmental regulations much easier and
       make  for  implementation of better projects.

       We would  also like to add that we are supportive of  this project since
       we are fully aware of the importance of protecting the sole source
       aquifer.

       We thank  you for  the opportunity to comment on  your  statement.

       Sincerely,
              v$sj-"w|"l'<«3
      Gordon N. Johnston
      Regional Administrator                                     J^  c^

      Attachment                                              ...

                                    21
                                  AREA OFFICES
                Portland, Oregon • Seattle, Washington • Anchorage, Alaska • Boise, Idaho
                                   Insuring Office
                                 Spokane, Washington

-------
 Memorandum
  To
  From
                                          U.S. DEPARTMENT OF
                                    HOUSING AND URBAN DEVELOPMENT
                                                         January 22,  1981
Robert C.  Scalia,  Director, Regional Office of
                           Community Planning and Development
                                                          IOC
Attn:  Ry  Tanino,  Environmental Standard Officer

Clifford T.  Safranski, 10.2S
  Subject:  Review of the EPA-DEIS
           Waste Water Treatment Facilities for the
           City of Coeur d'Alene,  Idaho
 Page 101  GROWTH INDUCEMENT AND LAND USE IMPACTS

 Protection of Prime Farmland,  floodplain and wetland values,  aquifer  pro-
 tection from urban runoff  and  fiscal constraints including property tax
 limitations and archeological  concerns suggest more definitive plans  and/or
 agreements may be necessary.

 In addition, the induced growth impact on police and fire protection,  ex-
 pansion of schools, increased  streets, increased solid waste,  increased
 water supply and replacement of 36 miles of wooden pipes and  other  services
 and facilities are left for the locality to resolve.

 We would anticipate the generation of serious requests for HUD Community
 Development Block Grant funds, HUD/FHA mortgage insurance and  requests to
 other Federal agencies for assistance in addressing needs generated by the
 induced growth that would  be locally unmanageable without additional  funding.

 Under current and anticipated  budgetary constraints we are unable to  fund
 all the applicants with existing needs.  Additional needs generated would be
 added to the competitive rating system and, if funded, displace another
 applicant.

 The economics of scale may prohibit phasing of the sewage system from  the
 standpoint of construction and maybe even for operating costs.   However, if
 economics are achieved for one element at the expense of other elements,
 the cost effectiveness needs to be evaluated.
 Regional or shared systems  by localities within reasonable proximity has been
 a longtime goal and seems to offer more flexibility in timing  of  local
 impacts including dispersed costs.
                                            ll'i
                                                 OAS  -..   :/:
                                  22
PREVIOUS EDITION IS OBSOLETE
                                                                 HUD-96 (7-75)

-------
Although the DEIS suggests this was not considered popular and each locality
wants its own facility, a full exploration of cost-benefit and public explanation
of impacts may revive a regional system as an alternative worth considering.
Thank you for the opportunity to concient.
Environmental Clearance Officer
                                       23

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                Response to Comments From the
               U.  S.  Department of Housing and
                Urban Development - Portland

1.    Comments noted.

2.    The treatment plant expansion is currently planned to
     occur in several phases,  as described in the EXECUTIVE
     SUMMARY.  The cost-effectiveness of this phased approach
     has been thoroughly analyzed in the Coeur d'Alene Waste-
     water Facility Plan (Chapter 9)  published by Brown and
     Caldwell (1981)  in July 1981.

3.    EPA agrees that local  interest in regional solutions
     to wastewater treatment may increase in the future.
     The engineering and institutional analyses conducted
     by the Cities of Post  Falls and Coeur d'Alene,  however,
     indicated that a joint or regional solution was not
     desirable economically or politically at this time.
     The current funding situation has encouraged individual
     solutions for near-term wastewater facilities needs.
                              24

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United  States Department of

             OFFICE OF THE SECRETARY
               PACIFIC NORTHWEST REGION
    SOO N.E. Multnomah Street, Suite 1692, Portland, Oregon 97232
                Djjiisniw
the Interioi(f\S^^^^
ii»v                  i Co 2fi 1QDI
                                                                       26 1981
                                                     February  24,  1981
    ER 81/30

    Norma Young M/S 433
    Environmental Evaluation Branch
    U. S. Environmental Protection Agency
    1200 Sixth Avenue
    Seattle, Washington  98101

    Dear Ms. Young:

    The Department of the Interior has  reviewed  the  draft environmental state-
    ment for Wastewater Treatment Facilities  for the City of Coeur d'Alene,
    Idaho.  The following comments are  offered for your consideration in pre-
    paring the final statement.

    General Comments

I    Recreation

    Alternative G is preferred due to the finding of no significant increase
    in the discharge of pathogenic organisms  during  the heavy recreation use
    season.  Selection of Alternative G would not impact existing recreation
    activities such as swimming,  scuba  diving and water skiing.   Selection
    of Alternative A or E would  cause an  increase in fecal coliform counts
    and bacterial  counts,  especially during the  peak summer recreation season
    when the river is low and  less dilution is available.  Swimming and water
    skiing near the outfalls would be discouraged under Alternatives A and E
    and recreational use downstream would decline as  the water quality deterio-
    rates, as stated on page 47  of the  statement.

    Cultural  Resources

    In accordance  with the findings of  the archeological resources investi-
   gation,  conducted by Jones arid Stokes Associates, we prefer Alternative G.
   No evidence of significant cultural resources was found near the Alterna-
   tive G site or its associated  irrigation  sites.    It is stated on page 95
   that although  no mitigations  are currently anticipated for the Alterna-
   tive G site, any excavation or ground-disturbing activity could potentially
   reveal  significant archeological resources, and  if this occurs, excavation
   should cease until  a qualified archeologist is consulted.   We would  like to
   see this statement  strengthened by saying excavation would cease if cultural
   resources are discovered.   We were pleased to note that it has been recom-
                                 25

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2|mended that an archeologist be present during excavation of the interceptor
  I routes north of the city, to determine presence or absence of artifacts.

   Alternative B, extension of the present treatment plant, is not preferred,
   because it is within the heart of the most culturally sensitive area of the
   surrounding region (page 146-Appendix A).   The loss of this area could not
   be fully mitigated.  This is also true of site options 1 and 3 of Alterna-
   tive E, which seem to have extensive intact cultural  records.

   Concern has been expressed about the quality of the river and the Rathdrum
   Prairie aquifer and about eutrophication of Long Lake (page 24).  We sug-
   gest that treatment should be considered for abandoned onsite sewage sys-
   tems following completion of the proposed wastewater facilities.  Treat-
   ment would minimize any long-term contamination of ground- and surface-
   water resources that may result from the migration of toxic substances
   draining from improperly abandoned septic systems.

   Thank you for the opportunity to comment.

                                           Sincerely,
                                           Charles  S.  Politika
                                           Regional  Environmental  Officer
                                 26

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                Response to Comments From the
                U.  S.  Department of Interior,
                   Office of the Secretary

1.   Alternative G  would have fewer potential surface water
     quality impacts than B or E,  but it was determined
     that the added cost of Alternative G was not justified
     by the reduced impact.  Proper treatment and disinfection
     under Alternative Bl will protect the beneficial uses
     of the Spokane River.

2.   The City's preferred alternative, Alternative Bl, will
     not affect archeological resources at the Alternative G
     disposal sites.  EPA recommends, however, that similar
     steps be taken during construction at the Alternative Bl
     site if archeological materials are discovered during
     excavation.

3.   See the response  to the Advisory Council on  Historic  Pre-
     servation's letter for a description of a more recent
     archeological  analysis of the Alternative Bl construction
     site.

4.   EPA concurs that  all abandoned on-site waste disposal
     systems should be properly pumped out and treated
     This cleanup is the responsibility of the City of
     Coeur d'Alene.
                              27

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   g STATE  OF  IDAHO
     DEPARTMENT OF FISH AND GAME             REGION i
                                                             2320 GOVERNMENT WAY
                                                           COEUR d'ALENE, IDAHO 83814


                                                               February 24,  1981
Ms. Norma Young
Environmental  Evaluation  Branch
US Environmental  Protection Agency
1200 Sixth Avenue
Seattle, WA  98101
              Reference:  M/S 443  Draft EIS
                         Wastewater Treatment Facilities
                         City of Coeur d'Alene

Dear Ms.  Young

From the  standpoint of fish and wildlife resources, those alternatives  which
would relieve nutrient loading in the Spokane River would be preferable.   Of
those alternatives  considered Alternative G would have eliminated  for the  most
part, summer loading in the river and greatly enhanced salmonid habitat.

Alternative E would provide the benefit of relieving the upper reaches  of  the
Spokane River from  current and future effluent impacts.   This would  be
advantageous to cutthroat trout populations which seasonally use the upper
mile of the river.

Should Alternative  E become impractical from a standpoint of funding, our
department would encourage the most cost effective approach to future wastewater
treatment which would meet the projected water quality requirements  of  the US
Environmental Protection Agency and Idaho Division of Environment.   Should this
involve expansion or alteration and use of the current wastewater  treatment
plant, we would encourage a design which would facilitate future incorporation
of advanced treatment(s) which may become necessary.

                               Sincerely,
                               David S. Neider, Regional  Supervisor
                               Region 1
cc  Bureau of Fisheries
    Bureau of Program  Coordination                                " "   pgg  £6 1981
                                      28

                      EQUAL OPPORTUNITY EMPLOYER              ENVIFK

-------
            Response to Comments From the
          Idaho Department of Fish and Game

While Alternative G would have the greatest positive
impact on Spokane River fish and wildlife resources,
its high cost is not warranted by the environmental
benefits it would provide.  In order to reduce the
impact of the Alternative Bl waste discharge on the
Spokane River, it is expected that when the City's NPDES
permit is rewritten seasonal removal of phosphorus and
year-round dechlorination of effluent will be required.
While these advanced treatment processes are not to be
part of the initial wastewater system improvements,
they are to be added as soon as funding becomes availa-
ble.
                          29

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John V. Evans, Governor                     TFZSimi!$V                        State CaPito1 BuildinS
Daniel T. Emborg, Administrator                x^gplfx                           Boise, Idaho  83720

	DIVISION OF ECONOMIC AND COMMUNITY AFFAIRS	
                                    February 9,  1981
         Donald P.  Dubois
         Environmental  Protection Agency
         1200 Sixth Avenue
         Seattle, Washington  98101

         Dear Mr. Dubois:

         The Idaho State Clearinghouse has  completed its  review of  the  Draft
         Environmental  Impact Statement WASTEWATER TREATMENT FACILITIES FOR
         THE CITY OF COEUR D'ALENE - SAI #00115340.   The  following  agencies
         were contacted for their review and comment:

         Panhandle Area Council
         Department of Health and Welfare/Division of Environment
         Department of Transportation/Division  of Highways
         Idaho Historical Society
         Department of Fish and  Game

         The Department of Health and Welfare/Division of Environment stated
         comments will  be made to EPA through  their normal  channels.   A copy
         of their comments  is attached for your perusal.   Comments were not
         received from the other reviewing  agencies.   Any late  comments received,
         will be forwarded to your office.

         Thank you for the opportunity to assist you in the review  of your Draft
         Environmental  Statement.  Please send  us a copy  of your Final  Environmental
         Impact Statement when it is completed.   If you have any questions,  please
         do not hesitate to call either myself  or Lois Wade at  308-334-4718.

                                            Sincerely,
                                               to
                                            Gloria   Mabbutt,  Coordinator
                                            Idaho State  Clearinghouse
         GM/lw

         enclosure
                                             30                      EN*	^MKH
                                      A Land For All Seasons

-------
  STATE  OF   II
DEPARTMENT OF  HEALTH
AND WELFARE
                                     DIVISION OF ENVIRONMENT
                                            Statehouse
                                          Boise, Idaho 83720
                                 March 20, 1981
Ms. Norma Young
Environmental Evaluation Branch
U. S. EPA
Region X - M/S 443
1200 Sixth Avenue
Seattle, Washington  98101

Dear Ms. Young:

The Division of Environment,  Idaho  Department of Health
and Welfare, has reviewed the draft EIS  Waste-water Treat-
ment Facilities For The  City  of Coeur  d' Alene3 Idaho and
wishes to submit the following comments:

1)
                                                      MAR 23 1981
                                                                   01
                                                   ENVIRONMENTAL EVALUATION
                                                         BRANCH
 2)
 3)
Pg. xiv, 1st paragraph - EPA only offers
funding options.  It is ultimately the"Grantee'ft
decision to implement a project.

Pg. xiv, 3rd paragraph - The EIS  lists impractical
rehabilitation of equipment at the present treatment
site as one reason the Citizen's  Advisory Committee
preferred Alternative E.   This is not entirely correct.
If rehabilitation were impractical,  Alternative B would
not have been the least cost alternative.

Pg. 14, Probable Effluent Limitations - The heading
and wording of this should be rewritten.   Effluent
limits are currently available and have been since
February, 1980.   The heading for  this section should
merely be Effluent Limits, and should point out the
following:

  Before Coeur d1  Alene began facilities  planning,
  when initial limitations were being developed,
  EPA conducted its own studies on the Spokane
  River and developed a model to  evaluate  the im-
  pact of the Coeur d'  Alene and  possible  Post
  Falls discharges.   In February,  1980 after  the
  facility planning had started,  the  final  effluent
  limitations were given to Coeur  d1  Alene  based on
  the EPA studies.
                            31
                EQUAL OPPORTUNITY EMPLOYER

-------
Ms.  Norma Young
March 20, 1981
Page 2


       At the time the facilities planning began the State
       of Washington was required to conduct a waste load
       allocation study on the Spokane River.  As a spin
       off of their study, Idaho was offered a small 208
       Grant to supplement the Washington study and to
       provide additional information to enhance the EPA
       model.  Possible modifications in the EPA model may
       allow a relaxation in the present effluent limitations.

4)   Pg. 14, Effluent Limitations - Alternative G (Land
     Application)may not be required to achieve 30-30.
     The land is serving as partial treatment.

5)   Pg. 17, Action Proposed by the City of Coeur d' Alene -

     The statement that Alternative G was rejected because
     of the risk of contaminating the Rathdrum Prairie Aquifer
     (Thompson pers. comm.) may not be entirely correct.  The
     Citizen's Advisory Committee, at the direction of Bruce
     Thompson, requested effluent limits of EPA for land
     application over the aquifer.  EPA (Bob Burd^  Wbs not the
     appropriate agency to produce these limits, as they weie
     being developed by our department at the time in accordance
     with Idaho Water Quality Standards & Wastewater Treatment
     Requirements.  Bob Burd did, however, respond to Mr.
     Thompson and detailed all possible protection measures
     that may be required of a sole source aquifer.   EPA could
     not give definite parameters since the sole source regu-
     lations have not been finalized.

     The vague requirements detailed by EPA in their August
     6, 1980 letter to Bruce Thompson (Committee Coordinator)
     suggested to the Advisory Committee many uncertainties
     as to future regulations and requirements that may be
     attached to their land application site.  This, rather
     than fear of contaminating the aquifer, steered the
     Committee away from Alternative G.

6)   Pg. 24, Existing Water Quality - The following sentence
     needs to be clarified:"Available records indicate that
     water quality in the Spokane River between Coeur d1 Alene
     and Post Falls (Table 2 - 1) is satisfactory although
     several parameters are not in compliance with proposed
     draft EPA water quality criteria (Federal Register)."
                           32

-------
 Ms. Norma Young
 March 20, 1981
 Page 3
 7)
 8)
 9)
10)
Pg. 58, Character of the Aquifer - States:  "The present
water quality of the aquifer is described as good, with
a very small percentage of water samples showing contam-
inants in excess of the maximum contaminant levels."
The EIS should continue here to detail what MCL's have
been exceeded and at what location in the aquifer.

Pg. 62, Resultant Regulatory Controls - 3rd paragraph -
The Spokane Valley/Rathdrum Prairie Aquifer is classified
as a Special Resource Water.  The State Water Quality
Standards no longer have an antidegradation policy.  The
present Water Quality Standards state:

  The waters of the Spokane Valley/Rathdrum Prairie
  Aquifer, as described by the U. S. Environmental
  Protection Agency in its designation as a "sole source"
  aquifer under Section 1424(e) of the Safe Drinking
  Water Act, must not be lowered in quality,as relates
  to appropriate beneficial uses, as a result of a point
  source or non-point source activity unless it is demon-
  strated by the person proposing the aciivixy r.hat such
  change is justifiable as a result of necessary economic
  or social development.

Pg. 75, EPA Mitigation Strategy - The guidance summarized
under this section was only first cut recommendations by
EPA, i.e. a place to begin negotiations.  IDHW has since,
in conjunction with EPA, significantly reduced and refined
specific requirements for land application over the Spokane
Valley/Rathdrum Prairie Aquifer.

Pg. 101, 1st paragraph - The State will not allocate
projected population increases to specific areas of the
county.  This should ultimately come out of the 208 Study
or through county allocations.   These projections cannot,
however, exceed State projections for total populations
in unincorporated areas.  The final numbers should pro-
bably be a result of coordination between IDHW, 208, and
the county.
                             33

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 Ms.  Norma Young
 March 20, 1981
 Page 4
11)
12)
Pg. 109, paragraph 3 - States:  "The City of Coeur d' Alene
should conduct an environmental assessment of prime
agricultural land losses prior to constructing new waste-
water interceptors into the prime farm land areas."
Since portions of these interceptors are allowable under
this project, why does this EIS not cover the environ-
mental effects of prime agricultural land losses?

Pg. Ill, 1st paragraph - IDHW-DOE should be consulted in
the environmental assessment of the Blackwell Island
Development.
 Thank you for the opportunity to comment on this Environmental
 Impact Statement.
                            Since,
                           'Lee W.  Stokes,  Ph.D.
                            Administrator
 LWS/WH/b
                            34

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                Response to Comments From the
           Idaho Department of Health and Welfare

1.   This is correct; EPA only offers grant funds to local
     jurisdictions.   It is the local jurisdiction's option
     whether or not to accept the funds under specified
     conditions.

2.   The reasons for preferring Alternative E that are listed
     on page xiv are those of the Advisory Committee and
     the City,  not EPA.  The validity of these reasons was
     not assessed in the EIS.

3.   The Draft  EIS should be revised to reflect the suggested
     rewording  of the section on Effluent Limits.

4.   Comment noted.   Alternative G is no longer being con-
     sidered by the City of Coeur d'Alene.

5.   The threat of aquifer contamination was stated by
     Mr. Thompson as a concern of the Citizen's Advisory
     Committee.  While the uncertainty of future regulatory
     requirements was also undoubtedly a factor in the
     decision to pursue Alternatives B and E rather than
     Alternative G,  aquifer contamination was considered
     a significant issue by the Advisory Commit Lee^

6.   Surface water quality data reported for the Spokane
     River near Coeur d'Alene show levels of zinc and copper
     that exceed EPA recommended criteria for the protection
     of freshwater biota.  These criteria were reported in
     the Federal Register on November 11, 1980 (Federal
     Register 45 [231]  FR 79318-79323; Section 307 [a]  [i]).
     While the  heavy metals levels exceed criteria for pro-
     tection of freshwater biota, the river water quality
     does not currently pose a threat to human health.

7.   National Interim Primary Drinking Water Regulation
     MCLs have  been exceeded for nitrate, arsenic, lead,
     chromium,  mercury, turbidity and microbiological agents
     (coliform  bacteria)  in the Spokane, Washington area.
     Nitrates have also exceeded MCLs near Dalton Gardens
     and Rathdrum, Idaho.  High levels, however,  were reported
     in a very  small percentage of the water samples analyzed
     (Esvelt 1978; Drost and Seitz 1978).  Groundwater from
     the urban-industrial portions of central Spokane Valley
     contained  the majority of the high readings.

8.   Comment noted.
                              35

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9.   The mitigations suggested on pages 75 and 76 of the
     Draft EIS were identified as preliminary guidance; more
     formal requirements were being developed by EPA and
     the State of Idaho.

10.   EPA agrees that allocation of unincorporated area
     populations in Kootenai County should be a combined
     effort of IDHW, the county and 208 plan staff.

11.   The Draft EIS identified the potential for prime
     agricultural land losses due to planned urbanization.
     The suggestion that the City conduct environmental
     assessments of interceptors prior to their construc-
     tion was based on the fact that the timing of their
     construction and the sources of funding were not known
     at that time.  As these interceptors are further plan-
     ned, the City should investigate ways to avoid  urbaniza-
     tion of prime farmland if at all possible.

12.   EPA concurs that the IDHW should be consulted in any
     environmental assessment of the Blackwell Island
     development.
                              36

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                          Chapter 2


      ORAL TESTIMONY ON THE DRAFT EIS AND EPA RESPONSES


                        Introduction

     A public hearing on the Coeur d'Alene Facilities Plan
Draft EIS was held in Coeur d'Alene, Idaho on February 18,
1981.  The following pages contain the transcript of the
oral testimony presented at that hearing.  Each comment re-
quiring a response has been identified by a line and a number
in the left-hand margin of the transcript.  Following the
transcript, each comment has been responded to in numerical
order.  If the comment has been responded to in the text
of an earlier chapter, the reader is referred to that chapter.
                             37

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                   U.S. ENVIRONMENTAL PROTECTION AGENCY
U)
00
                             PUBLIC HEARING
                Re:  Draft Environmental  Impact Statement
                                    Taken at:  Coeur d'Alene, Idaho
                                    Date Reported:  February 18, 1981
                                                    HESTON and HOWELL
                                                    REPORTING SERVICF
                                                          Irl l?ll«| IV, I Ml
       A Public Hearing was  held  in the matter of thf> Draft

 Environmental Impact  Statement  for Wastewater Treatment

 Facilities for the City of  Coeur d'Alene,  Idaho, before

 Charlotte R. Crouch,  a Notary Public,  at the Coeur d'Alene

 City Council Chambers, Coeur d 'Alene,.Idaho, at the hour of

 7:30 p.m., February 18, 1981.

       Appearances were:

       Mr. Roger Mochnick, Hearing Officer,  EIS Preparation

 Coordinator, Environmental  Evaluation  Branch, Seattle,

 Washington.

       Mrs. Norma Young, Project  Monitor, U.S. F.nvironnent-al

 Protection Agency, Region 10, 1200 Sixth Avenue, Seattle,

j Washington, 98101.

       Mr. Richard C.  Bain,  Jr.,  Vice President of Brown (.

 Caldwell, Consulting  Engineers,  100 West Harrison Street,

 Seattle, Washington,  98119.

       Mr. Michael D.  Rushton, Jones s  Stokes Associates, Inc.,

 105 South Main Street, Suite 203,  Seattle,  Washington, 9810-5.

       The Public Hearing was reported  in stenograph by the

 Notary Public, Charlotte R. Crouch, of the  firm of Heston 4

 Howell Reporting Service, 816 Sherman  Avenue, Coeur d'Alene,

 Idaho, 83814, and by  her later transcribed.

       WHEREUPON, the  following proceedings  were had and

 testimony given, to-wit:
                                                                                                                           -  2  -
                                               HESTON and Hi1' riL
                                               RIPORTING SfRVItT
                                                r. M!t,l St rt''lll,t I't,. ' r
                                                h * A"i ill I, ' fM Ml. ! HI

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                          INDEX




                                                    PAGE


 ri":sr::TATJOt;s BY:


       ROCFR MOCHNICK	4


       PICHARD BAIN, JR	  9


       MICHAEL RUSHTON  	 15


       RAY  KOEP	21


       EARL A. FERRIF.R	24
I

       BARRY G.  SCHULER	26


 QUESTION AND ANSWER SESSION  	 29
                              - 3 -
HESTQN and HOWELL
REPORTING SERVICE
 OHififfl <",fni'1hin(l linpnili"^
 lr»iMw M [70»| '« 1311
CmiuilAlcnt W (7"8I 6r,7 8214
      MR. MOCHNICK:   My  name is Roger Mochnick, and I am with  j

the Environmental  Protection Agency in Seattle, Wnshinaton.    ]

Mr. Donald Dubois, our Regional Administrator/ has delegated

me to be your Hearing Officer for tonight's proceedings.   We

appreciate your  attendance tonight, and we are glad that you

are here to discuss  the  many issues associated with the City

of Coeur d'Alene Wastewater Treatment Works Project.

         For purposes of the hearing record,  I would like  to

note that this public hearing was convened at 7:36 p.m.,

February 18th, 1981  in the City Council Chamber of the  City of ;

Coeur d'Alene, Idaho.                                          j

         As Hearing  Officer, I would like to  take a few

minutes  to tell  you  the  purpose of tonight's  hearing,

describe the hearing agenda, which will lead  to orderly

presentations by each of us here. Even though this  is an

informal public  hearing, I would also like to pass along  a

few rules of procedure which will assist us in making  sure

that everyone  has  the opportunity to participate  in  the

discussion.  Our primary purpose tonight is to provide  the

opportunity  for  local citizens to comment on  the  recently

published documents, the City  of Coeur d'Alene's  Draft

Facilities  Plan  for  Wastewater Treatment Facilities,  and  EPA's

(Draft  Environmental   Impact  Statement.

         The City has applied  to the Environmental  Protection

[Agency for  grant assistance  in accordance with  Section 201 of


                                               HESTCH and HH»ELL
                               ,                 REPORTING  5CRVICF
                             ~                   r,iil,.i 'I -I".'!'' r-n 'i'""
                                                 I,,.i • ., M i IIBI Mi, ! Ill

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the Clran Water Act for purposes of upgrading the City's


sowaqe treatment facilities.  Wastewater treatment improve-


ments are needed for the City to comply with its National


Pollution Discharge Elimination System Permit for affluent


requirement;;.   EPA has previously awarded to the City a Step


1 Planning Grant to develop the facilities plan, which

                                                    *
outlines a number of alternatives for improving the affluent


quality and for expanding service to City residents,  and


residentr, of the adjacent urbanizing areas.


      The Draft Environmental  Impact Statement has been


prepared by EPA.  It consists of a»t eo^tjual-iBa'iion. of each of


the alternatives identified in the City's facilities  plan.


Thr TIS has been prepared pursuant to the National Environment


al Policy Act.  The EPA is required to prepare such statements


on major Federal actions which could have a significant impact


on the quality of the environment.  The Federal action in this


case would be an EPA grant to the City of Coeur d'Alene, which


along with the State of Idaho grant funds would assist the


City in Step 2:  designing the selected facility; and Step 3:


actually constructing the selected facility.  However, before


any decision can be made regarding the award of additional


qrant funds for this project, the EIS process must be


completed.  The remaining steps in the process include receipt


and review of public comments on the Draft Facility Plan and


FIS, both at this public hearing and through written
                           - 5 -
MESTON and H DWELL

REPORTING SCRVICE
                                    IK
 submissions.  Preparation of a final Environmental  Impact      j


 Statement and receipt of comments during a 30-day review


 period following publication of that EIS.


          For those of you who need a detailed account of the


 EIS process, it is sometimes complex and I will be  hero and


 be more than willing to discuss it with you later this evening.


          Again, let me emphasize that the purpose of tonight's,


 hearing is to receive oral comments on the Citj's facility     :


 plans and EPA's EIS.  We are not qoing to try to limit th<5


 scope of your inquiries or your input, but I hope that each


 of you in your comments and statements will keep our purpose


 in mind.
                                                                i

          Those wishing to testifying at this public hearing
                                                                i
j have been sncouraqed to review the draft documents.  ns has   I
\                                                                \
 been on file at the Coeur d'Alene Public Library since


1 January 1981.  Copies were also mailed to State and local


,officials,  and to  numerous  citizens of the area.   Persons


 unable to testify at tonight's hearing or wish to  furnish      l


 cowments after the hearing may do so by writing Korma Young at


 EPA's Regional Headquarters, 1200 Sixth Avenue, Seattle,


;Washington 98101.   The close of comment period is  March 2nd of


 1981.  Norma Young is the Project Monitor on this  FIS for the


 EPA.   She is sitting on my far left.  If you need  that address,


 we will be glad to give it to you a little later on.


          I would also like to make mention now at this time    I
                                                                                                                - 6 -
                                              HCS1 ON and H'HELL

                                              RFPPIU ING  51 ('VICE

-------
                      	"    "          "        " ~  "    ""  "1

! that all questions  from  the  floor are  to be held until the


 third stage of  this hearing.  A question and answer period

 will be held  after  all  interested parties have had the


 opportunity to  present  oral  comments.  And given the amount of

 people we have  so far who  have signed  up to make presentation

 we  should have  sufficient  time to answer all your questions.

          I'd  like to next  give you  the agenda for this hearing


 and  introduce the two other  people  sitting with me.  On my
                               ?»vtM«sV-
 right  is Mr.  Richard Bain  from Caldwell  Consulting Engineers.


 Mr.  Bain will give  a brief presentation  on the various
                                                                I
 alternatives  and costs  which are  included  in the facility's

 plan.   Brown  and Caldwell  are consultants  to the City who


 prepared the  facility's plan.

          On my  left is  Mr. Michael  Rushton of Jones  and  Stokes

 Associates.   Mr.  Rushton will give  a brief presentation  out-


 lining  the  more significant  environmental  impact associated

 with the  alternatives.   Jones and Stokes are  the consultants


 who assisted  EPA in the preparation of the EIS.


           After these two short presentations, we will  receive

 oral comments on the project and documents.   I  will  call on

  the individuals in the order that I have received their cards.


  Following the presentation of testimony, we  will  begin the


  question and answer period.   I am aware that there are recent


 i developments of important issues associated with this project,

  and I am sure you will want  to discuss them.   Please hold
                             - 7 -
HESTON and HOWELL

REROUTING SERVICE
 frrlilii'il U-ilHn'1 Rr-iiruWi
 l»(H'lnn Id (?'im 1W, 1HI
(will il/Uiw I.I (?'!«) OB) MM
                                    10


                                    11


                                    12


                                    n
those questions until the latter stage of this hearing.        !

Questions may be asked of Mr. Bain or Mr. Rushton  through  me.

As Hearing Officer, I reserve the right  to  limit questioning,


call recesses, adjourn, and reconvene the meeting.   I  am going


to ask that presentations be limited to  ten to fifteen minutes.

Written material should be left with me  following  your        '


presentation or sent to Mrs. Young at EPA's Regional Office   '


in Seattle for inclusion  in the record.  You are under no

obligation to submit written material.   A written  account      '

would help us consider your statement more  fully and keep  our

record in order.   Written comments received on or  before  the
                                                               i
close of comment period on March  2nd will be responded to  in


the  final EIS.

         A record  of the  hearing  is being made by  the  court


reporter, therefore, I ask  that when you speak,  you speak


clearly, state your  name, address, and  affiliation, if any.

Also, it will be helpful  if you would come  forward so  that

the  audience  may hear  your  comments  and you will  be more


easily picked up by  the  court  reporter  and  I think this would

be the podium right  here, if you  would.

         Copies of this  transcript will be made available for


your inspection at the EPA's office,  of course,  in Seattle,

but  also  the  City  library and  the offices of the City here in


Coeur d'Alene.

         Are  there any questions  as  to  the procedures  that we
                                                                                                                   - 8 -
                                               HESTOH and HOWELL

                                               REPORTINIi SERVICE

-------
j are following tonight?

           {NO RESPONSE.)

,          Okay, Dick Bain.

       MR. BAIK:   I'll briefly outline  the  facility planning

 work that was done last year, and  then try to bring you up to

 date a little bit on where we are,  given the funding situation!

 that all of you are aware of.   This  is the facility plan

 document in draft form that was  submitted  to the City last     !
                                                                I
 November.  I'd like to briefly  go over all the alternatives    '

 described in that, and some of  the  assumptions used at that    \

 time,  and discuss briefly those  costs  that we had developed    |

 at that time, and then switch to the present situation in order

 to bring you up to date on the  situations  that relate to

 funding and options that might  now  be  available to the City,

 given the reduced funding that's been  announced.               j

          This map here, which you can  look at at your leisure  j

 after the meeting, but I think  most of us will recognize that  ]

 this is the City of Coeur d'Alene planning area of the City    !
                                                                i
 rioht here, and the Spokane River  flowing here  (indicating).

 In developing the facility plan, we  first had to become

 acquainted with the existing facility,  which is located in

 this area near the Fort Grounds.   It's currently a secondary

 treatment plant which is processing  approximately two million

 gallons of water each day during the peak  summer months.  The

 flows in the wintertime do get  higher  than this flow because
                                               HFSTON 3i"i HOWCI.L
                                               REPORTING  SERVICE
                                                f,,!,!,,'!.,,,,,,, ,„„,;,,,„>,,
                                                ir.,,, i™. in ('"U! MI, mi
 of the direct inflow connections  from  rain water  in City

 streets and off roof tops.

          As we looked at alternatives, we had  to  first

 consider the population of the area and what forcasted growth '

 we could see in a 20-year period  beginning in  about 1985

 through to the year 2005.  Vie translated these projections  to

 flows, and we're dealing with approximately six million gallons

i in the year 2005 for our sizing of our facilities.   Because

 this represented rapid growth, it was  necessary to  stage our

 plan and consider a ten year increment, something that would

 take us approximately to 1995, which we were using  as  4.2

 million gallons.  Those are the numbers that we used to

 generate the sizing of the sites  and plan facilities

 necessary for the City's population.                           |
                                                                [
          The other issue that we  had to deal with was:  What  1

 other requirement were we to meet?  Was it to  continue to

 discharge at the present level of treatment, which  is  a basic ,

 secondary treatment, or to some higher level of treatment,     i

! which was being suggested by regulatory authorities last year.

j These higher levels of treatment  involved increased processing

 from reduced oxygen consuming substances, increased treatment

 to reduce other substances involving ammonia compound  so that

 the ammonia in the waste would be oxidized, and the probability

 of a future requirement for phosphorus removal because of

 issues across the state line in Long Lake which the State of
                                               HESrO'i 3 iil HU*ELL
                                               REPORTING SFRVICE

-------
OJ
   Washington and others suggested would require controls in the

'  I State of  Idaho.  We received guidance last year on what these

'  j limits would he.  As a result of not having prescribed

   affluent  specifications, but rather some guidance, we had to

  ( look at a worst-case analysis for what treatment processes we

  i were going to consider.  So, we had to look at high-side or

   worst-case situations as in regards to the facilities because

1   we had to look at the worst case in the affluent prescriptions

   and that  caused the cost to be high.

             We had 27 options that we looked at with the

   committee initially, and I won't go through all of those.  I

:   tliink that's too many for this meeting, but there is some

11  discussion of that in the EIS, and in the facility plan.  We

!•  narrowed  that down to basically four:  Alternative A, which

   basically is a no-action alternative, to stay where we are,

   not expand, and to basically rely on septic tanks; an action

;   that's not currently acceptable to the regulatory authorities,

"  but is base case, if you will.  Therefore, there are no,

i   capital costs associated with that.  It's just where we are,

 '  continuing to operate.

 1  I          The second alternative that survived the screening

   process was to expand at the existing site or adjacent to the

   existing  site and still continue to discharge to the Spokane

'  (River.  We call this Alternative B, and it did involve a plant

   which ultimately, out in the future, could cost on the order of
                                   - 11 -
                                                 HESTON and HOWELL
                                                 REPORTING SERVICE
16

17


1H
                                                                                          ?2
$19 million when you consider the six million gallon flow that;

I mentioned, and the worst-case situation.  In fact, that was

for secondary.  A strict level of secondary, there were some  i

additive costs with phosphorus removal and ammonia nitrifica- '

tion.

         The other alternative that survived was Alternative  i

E, which involved a down-river plant.  In other words, ceasing

the treatment function at this point and putting in a pump

station and pipeline, moving our treatment plant function to  |

some point down river, a mile or so.  Three sites were

identified for this alternative.  We developed costs for this,

and they continued to run about two million more than

Alternative B.  Somewhere in the order of $21 million for the

full planning period, that's including both stages.  This

alternative would — the basic difference was the pipeline  and j
                                                               i
the fact that we had to abandon existing structures at the     j

present site.
                                                               !
         The  fourth alternative, which was looked at for a     j

while and is  covered in the EIS, involved retaining the

existing site, retaining the existing treatment  plant with

some improvements, but modest  improvements, and  going to some  ;

form of affluent irrigation after basic treatment with aerated i

lagoons, somewhere here in the north  (indicating).  We called  i

this Alternative G, and it involved aerated lagoon  treatment   |

with storage  and land irrigation, with discharge of the waste-
                                                                                                                                           HESTON an1 HO»fLL
                                                                                                                                           REPORTING  SCRVK.E

-------
water in the wintertime back  to  tne river, and retention of

tins existing plant with discharge to the river all year from

that small plant.  This plant would have served the northern

part of town in the north, and the southern part of the       i
                                                              i
existing site.  That alternative received a lot of discussion !

because of potential effects on  the aquifer, which I will

refer to the EIS writers.  It had a cost on the order of $26  ,

million, considerably more than  the others, and also some     '

controversy related to the aquifer.  Now, those costs and

those requirements are little bit passe right now because of

two thinqs.  One:  Some discussions with regulatory agencies

which would appear to lead us to at least near term considera-j

tion of less requirements, requirements that are more close to |

what we call basic secondary treatment, at least that

possibility is there.  It's not official, we don't have it in

writing, but there's some possibility that some lesser

stringency could occur in the next five years.  However, there

is still a likelihood for phosphorus removal down the road and

additional treatment down the road for removal of ammonia

nitrogen.  In addition to that,  the money available to fund

these projects, which is usually in the past — recent past —

have been on a formula of 75 per cent of the capital cost being1

from the Federal grant, 15 per cent being from a State grant,

and 10 per cfnt raised locally for the construction and related

design.  The Federal grant program is being cut back, we are
                           - 13 -
HFSTflN and HOWELL
RrPOFUINU SERVICE
 i,.','«! Mi '!'	i	,,
 in MI,  ii \>i'*\ />, mi
(Vui -i t.,,, M i-'iiii r,<; S711
                                        trying to keep up with this.  The latest I have today would   i

                                        indicate that there may not be any money for the next year or

                                        at least if there is, it will be sometime before we know
                                                                                                      i
                                        whether there will be any money for Coeur d'Alene.  It's

                                        doubtful whether there will be any money for Coeur d'Alene

                                        next year at best.  There is a little money this year, and

                                        perhaps some money further down the road in "80 or '85, but
                                       I
                                       | it's still very much up in the air.  Because of this and

                                        because of the changes in affluent prescriptions, we are look-

                                        ing now at several options that would involve use of the

                                        existing site trying to get as much capacity as we car. on that
                                       i
                                       |site,  and see what the cost would be for either minor upgrade

                                        of the existing plant or installation of new structures,

                                       i whether those be tailored structures to fit in with the exist-

                                        ing configuration or a separate plan such as a package-type   I

                                        plan that would exist just down river from the present trick-

                                        ling filter, which is the large structure on that site.  Ke

                                        are preparing a report in dealing with the regulatory agencies

                                        and bringing the information on a process evaluation to the

                                        City after we talk this over again with the regulatory people

                                        and with the Citizen's Advisory Committee, and the City staff.

                                        So, this will be occurring in the next month or so, a month or

                                        six weeks.

                                                 So, that's the new business.  Them will be ,1 grontly

                                        reduced scale on the cost somewhere in the order of anywhere
                                                                                                                 -  14  -
                                                                                                                                   HESTON anil  III)*1 ELL
                                                                                                                                   XEPl'lUING  STRVICF

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U1
from $500,000 to less than $2 million.  That's the sort of

numbers we are looking at as being attainable to get some

capacity to allow the moratorium to be lifted.  I think that's

the- first order of business, to get some additional capacity

no th.it the moratorium can be lifted and so then that other

improvements could then follow in due course.

         That's an update.  It's hard to predict all the

funding issues, but that's my summary for now, Roger.

      MR. MOCHHICK:  Mr. Michael Rushton of Jones and Stokes

will be giving a presentation on the Environmental Impact

Stater.ent.

      MR. RUSHTON:  I'll be brief in this discussion.  I just

wanted to first mention what the process that we have gone

through has been.  We started work on this environmental

review back in June of 1979 when the facility planning got

underway, and for the first year of your involvement we pretty

much checked the background data in the area and attended the

Citizen's Advisory Committee meetings that were held for the

facility's planning process, and we also in that role gave

advice and discussed at several of the meetings the environmen

al concerns that we saw that were coming up from the various

alternatives that Dick Bain's firm were developing for the

City.

         Finally, we participated in the screening of the

project alternatives that got down to the three basic alterna-
                                   - 15  -
                                             HESTON  and IIOWELL
                                             REPORTING  SERVICE
                                              CM !n'1 M'c'lh-iii'l IH'O'lPr',
                                              IfHH'nn III (?I]P| 1'V, IT)!
                                             l>m 

16

17

18

19

20

21

22

21

21

21)
tives that were analyzed in the  facility  plan.   In the last

six months we've been putting together  the  Drnft

Environmental Impact Statement,  which the hearing  is  on

tonight.

         Once this hearing  is over we will  continue,  and our

next objective will be to compile all the comments on tho

EIS, both written and oral, and  prepare n final  Environmental

Impact Statement that will  address all  those comments anci

concerns on the Draft EIS.  Approximately a month  after the

final EIS is published, EPA will be  free to make some sort of

decision on the funding of  the  facility in  the City of Coeur

d'Alene.

         I'd like to briefly  run through some of the major

environmental concerns that are discussed in the Draft EIS.

These first few are common  to all of the major project         j
                                                                I
alternatives that Dick Bain identified:  Alternatives B, E,    ]

and  G.  First, all of the major project alternative's would

eliminate the occasional discharge of poorly or untreated

wastewater that occurs  from the City's  treatment plant when

there's a hydraulic overflow  during  rainy periods or  snow

melts'in the area.  All of  these alternatives would also allow

new  development  in  the  City to  be  hooked into the City system,

and  growth to occur.  They  would also eliminate existing

septic  tanks over  the Rathdrum aquifer  that are now serving

approximately  5,000 people.  This  would occur over a  period  of
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                                                  HESTON and HO*F LL
                                                  RETORTING SFRVICE

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(Ti
!   timo.  These septic tanks would be eliminated as the people

   would be hooked into the new  expanded  system.  These septic

  1 tanks and draining systems  are now contaminating the aquifer

  ' which is the principal water  supply  Cor  this area and for

   dov/nstream areas in the State of  Washington.

            If the wastewater  facilities  are  constructed as

   nlanned as described in the facility's plan, and the Coeur
                                                                  I
   d'Alene area grows as envisioned  in  wastewater facility's      j
                                                                  I
   plan and the local land-use plans, there would be approximately

   2,300 new urban acres added to the City  of Coeur d'Alene by    j

   the year 2005.  Some of this  planned development as envisioned;

1   in the City plan would occur  in environmental sensitive areas.i

   The areas that we discussed most  heavily in the Environmental

1   Inpact Statement were prime agricultural losses that would

   occur from this development.  Also,  some commercial and

   residential development that  was  planned in flood plain areas

1   and wet areas, and also some  development that would occur in

   areas of cultural resources along the  banks of the Coeur

1   d'Alene River.

            EPA  is responsible for protecting the natural

   resources like wetlands and prime agricultural lands, and

   these other cultural resources  such  as archaeological

   materials.  Therefore,  the  Environmental Protection Agency  is

   concerned about these  losses  that would occur  and would  hope

 1  ' to discuss  those  things with  the  City before providing grant
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                                                 IIESTON and HOWELL
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 resolve  in the future here.

          Alternative E,  which would be moving  the  plant down-

 stream to one of three possible locations,  has no  major land-

 use conflict that we could identify.  It would, in fact,

 rornedy existing conflicts at the treatment  plant site that you

 have now.  There would be archaeological disturbances  that  we

 could identify if the middle of the three sites were  selected.

 The middle site is an existing gravel pit,  and that site has

 been disturbed heavily already, and, therefore, would not

 involve  any possible loss of any archaeological resources if

 it  were  used.  This move would obviously move  the  waste

 discharge the rivec about one mile down, further downstream

 from the City.  This moves it away from the City,  but it moves

 it  about a mile closer to what the Panhandle Health District

 has identified as approximately 160 people that draw  domestic

 water from the river down between the City of  Coeur d'Alene

 and the  state line.  The local share cost of that  alternative

 was identified as about $1.94 million.
                                                 &
          And the final alternative. Alternative ,15, which has

 two treatment plant sites maintaining the existing site and

 building lagoons in the north area  for a portion of the flow,

: the major alternatives we discussed for that alternative were:

 continued land-use conflict at the existing site,  the treatmen

 plant closely located to  residential and developing areas,
I
' possible land-use conflicts in the  proposed lagoon areas.   The
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IIESTON anti HOWEU
REPORTING SERVICE
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                                     24
County's comprehensive plan shows this particular portion of

the County  as  a  transition zone between agricultural and

residential  areas  with possible residential development in

the long-term  in that area.  There were no significant

archaeological impacts identified with Alternative G.  As far

as water quality goes, that alternative would keep summer

discharge to the river at its present volume level, and its

present location in the winter.  However, you would have the

discharge of the expanded area to the river down here

 (indicating)  if  you were about a mile downstream from the

existing plant,  proposing the same general public health

concerns I  mentioned for Alternative B with the site moved

closer to those  domestic water users downstream.

         Finally,  Alternative G with its spray irrigation

disposal of the  wastewater in the summer up here  (indicating)

poses a potential threat to the ground water quality and

integrity of the Rathdrum Prairie aquifer, which underlies

this large  agricultural area to the north of Coeur d'Alene.

The  local share  cost of the alternative was identified as

about $3.17 million.

         That basically summarizes the major environmental

concerns that we put in the Draft EIS.  I'll turn  the hearing

back over to Roger.

      MR. MOCHNICK:  Thank you.  Okay, with that,  I think we

can  proceed now  to those people who would like to  make
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presentation on either the facility plan or the EIS,  and  the


first name we have is Mr. Ray Koep.


      MR. KOEP:  I'm Ray Koep.  I'm a Coeur d'Alene City


Councilman, and Chairman of the Public Works Committee.   I've


been dealing with the sewer problem of Coeur d"Alene now  for


about right years.  I learned something last night,  however.


I thought all the wastewater overrun and high water went  into


the Spokane River, and I understand some of it ends up  in the


bathtrbs in the Fort Grounds, and the lady that made that


point was very concerned that we might be adding an eleven


story building into the system.  She felt sure that that  wouldi


fill her house, not just the bathtub, and that highlights a


concern that I have as a councilman, and I would like to  speak


to that for just a moment.


         For the sake of brevity, I straightened out the


Spokane River here (indicating on chalkboard), and this might


be Snndpoint, this is the far side of the City of Spokane,


this might be Athol, and Coeur d'Alene, state line, and the


city limits of Spokane.  Until you get to Coeur d'Alene — oh,


incidentally, I'd like to say that that overburden — and I'm


going to be talking in real round numbers because there could


be some mistake on this, but that overburden of debris  that


caine down with that dam breakage 10,000 years ago left  about


400  feet of overburden in — this is really exaggerated — in


Eandpoint, and something like 325, say for numbers in Athol,
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                                                     HESTON and HOWELL

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and 250 in Coeur d'Alene, at the state line about 125.   I     I


think at the city limits of Spokane it runs from 50 to 75     ]


feet.  I read a handout at the Health and Welfare office in   I


Boise a while back.


         Another point I'd like to make is that in 1950  there


were five sewer treatment systems in the State of Idaho, and


Coeur d'Alene was one of them.  Boise had the most expeditious,


they dumped the water in the Boise River at the time, but \ve  1


at that time had been treating sewage, I guess, for 15 years  i


or something like that.  We'd been in the business, we'd been


working hard and spending a lot of Coeur d'Alene taxpayer's


money to get this job done, and we keep working at it.


         Now, back to this thing:  Until you get near Coeur


d'Alene there's virtually no pollution down through this


water flow down here.  Simply  because there is not much      ]


industry and there's very little pollution.  t/hen you get  to


the state line — let's see, we have sewer treatment  in  the


City of Spokane.  Incidentally, this overburden comes down


here, and this area on the west side of Spokane is surfacing
                                                               i

of that water system, that sole-water source.  This area here  j


is treated.  Now, this is an area that I have concern with,


from here to here  (indicating).  Estimated -- and these  are


very rough estimations -- that there are more people  here


polluting the aquifer than there is all the way from  Pend


Orielle Lake to that area.   It has to be  in the order of a     j
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                                              HES1 Oil 3T) H'HEll.

                                              REPORTING  SERVICE

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 hundred thousand people, and there isn't a piece of pipe in

 the ground in this area, and from what we can see — and our

 concerns are political because we have businesses and

 taxpayers, people wanting to develop and live1 here, they      |

 cannot develop because of tight restrictions that exist here  I

 in Cocur d'Alene.  And when you get to the state line, from what

 we can see, there are no restrictions, at least our people

 who would like to build  in Coeur d'Alene must go across the

                            LL n (csh > <'t]^
 state line where they have wvferaveled building, and we don't

 understand that:  Why there is a different standard here

 where the chance for pollution is much heavier, the ease of

1 pollution, because the overburden certainly appears to be a

 lot worse.  We even halfway between here have the City of

 Post Falls and another problem, another thing that we can't

 understand is this particular  city has been deemed to be an

imminent health threat to this  aquifer, and we have honestly

 endeavored to find out why that was.  The best we can find

 out is that  it was -- and don't misunderstand me.  I certainly

 don't bearudge the City  of Post Falls what they are getting,

 they need  it, and they have worked hard for it.  They are

 fine people, and we support them, but I understand that there

i was an involvement with  their  water  supply.   Now, to my

 knowledge, at least,  they haven't had to close their water

; supply.  We  in Coeur d'Alene have had our biggest water supply
i
 our Fourth Street well has been down, and I'm not sure if it's
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HES70N and HOWELL
REPORTING SERVICE
 OiM'i-d V'-iMliii"] HrfuMfr,
 lf»i l-n 'il 1/081 Mfi I )j!
("(•'if d AI'Tie Id C'UH) fiO/ H?11
                                        a year or a year and a half, something like that, but it's

                                        been totally back into the system again because we think we

                                        have determined the source of pollution and have cut it off.

                                        We believe that to be the case, and we are back using the

                                        well,  but we did have the involvement, yet, somehow we don't

                                        seem to qualify.  We are not enough of a hazard, apparently,

                                        to be qualified as an imminent health threat, which we think

                                        would give us more support in our applications.  On the other

                                        hand,  we seem to be somewhat of a threat because we have an

                                        imposed moratorium by the Health authorities.   I'm not

                                        questioning that; I mean, this certainly should be able to

                                        be substantiated why they have come at that, but I just can't

                                        understand the dichotomy of the thing, and it  just doesn't

                                        make any sense that we would be riding the fence like that.

                                        So, I would hope that we'd see a solution where we would

                                        either have someone acknowledge the fact that  we are actually

                                        a health hazard or deny  it and allow us accordingly to

                                        continue with our development.

                                                 That's about all I have.

                                              MR. MOCHNICK:  Thank you, Mr. Koep.

                                                 Earl A. Ferrier.  Is  it F-E-R-R-I-E-R?

                                              MR. FERRIER:  That's correct.

                                                 I live down the river about two and a half miles  at

                                        Harbor Island.  Now, this condition that we have on  the river  j
                                                                                                       i
                                        doesn't occur every day, but every time it rains in Coeur      j
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o
I d'Alene, why, we  get  your  raw sewaqe  from  Coeur d'Alene.  Now,

i this  is  --  I don't  think it can be disputed  because  that

. river  has been  tested,  and sometime ago  it was ascertained

• that  it  was raw sewage  being put in the  river, and there was

 a  big  fuss  at that  time.   The superintendent resigned,  and

 he'd  been falsifying  the records.

          Now, there's a whole lot  —  there is several people

 on the island that  take their water off  the  river, and  I'm

 sure  they must  chlorinate  it or flse  they'd  be taking a heck   |

 of a  chance.  On  down,  there's a whole— about possibly a mile

 and a  half  down,  there  is  the Green Ferry  Water District.   It  i

 takes  all their water from the river.  Now,  is there any       i
                                                                I
 reason that we  should — that Coeur d'Alene  should be allowed

 to dunp  raw sewage  against the laws and  rules of  the EPA?

 Mow,  they've already  told them this.

          t!ow, you keep  talking about  money up here.  Well,

 Copur d'Alene should  generate the money  and  take  care of  this

 sewage,  not dump  it in  the river.   Spokane has.

           I  want to  remind you that the people in  Long Lake

 won a suit  against  the  City of Spokane because  they  dumped  raw

 sewage in  the river.

           Now,  if  anybody can dispute  that  there  is not  raw

 sewage going  in,  they should have looked at the  river  this

 norning.  Half  an inch  of rain last night, and  the river  was

 a  foam on  top  this  morning.  Now, was there no  water — no
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                                                     and HOVrELL

                                               REPORTING SLRVICF.

                                                Oilr'i»r1 Minll'jnil R-v'trr
                                                Ir.iilnn I.I |,"I3] 71C, ! t1!
                                               r. ,>,„ (I nil m  \<[ (,»iKt M,' 4714
sewage went in last night?   I don't know.   Go  see  along  that


valve down there.

         That's all I have.

      MR. MOCHNICK:  Thank you very much.

         Barry G. Schuler.

      MR. SCHULER:  I'm Barry Schuler,  President of  north

Idaho College and I am here  to reiterate our  position on this

matter, and that is that Alternative  B, which  would  involve

any expanding of the existing site, we  are  very much opposed

to.  For obvious reasons, our expansion, our  future  growth

must be in that direction.   We already  don't  like  the nearness

to the present plant facility.   We object  to  the offensive

odors, particularly in the summertime,  but  I  think it should

be pointed out that we have  obtained  Federal  funds recently to

develop now the whole beach  area as a major recreational site.

The north end of that area would be very close to  the present

plant.  We are putting in restrooms,  bicycle  paths,  picnic

tables, those sorts of things to now  make  that beach more

useful to the general public.

         Also, obviously, the existing  situation is  not very

ideal  for the college campus itself.   The  students in good

weather are out of doors  involved in  sports in the athletic

field  very near to that  site if  you get down  to the northern

end of that field.  The  dormitory is  not  too  far away, also.

It's on that end of the  campus,  and all these things are
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objectionable already to the facility as it now exists,  and

we certainly do not want to expand it.

         I think you need to know that North Idaho College is

Idaho's fastest growing institution of higher education.  We

have grown an average of nine per cent per year since 1976 in

our full-time equivalent student body.  We presently serve on

the Coeur d'Alene campus over 2,000 students.  This is our

largest semester ever.  We grew even over the fall semester,

which is a rather unusual occurrence.  So, we are now serving

over 2,000 students on the Coeur d'Alene campus this semester,

and that does not count the satellite campuses that we operate

in other counties in the area.  Therefore, we must look to the

north for our future expansion.  We have every reason to

believe that this growth is going to continue as the populatior

increase continues in Kootenai County.  And we can't go to the

east very well since you are talking about a residential area

that exists there.  We obviously can't go to the south or to

the west because we are bound by the lake and the river on

those sides.  Our only possibility for the future is to go to

the north.  So, we were rather pleased when we heard that

Alternative E was the one that would probably be selected

because it was our anticipation that that would then free up

some land that we could purchase from the City of Coeur d'Alene

to add to our campus needs.

i         The thing that I think you could be rather certain of
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                                              HEUON ant MOWELL
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18
is that if it were necessary to pass a bond issue to expand   |
                                                              ]
the plant at the present site, there would be a lot of

people opposing that particular bond issue, which could       '
                                                              1
                                                              i
jeopardize its success at the polls.  It seems to us that  the i

very logical solution to this is take the money, the next

dollars that are available for the sewage treatment and  the   !
                                                              i
establishment of a plant, and to begin the new facility  down- !

stream as is proposed in Alternative E.  Acquire the land,
                                                              i
and design it so that it can be readily expanded in the       '

future.  Then, leave the plant in operation,  and as the  money

becomes available in increments, continue to  expand that

plant as proposed under Alternative E until such time  as you

no longer need this planl; and it becomes a pumping station   |

sending that sewage to be treated up there to the plant

further down the stream, and  the other good part of that is

that then you would already start bringing your lines  in from

the northern end of the City  where  the growth is taking  place,|
                                                               I
and you would start bringing  those main  trunk lines into what
                                                               t
will become the new main plant, and you would not go  to  all

the expense of bringing those lines way down  to  the Fort      i

Grounds area and involve all  that  investment  of capital  outlay'

only to eventually have to  change  it over  to  a plant  further   '

downstream.   It seems very  logical  that  there's  a very good    j

alternative to the proposal  just  to  expand on the  present site

in accordance with Plan B.
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KJ
         Thank you.  That's all  I want to say.

      I1R. MOCHNICK:  Thank you very much.

         Elton E. Bentley?

      MP. BENTLEY:  I think there's a question mark after that

I think  I'll remain silent.

      1TR. MOCHNICK:  Okay.  Thank you very much.  The other

one with a question mark  is George Gumprecht?

      MR. GUMPRECHT:  I'll wait  for questions later.

      MR. MOCiltlICK:  And  Mr. McAdama?

      MR. McADAMS: Mine are primarily questions as well.

      MR. MOCHNICK:  Okay.  Is there anyone who had filled out

a card and had checked the square that they did not want to

make a presentation who have changed their mind?

          (NO RESPONSE.)

         All right.  We can then proceed  to the last stage of

the public hearing, which is the question and answer period.

I would  ask that  you would ask your questions through me to

either Mr. Bain or Mr. Rushton.  We're open for questions.

      MR. JONES:  My name is Ed  Jones.   I am  a City Councilman,!

and  I would like  to know  if Mr.  Bain can  give us  the facts --

and  I know we  put smoke  through  the  sewers  — if  we were able

to  separate the  storm  sewers  from  the  sanitary sewers,  how

much would  that  reduce our load on  our  plant presently?

j      MR. BAIN:   Okay, let me go from  memory, and then  I can

get  specifics,  if you  like,  from the  report.
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                                              HHTON and HOWCI.L

                                              REPORTING SF.RVICF
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          There was a smoke testing program carried out last

 summer.  In the Fort Grounds area we did do  that  type  of       i

 testing, and in our evaluation of those flows  from the sewers,

 we had this condition:  We have a ten-inch pipe,  which flows

 from the Fort Grounds area to the plant, and that's  a  bottle-

 neck.  If we look at the flow to that pipe,  we can normally

i get about eight-tenths of a million gallons, I believe is  the

 figure, through that pipe unless there is  surcharge which

\ sometimes happens when water stands in the streets.  So,  you

' can get a surcharge of maybe five feet, and  I  think  that  will

! put about 1.1 million gallons into the plant.   So, that's

!about how much you can get from the Fort Grounds  under the

 worst of conditions, okay.

          If you were to separate that, obviously, you  could

 cut back a lot of that flow, certainly back  down  to  something

 more normal like maybe a couple of tenths of a million gallons

 So, it's probably worth something like  .75 million gallons to

 the plant flow.

          Now, when you look at the plant record — well,  just

 take last week.  I just talked to the treatment plant  operator

 about this kind of problem, asking him the questions I think

 you are suggesting is what did he see as the impact  of sone;

 of the separation that's already occurred because you've  done

 a little bit of it already because of work  that was  done  a

 year or so ago.  He thinks he does see a little improvement,
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                                                                                                                                           HE^ fUN and H"*F LL
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en
U)
 but with a pretty good storm on the 13th of February, for

 example, arid we did get a peak flow that reached, I think,

i 3.8 million oallons.  The plant, when you are operating all

 the numps, can get about 4.3 or 4.4 million gallons to it,

 okay.  What's happening during the really severe storms,

 which have to be pretty severe, when they are severe you'll

 get what you can to the plant, but the Fort Grounds area,

. which can only get certain amounts through the sewer, will

 just overflow to the river and not get into the sewage treat-

 ment plant.  So, the question that came up from the gentleman

 from Harbor Island isn't necessarily that there is waste

 that's coming from the treatment plant, it's waste that never

 even got to the treatment plant.  It's of equal concern, but

 it's arriving by running off  the flooded area.  That's about

 what it's worth, about .75 million gallons.

          Now, downtown you've got some roof drains that also

 are direct connections and you get a fair bit through them.

 Overall, now, though, when you look at a wet day like the 13th

 of  — Friday the 13th, I guess it was, we had about  2.4 millior

 gallons through the plant even though we had a peak  of 3.8.

 So, it  tends to average out,  and when you look at  the data,

 we  had  a lot of days — normally, even in a wet month, you

 don't average much over 2 million gallons a day, but during

 the really  intense long rains you can get up to  four that  I

 talked  about, but  if you corrected all the Fort Grounds, you
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                                                      HESTON and MOWELL
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18

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wouldn't bring that four down to two.  You'll bring it down   ]

to 3.2, maybe.

      MR. JONES:  What about the, say, downtown and the other •
                                                              i
      MR. BAIN:  The downtown area, if I recall right, is
                                                              i
worth another approximately .75 million gallons.  Let me

check that for you.  I just don't like to be too  flippant     ,

about that number.  I had just studied the one on the Fort    i

Grounds, so I recall it.                                      i

      MR. JONES:  We have been turned down on the grant twice.,

      MR. BAIN:  I understand, and  from what I heard on

television, there might not be a EDA anymore.

         Well, I'll have to just go through  this  and perhaps

I can answer your question in a little bit.  I'll just study

this and find the answer.

      MR. MOCHNICK:  Sir?

      MR.. GUMPRECHT:  Donald Gumprecht, a Coeur d'Alene        |
                                                               [
resident.                                                      ,

         What you're saying, then,  is that  the reason for  raw  I
                                                               [
sewage overflow  into the Spokane River  is primarily  the bottle-j

neck,  and that you don't necessarily have to go through the    i

processes of  separating  sewers  to  prevent that;  is  that what

you are  saying?

       MR, BAIN:  Well, you either  have  to separate  them to

what the present course  is or  provide  for flow, relieve the

bottleneck  and  get that  flow  to  the plant,  and  unfortunately
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Ul
 tho plant can't take much more, so you have to do one  or  the

 other.   If you take more flow to the plant, it worsens our

 problem with the plant,  so I would encourage the City  to

 continue on their course to separate the waste because that

 wi: 1  solve the problem for the down river people and  for the

 Fort  Ground people not to experience that flooding,  and also

 keep  a  little more flow  out of the plant.

          The problem is  funding that,  and the City had

 trouble getting grants for that work,  which is,  I think,

 estimated  at about three quarters  of a million dollars.

      MR.  MOCHNICK:   Are there any other questions,  sir?

      MR.  McADAMS:   My name is Gene McAdams.   I'm employed by

 the City of Coeur d'Alene.

          I'm interested  in the archaeological considerations,

 first,  in  relation to Alternative  E, which is the downstream

 site  or the new site that was  selected by the City Council and

 by  the  Citizen's  Advisory Committee.  The environmental

 engineers  indicated  that two  sites could involve archaeological

 considerations.   Those archaeological considerations  are        ;

 primarily  Indian  burial  grounds or possible Indian relic  areas

'or  I  don't know what the description is,  but  what I'm

 interested specifically  in  is  this:   If that  is  suspected, if

 that  is a  fact and  it bears out as a fact,  how does  the City

 mitigate that and build  upon one of those sites?

      MR.  MOCHNICK:   Maybe  I'll start  off and answer that
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                                              HESfON and HOWFLL
                                              prponritir, SFIIVICF.
 question, and Mike can add some things.

          As a result of the Historic Preservation Act,  there

 are regulations that have been prepared by the Advisory

 Council on Historic Preservation, and it details out what

 Federal agencies have to do prior to giving a permit or giving

 money or some action that would cause an impact on either an

 historic site or a cultural site.  In this case, what we have
 iov^
 down is we have had to contact the Idaho State Historic

 Preservation Office  and to ask them if there have been

 surveys of the area.  If there have been surveys, what have

 they found.  If not, then the City would be required to do a

 detail extensive survey as part of their whole grant applica-

] tion.  It's easier to take a site if there — if we're talking
I
: about a cultural resource, and if you have an historic build-
I                                                                I
 ing,  it's very difficult.  What normally happens is it's up

 to the city,  the state, and the EPA to come to agreement on

 the mitigation measure that can be taken to excavating the

 site.  Sites can be taken, but quite often one of the

 mitigation measures is an agreement to allow a professional

 archaeologist to come to the site and go through the excavated

 material.  The extent of that, we don't know because we don't

Iknow the level of detail of any of those sites, but to be fair

 and honest with you, that can be an expensive process aiven the
I
iway that archaeologist — I think it depends on what kind of

 site they have to go about excavating the material.  Sometimes
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U1
 when they look at  it,  they  just  simply like to register what

 it was, where it was,  and they don't  need to go into it.  It

 sometimes provides  —  and this is my  interpretation, I'm not
I
 an historian or archaeologist, but  I  think it sometimes

 provides  the same  type of cultural  resources that they have,

' and they  don't go  into the  expense  of excavating.

           So, I don't know if  that answers your question, but

 that would  be the  process that would  be  remained if — when a

 nite is selected,  a survey  would have to be done if not

 already done, and  then, mitigation  worked out with the State

 on how  that site would be taken.

       MR. McADAMS:  Okay, then,  that  site, then, or those

 sites,  I  presume that  work  is grant eligible; is that correct?

       MR. MOCHNICK: Yes,  it is.

'       MR. McADAMS:   I  presume that  there are no alternatives

, to handling it other than  through  that  process.  In other

 words,  if we had an extremely adverse situation as an example,

 and  the Federal  government  was  not  going to  fund an
i
 appreciable portion to the  wastewater treatment plant,  and

  the  City  took  it upon  itself to build the  plant,  I presume

  that if the City expected State and Federal  participation  that

  it would  be necessary  to fully  mitigate the  archaeological

  concerns  according to  the process  that you've  defined?

i       MR. MOCHNICK:  That's correct.   If it's  a  private

  venture that does  not require certain Federal  funds,  none  of
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                                               HE'STON and HOWELL
                                               REPORTING SERVICE
                                                C"iltli"rl Muirthpnd Rciiivtcts
                                                iPW'liip hi l?l)8) MS 1131
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 9

 II)

 II

 12

 n

 11

- 15

 16

 17

 1R

 19

 20

 ?l
                                                                                          2-1

                                                                                          2-i
those requirements need be met,  I don't  know  whether  you     j

locally have some requirements to be met,  but  it's  quite  often
                                                               i
brought up as an unfair technique when  a  developer  can build  '

on a site and a Federal project  finds itself  in much

difficulty in getting project going.                           i

      MR. McADAMS:  And I didn't ask the  question for  you to  |
                                                               i
respond or assume responsibility for State funds, either.     I
                                                               i
         I would like to ask. this then:  In terms of          I

archaeological considerations, I understand from the Draft
                                                               j
Environmental Impact Statement that  there was  no problem  at   !

Alternative B, and then when I listened to the description a

little bit earlier, I surmised that  there might be.  I'm

interested in a specific answer. Is that an issue with

Alternative Bj that's the alternative  that expanded at the

plant at the present site.

      MR. RUSHTON:  That's  the primary  area which is

Alternative B.  That's an identified registered site in that

area.

      MR. McADAMS:  So,  therefore, we  would probably assume,

then — speaking  from the historic preservation or

archaeological point of  view,  that Alternative B would be more

difficult to mitigate than  Alternative  E, or if it's about the

same, say so, but I'm trying  to  weigh   a degree here between

the two alternatives.

      MR. RUSHTON:   I think that would depend on work that
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01
i you'd have to do after deqiding  on  a  site.  That site is

1 already identified.  There may be similar  resources, that's
i
1 what the archaeologists believe.  There may be  similar

 resources that would be unearthed in  the ground at  the site

 of E, but you wouldn't really know  that until somebody comes

 back and actually digs some  test excavations.

       MR. MOCHNICK:  Are we  saying  that the area where the

 gravel pit is, that is --

       MR. RUSHTOtJ:  They did say that specifically  that the

 gravel pit site of E, which has  already been disturbed,

 obviously, and is now a hole in  the ground would not have any

 remaining resources, but the two undeveloped sites  that were

 part of E are relatively undisturbed land  and may contain

 resources similar to what they know is in  the area  of

 Alternative B.

       MR. McADAMS:  I was under  the false  assumption that

 with all of the activity that had taken place with  the rail-

 road, with the construction of the  present plant, and the

 adjoining property around there  that that  property  at

 Alternative B had been pretty well  scratched over — if you

 will — by now, but that's not the  case as far as you are

 concerned?

       MR. RUSHTON:  That wasn't  the archaeologists' opinion.

 Their opinion was that it was still a significant resource,

 there could be a significant resource.
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                                              REPORTING  SERVICE
                                               r>lil.viy«ii'ri«iv1 II,-i wins
                                               ltwi''on 111 irOK! IV mi
                                              O'lr r|»lin" H l?!r«l f'.lt?H
                                                                                          I 7


                                                                                          IS

                                                                                          1"

                                                                                          20
       MR. McADAMS:   Okay.                                      i

       MR. MOCHNICK:   We  will  take Mayor Johnston.              ,

       MR. JOHNSTON:   Don Johnston,  Mayor of Coeur  d'Alene.

          With regard to  this,  what I  was concerned about,

 Roger,  is:  Are we able  to  challenge  whoever it was that
i
 identified that as an archaeological  site?   I'm — being a

 life-long native, I'm not convinced that there is  a problem

 there,  and I agree that  it's  been scraped over enough that

 it just amazing to me that  —  and as  I  read this report, some

 guy from Texas made  the  determination.   I don't understand.

 Would we be able  to  challenge  that determination that that is

 an archaeological site?

       MR. MOCHNICK:   Yes, I'm  sure that iou can challenge that

 The eventual challenge,  I suppose,  would go to the Idaho State

 Historic Preservation Office.   However, I don't want to nake

j it sound as if there are -- you know, great delays and lots of

 people  out digging up that  site to find all the archaeological

 resources.  We quite often  have archaeological resources in

 many of our projects simply by their  location next to the

 waterways.  They  are usually not a problem.  We have been

 able to work on a grant  condition where the City allows, as I

 say, an archaeologist — or sometimes as the construction is

 going on with the site,  if  something  is uncovered they will

 call the archaeologist who  the State  recommends one for you

 that you can use, and he will  be able to come down and take a
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                                                                                                                                           REPORTING  SERVICE

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j look at  it  and  see what  it  is,  and only if it was something —

 I think  rare or unusual  circumstances would they actually

| stop construction.   And  I would say  in our region, I don't
I
I know of  nnywhere we  have stopped construction because of an

 archaeological  site.   We have had problems, as I said, with

 historic buildings,  but  that's  a whole other story.

          Maybe  — Roger  Tinkey  is here from the State of Idaho

 I don't  know how closely you work with the State Historic

 Preservation officer.  Do you have anything to add to that?

       MR. TINKEY:  I can't  recall where we've ever stopped

 construction on a job  as a  result of that.

       MR. HcADAMS:   One  final question is:  Is contesting

; these kinds of  things  -- I  presume the City takes it on

• itself or does  — do our State  and Federal friends — or

 Federal  friends help us  with the cost of  those expensive kinds

 of projects?

       MR. MOCHNICK:  Okay,  that's a  complicated question.   I

, don't know  whether I understood it.  Take on the cost of it?

       MR. McADAMS:   In other words,  as the Mayor said — let's

 just make a statement:  We  challenge the  efficacy of the

 archaeologist's report.  All right.  And  we want to proceed

 with that challenge.  Is that cause  grant eligible?

       MR. MOCHNICK:   I would say no.  That is not grant

 eligible.   In  the way  of helping you,  I suppose it would

 depend on the  challenge  —  it would  depend on what kind of
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REPORTING SERVICE
 Colt'"'I Shinlhsiul Rpi'tirtPrs
 l?*t \w W l?l)R) Mfi U^l
rm-iii (JAnvif 111 17081 IWW'I'I
                                     20

                                     71
data you have in the way of your challenge.  Again,  I don't

know that it would be that big of a problem, but  it  could  be   >

something that's faced later.                                  !

         Warren McFall, who is also in  the audience,  is  the

EPA's Project Engineer on this, and is  out of  the EPA's  Boise  '

office.                                                        j

         Warren, do you have something  to add?

      MR. McFALL:  I was just going to  say regarding the

difficulty in mitigating the archaeological  aspect of  it,  we

do have some recent experience down in  the         area  where

there was identified an Indian burial ground in the  riverbed

where they were supposed to build a treatment plant.  The

mitigation measures there were merely to  have an archaeologist

on the site during the construction period and during the

excavation period.  It wasn't a long complicated drawn out

affair, it was a matter of  just having  an archaeologist there, j

         Yes, it did cost some money.   I  think the cost of    I

having him there was something  in the neighborhood of eight or !

ten  thousand dollars during  the period  of construction.        !

      MR. MOCHNICK:  He was  physically  there?                  !

      MR. McFALL:  He was physically  there during all         j

construction, and  the project hasn't  been completed  yet, and  ;

as far as I Xnow nothing has been uncovered  yet.              :

      MR. MOCHNICK:  Okay,  I believe  Dick has an answer to the

earlier question.
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oo
j       MR. BAIN:  Regarding  the  question about roof tops in

' the downtown area and the amount of  flow attributable to the
I
 rain water that might get into  the sewer system from roof '

 drains and other related connections, there is about 250,000

 square feet of roof area down there  that we were able to

 confirm is connected to the sanitary sewer.  It might be a

 little higher figure because at the  time we were doing this

 some of them were plugged from  volcanic ash.  We estimate

 somewhere between 600,000 and 900,000 gallons per day.  That

 would be about 750,000 gallons  --

       MR. JONES:  So, we would  have one and a half million

 gallons, then, we could cut down?

       HP.. EAI1J:  From those two sources, at least, yes.  From

 those two sources — as far as  extraneous winter flow.

       MR. JONES:  Which is what we're —

       MR. BAIN:  You're concerned about that, certainly.

       MR. JONES:  In restricted financing, it's something

 worth looking at.

       MR. GUMPRECHT:  Why aren't the roof tops connected?

       MR. BAIN:  The roof tops  from decisions years ago, many

 of the roof top drains are connected not to a storm sewer, but

 to the sanitary sewer.  It's an artifact of history.  It's —

 it wouldn't be present code.

j       MR. GUMPRECHT:  Correct me if  I'm wrong.  A year ago we

 were discussing a Federal grant to rectify some of our
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                                              HESTCIN and linwELL
                                              RfPORTIKG SERVICE
                                                          M (/CXI IK H1I
                                                         lll- 111 I'OSI Sl,lfl?1
difficulties, and that grant  involved  tearing  up  streets  in    !
                                                               I
the Fort Grounds area, to which  I'm opposed or at least  I'd    '
                                                               i
like to see a minimized impact in  that regard,  and there  are   ;

two problems.  One is the water  flow,  and  the  other was  the

raw sewage, so from what I've heard tonight,  it sounds like  if

private building owners were  able  to alter their  connections

we would save as much water overflow as was proposed  for  the   i

Federal grant last year by tearing up  the  streets in  the  Fort

Grounds.  If you're saying it's  going  to save  .9  million

gallons, that's the same as the  Fort Grounds,  roughly, and if

we just increase the width of the pipe from ten inches,  then

we save that raw sewage.

      MR. BAIN:  Let me go through that kind of carefully
                                                               i
because I don't fully agree with everything you said.          }

         What I said was:  There's about -- we'll use the high

figure.  We'll use the 900,000 gallon  figure as what would

come from roof drains into the sanitary sewer  destined to

eventually get to the sewage  treatment plant.   If that wore

removed from — the roof drain connections were moved, it would

go into a storm sewer which would get  eventually  into the lake.'

Now, when we use the figure of say 750,000 gallons that  I was

attributing from the Fort Grounds, that's  the  amount that --

because of the bottleneck, the amount  of total  storm water

flow in the Fort Grounds which contributes to  the flooding

would be a larger figure.  I'm saying  a lot of  that doesn't
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                                              REPORTING SERVICE

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vo
 ever  get to the plant.   Now,  if you make the  pipe  bigger  so

 that  it can, that aggravates  the plant problem,  and,  in  fact,

 in several ways.

       MR. GUMPRECHT:   You don't have, any estimate  of  what

 that  would be?

       MR. BAIN:  Well,  we have an estimation  for the  separa-

 tion  at the Fort Ground of being on the order of $750,000.

 That's separation at the present —

       MR. GUMPRECHT:   I'm talking about volume,  not dollars.

       MR. BAIN:  Oh,  the total volume of storm water  in  the

 Fort  Grounds?  I don't, but,  Jim, if you did  any work on  that

 storm drain you're more directly connected with  that.  Is that

 a fair question for you?

       MR. KIMBALL:  Well, we calculated at one time a peak

 hydraulic run-off of — I think we sized the  pump for around

 10,000 gallons per minute, and you can run that out,  and  that1

'a lot of water.

       'MR. BAIN:  A lot more than what we were talking about

' going through  that ten-inch pipe?

;       MR. KIMBALL:  Yes, you bet.

       MR. MOCHNICK:  Do we have some other questions?

i       MR. McADAMS:  Yes, I have another.  In relation to a

 statement made on Page  57 of the Draft Environmental Impact

 Statement, one can interpret the continuation — it's under

 the section  "Continuation of Ongoing Studies".  It says that,
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                                              HESTOII and HOWtLL
                                              REPORTING SF.KVICE
                                               Ot1|l|«"l MiMllMml pritiiMi'i',
                                               Ipwislofi I.I I7IWI Mr, I III
                                              COHIII iHkn. Id |2i)PlM/»7M
"The State of Washington waste allocation  study should         I

establish specific loading limits for  the  Spokane River        ;

upstream of the Idaho/Washington state line."
                                                               I
         I think that Mr. Koep earlier described his under-    i

standing of the situation in terms of  the  Rathdrum  aquifer     ;
                                                               i
which is sole source designated now, and we  are very concerned

that Washington not establish or unduly influence the          '
                                                               !
National Pollution Discharge Elimination System Permit

requirements, and we are also concerned because as  Mr.  Koep

said, it appears that the controls are very  stringent  in this

part of the country and  there's much,  much less control across

the state line, and I'm  interested in  any  comments  that you

might have in relation to equivalency, if  you  will,  in  terms

of the degree of treatment required  in Coeur d'Alene versus

the Spokane Valley.

      MR. MOCHNICK:  Okay, I cannot  answer that question.  I

will start out, and maybe some other people  will offer  some

assistance.

          I think that we at EPA have heard your concerns and

realize that all concerns you have are based on  the allocation

study that is presently  being done,   I understand  that there

has not been, at least  in the City's point of  view, there has

not been  good coordination at this point  with  the  Department

of Ecology in Washington on this  study.   EPA has,  I think,

committed  itself to Mayor Johnston  to try to coordinate better
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 i the roles of the Waste Allocation Study, and I know that that

  is one of the things that we will be doing to make sure that

 ! specifically the City of Coeur d'Alene has some involvement

 , as far as where this Waste Load Allocation Study is and where

  it's going.

           As far as the treatment levels and requirements,  the

  V.'asto Load Allocation Study is not completed yet, at least

  that's my understanding.  We will be looking for some numbers,

  I think, out in the next month or so.  1 believe those are

  even draft numbers.  I don't know what it's going to say.

        HP. IlcADAMS:  Well, what I'm really trying to indicate

  to you is that the Mayor and the City Council has never

  indicated anything other than assuming their fair share of the

  load, but I do believe that they had legitimate concern when

  we read these statements, and because it can be interpreted in

  a nunber of ways, and then when we are advised by some of  our

  local developers, for example, that in order to continue with

  their occupation the only opportunity that they have — well,

  I should rephrase that:  The best opportunity that they have

  is to expand their operations in the State of Washington,  and

  I just think that that's a problem.

        MR. MOCHNICK:  Okay, I think we have heard that comment,

  and I think that EPA will be working with you to try to

•  rectify some of that problem and get information back to you,

'  and I don't know if anyone has anything to add to that.
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HF.STON and HOWELL
REPORTING SERVICE
 Cnn.lirrl r.h [hind Pr^rlPrs
                                                     M l
                                                          I r.M R
                                                 Warren or Roger?                                     i

                                              MR.  McFALL:   Well,  not perhaps on the growth issue, but

                                        as  far as  the Waste Load  Allocation Study, I think it should  •
                                                                                                      i
                                        be  pointed out that although Washington is conducting the

                                        study,  it's being  conducted through Washington funds primarily.

                                        The study  is not strictly Washington telling Idaho what's

                                        going  to  be acceptable to the river.  There's going to be     \

                                        information that's going  to be collected during the study     ,

                                       | which  will be utilized by our agency, and as far as I can see,

                                        it's an interstate situation, and Washington doesn't really

                                        have the  authority to tell Idaho what it can discharge, and so

                                        our agency, EPA, is going to have to get involved and

                                       !negotiate  these waste load allocations with both states, but

                                        maybe  this — you're getting carried on by the fact that it's  •
                                                                                                       I
                                        called the Washington Wastewater Load Allocation Study or      '

                                        Spokane River Allocation  Study by the Department of Ecology,

                                        but we really suspect that information will be used by our

                                       'agency to  work with both  Idaho and Washington to negotiate out

                                       i the actual allocations.

                                       !       MR.  GUMPRECHT;   As  a citizen, I'd like to amplify what
                                       i
                                        the Mayor  and Mr.  Koep and Mr. McAdams said, and that is seems

                                        ridiculous to be talking  to Federal officials here if we're

                                        talking about such discrepancies across the state line because

                                        the whole  point of having a Federal agency, it seems to me, is

                                        to  take care of a  problem that is apparently a common problem
                                                                                                                   -  46  -
HESTON and HnwEU
IUPORTING SIRVICF

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 state to state, and it's absolutely preposterous that you can

j come ur here as Federal officials and tell us that you don't

j have an answer on what's going on over there, and you don't
i
1 have any ready answer for the questions, and that you don't

jhave any well worked-out plan of coordinating things.  The

 whole point there being a Federal agency is to smooth things

 out in situations that are between states.

'       MR.  MOCHNICK:  And I would agree,  and when I said I

 didn't have an answer, what I meant was  we don't know what the

 Waste Allocation Study is saying, and I  think Mr. McAdams'

 question was dealing more with the treatment level —

       MR.  GUMPRECHT:  But it sounds like you don't really have

 a  way of coordinating things right now.

       MR.  MOCHNICK:  Well,  I'm not the person probably to ask.

 I'm not  involved with the Waste Load Allocation Study, I'm

 involved with  EIS on the Coeur d'Alene Wastewater treatment

 plant.   There  are people in EPA,  in fact,  who are on  the

 review committee of that Waste Load Allocation Study,  and it's

my understanding that  there has been some  coordination with the

 State of Idaho in the Waste Load Allocation Study.   I don't

 know that  there has been any coordination  with the City of

 Coeur d'Alene,  if Mr.  Tinkey can add to  that and tell  us  what's

 going on with  the State  of  Idaho  with the  Waste Load  Allocation

 Study.   I  do not know if they have contacted the City  of

 Coeur d'Alene,  but I imagine the  State has worked with them.
                            -  47  -
MESTON and HOWELL
REPORTING SERVICE
 Iwilii'il Mioilliinil Bc-i'Oflm
 |p*nlc.n W I/II8I IK 1111
Ow iHLnf M (;ra|C6'«W
                                              MR. TINKEY:  Well, the first phase of the Waste Load

                                        Allocation is for an assessment of the river and the impact   ^

                                        on Long Lake.  The second phase that hasn't been started yet

                                        will be to work out various methods for allocating the waste  j
                                                                                                      !
                                        loads.  That hasn't even really started yet.

                                              MR. GUMPRECHT:  Yes, but there's been a  clamp placed on

                                        sewage hook-ups in this area.

                                              MR. HOCHNICK:  Hot because of the Waste  Load Allocation .

                                        Study?                                                        '

                                              MR. JONES:  What  I think he's getting at is  in our area i

                                        there is a clamp, unless you have  five acres you don't  put

                                        down a septic tank over the aquifer.   In  Spokane Valley there >

                                        is no such clamp that I know of.   In  fact,  the Spokesman

                                        Review spoke to  it, and said they  ought to  do  something, but
                                        nobody is, and we get blamed  for  it  and  they're doing it.      j

                                        That's what we're getting  at.                                  j

                                              MR. WELLS:  My name  is  Tom  Wells,  I'm an employee with  i

                                        the City of Coeur d'Alene.                                     j

                                                 Several weeks  ago  I  attended a  meeting in Washington r

                                        or in Spokane of that waste load  allocation rule.   At that    j

                                        meeting the State of Washington -- and what was of even more

                                        concern to me was the City of Spokane were directly discussing

                                        how to allocate waste loads,  and  were talking about what Idaho

                                        and Coeur d'Alene in particular would be allowed to discharge

                                        to the river.  So,  I think the City's concern is that not only
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REPORTING SERVICE

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K)
 that we be kept informed of what's happening,  but that we be

 given the same opportunity to participate that the City of

 Spokane has.

       MR. MOCHNICK:   I would agree.
           Al'l :e                  AVi-.oi
       MR. MeWilS:   My name is Ed Morris,  and  I'm  a resident of

 Coeur d'Alene.

          I would  certainly agree with  everything  that Tom

 Wells just said,  and  I think over about the past  year I've

 served on a 201 Study Committee for the City of Coeur d'Alene.

 At different,  times  we were led to believe that at least the

 assessment for  discharge into the Spokane River and the Waste

 Load Allocation Study had been completed, and  perhaps some

 discharge criteria  or some guidelines  had been drawn up, and

 I think maybe Boise had a lot of input  into that,  and maybe

 the EPA did,  and  maybe the Department of  Ecology,  and the City

 of Spokane,  but it  doesn't take a real  smart individual to

 look at a map and see that the people  that are impacted

 directly, and the people that really have a vested interest

 and the people that live along that river where it's behind

 the dam are the people from Coeur d'Alene down to  Post Falls

 dam.  Those are the people that should  be involved in that

 Waste Load Allocation Study.   They should be — they should

 have an input,  they should have the input into the design

'criteria, and to  the  best of my knowledge those people have

 had no input  whatsoever.  It's kind of  a  farce to  let
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                                                    IIFSFON and IIOWELL
                                                    REPORTING SERVICE
                                                                                         1R
Washington draw up a Waste Load Allocation Study  and  tell      j

Coeur d'Alene and Idaho what it is or to let  some Boise

officials have a little bit of input into it, and then we  have

to live with it.  So, I would certainly encourage you people,  '

first of all, go back and sidetrack that study  and reassess

some of your conclusions in view of that, realizing the very

limited data input that you have.                              '
                                                               i
      MR. MOCHNICK:  May I ask you a question?  What           .

conclusions did you find that EPA is using as a result of

that Waste Load Allocation Study?

      MR. I^G&RJifi-:  Well, I think some of the  discharge         |

criteria for the sewer plant are based upon discharge levels   ]
                                                               j
arrived at under the Waste Load Allocation Study.              i

      MR. MOCHNICK:  Okay, the Waste Load Allocation  Study,    '

however, is not completed, and I would say that at this point

that the numbers that have come out were — could be  estimates ,

in the State of Idaho and have not been based on  that, but I   i

agree with you on your other concerns as far  as the impact it  i

could have and the need certainly for coordination with the    j

State of Washington.                                           !

      MR. MeRftls:  Well, then, I think many of us have been    i

lead to believe that there are at least some discharge

criteria that are guidelires because where we originally

started out with the design for a sewer plant was:  What is

our discharge criteria?  And we asked the EPA, and we couldn't
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                                                                                                                                   REPORTING 'ERVICt

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U)
 get  a definite  answer;  and  we  asked  the  State of  Idaho, and

 we couldn't  get a  definite  answer; and  I think  that probably

 the  last meeting that we  had we  found out that  we've got  some
I
' rough guidelines,  and some  parameters to work within as those

 criteria seem to be  changing now in  view of  the budgetary and

; nonetary constraints which  I don't think is  necessarily a

 good policy.  That means  if you've got money, then you design

| for  the most stringent criteria,  and if  you  don't have the

 money, then, gosh, what can you  do for us?  Why don't we  sit

 down and find out  what we really need in terms  of discharge

 criteria,  and only make the people of Coeur  d'Alene build to

 those standards and  let's quit trying to fool somebody.   Let's

 lay  all the  cards  out on  the table,  and  nobody's  willing  to

 do that with the City of  Coeur d'Alene.   They want them to

' build a new  plant, but they don't want  to give  them any

 discharge  criteria or involve  them  in that discharge criteria

 or involve them in a Waste  Load  Allocation Study.

       MR.  MOCHNICK:   Okay,  Dick, would  you like to speak  to

 that?

       MR.  BAIN:  I'll just  read  the  record.  We did — as a

 facility planning engineers and  discussed this  with the

\ Citizen's  Committee  — received  guidance on  February  13,  1980

 from the State  of Idaho,  Division of Environment, and  in  a

| meeting which was also attended  by EPA,  these  facts:   "The

i total phosphorus limitations based on the present State of
                                   -  51 -
                                               HESTON and HOWFLL
                                               REPORTING  SERVICE
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                                                                                          M
Washington policy  for  the Spokane River which requires 85     |

per cent removal of  total phosphorus for discharges over one

million gallons per  day,  the  policy has been established to   ]

reduce putrefaction  problems  in Long Lake below the City of   '

Spokane.  When the joint  Washington, EPA, and Idaho Waste

Load Allocation Study  is  completed,  the State of Idaho will   '

be expected to control  their  phosphorus sources of which Post ;

Falls and Coeur d'Alene are the most significant."            |

         That written  statement, which was provided to us and j

to the Committee at  that  time,  was reiterated later by EPA,

Region 10 in a letter  dated August 6,  1980.  So, I think it's

a matter of record that we've had that kind of guidance, and

it has been limited  to  the Waste Load  Allocation Study.

      MR. GUMPRECHT:  But that's exactly my point.  You still

haven't involved Coeur  d'Alene  in those studies.  However,

you've told them that:  By the  way,  the State is involved,  and

EPA and the Department  of Ecology in Washington are going to

draw up these standards,  but  they are  not involving anybody

else in them, and  no input as to what  they are.  Yet,  I agree.

You've  told the City and you've told  the citizens:  Yo\i are

going to be held to  those standards.  And you've given nobody

input into drawing up those standards.   You've merely told

them that they are going  to be  held  to  the Department of

Ecology standards  in Washington.

      MR. MOCHNICK:  Do we have some other questions?
                                                                                                                        -  52  -
                                                  HFSTON and HOWPLL
                                                  REPORTING  SFRVICE
                                                   i ,-.1.1.1' I '', I'h.r, I I . |."l, ,',
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       MR. McADAMS:  Gene McAdams, again.

          This is related obliquely to environmental considera-

I tions, I believe, but the philosophy that we've been operating

 on here in the City is that — it's been in the Federal

 registry, and I haven't read it for the last couple of years,
i
1 but I think that the intent of Public Law No. 92-500, however,

 was to inprove the quality of the water in the streams in the

 country, et cetera, et cetera, et cetera.  The intent of that

 legislation also required that any grant that was to be

 received by any community would be for all practical purposes

 a one-tine grant.  In other words, the local community would

j get the project together, they would build it, and then after

 it was built would assess an adequate monthly service charge

 or some form of generating money to guarantee that the future

 rebuilding of that plant would be built with the community

 resources and without accessing the Federal government.  We've

 been building under the assumption that the grant that would

 be allocated for all practical purposes to the City of Coeur

 d'Alene would be a one-time grant, and, of course, when we

 talked about 75 per cent Federal money, 15 per cent State

 money, the objectives of the Mayor and the Council has been to

 build the best plant possible that will last for the long term,|

 that could be added to flexible -- et cetera, et cetera, et

 cetera.

          When we started out, the first phase of the project
                             -  53  -
HESTON and HOWELI.
RCPORTING SERVICE
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(oriuilMint. M IW «>' H/"H
                                        for  the selected alternative,  which is Alternative E, was a  j

                                        4.2  million-gallons-per-day plant at a cost of — gross cost

                                        of just under  $15 million.  We were advised because the United

                                        States  Congress was not able — for a variety of reasons —

                                        to provide sufficient funds to the State of Idaho so this

                                        project could  be funded, that we would be required to build a |

                                        2.1  MGD plant.   Our estimated cost of that was about 11 million.

                                        We're now advised that — and only speaking now not to growth •

                                        cost, but to the Federal participation of the project, we've

                                       jbeen informed  that's in the neighborhood of 3.27 million for

                                        the  Federal government's 75 per cent share.  I think in the

                                        consideration  of this project, and in relation to the considera-

                                        tion of archaeological environmental impacts, it's very

                                        relevant to know specifically if any grant given the City of   j

                                        Coeur d'Alene  at this time will be considered a one-tirne grant |

                                        or if it's funded at this reduced level if it will be          [

                                        considered as  a temporary fix, and whether or not the City will

                                        be entitled to start over again at a future date because of

                                        today's funding shortages.

                                             MR.  MOCHNICK:  I'd like to have Mr. McFall respond to    '

                                        that or Mr. Tinkey.

                                             MR.  McFALL:  Well, the one-time nature that you question,

                                        if it turns out that the funds aren't available, there's       |

                                        nothing that EPA can do about it.  The only thing we can do is i

                                        itake the funds that are allocated to Idaho, let Idaho          I
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                                                                                                                                     RFPORTING 5FKVICF

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                                                                     1
(Ti
Ul
i designate which  cities  are  going  to  get the funds for the
 particular year  in question,  and  then go through the
 administrative processes of allocating these — or obligating
 those grants  to  those communities, and at the current time
I
 you're  talking about $3.2 million.   I think you're talking
i
j about 1982 money.  1982 money hasn't been authorized by
 Congress.  1981  money is currently available, and we're
 talking about, I think, the project  priority list for the
 City of Coeur d'Alene has something  like $800,000 on there
 for design money, Step  2 money.   So, anything beyond — well,
 let me  draw a precaution there because we've heard some
 rumblings that there may be some  constraints placed on FY
.  '81 money, and further  constraints on FY  '82 to the extent
!                          I*-
i that there may be no FY '-80" money at all.  So, when you say,
l you know, is  this going to  be a one-time grant, well, I think
 in light of today's political and economic climate, you know,
 whatever comes down the road, we  can't promise anything beyond
 that, and we  hope that  what's on  the priority list will be
 available when you are  ready  to use  it.   I don't know how we
 can say anything much beyond  --
i       MR. McADAMS:  Warren, .1 recognize that, but as far as
I
I we are  concerned, the project that's under consideration now
  is a -- if you will —  a Band-Aid expansion, possibly at the
j present site, and  I don't  know what  that  entails, but I'm
' concerned that the City has one nickel to spend, for example,
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                                              HESfON and HOWELL
                                              REPORTING  SERVICE
                                               luMiM Shc.illumi R^nKm
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and if we're only funded one time, and  if.  that one-time
nickel expenditure is going to be the Federal entitlement  for .
evermore, one alternative that could be considered,  perhaps,
is to do nothing until such time as the discharge  permit
requirements are lessened.  Until such  time  as more  funding
is available or until such time the pressure gets  so great or
you've re-evaluated the sole source designation  on the
Rathdrum aquifer, that you will allow a development  here       |
similar to that that allegedly is taking place in  Washington. !
      MR. McFALL:  Those are all good concerns, and all good
possibilities.  I mean, you could consider all those.
      MR. McADAMS:  I can remember when I  used to  go to  the
store with my nickel and I was very careful  as to  what I  was
going to spend it for because that's all  I was going to  get
that week.
      MR. McFALL:  I think as we discussed before, I think
that's a very important part, I think.  You know,  it's one
thing that when we're talking about not an unlimited source
of funds, but certainly a solid source  of  funds, and we can
look ahead for the 20-year project life,  and we  can  plan  for
20 years down the road and be relatively  assured that the     !
funds will be forthcoming if we stage  this project five years !
at a time or whatever it might be.  But we're  suggesting here
looking  at a very risky situation  from  the funding standpoint,
and I think your idea about looking at  what you  can  buy with
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                                                 HESTON and HOWELL
                                                 REPORTING  SERVICE

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cr\
en
 that nickel is the way to. go.   I  think you have to look at


 the increment which you can buy for  that amount of funds, and


 if all you get is a small amount  of  money put aside to build


! a facility, then I think  it behooves you —  it behooves all


i of us as public officials to assure  that the project con-


 structed is the most project for  the least amount of money.


       MR. McADAMS:  All I want  said  is simply this:  That the


 project contemplated is temporary, and it wouldn't take our


 nickel.


       MR. McFALL:  Are you trying to qualify your project as a


 temporary project?  I don't understand.


j       MR. MOCHNICK:  Could we have one person at a time,


1 please.


          Vlarren, do you want to —


       MR. McFALL:  I was  trying to understand Mr. McAdams'


 question with regard to the temporary nature of --


i       MR. McADAMS:  I'll  expand that a little bit.  I think


 from my viewpoint that Alternative B is  in an area of the


 City that will have demands upon  it  to expand.  You've already


 heard from North Idaho College, their proposal for development


 there, their plans to move some of the manufacturing operation


 from that area.  I believe that the  Citizen's Advisory


 Committee and the City Council  have  gone on  record and have


 stilted that the most desirable  permanent site is Alternative


 E, that  is, down river.   And what I'm trying to say is that
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                                               HESTON and HOWELL

                                               REPORTING SERVICE

                                                (pil.ln'l Miinlln'iil HI'ILKI. r.
                                                |p»i'iim H (PHI) Mf- I III
                                               «! M', I'll

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 reconvene the meeting at 9:21 p.m.  We will  continue with our
 question and answer section, but before we do,  one quick
 announcement:  For those of you who have not read the EIS —
 most of you seem to be very familiar with it — there are
                          A*.
 some summary documents of EIS up here at the front table, and
 if you'd like to have one of those, be sure  to  pick one up.
       MR. BAIN:  I have a carry-on question  to  take up where
 we'd left off.  I want to rephrase Gene McAdams'  question to
 you, Warren, and see if we can get an answer that I think is
 real.  Basically, if the City were to take the  existing site
 and do what I'll call a quick fix or a — I  don't want to
. use the term Band-Aid, but some sort of minimal improvement
 to get to capacity and was looking at that as an interim
; measure, and it had to go to another plant later, and they
. got grant money for this quick fix, could they, if the grant
. program cranks up again in a few years, is it possible for
[
', them to at least be considered for grant money  in the future
 to move down river?  I guess that's the essence of the
 question as I understood it.
       MR. MeADAMS:  Yes.  You did a better job.
i       MR. BAIN:  Is it possible or are they  administratively
 out?
       MR. McFALL:  I may have to ask some questions or do
 some supposing before I answer because it depends on whether
 or not that segment that's constructed meets the ultimate
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HESTON and HOWELL
REPORTING SERVICE
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CXI
 concerned about  that.   And  that's  where we  are  coming from.

|       t!R. McFALL:   I would  like to carry  that on because  I

] put that supposition in there  that if  it  did make  the

 Affluent limitations that we wouldn't  be  prejudiced, but  the

 other thing  is,  obviously:  Well,  what if it doesn't?  Okay,

 what if your  first  piece of work just  provides, let's say,

 secondary treatment for an  additional  growth increment, and

 the Affluent  limitations would  be  for  something a  little  bit

 nore stringert than secondary  treatment,  then in that case

 we would consider that  increment — that  construction

 increment wouldn't  be -noofo-iatp  the Affluent  limitations, and,

; therefore, it would be  only a  segment  of  the total facility,

 and in that  case we would have  to  get  a schedule for the

 remaining segment to bring  it  up to the water quality

 standards.  We would need a schedule or basically  a

 corraitment from  the City that  those additional  facilities

 would be constructed to bring  the  project up to a  full

 operating treatment plant that  would meet the water quality

 standards.
i
          Does that  complete the picture?

       MR. JOHNSTON:  Basically, yes, but  you know, we've

 hired Brown  and  Caldwell to get us at  that  point in view  of

 what you've  said about  FY  '81  being even  cut back, FY '82

 possibly not  even being.  We've asked  Brown and Caldwell  to

 get us the best  plant for the  money that  we could  possibly
                                    - 61 -
                                              MCSTON and HOWELL
                                              RFP0RTING SFHVICE
                                               r.ciMi.'rt Viuillidiifl Id intiV'K
                                               iKHlin III I/II8I I'd IHI
                                              Com, if Alrnr III |?I|P| H,l 8,M1
 attain,  and  I  have recognized what you said, but I still say

 we have  to also  be assured that that isn't our last chance

 because  for  the  last three years we've been marching toward

 that ultimate  goal of what we both want, and that was the

 best and  largest and most cost-effective plant that was

 attainable.

      MR. McFALL:   Okay,  then I don't mean to step backward

 and change hats  or change stories, but I guess I have to ask

 you a little more,  then.   I guess I thought you were saying

 you were  changing  your favorite alternative -- your favorite

 alternative  was  to expand at the existing site.

      MR. JOHNSTON:   No,  Alternative E is still our ultimate

 goal, but we recognize that as unattainable.

      MR. McFALL:   In that case,  I guess we will have some

 trouble because  it wouldn't fit into the total picture of the

 two-year projections.

      MR. JOHNSTON:   That's why we've hired our consulting

 engineers.   He is  going to be working with the 201  Advisory

 Committee, and we  hope that we can arrive at a solution with

 the money available  that  will speak to some program,  which I

 don't know at this  time.   We hope that the Advisory Committee

with the assistance  of  the consulting engineers can come UD

with this solution  that is going  to get us to the most cost-

 effective plant  and  the highest level of treatment  available

with«'the existing  funds available.
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                                              HF.STON anil H (H F L I
                                              RFPOIUIir.  5FRVICI

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(Ti
       HR. MOCHNICK:   We  have  someone who might want  to  add  to
 this.
       MR. THOMPSON:   My  name  is Bruce Thompson,  a  resident  of
, Coeur d'Alene.
          Warren,  I've got to  ask you another  question that's
' going to duplicate one you've just been asked, but I didn't
 understand  your  response.  Let me put it this way:   If  the
 City does fix up the  existing wastewater plant at  the present
 site, and those  repair jobs do raise the quality of  the
 Affluent, and it does meet the permit limitations  say for the
 next five to ten years,  my question is this.— it  relates
 back to  the one  time  only funding — if the City does,  in
 fact, meet  the Affluent  limitations with  the Band-Aiding,
' then I would say that EPA would not participate  again in
i
 funding  a plant  at site  "E because those repairs  are meeting
 the Affluent limitations.  Why would you come back in and
 fund it  another  time?  I thought your answer was going  to be:
 Ho, we won't fund it  again since the fix-up does,  in fact,
i meet the water  quality standards for the river.  But you said
 something different,  and it confused me.   What were you saying
 in fact? Was  it that or something else?
i      MR. McFALL:  Well, if I can try to answer  that:  It may
 be that  my  answer is  coming across slightly confused because
 ', I am  thinking  out loud now because this is a new area,  but
 what  —  I  think the  key thing that we've got to concentrate
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                                               HESTON and  IIDWELL
                                               REPORTING  SERVICE
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on is:  What is the project  that  we are focusing on for the
20 years, okay?  Our rules right  now say that if we are to
going to fund the project, you  must specify what is the cost
effective solution for  this  20-year picture.  Now, of that
selected project, we can  fund any increment of that, all right?
We can fund it on incremental basis and funds being available,
we can come back and fund the next increment.  Now, if you
determine that your selected alternative is Alternative E,
then you want funding to  build  on Alternative B, then we've
got a problem because then you're saying:  Let's put Federal
and State and local funds in other than the cost effective
alternative.
         Now, there's only one  situation where I know that we
can help you on that, and that  is where we provide interim
emergency-type funding, which we have done in the past, and
I've never  seen a project here  in Idaho that's been funded
under that, but we have provided emergency-type funding as a
get-by solution, a Band-Aid  solution — that word has been
used — that just recognizes that there is some cost to just
get you by, but I can't give you any guideline.  If that's
what you are proposing, then I  can't answer your question.     |
      MR. JOHNSTON:  But  you're asking us to commit to  20      [
years, and  you're telling us you are not even going to commit
one year.
      MR. McFALL:   I'm  not  asking you to commit to 20 years.
                                         			         .	i
                                                                                                                          -  64  -
                                                  HFSTON and HOWFLL
                                                  REPORTING StRVICE
                                                   Ulliliul Sh'i 'I!'!"'1 Ni'p f1«",
                                                   II«.'|,>M 1,1 I.,if! '".' 1)31

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 You've instructed your engineer,  he's  using our guidelines;

j our guidelines say that  if we  are to provide  funding for a

j project, it must be shown to be part of  the 20-year package.

 I'm not saying that you  need to commit for the full 20 years

 I'm saying what you need to do is determine what alternative

 you are going to select  based  on  looking at the alternatives

 over 20 years; not over  two years,  not over five years, but

 over 20 years, and then  once you  select  that  alternative, then

 let's start funding it in phases  and stages,  but if we select

 that one alternative we  can't  jump to  another one and then

 fund that one.  That's the problem we're having, you see.

 The only way we can do that is on an interim  emergency-type

 basis .

       MR. JOHNSTON:  Can I finish up by  just  saying this:

 What I hear you saying is that you are not saying that if we -

 because of the lack of funding — take something on this year

 that that is our last shot?

       MR. McFALL:  Unless —

j       MR. JOHNSTON:  Well, now you get another  "unless" in

 there.

       MR. McFALL:  I'm saying  what you want to do, if you

i want to fund the Alternative B, and if that is what you've

 selected  for your  20-year alternative, I don't  see any

 problem,  but when  you select Alternative E and  then want to

'  fund B, then we've got a problem.
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HESTON and HOWELL
REPORTING SERVICE
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      MR. MOCHNICK:  May I ask a question, Warren?   How about

Alternative E under a phased situation?   I think that's what

the Mayor was saying.

      MR. JOHNSTON:  Wei:., except, Roger,  I  think I recognize

that under Alternative E you can't build  a nev; treatment

plant, you can't put in a clarifier  and let  it sit  there for

five years until you get money to put  in  a trickling filter or

whatever — and here I'm getting in  a  technical area I don't

know much about — but you've got to build a whole  plant.

That's what I hear; is that correct?

      MR. TINKEY:  You should build  an operable fraction.

      MR. JOHNSTON:  Well, I didn't  understand that you could

build operable fractions and have a  working  plant and meet the

guidelines for the discharge permits and  the rest.   I didn't

understand that that was available.

      MR. McFALL:  If you're talking about building a naw

plant at a new site, then you'd have to commit to an operable

facility which would eventually take you  through the Affluent

limitations, but you can build it in segments if you wanted.

We have been told that we can award  a  grant  on anything that

you can write a contract for.  Okay, so we can build it in as

many segments as you want, but if we are  talking about a

segmented facility, you're going to  have  to  — in thnt case,

there needs to be a commitment on meeting the A

limitations.  I can see your confusion.
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I        MR.  MOCHNICK:   We have another question.   Sir?

I        MR.  EEHTLEY:   I'm Elton Bentley,  and  I'm  on the Citizen'

 Advisory Committee.

          I'm  interested in the term "operable fraction";  is

 that  it?   Could  we consider Option B as an  operable fraction

 of  the total  picture?

          Now,  I  promised myself I wouldn't  say  anything

 tonight, but  I think in more simpler terms,  and I will have

 to  admit that  I  get  quite confused on some  of this discussion

 here  on what we  can  do  and can't do.  Could we  consider  the

 present site  as  a fraction of the total solution for  our

 sewerage disposal problem?

        MR.  MOCHNICK:   Warren, would you like to  respond to

 that?

        MR.  McFALL:  I think probably Dick Bain ought to answer

 that.   I mean, really,  because it's really  a design question.

 It's  a question  that relates — that your engineer should

 answer because if he's  determined that the  existing facility

 can fit into  the total  cost-effective alternative, then  it

 can.

        MR.  BAIN:  If  you take it simplistically, and say

I Alternative E  is our goal, Alternative E, by definition, does
i
 not involve any  facility at the existing site.   If you say

 Alternative E  is our goal but we can't get  there from here

 because of money, we want to someday, and meanwhile we've got
                             - 67 -
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                                     72
an existing plant, let's make use of  it  and hope  for  the best

in terms of two things:  One, a grant program in  the  future;

and two, some income from hook-ups.   Then one way to  get

there is start raising some revenue and  hoping for a  grant

program in which case some improvement in terms of capacity,

now, at the existing site would allow you to stay in

compliance, which is important to the City and the EPA, and

allow you a way to provide some income to the City that we    I

could net in a reserve fund for future expansion  either there ;

or some other place.  And three, the  hope that the grant      i

program will come down back to life,  and if it does,  then     !
                                                               i
they wouldn't then be barricaded from a  future appeal to move .

down river and then abandon it.  So,  it's just an implementa-

tion step.  You could lay it out in a schedule, that's the

only way to get there because  there's no money, but if we are j

told that anything you do at the existing site is by  defini-

tion a departure on another trail,  then you are obviously shot

down from a future grant, and  that  would worry the City.

         If you've got to take some action, then, you don't

have enough money to commit to a down river situation unless

the City is willing to pass a  rather  large bond issue and

commit to a future action without  a grant, since they can't

be served another grant.

      MR. MOCHNICK:  Mr. Tinkey?

      MR. TINKEY:  This would  work  in one way:  We've been
                                                                                                                   - 68 -
                                              HESTON .mii  HOWCLL

                                              KEI'dRllNfi  SERVICE
                                               (••(I'lKi! Mi -I	I I •'(. ,', •
                                               l.ci 1,11 1,1 I HI •••, I Ml

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| talking about whether you can  dump  money  in  the other

I solution,  if we put  a limited  amount  of funds  into Alternative!
i                                                               |
 B, and it  only bought you five years  capacity, and at the end >

 of the five years the grant  program became available again and

 you used up your capacity, sure,  you'd be eligible for new

 funding at the new site.   Of course you would, because you'd

 be in need again.  What EPA  doesn't want  to  do is waste money

 building capacity just to  abandon it.

       MR,  McFALL:  Do you have anything to lose by telling

 yourselves that what you want  to  put  your money in on now is

 the existing plant,  and somewhere down the road we might

 change our mind, but to make sure that we have got a project

 that is compatible with the future  needs  —  if in fact the

 grant program isn't available  —  and we don't get a lot of

 funding,  do you have anything  to  lose by  just saying:  Well,

 let's say today that Alternative  E looks like the best way to

 go,  and for the 20-year haul we're going to go with

 Alternative B.   Okay, do you have anything to lose from that

 standpoint?  From our standpoint, if that's what — and like

 Roger was  saying —  if you build  a five-year facility,  it is

 fuJly operated  and meets the .affluent limitations, five years

 down the  road you re-examine your alternative and decide:

 Well,  although  five  years ago  it  looked like over the 20-year

 haul  siting at  this  existing site was the way we wanted to go,

 but  today  we  decided that, well, we want to — I can  see  where,
                            - 69 -
HESTON surf HOWELL
REPORTING SERVICE
 O;i Itfl '.hirUm.'! l'i |n,M. •>,
 lc*i I'iri hi (,TI1'| IV, I l!l
Cnruf tl Akiic Itl |/[)R| ! 8?M
                                        you  know,  you could change courses.  But, see, our problem — i
                                                                                                       j
                                        and  I  hate to throw a bunch of red tape here, but if you

                                        start  funding something that is not the 20-year solution,     [

                                        we've  got  a problem.  That isn't part of the 20-year solution.!

                                               MR.  MOCHNICK:  I think that we've probably discussed

                                        that one question,  that we didn't have an answer for, at

                                        length.  Let's move on to — maybe Warren can get together — i

                                        and  I'm sure we will be getting together with the City of

                                        Coeur  d'Alene to discuss future grants, and certainly new     !

                                        alternatives and some other costs, and go into it then.

                                                 Do we have any other questions?

                                               MR.  SCHULER:   I want to — on the-basis of this
                                                                                                       I
                                        discussion, I want  to re-emphasize again, though, the         j

                                        situation  that the  college is in.  I hope that you are all

                                        aware  that the replacement value of that college campus and

                                        the  buildings on it is today well over $20 million.  In other

                                        words, much more than what the plant was supposed to cost on

                                        site E.  We have no alternative.-  With that kind of investment

                                        and  commitment having already been made in that area, the

                                        State, the Federal  government, the local taxpayers have all

                                        contributed to that development.  Amortization schedule on

                                        the  buildings is 50 or 75 years on the newest ones, so they

                                        are  going  to be a long-time there.  I dor. "t think that the

                                        State  is going to be willing to commit on a second campus site

                                        to serve the students of this area in five northern counties.
                                                                                                                  - 70 -
HESTON and HO.iflL
REPORTING M RVICt

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Ul
   So,  I  guess  what I'm saying is that I think we all have to
  i
   keep in mind that that is the only place we have to grow.
   The Coeur d'Alene sewage plant today is  effectively
  i amortized, it's  life expectancy has been lived out. They now
  ; have the alternative or the option to go to a  different site
   and commit the millions of dollars that  will be necessary  to
  , build  another plant  at that site.   We don't have that  option
  | anymore because  our  funds have already been expended.   So,  I
  | think we really  have to look at Site E,  and I  can't emphasize
   that strongly enough.
         MR. MOCHNICK:   Okay,  thank you.
         MR. THOMPSON:   I have a question for  Mike.   It deals
   with one of  the  recent impacts on  the City  with this project.
  | It would seem to  me  that sometime  ago, eight months, ten
  i
   months, twelve months  ago people in higher  positions had to
   be aware of  this  funding crunch that was coming.   It's not
   created all  this  consternation on  this project,  it's probably
'•  the most significant impact that we now  have on the City,  just
 '  the fact that the money is  not there.  I can't fathom  or
1  'believe someone,  some  people,  or some group didn't know a year
 '  ago at  the time that we were  approaching this  problem  now  that
   we can't seem to deal  with  very effectively, and  I don't know
  [if anybody knew that a'long-time ago or  if  they  did, why the
'' iinformation didn't get to the Citizen's  Committee  or the
  jengineers or someone because  we all  did  go  down  a  certain path
                                   - 71 -
                                                 HESTON and HOWELL
                                                 REPORTING SERVICE
                                                  CerhM Shorthand Ri'i»ml»is
                                                  Initlon. M |?l») 7«f.n31
                                                 Co'ui d Unit M 1203) fifj'SPM
6
7
8
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10
11
12
1?
M
Is-
16
17
18
19
70
21
22
assuming certain things would  happen,  and they didn't
materialize, and here we  are.   And I just can't believe that  I
we didn't — someone didn't  know that we were going to have   I
this terrific funding crisis that's now upon us.
      MR. MOCHNICK:  Mr.  Tinkey,  would you like to respond to
that?
      MR. TINKEY:   I just wanted to know who he voted for for
President.
      MR. THOMPSON:  That's  not answering my question.
      MR. MOCHNICK:  No,  but as far as being in upper
positions,  I think  we have found out -- tonight on the six
o'clock show of President Reagan, I think all kinds of things
will come out of that as  far as funding goes.  I don't know
that EPA heard any  rumor  about funds months ago.  We're
hearing one that Warren mentioned a minute ago that there
might not be any construction  grant money.  We don't know,
and that's  as a result of the  last few days, that I started
hearing that rumor, and  I think that that will probably —
something like that could very well happen, and the next few
days should tell us.
         What I guess —  in answer to your question, yes, I
think it can happen that  overnight you may find funds,
Federal funds disappearing,  and that is not necessarily
something that's known  for many years down the road in advance
of how a program is going.
                                                                                                                          - 72 -
                                                  HESTON and HOKELL
                                                  REPORTING SERVICE
                                                   CfrMu'd M><.ithvvl l;<-pi '"'•
                                                   lr« <,![«! Ul |,.WI III 11)1
                                                  riirin il»Wi. I.I ('ill'] I1 . H '!

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        MR.  BENTLEY:   Elton. Bentley, again.


           I'd just like tc change the formula from what we can


  do  to  what we can't do to simplify it a great deal,  and just


  admit  we  can't continue to dump untreated sewage into the


:  Spokane River,  and  then go on from there.  That wouldn't be


;  half as confusing to me as some of these things that we've


  been discussing,  what we can do.  We might go back to


  outhouses.


:        MR.  HOCHNICK:   Okay,  do we have some other questions?


  Mayor  Johnston.


        MR.  JOHNSTON:   In the Environmental Impact Statement


I  you have already  addressed items based upon previous


  suppositions.  Alternative E,  B,  G, the rest.   Is this


j  Environmental  Impact Statement now going to readjust and


1  speak  to the  issues  that have been spoken here tonight and in


  effect reduce  funding,  is your Environmental  Impact


:  Statement  going to  respond to that so that we don't  get down


I  the road and get  caught going through another environmental
i

I  impact public hearing?   Have  I made that clear enough?


       MR.  MOCHNICK:   I  think  so, and I'll try to answer the


  question.


          There might be two points:   One, will the final EIS


  reflect the new information that might come out of the new


  alternatives?  Yes,  the final EIS would do that.   If a new


  alternative, however,  is developed that the City is  willing
                             -  73  -
HESTON and HOWELL

REPORTING SERVICE

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 lK.I'lrjll ID |?I|R| 71C, |13|

Conn dAlcne 111 f/(lH|
                                         to select and EPA and the  State  is  willing to fund,  in other


                                         words, a good feasible reasonable alternative,  a requirement


                                         for another public meeting certainly  could be reasonable, and


                                         a meeting would have to be held  so  that that alternative and


                                         those costs can be given to the  public, by virtue of the fact


                                         that at this point we have alternatives and costs that the


                                         public — those ones which attended and came to find out


                                         about, the new alternatives that somebody might be talking


                                         about have not, in my knowledge, been costed out.


                                               MR. JOHNSTON:  Would your  EIS comment on the fact that


                                         there's been a change in the ball game?


                                               MR. MOCHNICK:  Yes,  sir, absolutely.


                                               MR. JOHNSTON: And even possibly speak to maybe reducing


                                         regulations to meet the funding  or  whatever?  I don't know


                                         that that's going to happen,  but maybe there could be comment


                                         upon it.


                                               MR. MOCHNICK:  I would say yes  to that.


                                                  Do we have any other questions?


                                               MR. McADAMS:  I want to ask one quick one, if I may.


                                                  Environmentally speaking,  would it be better for the


                                         City in view of the size of the  Spokane River to consider


                                         possibly two out falls in  order  to  mitigate impact upon the


                                         river, the fish life, epitaph, that kind of thing?  In other


                                         words, the Spokane River is not  that  gigantic a stream, and


                                         I'm wondering if that type of thought process would appear
                                                                                                                   - 74 -
HESTON and  HO«CLL

REPORTING  SERVICE



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'UIUI it 111-.I" I.I I  ' -> ^', * " I

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: meritorious  to  particularly to environmental engineering?

,        MR.  MOCHNICK:   Do you want to respond to that,  Mike?
I
       MR.  RUSHTON:   Well,  I'm not the water quality expert
  that worked  on this report.   I think that there are different

1  environmental  factors for the different choices.   You are
i
  saying  either  having two separate discharge  points or one,

  which is  the best environmentally?

       MR. McADAMS:   With the same MGD and the same level of
I
  treatment.
i
j       MR. RUSHTON:   Right.   1 think for the  same  water quality

  parameters the two  sites would be obviously  givi.ig you better

  dilution  situation  than you'd have with one,  and  therefore,

j  in  the  immediate areas of those out falls would have less of

!  an  impact than one  large out fall, but in terms of other

  water quality  situations, maybe further downstream, say the

  dissolved oxygen sites that  they have up above Post Falls dam,

  I don't see  how two locations that close together would have

I  very much difference in that regard.  So, there's different

j  situations for different environmental parameters.  Also,

I  maybe the dilution  provided  by the two might be better for

I  fish life than one  large discharge, but it's hard to select

  overall which  is the best.

       MR. McADAMS:   Well, what you said is that maybe depend-
i
:  ing upon  the circumstances;  is that what you're saying?

I       MR. MOCHNICK:  I would think that's right,  and I think
                             - 75 -
HESTON and HOWELL
REPORTING SERVICE
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                                      •s

                                      6

                                      7

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                                     10

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                                     12

                                     11

                                     M

                                     15

                                     16

                                     17

                                     18

                                     19

                                     70

                                     ?1

                                     22
                                     25
that depends on the water body,  it  would  certainly,  and the

location of those out'falls  and  the amount of  Affluent being

discharged, that would be a  very good  answer.

      SPECTATOR:  Did I understand  correctly  that if they

adopted plant E as their ultimate goal but it's going to take

awhile to get there that there's this  kind of  rare emergency

grant that might be available  to keep  plant site B going until'

they got there because the City  is  already in  a critical state?

Did I understand that correct?  Is  that a possibility, and

that wouldn't affect the grant for  E?

      MR. McFALL:  Right,  I don't  have any personal

experience on working with the project that's  used that type

of grant, but I understand it's  been awarded before with

other projects in Washington and Oregon.

         Are you familiar with any  of  those,  Roger?

      MR. MOCHNICK:  No,  I'm not.

      MR. McFALL:  But I've  heard interim temporary-type

facilities recognized not to be  pieces of the total project

just to get them over the hill,  I understand that has been

done, but —

      MR. MOCHNICK:  We've funded interim solutions.  I

suppose maybe the one you might  be  talking about is the Bend,

Oregon project.  This is  the one where we have funded an

interim Affluent disposal alternative  and are now in the

process r- or have been  in the process of looking for the
                                                                                                                   - 76 -
                                              HESTON and HQ#ELL
                                              REPORTING  SERVICE
                                                                                                                                      ii.«i.!« M i;i>ni ;i'. I in
                                                                                                                                      rin (I Aldio It (,'fiHi O, ,' H M 1

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 ultimate solution.

       MR. McFALL:  Even though that interim solution did not

 fit into the total -- you don't know?

       MR. MOCHtllCK:  We don't know whether it will, but maybe

 Roger said earlier we have the interim process there.  We

 have a treatment plant, but we did a study on /ff fluent

 disposal, but it was not emergency funds, it was just some-

, thing that was funded and will continue to be funded, I think,

 if it becomes part of the ultimate solution itself/ then all

 becomes grant eligible.  We are guessing.

|       SPECTATOR:  Do you know if there was any conditions in

 there that if it had to be abandoned whether there'd have to

• be a pay-back or anything, a reduction?

!       MR. MOCHMICK:  There was no condition —

'       MR. McFALL:  We can't answer that.

       SPECTATOR:  It seems to me, though, that's an alterna-

 tive that would be well worth looking at, the interim-solution

 type thing to use for plant B.

!       MB. tlcFALL:  I would expect, though, that we would be

 willing to go along with that if the cost were not a

 significant bunch, and don't try to pin me down on that,

 either, but it doesn't seem very prudent to spend a lot of

 money on an interim solution when you know in fact it's not

 going to be part of the total picture, but in the sake of the

; situation, you know, you can see where for a less significant
                            - 77 -
HESTON and HOWELu
REPORTING SERVICE
                                               Com dt'*n» M 1708] 66' tWI
                                        amount of bucks it could work.

                                              MR. BAIN:  Is that something you could check on or do

                                        you know somebody we could talk to?

                                              MR. McFALL:  You could certainly check with Roy

                                        Hllerman.                                                     i

                                              MR. MOCHNICK:  Okay, do we have any other questions.    j
                                                                                                      I
                                              MR. McADAMS:  I want you to know that I could go on for '
                                                                                                      i
                                        another hour or two, but I think everybody is getting tired.  <
                                                                                                      ]
                                              MR. MOCHNICK:  Well, thank you very much for coming.

                                        I appreciate your comments and your questions.  We will be

                                        responding to these in our final EIS.

                                                 I have one written record on a card from a Mrs.

                                        Ferrier that will be put into the record.

                                                 Thank you very much for coming.  We are adjourned at

                                        9:55 p.m.!

                                              (WHEREUPON THE HEARING ADJOURNED AT 9:55 P.M.)
                                                                                                                  -  78  -
                                                                                                                                     HESTQH ind HO*rLL
                                                                                                                                     REPORTING StRVICE

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                    C E R T  I  F  I  C A T E
STATE OF  IDAHO     )
                    ) ss
COUNTY OF  KOOTENAI )

      I, CHARLOTTE R. CROUCH,  the  undersigned Certified

Shorthand  Reporter, hereby certify that I took in stenograph

and thereafter transcribed into  the foregoing record the

proceedings  in the within entitled cause, and that the said

transcript is  a full, true and correct copy of the

proceedings  had in the above-entitled cause held at Coeur

d'Alene, on  the 18th day of February, 1981.

      DATED  This iJtL day of     jA.4^-.A_     , 19 JT/  .
                               CHARLOTTE R.  CROUCH
                               Certified Shorthand Reporter
                             -  79 -
HESTON  and HOWELL
REPORTING  SERVICE
 OM'finl Shurlliaml Pr|jnitr'',
 lp«r,loci. M (?U«| Ml))]
Cnnir i! Alrw. M |?OH|60;e?«

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         Response to Comments Received at the Public
           Hearing on the Coeur d'Alene Draft EIS,
                      February 18,  1981

1.    EPA has participated in the funding of 201 (wastewater
     facilities planning)  and 208 (nonpoint source  pollution
     control)  studies on both the Idaho and Washington sides
     of the Spokane Valley-Rathdrum Prairie Aquifer.  Both
     of the 208 studies concluded that sewering of  urbanized
     areas and restrictions on proliferation of on-site
     waste disposal systems over the aquifer were desirable.
     EPA and other federal agencies have encouraged imple-
     mentation of strategies to achieve these goals.

     While EPA has helped to fund the aquifer protection
     planning, it is not responsible for implementation of
     protection strategies.  In Idaho, the Panhandle Health
     District has been given that responsibility and has
     established policies that are  effectively restricting
     the proliferation of on-site waste disposal over the
     aquifer.   In Washington, a special 208 management pro-
     gram has been established in the County Public Works
     Department.  While the 208 plan has been completed and
     a series of aquifer protection policies have been
     developed, an implementing agency has not vet  been
     established.  EPA has requested that the Spokane '. oa-ity
     Board of County Commissioners  act as lead in this effort
     until one or more agencies officially accept the re-
     sponsibility.   In the meantime,  EPA has urged  local
     planning agencies to use the 208 plan findings to
     develop more restrictive controls on residential,
     commercial and industrial development in unsewered
     portions of the Spokane Valley.

2.    Refer to Mr. Bain's statements beginning on page 29
     of the public hearing transcript for a clarification
     of the untreated sewage overflow situation in  the Fort
     Grounds area.   EPA placed a Compliance Order on the
     City of Coeur d'Alene in March 1979 so that the un-
     treated discharge would be rectified.  The Coeur d'Alene
     facility planning process was  conducted to identify
     ways of correcting this hydraulic overload situation.
     The City is planning to begin  wastewater facilities
     improvements in the near future; construction  is
     expected to begin in the spring of 1982.

3.    The Spokane River waste load allocation study  is being
     conducted by the Washington Department of Ecology,
     partially in response to a court ruling regarding the
     Liberty Lake wastewater facilities plan.  The  first
     phase of this study,  conducted by URS Company, has
                              78

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been completed.  The first phase was primarily a data
compilation effort designed to identify sources of
pollutants in the Spokane River and maximum acceptable
loadings of pollutants to Long Lake.

The Phase 1 report also included a method for allocating
phosphorus loads to the various source categories identi-
fied in the data collection effort.  An example phos-
phorus allocation was made for the Spokane area waste-
water treatment facilities after making various assump-
tions regarding inputs from the Idaho wastewater sources.

This waste load study is being conducted by the Washington
Department of Ecology to aid them in establishing efflu-
ent limitations for Spokane area wastewater treatment
plants; these NPDES limits are reviewed and approved
by EPA.  The State of Washington cannot dictate NPDES
permit conditions in the State of Idaho.  EPA has closely
followed and participated in technical review of the
waste load allocation effort in Washington.  The infor-
mation generated there is being used along with water
quality data collected in the Idaho section of the
Spokane River to establish NPDES permit requirements
in Idaho.

Effluent limits must respond to localized water quality
conditions as well as basinwide water quality goals;
therefore, effluent limits may vary from one stretch
of river to the next.  Dischargers in the State of Idaho,
however, are not being required to meet stricter waste
discharge limits than treatment plants discharging to
the Spokane River further downstream.

The interim improvements described in the Coeur d'Alene
facilities plan are the initial phase of the preferred
alternative, Bl.  This alternative has been proposed
as the 20-year solution to Coeur d'Alene's wastewater
treatment needs.  EPA is now funding the interim im-
provements because they are a part of the selected
20-year solution.  As funds become available, EPA will
accept grant applications for the additional phases
of the selected alternative.  If Coeur d'Alene proceeds
with the interim improvements and at a later date de-
cides to pursue a wastewater solution that is not a
part of the approved facilities plan, grant applications
for this new course of action would likely be denied.
                        79

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This Final EIS discusses the implications of a revised
Alternative B (Bl).   It has been determined that neither
a Supplemental EIS nor an additional public hearing
are necessary to address the plan changes that have
been made.
                          80

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                        BIBLIOGRAPHY
Brown and Caldwell.  1981.  City of Coeur d'Alene wastewater
   facility plan.  Prepared for City of Coeur d'Alene, Idaho.

Drost, B.,  and H. Seitz.  1978.  Spokane Valley-Rathdrum
   Prairie aquifer, Washington and Idaho.  U. S. Geological
   Survey Open File Report 77-829.  U. S. Geological Survey,
   Tacoma,  WA.  79 pp. + appendices.

Esvelt, Larry A.  1978.  Spokane aquifer cause and effect
   report.   Summary report of '208' water quality results and
   cause and effect relationships for water quality in the
   Spokane-Rathdrum aquifer.   Spokane County Office of County
   Engineer.

Geckler, J. R.,  et al.  1976.  Validity of laboratory tests
   for predicting copper toxicity in streams.  EPA 600/3-76-116,
   U. S. Environmental Protection Agency, Duluth, MN.  208 pp.
                              81

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                  LIST OF REPORT PREPARERS
      U. S. Environmental Protection Agency, Region 10

Elizabeth Corbyn - Chief, Environmental Evaluation Branch;
     Seattle, Washington

Roger Mochnick - EIS Preparation Coordinator, Environmental
     Evaluation Branch; Seattle, Washington

Norma Young - Project Monitor, Environmental Evaluation
     Branch; Seattle, Washington
               Jones & Stokes Associates, Inc.
                   Sacramento, California

Charles R. Hazel - Vice President; program management

Michael D. Rushton - Environmental Specialist IV; project
     manager

Mark D. Cudney - Environmental Specialist I; wa :er quaj J.ty
                              83

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                 ACRONYMS AND ABBREVIATIONS






BOD   - biochemical oxygen demand




DO    - dissolved oxygen




EIS   - Environmental Impact Statement




EPA   - U. S. Environmental Protection Agency




FNSI  - Finding of No Significant Impact




IDHW  - Idaho Department of Health and Welfare




MCL   - maximum contaminant level




mgd   - million gallons per day




NEPA  - National Environmental Policy Act




NPDES - National Pollutant Discharge Elimination System
                              85

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        Appendix A
DRAFT EIS DISTRIBUTION LIST
             87

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                COEUR d'ALENE,  IDAHO EIS DISTRIBUTION  LIST
 Federal Agencies

 Advisory Council on Historic  Preservation
 U.S. Department of Agriculture
  Farmers Home Administration
 U.S. Department of Commerce
  National Marine Fisheries Service
 U.S. Department of Defense
  Corps of Engineers, Seattle District
 U.S. Department of Health, Education & Welfare
 U. S. Department of Housing & Urban Development
 U. S. Department of Interior
  Fish and Wildlife Service
 U. S. Department of Transportation
  Federal Highway Administration

 State and Local Officials

 Office of the Governor
 Donald E. Johnston, Mayor
 G. Eugene McAdams, City Administrator
 Tom Wells, Director, Public Works
 John Carpita, Kootenai County Engineer
 Kootenai County Commissioners
 Art Manley, State Senator
 Gary J. Ingram, State Representative
 L. C. Spurgeon, State Representative

 Local Distribution

 Evalyn Adams
 Jerry Adams
 Wally Adams
 John Aguilar
 Eugene M.  Ballou
 Jim Bellamy
 Elton Bentley
 Ronald Briggs
 Roger Brockhoff
 Brown & Caldwell, Seattle, Washington
Jim Burns
 Ray Capaul
Marjorie  Chadderdon
Coeur d'Alene Press
Coeur d'Alene Public  Library
 Larry Comer
Lloyd L.  Conrad
State  Agencies

Idaho  Air Quality  Bureau
Idaho  Division  of  Environment
Idaho  Fish & Game  Department
Idano  Transportation  Department
Panhandle Area  Council
Panhandle Health District
State  Clearinghouse
Organizations

Idaho Wildlife Society
Kootenai Environmental Alliance
League of Women Voters of Idano
Lee Dean
Bill DeCroff
John DeSelle
Everett Dicksion
Val Dicksion
Ford Dunton
Loren R. Edinger
Frank El kins
Dave Finkle
Art Flagan
Jim Fromm
Jim Fullmer
Bill Goodnight
Russell  Greenfield
Joe Haines
Ellen Healy
Kent He liner
                                     89

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                 COEUR d'ALENE, IDAHO EIS DISTRIBUTION LIST
Local Distribution (Continued)

Frank Henderson
Martha Higgins
Edwin H. Jones
Lester A. Jones
Kenneth S. Kirking
Ray Koep
KVNI
Lois Land-Albrecht
LePard & Frame, Inc.
Tom Listen
Jim Markley
Bill McFarland
Charles McLain
Brian Meckel
Meckel Engineering & Surveying
Ted Menzel
Rosalie Moore
Ed Morse
Ted Mueller
Ward B. Newcomb
Dan Paulson
Charles Pearson
John A. Pierce
Post Falls Public Library
David Priano
Tom Price
Hester Pulling
Ma^y Lou Reed
Joe Roope
Lester E. Routh
Herb Sanderson
Clifford Schoener
Lorna Sears
Bryan Shertz
Jack Simpson
Elizabeth Sowder
Spokesman-Review
Jack Spurgeon
Jim Stravens
Whitey Swendener
Fay Sweney
David Tyler
URS Company, Spokane, WA
Roy Wargi
Joseph G. Wark, dr
Bill Wassrnuth
Roy WeiIman
Dave Yadon
                                     90

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           Appendix  B







CULTURAL RESOURCES CORRESPONDENCE
                91

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IDAHO STATE  HISTORICAL  SOCIETY

r,10 NORTH JULIA DAVIS DRIVE    BOISK.  IDAHO 01706
                                                                   STATE MUSEUM
                                   October 13, 1981
Ms. Norma Young
Environmental Protection Atjcney,  Kcyion X
1200 Sixth Avenue
Seattle, WA   98101

Dear Ms. Young:

          We recommend that further evaluation of the Coeur d'Alene
wastewater facility site be conducted.   We realize the current pro-
posal is to expand the present wastewater facility plant.   We also note
that the current facility is in the "heart" of the sensitive area  for
archaeological materials, as defined by the previous (1980) archaeo-
logical research in the area.   Therefore, we recommend that an additional
inspection of the proposed construction site be made to determine  whether
intact archaeological deposits occur.  To do this, it may  be necessary
to place small (1X1 meter) test pits  in the soil in order to determine
the subsurface nature of the area.  If  there is evidence that this land
has been substantially altered or if it can be demonstrated that  no
archaeological deposits occur at  this locality without digging test
pits, then they obviously won't be necessary.

          If you have any questions concerning these recommendations,
please contact me.

                                   Sincerely,
                                   Thomao J.  Gre.cn
                                   State Archaeologist
                                   State Historic Preservation  Office
                                                           OCT 15 1981
93
                                                       tNVIRONMENTAirvALUAllON
                                                              BRANCH

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           U. S.  ENVIRONMENTAL  PROTECTION   AGENCY

                                REGION  X

         "G                   12°°  SIXTH  AVENUE

                        SEATTLE,  WASHINGTON  98101
             443
7  DEC 1S81


 Mr. Thomas J. Green
 State  Historic Preservation Officer
 Idaho  State Historical Society
 610 N. Julia Davis Drive
 Boise, Idaho  83706

 Dear Mr.  Green:

 As requested in your letter of October  13,  1981, the further evaluation
 of the proposed construction site of the upgrade of the Coeur d'Alene
 wastewater treatment plant has been completed by Dr. Roderick Sprague,
 Director  of the University of Idaho Laboratory of Anthropology.

 Enclosed  are copies of his clearance letter and a City of Coeur d'Alene
 cover  letter.  Dr. Sprague has confirmed that there are no undisturbed
 cultural  remains at the site.  Will you please send me your final
 clearance on the proposed site as soon as possible?  We need to include
 the clearance in our Final Environmental Impact Statement.  We hope to
 get the FEIS to the printer by the end of the year.

 Sincerely,
 Norma A. Young
 EIS Project Officer

 Attachments

 cc:  Dick Bain - Brown & Cal dwell
      Mike Rushton - Jones & Stokes
                                     94

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                      Qity   of  Qoewr  d'fllene
                           CITY  HALL
                                              8TH &  MULLAN
                             Coeur d'Alene, Idaho  83814
                              Department of  Public Works
                                             December 4, 1981
Mrs. Norma Young
EPA
1200 Sixth Avenue
Seattle, WA.  98101

Subject:  Archaeological Survey - Coeur d'Alene Facilities Plan

Dear Norma,

Attached is a letter from the University of  Idaho confirming that there  are
no significant cultural remains within the fenced area north of the existing
treatment facility.

The fenced area referred to by Mr.  Sprague includes ail the property prese^ cly
owned by the  City of Coeur d'Alene and, according to the Brown & Caldwell
proposal, is  adequate for the full six million gallon per day expansion.

I assume that this letter will suffice as the archaeological review for  all
phases of the treatment plant expansion presently proposed under the 291
Facility Plan.
Sincerely,
Tom Wells
Director of  Public Works
TW:ho: Attachment
cc: Dick Bain - Brown & Caldwell
    Roger  Tinkey - Dept. of Health  &  Welfare, CDA
    Warren McFall - US EPA
    Gene McAdams - City Administrator
                                                           DEC  7  1981
                                 95
ENVIRON - -     .VALUATION
       tttnnv'ri

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                                                 grc University of Idaho
                                                       Laboratory of Anthropology
                                                       Moscow, Idaho 83843

                                                       1 December 1981
Dick Stauffer
City of Coeur  d'Alene
City Hall
8th and Mullan
Coeur d'Alene, ID  83814

Dear Mr. Stauffer:

     A supplemental archaeological survey was conducted on the
additional  area to be included in the modified treatment facility
for the city of Coeur d'Alene.  Our  findings are that the fenced
area north  of  the existing facility  is  a  fill area and contains
no significant cultural remains.

     I again apologize for the delay in response.

                               Sincerely yours.
                               Roderick Sprague
                               Director
RS:cll
                                 96

  The University o! Idaho is an equal opportunity ,
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IDAHO STATE  HISTORICAL SOCIETY

610  NORTH JULIA DAVIS DRIVE   BOISE.  83706
                                                                   STATE MUSEUM
                                     December 14, 1981
            Ms. Norma Young
            EIS Project Officer
            Environmental Protection
              Agency, Region X
            1200 Sixth Avenue
            Seattle, WA   98101

            Dear Ms. Young,

                  Thank you for sending a copy  of Dr.  Roderick
            Sprague' s report on the archaeological significance
            of the construction site for the improvements to  the
            Coeur d'Alene wastewater treatment  plant.   Based  on
            Dr. Sprague' s report the improvements to  the treat-
            ment facility will have no effect on  significant
            archaeological or historic properties.
                                     Sincerely ,
                                     Thomas J.  Green
                                     State Archaeologist
                                     State Historic Preservation Office
            TJG/kiiih
                                                             DEC  15 1881
                                     97

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