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FINAL
ENVIRONMENTAL IMPACT STATEMENT
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
KING COUNTY, WASHINGTON
EPA PROJECT # C-530475-02
Prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
SEATTLE, WASHINGTON 98101
Regional' Admini
\
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PREFACE
EPA Region X has received 23 letters of comment on the
draft EIS. These comments were considered in reassessing the
project and determining EPA's final decision. This final EIS
documents that decision together with the various comments on
the draft EIS used in the reassessment.
Although there were minor corrections in many subject areas
of this EIS, major adjustments occur in the Air Quality and Ad-
verse Impacts & Mitigative Measures sections. Major new additions
to the text include discussions of agriculture in the Existing
Land Use section, low-flow augmentation in the Water Quality
Impact section and in Appendix E, and includes a chapter "Comments
and Responses to the Draft EIS".
Many comments indicate concern with the secondary impacts
of installing a sewerage system which is designed to handle a
Year 2000 population of 175,000, as determined by the projections
of the Puget Sound Governmental Conference. In general, these
concerns relate to the validity of the population projections;
the adequacy of local land use plans to protect the environment,
including protection from urban sprawl; and EPA's conformance
with regulations and guidelines established to protect the environ-
ment. These issues are answered directly in the comment section.
The alternative selected by EPA is the 72-inch interceptor.
This alternative was chosen because it is designed to handle the
expected population growth in the area, is the most cost-effective,
and will cause no significant adverse primary impacts. The draft
EIS and the comment process did not identify a more cost-effective
or environmentally-acceptable alternative.
To some, such a decision may seem inconsistent with some as-
pects of environmental protection, particularly with regard to
the potential for and impacts from urban sprawl. EPA does, in
fact, find itself in a dilemma concerning sewers and growth. This
dilemma is well-documented in a recent Congressional report (Interim
Staff Report of the Subcommittee on Investigations and Review,
Committee on Public Works and Transportation, U.S. House of Repre-
sentatives, on the Federal Water Pollution Control Act Amendments
of 1972, April, 1975). It states: . . . "in the absence of a
clearly-defined federal land use policy, and with obvious public
ambivalence over economic and environmental issues, how can EPA be
expected to make local growth and non-growth judgments?
In protecting the environment, EPA does not have a mandate to
stop growth and alter land use patterns. This is a fundamental
responsibility of local government. Local and regional officials
agree that growth will occur in the Green River valley with or
without this interceptor. Therefore, EPA must seriously consider
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(2)
growth potential and development pressures as a major factor
in assessing future sewerage needs to protect water quality,
because EPA does have a mandate to protect water quality.
It is also true that EPA has mandates to prevent adverse
impacts on such areas as wetlands and flood plains. EPA cannot,
however, protect these by a broad-brush approach of stopping or
controlling growth or land use. When these areas are directly
infringed upon in terms of impending primary impacts, EPA can then
exercise its legislative mandate to avert environmental damage
from projects in which EPA is participating.
In the meantime, EPA will help assure environmental protection
to the fullest extent possible at this time by imposing on the
72-inch interceptor the following grant conditions:
1. The grantee shall revise the alignment of the interceptor
so as to completely avoid passage through any portion of
the 20-acre wooded swamp Type VII wetland located im-
mediately south of 277th Street.
2. The grantee shall develop procedures and provide assurances
satisfactory to the Environmental Protection Agency that
all extensions, connections, laterals, and sewer mains
proposed to discharge into the facilities constructed under
this project shall be developed in accordance with approved
service area boundaries and applicable statutory or regu-
latory environmental and zoning requirements.
3. The grantee shall assure adequate monitoring of onsite
environmental effects of the construction of the inter-
ceptor through provision of an onsite project inspector
whose duties shall include compliance with regulations and
recommendations of the environmental agencies including,
EPA, DOE, PSAPCA, Dept. of Fisheries, and Dept. of Game.
The inspector shall be responsible to immediately notify
Metro management of changes which are necessary in construc-
tion techniques to minimize adverse impacts on the environ-
ment. Metro shall take whatever action is required to
implement construction techniques which protect the environ-
ment. The inspector shall be knowledgeable in the area of
environmental concerns through training and experience.
Periodic reports shall be prepared at not less than
monthly frequencies by this inspector to inform Metro of
any deficiencies in compliance by the construction con-
tractor and to identify any problems and problem resolu-
tions which have occurred. A summary report for the project
shall be prepared and a copy sent to EPA which briefly
summarizes any problems and resolutions. Environmental
amenities related to air, water, noise, solid waste, pesti-
cides, and fish and wildlife shall be addressed.
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(3)
The grantee shall forthwith explore the possibility of
low-flow augmentation of the Green River through consulta-
tion with the Corps of Engineers, the Department of Fisheries,
and the City of Tacoma, in consultation with the State DOE's
management of water rights in the State of Washington.
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corners
Page
I. CHAPTER I: INTRODUCTION 1
A. History of Proposed Action 3
B. Purpose of EIS 5
II. CHAPTER II: DESCRIPTION OF THE ENVIRONMENT 6
A. Sewerage Area Boundaries 7
B. Physiography 7
C. History of the Green River Valley 9
D. Existing Land Use and Land Use Trends 10
1. Existing Uses 10
2. Land Use Trends 11
E. Existing Socioeconomic Environment 15
1. Present Environment and Trends 15
2. Historic Environment 22
F. Existing Water Quality 23
1. Hydrologic Conditions 23
a. Surface Drainage 23
b. Groundwater 25
2. Green River and Duwamish River 26
a. Uses 26
b. Flows 27
c. Water Quality Problems 28
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Page
3. The Auburn Sewage Treatment Lagoon 31
a. Present Discharge 32
b. Effects of the Auburn Lagoon on
Water Quality 34
4. Tributaries to the Green River 35
a. Newaukum and Crisp Creeks 35
b. Soos Creek Drainage System 36
5. Lakes 36
6. Water Quality Standards 37
G. Existing Air Quality 39
H. Existing Natural Vegetation, Wildlife, and
Fisheries 42
1. Habitats 42
a. Wetlands 42
b. Wooded Areas 46
c. Aquatic Areas 47
d. Other Areas 47
2. Rare and Endangered Species 47
3. Fisheries 51
III. CHAPTER III: PROPOSED ACTION 58
A. Design Criteria And Flow Forecasts 60
1. Land Use 61
a. Developed Land 61
b. Undeveloped Unavailable Land 62
c. Undeveloped Available Land 62
ii
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Page
2. Industrial 62
B. Description of Proposed Interceptor 64
1. Alignment of Interceptor 67
2. Cost Estimate 67
IV. CHAPTER IV: ALTERNATIVES TO PROPOSED ACTION 71
A. Interceptor Design For The Year 2030 ... 72
B. Staged Interceptor Construction For
The Year 2000 73
1. Plan B 73
2. Plan C 78
C. Regional Treatment Plant At Auburn 78
D. Upgrading of Lagoon System At Auburn 83
E. No Action Alternative 84
F. Comparison Of Proposed Action and Alternatives . . 85
V. CHAPTER V: ENVIRONMENTAL IMPACTS OF ALTERNATIVES ... 89
A. Land Use Impacts 90
B. Socio-Economic Impacts 101
1. Impacts on Existing Socio-Economic
Environment 101
2. Impacts on Historic and Archaeological
Sites 106
C. Water Quality Impacts 109
1. Effects of the Proposed Action on
Water Quality 109
a. Green-Duwamish River 109
b. The Interceptor Corridor 114
ill
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Page
c. Other Creeks and Lakes 116
d. Groundwater 121
e. Septic Tanks 121
f. Sludge 122
g. Flood Areas 125
2. Regional Plan with Staged Interceptor . . . 127
3. Regional Plan with Secondary Treatment
Works at Auburn 128
a. Green-Duwamish River 128
b. Other Lakes, Streams, and
Groundwaters 130
4. Upgraded Lagoon 130
a. Green-Duwamish River 130
b. Other Lakes, Streams, and
Groundwaters ". 131
5. No Action Alternative 131
a. Green-Duwamish River 131
b. Other Lakes, Streams, and
Groundwaters 132
c. Septic Tank Problems 133
D. Air Quality Impacts 136
1. Land Use Projection 136
2. Emission Inventory 137
3. Extimating Current and Future Air
Quality 138
a. Results 139
b. Conclusions 143
IV
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E. Natural Vegetation, Wildlife, and
Fisheries Impacts 145
1. Primary Impacts of the Proposed Action ... 145
a. General Impacts on Vegetation
and Wildlife 145
b. Specific Impacts on Wetlands .„ ... 145
2. Secondary Impacts of the Proposed Action . . 147
3. Impacts of Alternatives 148
4. Impacts of the Proposed Action on
Fisheries 149
a. Primary Impacts 149
b. Secondary Impacts 149
VI. CHAPTER VI: UNAVOIDABLE ADVERSE IMPACTS AND
MITIGATIVE MEASURES 154
A. Adverse Primary Impacts 155
1. Short-term Impacts During Construction ... 155
2. Long-term Construction Impacts 156
3. Operational Impacts 156
B. Adverse Secondary Impacts 157
1. Water Quality Impacts 157
2. Air Quality Impacts 157
3. Terrestrial Impacts 158
4. Land Use Impacts 159
5. Socio-Economic Impacts 159
VII CHAPTER VII: IRREVERSIBLE AMD IRRETRIEVABLE
RESOURCE COMMITMENTS 160
v
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Paqe
VIII. CHAPTER VIII: RELATIONSHIP BETWEEN SHORT TERM
USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE
AND ENHANCEMENT OF LONG TERM PRODUCTIVITY .... 163
A. Impacts of the Proposed Action 164
B. Impacts of Growth and Development 164
IX. COMMENTS AND RESPONSES TO THE DRAFT EIS 167
APPENDICES 259
APPENDIX A: Washington State Water Quality Regulations
APPENDIX B: Auburn Interceptor Service Area Air Quality
Impact Analysis
APPENDIX C: Air Quality Impact Assessment of the Auburn
Interceptor Service Area - The Development
of Particulate Emission Projections and
Small Area Projections
APPENDIX D: Fauna of the Sewerage Area; Flora of the
Sewerage Area
APPENDIX E: Relationship with Existing and Proposed
Projects, Plans, Policies, and Regulations
VI
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LIST OF FIGURES
FIGURE PAGE
1 Location Map 8
2 Hydrology 24
3 River Flow - Green/Duwamish River 28
at Tukwila
4 Diurnal Variation of Dissolved Oxygen 30
& Temperature
5 Auburn Lagoon - Flows & BODs Removal 33
6 Plant Communities 43
7 Wetlands 44
8 Proposed Action 66
9 Staged Construction-Alternative Plan B 75
10 Staged Construction-Alternative Plan C 79
11 Generalized Local Comprehensive Land Use Plans 95
12 Generalized Interim Regional Land Use Plan 96
13 Septic Tank Suitability 123
14 Activity Allocation Model 140
vii
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LIST OF TABLES
TABLE PAGE
1 Land Use Allocations 9
2 Land Use Areas, 1965 and 1973 11
3 Population Growth in the Seattle-Everett 17
SMSA 1960-1970
4 Green River Population and Employment 18
5 Assessed Valuation/Capita for Valley Cities 18
6 Tax Codes and Rates 21
7 Violations of State's Dissolved Oxygen 29
Standard
8 Numerical Criteria for Secondary Treatment 34
9 DOE Water Quality Classifications 38
10 TSP Air Quality Data for the Auburn 40
Monitoring Site
11 Rare, Threatened, or Endangered Animals 49
Range Includes the Green River Sewerage Area
12 Significant Spawning Reaches for Anadromous 52
Fish and Resident Game Fish, Cedar-Green
Basins
13 Anadromous Fish Spawning Escapement, Natural 53
and Artificial, in Cedar-Green Basins
14 Anadromous Fish Natural Production (Harvest 54
Plus Escapement), Cedar-Green Basins
15 Proposed Action (Plan A)-Flow Forecast Summary 65
16 Auburn Interceptor-Preliminary Estimate 69
17 Plan B and C - Flow Forecast Summary 74
18 Auburn Interceptor - Plan B 76
viii
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TABLES (continued)
TABLE PAGE
19 Auburn Interceptor - Plan C 80
20 Comparison of Year 2000 Interceptor 86
Alternatives
21 Cost Comparison of Proposed Action 87
and Auburn STP
22 Green River Valley Land Use Trends 93
23 Comprehensive Plans-Total Acreage 97
24 Acreages from Zoning and Comprehensive Plans 97
25 Green River Valley Population and Employment 103
Forecasts
26 Projected Central Puget Sound Population 104
27 Annual Rates of King County vs. Washington 105
28 Comparative Population Projections 106
29 Comparison of Alternatives to Reduce Future 113
Dissolved Oxygen Deficit in Duwamish River
30 Urban Runoff Pollutant Concentrations in the 118
Seattle Area
31 Estimated Sludge Output at West Point 124
32 Service Area Population and Emission Estimates 139
33 Expected Annual Geometric Means for 141
Particulates at Auburn
34 Impacts on Fisheries 150
35 Comments Received 169
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SUMMARY SHEET FOR FINAL ENVIRONMENTAL
IMPACT STATEMENT
AUBURN INTERCEPTOR (GREEN RIVER SEWERAGE AREA)
KING COUNTY, WASHINGTON
Environmental Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
1. Type of Statement: Draft ( ) Final (X)
2. Administrative Action
3. The subject action for this Environmental Impact Statement
is the awarding of grant funds to the Municipality of Metropolitan
Seattle (Metro) for the construction of an interceptor sewer line in
King County, Washington to service the Green River Sewerage Area.
The present total estimated project cost is $10,417,700 for approxi-
mately 7.1 miles of pipe sized from 72" to 36". Metro's "Environmental
Impact Statement on Auburn Interceptor," dated January, 1974, was used
by EPA as a major resource document for the preparation of this
environmental impact statement.
4. The project would result in the elimination of the discharge,
to the Green River, of inadequately treated wastewaters from the City
of Auburn lagoon system and would be a segment in the extension of a
regional wastewater collection system providing for (1) the elimination
of wastewater discharges to the Green River and its tributaries;
(2) discontinuance of use of septic tanks in unsuitable soils in the
Green River Sewerage Area; and (3) the removal of the constraint on
growth and development represented by a lack of adequate sewer service.
X
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Major adverse primary impacts and mitigative measures are:
a. The construction corridor passes through easterly
margin of one small area identified as a permanent wetland. Miti-
gation of the impact on this area could be provided by (1) specifying
summer construction, a narrow area to be disturbed and replacement
of both seeded and wooded vegetation; or (2) relocating the pipeline
to avoid the wetland.
b. Wastewaters intercepted by the project would be treated
at Metro's existing secondary treatment plant at Renton. Effluent
is discharged to the Green-Duwamish River at Renton; waste sludge
is pumped to Metro's West Point treatment plant for digestion. Water
quality in the Duwamish estuary could be affected by the projected
increased effluent discharged from the Renton plant. This potential
impact is being minimized by dechlorination and could be minimized
further by low flow augmentation (if this proves feasible) and, if
necessary, advanced treatment. Sludge presently is removed from
the West Point plant by trucks, which pass through residential areas
en route to disposal sites. Ultimate disposal method has not been
determined yet; however, mitigation of this impact could include re-
moving sludge by barge or providing digestion facilities at other
locations such as the Renton plant.
c. No adverse impacts are anticipated on archaeological,
historical or cultural resources; however, a preliminary survey of
the construction right-of-way shall be made before construction be-
gins to determine if any unique sites would be damaged by the proposed
construction. If any areas are identified, measures will be taken
to avoid irreparable damages.
XI
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Major adverse secondary impacts resulting from growth and develop-
ment in the Green River Sewerage Area are:
a. Surface water quality will decrease due to urban runoff
and to slightly reduced recharge of ground water. Mitigation of this
impact could include regulation of runoff by ponding storm water to
minimize flood hazards, frequent cleaning of paved surfaces and storm
sewers and by low flow augmentation from stored water upstream. Im-
pacts on the native fishery could be mitigated by enhanced hatchery
production.
b. Concentrations of total suspended particulates were
found to exceed the secondary standards in 1973 air samples taken
at Auburn and are projected to be higher by 1990; however, the primary
standards, concerned with public health, are not expected to be
exceeded. Mitigative measures could include elimination of slash
burning, improved mass transit and reduced automobile traffic, con-
version from fossil fuel to electricity for heating and technological
improvements.
c. There is a potential for loss of wetlands, vegetation
and wildlife habitat, given the present local land use plans. Miti-
gation of this impact could be provided by amending these plans or by
the acquisition of wetlands and other sensitive areas by local
governments, conservation agencies or societies. The environmental
effects of specific projects, including future interceptor extensions,
would be subject to evaluation ir, accordance with provisions of the
Washington State Environmental Policy Act, the National Environmental
Policy Act, or both.
xii
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d. Needs associated with growth and development permitted
by local land use plans include sewer service, water supply, trans-
portation, power, schools, open space and recreational facilities,
shopping areas, fire and police protection, health facilities, and
solid waste collection.
Any impacts of providing these facilities and services could be mini-
mized with proper planning by local governments.
5. Alternatives considered were the "no action" alternative;
the upgrading of the Auburn lagoon system; a year 2030 interceptor
design; two staged interceptor designs; and construction of a
conventional secondary treatment plant at Auburn.
6. The following State, Federal and local agencies and interested
groups were invited to comment on the environmental impact
statement.
xiii
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FEDERAL AGENCIES
COUNCIL ON ENVIRONMENTAL QUALITY
U,S, DEPT, OF AGRICULTURE, SOIL CONSERVATION SERVICE
U,S, DEPT, OF DEFENSE, DEPT, OF THE ARMY
U,S, DEPT, OF INTERIOR, BUREAU OF OUTDOOR RECREATION
U,S, DEPT, OF INTERIOR, FISH AND WILDLIFE SERVICE
U,S, DEPT, OF TRANSPORTATION, REGION X
U,S, DEPT, OF HEALTH, EDUCATION, AND WELFARE, REGION X
U,S, DEPT, OF HOUSING AND URBAN DEVELOPMENT, REGION X
ADVISORY COUNCIL ON HISTORIC PRESERVATION
FtMBERS OF CONGRESS
HENRY M, JACKSON BROCK ADAMS
U,S, SENATE U,S, HOUSE OF REPRESENTATIVES
WARREN G, P!AGNUSON
U,S, SENATE
STATE
GOVERNOR OF WASHINGTON
OFFICE OF COMMUNITY DEVELOPMENT
OFFICE OF PROGRAM PLANNING AND FISCAL MANAGEMENT
OFFICE OF ENVIRONMENTAL HEALTH PROGRAM
WASHINGTON FUTURE PROGRAM
DEPT, OF ECOLOGY
DEPT, OF FISHERIES
DEPT, OF GAME
xiv
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DEPT, OF HIGHWAYS
DEPT, OF NATURAL RESOURCES
DEPT, OF SOCIAL AND HEALTH SERVICES
HEALTH SERVICES DIVISION
PARKS AND RECREATION COMMISSION
REGIONAL & LOCAL
[MUNICIPALITY OF ftTROPOLiTAN SEATTLE
PUGET SOUND GOVERNMENTAL CONFERENCE
PUGET SOUND AIR POLLUTION CONTROL AGENCY
RIVER BASIN COORDINATING COMMITTEE
KING COUNTY
PIERCE COUNTY
CITY OF AUBURN
CITY OF KENT
CITY OF ALGONA
CITY OF PACIFIC
CITY OF BLACK DIAMOND
CITY OF SEATTLE
CASCADE SEWER DISTRICT
INTERESTED GROUPS
NATIONAL AUDUBON SOCIETY
FRIENDS OF THE EARTH
GREEN BELT AT THE LXKS ASSXIATION
LEAGUE OF WOMEN VOTERS
TlAGNOLiA COMMUNITY CLUB
NORTHWEST STEELHEADER'S COUNCIL OF TROUT UNLIMITED
XV
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SIERRA CLUB
STEELHEAD TROUT CLUB OF WASHINGTON
WASHINGTON AIR QUALITY COALITION
WASHINGTON ENVIRONMENTAL COUNCIL
MERCER ISLAND ENVIRONMENTAL COUNCIL
P.L.A.N. KING COUNTY
MOUNTAINEERS
GREEN FOR TOMORROW
THIS DRAFT EIS WAS MADE AVAILABLE TO THE COUNCIL ON
ENVIRONMENTAL QUALITY (CEQ) AND THE PUBLIC ON APRIL 11, 1975,
THIS FINAL EIS WILL BE MADE AVAILABLE TO CEQ AND THE PUBLIC
ON JUNE 27, 1975.
xvi
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Title II of the Federal Water Pollution Control Act (PL 92-500)
provides authority to the Administrator of the Environmental Protec-
tion Agency (EPA) to make grants to State agencies and municipal cor-
porations for the construction of publicly-owned treatment works.
Eligibility requirements and procedures necessary to qualify for a
grant are set forth in 40-CFR, Part 35, Construction Grants for Waste
Treatment Works. The Federal share shall be 75 percent of the total
cost found to be eligible.
The Municipality of Metropolitan Seattle (Metro) has requested
funds to aid in the construction of an extension of an interceptor
sewer from the City of Kent to the City of Auburn. The immediate re-
sult of its construction would be to eliminate the discharge to the
Green River of inadequately treated wastewaters from the City of
Auburn lagoon system. Effluent discharged from the Auburn lagoon
does not meet the limits defined by EPA for secondary treatment of
wastewaters. Over the longer term, the interceptor represents one
phase in the development of regional sewerage facilities which would
prevent or eliminate water quality problems in the Green River Sewer-
age Area.
As received by EPA, the project proposed by Metro was for con-
struction of 7.1 miles of 78 and 42-inch diameter pipe, beginning at
a connection to the Kent Cross Valley Interceptor and ending at the
headworks of the Auburn lagoon system. Based on a service life of
50 years, the interceptor was designed to accommodate the peak flow
from that portion of the Green River Sewerage Area anticipated to be
served by the year 2030. The design peak flow of 114 mgd was based
on Metro's extrapolation of PSGC projections of population and in-
dustrial growth for the year 1990.
Following a joint review by EPA and Metro, the maximum diameter
of the proposed interceptor was reduced to 72 inches. Metro deter-
mined that a pipe of this size would be required to accommodate the
design peak flow for the year 2000, as developed during studies of the
River Basin coordinating committee (RIBCO), a committee formed to make
basin wide environmental waste management studies.
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HISTORY OF PROPOSED ACTION
Metro is a municipal corporation, authorized by State law and
approved by the voters, to deal area-wide with water pollution. To
this end, the corporation is empowered to prepare a comprehensive
water pollution abatement plan; to acquire, construct, operate, and
regulate the use of metropolitan facilities; to fix rates and charges for
use of metropolitan facilities; and to establish minimum standards for
the construction of local sewer facilities and approve plans for their
construction.
Regional sewerage service to the Auburn area has been a part of
Metro's Comprehensive Plan since its adoption. Extension of an in-
terceptor is shown in the 1974 Plan revision as a part of second
stage facilities planned for construction between 1974 and 1985.
Connection to the Metro system is recommended in the 1968 Comprehen-
sive Sewerage Plan for the City of Auburn.
On the State level, the Washington State Water Pollution Control
Commission, the predecessor of the Department of Ecology (DOE) pub-
lished in 1970 an implementation and enforcement plan as a supplement
to the intrastate water quality standards. Under this plan, the City
of Auburn was advised, on February 17, 1970, that it must intercept
its sewage from the Auburn Lagoon and connect to the Metro system.
Later that year, the DOE placed a ban on further extension of Auburn's
local sewerage system until Auburn and Metro worked out a service
agreement. The proposed link up with the Metro system was to have
been operational by April, 1973.
In fulfillment of one of the requirements for financial assis-
tance from EPA, Metro prepared and made available to the public, on
November 13, 1973, an environmental assessment of the proposed inter-
ceptor extension, identified as the "Auburn Interceptor." A month
later, a public hearing was held at the Auburn Legion Hall by the
Sewer Committee of the Metropolitan Council. Participants included
representatives from Federal, State, local, and regional governments,
environmental groups, citizen's groups, and individuals. Further
meetings, open to the public, were held in January and February, 1974.
Following these meetings, the project was approved by the Metropolitan
Council.
Also in January, approval came from the Puget Sound Governmental
Conference (PSGC), after resolution of differences between its Interim
Regional Development Plan and the City of Auburn's Comprehensive Land
Use Plan.
On February 27, 1974, Metro applied to EPA for a grant (EPA ID #
C530475-02) for Federal funding of the Auburn Interceptor. On April
18, 1974, the DOE held a public hearing on the Project Priority list,
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which included the Auburn Interceptor. Following this hearing, the
State placed the project on the priority list. Only projects on this
list are eligible for Federal funding.
On December 21, 1974, the DOE issued Metro an NPDES [National
Pollutant Discharge Elimination System) permit for the Renton Sewage
Treatment Plant, which requires the construction of an interceptor to
transport wastes from Auburn to Renton.
In summary, the Auburn Interceptor had received official endorse-
ment at the State, regional, and local levels of government by January,
1974. Metro had submitted a grant application and an environmental
assessment; following independent review of the information submitted,
EPA prepared an environmental impact appraisal, summarizing the project.
Based on this appraisal, an initial decision not to prepare an environ-
mental impact statement was made and, on January 10, 1975, EPA issued
a negative declaration with the environmental appraisal, informing the
public that an EIS would not be prepared on the proposed Auburn Inter-
ceptor project.
During the 15-day review period for the negative declaration,
several environmental groups expressed concern about some of the im-
pacts of the project discussed in the environmental appraisal. After
reviewing this additional public input, EPA decided to prepare an EIS
which would provide for further public participation in the issues
raised. On February 3, 1975, a notice of intent to prepare a draft
EIS was sent to the news media, to interested governmental agencies,
and to environmental and other citizen groups.
To ensure the opportunity for public participation early in the
preparation of the draft statement, EPA held a public meeting in
Auburn on February 19, 1975. Notice of the meeting was given to the
news media and mailed to over one hundred governmental agencies,
groups, and individuals. Written statements were received and a
transcript of comments made.
In May 1975, the DOE announced its intention to issue an NPDES
permit for the Auburn Lagoon after a 30-day comment period. This
draft permit contained a compliance schedule to attain adequate waste
treatment. If the draft permit were issued, the City of Auburn would
be required to submit, by May 15, 1977, either an agreement and time
schedule for Metro's interception of Auburn wastes or an acceptable
plan for achieving secondary treatment requirements at Auburn.
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PURPOSE OF EIS
Most concerns expressed about the proposed project appear to be
related to growth and development and to the attendant changes in
land use attributable to providing sewerage facilities. There are,
of course, many factors which influence growth and development, in-
cluding the availability of all utility and community services; trans-
portation facilities; and world, national, and local economic condi-
tions. Nevertheless, to the extent that the construction of this
project might be such an influence, EPA must attempt, in this EIS, to
evaluate impacts resulting from growth and development.
Metro and supporters of the project feel that the extension of
sewer service to individual properties is feasible only when a need
for the service has been established. Further, Metro has evaluated
the alternatives of a smaller interceptor project or the upgrading
and expansion of Auburn's lagoon system and found them to be less cost
effective than the proposed project.
Before awarding grant assistance for any treatment works project,
the EPA Regional Administrator must determine that all applicable re-
quirements have been met. This EIS is to assist in and document the
administrative decision-making process. No final decision can be made
until the NEPA impact statement process has been completed.
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SEWERAGE AREA BOUNDARIES
The Green River Sewerage Area, which includes the Auburn
Interceptor Service area, encompasses over 85,000 acres in southwest
King County and a small portion of northern Pierce County. Its
boundaries extend east and west from the town of Black Diamond to
Interstate Highway Five and north and south from Lake Youngs to
Lake Tapps. Included within this area is the entire Lower Green
River valley in the vicinity of the cities of Kent, Auburn, Algona,
and Pacific; portions of the Des Moines Plateau (West Hill) to the
west; and the majority of the Black Diamond Plateau (East Hill) to
the east of the Valley. (See Figure 1)
PHYSIOGRAPHY
The principal topographic features are the upland plateaus,
Des Moines and Black Diamond, lining the valley to the west and to
the east; and the flood plain of the Green River. The ascent to
the upland areas is abrupt with a difference in elevation between
the river bottom and the plateaus of more than 300 feet. The roll-
ing, glacial topography of the uplands is spotted with depressions
and hummocks in which stream courses and drainage patterns are
often poorly defined. Numerous local basins and depressions have
become small lakes, swampy areas, and bogs because of inadequate
drainage.
The Lower Green River valley is a mature flood plain. This
broad, alluviated valley was formed from thousands of years of
flooding and sediment disposition by the Green and White Rivers.
Steep valley walls border this valley to the east and west, which
limits the natural floodway. Man has altered the natural flood
plain condition of the Green River valley. The Green River is
artificially controlled by an upstream dam, the Howard Hanson Dam,
and by man-made levees, which parallel the stream throughout most
of its length within the sewerage area. As a result, natural over-
bank flooding has been eliminated from most of the Lower Green River
valley.
-------
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE SERVICE AREA)
LOCATION MAP
SEATTLE
LAKE
S AM MA MIS H
Vt
<•<
Renton
Sea-Toe
International
Airport
v V*v m — * *-vo
<) *
Maple Valley
:-:.:Kent '••:•:••.. Youngs
''''+
«l fibril; ^
:: ^
'£$. Auburn
FIGURE 1
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HISTORY OF THE GREEN RIVER VALLEY
Up to the time of the first ice age, the Green River area was
intermittently covered by seas and was influenced by periods of
volcanic activity to the east. These events helped to turn this
area from an underwater basin to a broad plain similar to modern
deltas.
The subsequent invasion of glaciers carved this plain into a
valley. The Vashon glacier 14,000 years ago covered the entire area
with a 3,000 foot thick layer of ice. This final glacier further
deepened the river valley and formed the hills now standing parallel
to it on the east and west.
As the ice retreated further north, the Straits of Juan de Fuca
became ice-free and the ocean invaded the Green River valley. In
the 10,000 to 15,000 years since glacial activity in the valley,
this embayment has slowly filled with alluvium carried by the White,
Green, and Cedar Rivers. The Green and Cedar Rivers built large
deltas into the deep water of this emfaayment. When the water slowly
receded, a flood plain was created filled with a series of bogs and
swamps.
About 5,000 years ago, the Osceola mudflow came down the White
River valley from the flanks of Mt. Rainier. As a result, the White
River was diverted to the Green River valley, where it formed two
channels: one flowing to Puget Sound at Tacoma and the other at
Seattle. Until 1906, when its entire flow was diverted southward
into the Puyallup River during a flood, the White River was the pre-
dominant source of the sediments which were deposited as a large
delta in the Green River valley embayment, covering the older depo-
sits and filling the valley to nearly its present level.
The Indians hunted and fished in this region, then in 1850
agriculture came to the valley when the first white settlers began
clearing the valley bottom. By 1870, most of the 25,000 acres of
the valley was growing berries and vegetables. In 1946, a major
flood occurred destroying many of the crops and forcing many people
from their homes.
Following this disaster, the Corps of Engineers initiated several
flood control projects on the Green River, including a dam, dikes
and levees. Agriculture never regained the importance it had before
the flood; many of the remaining farms have converted to dairy oper-
ations. In the late 1950"s, the cities of Kent and Auburn began to
annex land at a rapid rate and zone much of it for industry. Indus-
trial and commercial development ensued. The valley today is a
rapidly urbanizing area.
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EXISTING LAND USE AND LAND USE TRENDS
LXISTING USES
The Green River Sewerage Area is characterized by a diversity
of land uses: forestry, mining [gravel pits), open space, recrea-
tion, and scattered rural residential and agricultural uses on the
eastern uplands; retail, commercial, and residential uses in cities
and towns; and agricultural and industrial developments in the Green
Kiver valley. Photogrammetric interpretations of the sewerage area
done by Metro's environmental assessment consultant in the Spring of
1973 reveal the following land use allocations:
TABLE 1. LAND USE ALLOCATIONS.
ESTIMATED ESTIMATED %
USE ACREAGE QF TOTAL AREA
Woodland 37,700 A 40
Suburban Land (in- 15,780 A 17
eluding low density
residential, recrea-
tional home, neighbor-
hood cornmerical areas)
Agricultural Land 9,030 A 10
Open/Vacant Land 8,720 A 9
High density residen- 6,300 A 7
tial and commercial
areas
Transportation Corridors 5,890 A 6
(including railroad
yards and freeways)
Transmission Line 4,140 A 4
Utility Corridors
Industrial areas 1,140 A 1
Recreational areas 410 A 0.5
Surface Water 4,250 A 5
10
-------
Acreage designated as commercial probably includes some light
industrial and warehousing establishments. In aerial photographs,
it is often difficult to distinguish between these facilities and
other commercial establishments.
Land uses adjacent to the proposed interceptor route range from
rural classifications such as open land, pasture land and cultivated
fields, to urban uses including residential neighborhoods, industrial
plants, automobile distribution yards, and the Auburn Airport.
A visual survey of these adjacent land uses, however, does not
necessarily convey their often tentative status. Almost all of the
proposed interceptor route lies within the incorporated limits of
Kent and Auburn. These cities have zoned most of the land through
which the interceptor will pass to allow more intensive uses than
those now occurring. For example, the land in Kent to be traversed
by the interceptor is zoned for industrial use. Much of this land
has been sold to investors and developers who are leasing the land
to farmers until industrial development is feasible.
In other locations, land owned by industrial firms has been only
partially developed with the remainder reserved for future expansion.
Large portions of the Green River valley within the sewerage area,
therefore, appear to be committed to open space or agricultural uses
when in reality they are committed to industrial uses. See discussion
on page 12a.
The only formal recreation facilities near or in contact with
the construction corridor are trail routes: one is the undeveloped
Kent Park Department trail system which utilizes the Puget Power
right-of-way; and the other is the Green River Levee maintenance
road. These trail locations have not been improved except for signs
to mark their location. The Green River Levee is planned to even-
tually become a part of the Lower Green River Trail of the King
County Urban Trails System. There are no other existing or planned
parks or recreation areas in or near the construction corridor.
It should be noted, however, that the route will pass through
two ecosystems, near South 228th Street and South 277th Street in
Kent, that are considered to have informal recreation value. (See
section on Existing Natural Vegetation, Wildlife, and Fisheries).
LAND USE [RENDS
Before 1950, the Greer. River valley was predominantly rural
with large dairy operations and small truck farms. The valley cities
were small, and most of the land was in unincorporated King County.
11
-------
Today, the cities control approximately 73% of the valley lands and
the observable land use trend is toward increasing urbanization.
A study completed by Corff and Shapiro, Inc., (The Green River
Valley: A Study of Demand, Capacity and Trends, Draft, Sept. 1974)
of an area which covers 33,320 acres of the Green River valley,
extending from the valley floor to parts of the plateaus bordering
the valley, clearly reveals this trend. The figures in Table 2
indicate that between 1965 and 1973 there has been a dramatic decrease
in agricultural and open space land uses and a significant increase
in industrial, residential, and commercial uses.
TABLE 2. LAND USE AREAS, 1965 & 1973*.
USE
Industrial
Power Lines
Commercial
Residential
Agriculture
Open Space -
Tract
Non-Tract
Multi-Family
Mobile Homes
Wooded
Non Wooded
Site Preparation
Institutional
Parks - Recreation
Transportation - Freeways
Gravel Quarries
Water
Total
1965
1,150
230
250
2,420
3,690
80
20
14,370
,560
,290
840
340
150
80
250
600
33,320
5,.
3,;
1973
3,130
230
700
4,220
3,990
160
210
,020
,160
,700
1,540
530
430
920
700
630
33,320
9,
4,
2,.
CHANGE
+1
172
0
180
74
8
100
950
37
25
18
83
55
186
,050
180
13
*Data Sources: National Aeronautics and Space Administration color—
infra-red aerial photography, NASA-Johnson Space Center Mission 212,
Sept. 1972, scale 1:50,000, updated to 1973 using photography from
NASA-Ames Research Center U-2 Flight 73-109, July 1973, scale 1:135,000.
Photo interpretation and map compilation performed on the Bausch and
Lomb Zoom Transfer Scope. Frank V. Westerlund, project consultant.
Green River Valley AAM Districts only.
-A negative % means that area devoted to that land use has decreased.
12
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The amount of Sand devoted to freeways has increased 1,050%
because of the construction of the Valley Freeway, SR 167 (1972)
and of 1-5 (1966). Because accessibility is often critical in
determining where development will take place, SR 167 has had a major
urbanizing influence since its completion to Kent in 1969 and to Auburn
in 1972. Direct high speed access to the southern part of the valley
and visual and noise impacts resulting from the freeway have had
noticeable effects on the neighborhoods in Kent. These middle-class
residential areas near the proposed interceptor route have been trans-
formed into less appealing areas.
The 83'= increase in the amount of land used in site preparation
is a clear indication of increasing urbanization. Associated with this
particular use, land devoted to gravel quarries, primarily located on
valley walls, has increased by 180". Most of the site preparation
activity has occurred on the valley floor, especially in the Renton-
Tukwila area and in the vicinity of SR 167 near Auburn - Algona.
In the valley, agricultural land has been lost to three major
types of uses: industrial development, site preparation and non-forested
open space. Although development has encroached upon formerly culti-
vated lands, it is still largely scattered. The unused vacant lands,
which fall into the "non-forested open space" category lie in blocks
near or adjacent to these developed areas. As much of this land is
zoned for intensive uses, planners view these vacant areas as the key
to the valley's future. The rate and amount of development that will
actually take place is, however, dependent on numerous factors such as
the current stabilization of the valley population, on-going speculative
land-filling and utility provision, the comprehensive plans and zoning
ordinances of the local jurisdictions, and the state of the world,
national, and local economy.
The process of development is well advanced and the pattern of
land ownership, institutional and economic factors that govern land
use are conducive to the continuation of the process. The proportion
of valley land that is occupied for urban-industrial purposes exceeds
that of either the Puyallup or Snohomish Valleys, the other areas of
central Puget Sound that are suited for large scale development. Land
ownership is concentrated in corporate hands that have assembled large
parcels either for their own use or for speculative development. (Major
land owners in the valley are the Boeing Company, Allied Stores, the
three railroads—Union Pacific, Burlington Northern, and the Chicago,
Milwaukee, St. Paul, Herb Mead and Associates, and the Shell Oil
Company).
The transactions that created those large, essentially absentee
holdings, in the late 1950's through the mid-19601s touched off an
explosion in land values. In the northern parts of the valley, for
example, the mean market price per acre of land rose from $4,630 to
$8,950 in a single year and to $10,340 by the end of 1966 ("Land Value
12-A
-------
Changes in an Area Undergoing Urbanization", M. T. Rancich, Urban
Studies). The number of acres involved in transactions in the valley
more than doubled from 1964 to 1965. Concommitant with these transac-
tions that placed large parcels of agricultural land in corporate
hands, the cities of the valley annexed large chunks of adjacent
land—more than 16,000 acres were annexed by Auburn and Kent in
the late 1950's and 1960's—and much of these lands were zoned for
intensive uses.
Higher taxes and higher tax rates, resulting from inflated land
values, made it both profitable and expedient for farmers and small
land holders to sell their land to developers and speculators who
could afford to hold the lands for future development or as an invest-
ment. Higher taxes are not, however, solely responsible for the loss
of agricultural land to urban uses. In fact, records show that very
few landowners have taken advantage of the Washington State Open Space
Law (RCW 84.34) which allows assessment of property based on current
use of agricultural and forest land, rather than "highest and best
use."
By 1974, only 186 acres within the jurisdiction of the valley
cities were under the current use assessment. Nationwide., the number
of acres of prime agricultural land lost to urbanization annually is
astounding and the issue is of critical concern to environmentalists,
planners, and others. While the escalation of land values and assess-
ment rates (the latter associated with annexation and zoning) are
responsible for squeezing out vestigial agriculture in the Green
River valley, numerous other factors such as (1) the profit motive,
(2) the internment of Japanese-Americans during World War II, which
virtually eliminated the entreprenurial base for diverse, intensive
agriculture, (3) the post-war development of monoculture, food pro-
cessing and efficient national distribution channels for agricultural
products, and (4) simply, the loss of the farmer's interest to con-
tinue farming have collectively contributed to this phenomenon. As
is true elsewhere, no one can dictate what the farmer or small land-
owner can or cannot do with his land if the desired use is consistent
with zoning ordinances and local plans.
The extent and importance of the agricultural industry in the
Puget Sound region is evaluated and emphasized in the Regional Agri-
culture Land Use Technical Study of the PSGC.* This study concludes
that most of the agricultural production in the region (covering
Snohomish, King, Kitsap, and Pierce Counties) would cease to exist if
*Regiona1 Agriculture Land Use Technical Study - Central Puget Sound
Region. Puget Sound Governmental Conference, July 1974
13
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the rate of loss of cropland harvested and pastured were to continue
at the current rate of over 3,000 acres per year. The report emphasizes
that all of the factors contributing to the decline of regional agri-
culture (with the possible exceptions of federal inheritance taxes,
minimum wage requirements and some environmental protection regulations)
are manifestations of current local public policies and could, therefore,
be alleviated through policy amendments by public action. This document
is valuable for it defines the requirements necessary to allow agricul-
ture to remain a viable industry and analyzes the existing potential
means for achieving those requirements.
The perservation of vestigial agricultural lands cannot be over-
emphasized. Not only is agriculture currently a substantial economic
asset to the regional community, but the commitment of land to agri-
culture provides flexibility and opportunity for future land use
reallocation.
Overall evaluation of trends indicate, however that the trend
toward urbanization in the Green River Sewerage Area is expected to
continue. The stage for intensive uses is set; physical service
requirements for industrial expansion and for the additional settle-
ment of people are all in place. Rail lines have traversed the valley
since the turn of the century. Major highways--SR 167, 1-5, and
I-405--installed during the 1960's and early 1970's have served as
the prime lever on the substantial industrial, commercial, and popula-
tion growth that has already taken place.
In summary, the interlocking, interrelated set of physical,
institutional, and economic influences is leading the Green River
valley toward:
(1) increasing urbanization,
(2) increasing industrial development on the valley floor,
(3) further loss of agricultural land,
(4) an increasing tax base,
(5) increasing tax burden on valley landowners due to
increasing land values,
(6) high expenditures for services,
(7) increasing concentration of employment in the valley,
(8) possibility of increasing commuter trips, and
(9) increased expenditures for flood control and drainage.
14
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EXISTING SOCIO ECONOMIC BMRONMENT
PRESENT ENVIRONMENT AND TRENDS
The Green River Basin is undergoing a transition from a sub-
sistence farming economy that began with the initial clearing of
the valley floor in the 1850's to commercial-industrial-suburban
development as an extension of the City of Seattle. An inter-
locking set of physical, institutional, and economic influences
has made, and continues to make, the Green River Basin the site of
the most rapid population growth in the Seattle-Everett SMSA in
the period between the most recent national censuses. As significant
increases in population and employment are symptomatic of an urban-
izing area, studies of the Green River valley indicate that this
area will continue to be subject to increased development; pressures.
Table 3 shows that population in the Green River valley in-
creased almost three times as fast as in the SMSA as a whole. This
substantial annual increase (7.2%) in an area that is largely dedi-
cated to industrial and commercial purposes demonstrates the strong
expansionary pull of local industrial emplacement. Although develop-
ed lands east of Lake Washington were at this time being built up
primarily in a suburban residential fashion to serve some housing
needs of the larger metropolitan area, people tended to move toward
the less developed Green River valley area, perhaps to be closer
to employment centers.
A recent PSGC study* of population and employment trends in the
Green River valley indicates that while the valley population in-
creased by 70% between 1961 and 1970, the valley employment jumped
250% in the same period of time. The 11,000 persons employed by
Boeing at the new centers in Kent and Auburn account for about one-
third of this increase. As indicated in Table 4, all employment
categories registered increases well in excess of 100% over 1961
figureSo WTCU (Wholesaling, Transportation, Communications and
Utilities) increased by 330% and manufacturing by 600%. These sub-
stantial increases reflect the new Boeing facilities and the inten-
sive business park development in the northerly portion of the study
area.
* Study area covered 32,320 acres of the valley floor and parts of
the surrounding plateaus - Beam, Brian, "The Green River Valley -
A Discussion Paper", February 14, 1975.
(Page 16 is omitted) -| r
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TABLE 3. POPULATION GROWTH IN THE SEATTLE-EVERETT SMSA
1960 - 1970
City of Seattle
City of Everett
East Lake Washington
(Renton Division)
(Overlake Division)
Other King County
Other Snohomish County
Green River Valley
(Auburn Division)
(Kent Division)
Seattle-Everett SMSA
Population (1000's)
1960 1970
557.1
40.3
100.8
(41.8)
530.8
55.5
168.6
(64.4)
(59.0) (104.2)
241.0 385.2
131.9 209.7
36.1 72.0
(19.3) (33.1)
(16.8) (38.9)
1,107.2 1,421.9
Annual
Change
- 0.5 %
3.3 %
5.3 %
4.8 %
4.7 %
7.2 %
2.5
17
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TABLE 4. GREEN RIVER VALLEY POPULATION & EMPLOYMENT
Year Total Total Retail Services Manu- WCTU Gov't
Population Employment facturing Education
1961 34,441
1970 58,382
8,509
30,076
1,847
4,471
1,031
2,555
2,082
14,663
1,037 1,161
4,603 3,784
It is obvious that the socio-economic trends in the valley are
toward (1) industrialization, (2) an increasing tax base, (3) an
increasing tax burden on valley landowners, (4) high expenditures for
services that may not be needed for many years, (5) increasing con-
centration of employment in the valley, (6) increasing commuter trips,
and (7) increased expenditures for flood control and drainage.
Corff and Shapiro, Inc.1 provide data which support these trends:
J-nerea3^ng tax base.
The assessed valuation per capita for
Kent, Auburn, Renton, and Tukwila from 1950 to 1974 is shown in
Table 5. Clearly all cities have increased their assessed valu-
ation per capita. Tukwila has had the most dramatic increase, from
$274 in 1950 to $26,211 in 1974, a factor of 95,
TABLE 5. ASSESSED VALUATION/CAPITA FOR VALLEY CITIES*
City
Kent
Auburn
Renton
Tukwila
Assessed Valuation, $ Per Capita
1950 1960 1970 1973-1974
1,763 2,283 5,034 10,388
544 1,918 4,443 7,977
1,100 2,540 7,526 11,232
274 614 7,845 26,211
* Source: Responses to letters from Keith Dearborn to Valley
planning departments, February 1974.
18
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Higher expenditures for services (that may not be needed for
many years). The North Kent Industrial Area water project funded
extensive improvements in a water supply system designed to serve
a 3000 acre industrial zone north of Kent. The projected industrial
development has not yet occurred. The total project costs were
$2,774,217--a breakdown of funding is shown:
LID 252 = $ 486,257.97
LID 256 = 97,949.67
EDA = 510,700 + 264,300
Miscellaneous = 5,497.96 (sale of salvage, interest)
City Bonds = 1,726,781.92
TOTAL = $2,827,186.62
Kent's bonded indebtedness in 1974 was $490 per capita.
Increasing tax burden on valley owners. Increasing land values
in the valley have resulted in higher taxes per acre, and tax rates
themselves have risen. Tax information for 1950, 1960, and 1974 and
the selling price and date of sale for two parcels of land in the
Green River valley is shown in Table 6. These parcels are listed
in the March 1974 printout of the King County Real Estate Monitor
as Green River valley unimproved industrial land and acreage. Table
6 shows a steady increase in mi 11 age rates between 1950 and 1974
(note change in determination of ratio between 1960 and 1974). Land
values rose significantly during this period. The King County Real
Estate Monitor, March 1974, lists unimproved industrial land and
acreage selling for up to $33,000 per acre. Clearly, valley land-
owners carry a heavy tax burden.
Increasing concentration of employment in the valley (with
regional implications). In the period 1961-1970 employment in the
Duwamish basin declined. In 1961 the Duwamish area had 55% of all
manufacturing employment in King County; in 1970 this had dropped to
42%. During the same time period nonmanufacturing employment de-
clined from 15% to 11% and total employment dropped from 28% to 18%.
Employment in the Green River valley study area rose during those
nine years, primarily due to the migration into the valley of the
aerospace industry. Based on these observations, one may speculate
that the desirability for industry to locate in the Green River valley
may be one of the factors which has caused employment to decline in
the Duwamish basin and, perhaps, elsewhere in the region.
19
-------
Increasing oommuter trips. This is supported by the decline in
the population to employment ratio in the 1960-1970 decade from 4.5
to 2.5 for the study area. These ratios indicate that the number
of persons living in the study area has not kept up with the in-
creases in the number of persons who work there.
Increased expenditures for flood control and drainage. 30
million dollars were spent to build Howard Hanson Dam and to dike
the Green River. The flood control and drainage system proposed by
the Soil Conservation Service is projected to cost $38 million,
$15 million of which must come from local governments. In addition,
developers will find it necessary to fill to levels above the 100-
year flood point to guarantee sufficient protection to the develop-
ment, and this will also be expensive, since fill is currently run-
ning at approximately $1.65/cubic yard.
To provide protection from 100-year floods, additional expendi-
tures are required for enlarging the channel capacity of the Green
River to accommodate increased flows from the SCS drainage project.
20
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TABLE 6. TAX CODES AND RATES*
1950 1960 1974
1. NE 1/4 of SW 1/4 of 12-21-7 Code not coded 0150 0140
SE Ly COR Freeway and 15 NW Rate 47.50 62.60 46.88
Auburn Ratio 25% 25% 50%
date sold - 2 January 1973 purchase price - $0.32/sq.ft. or
$13,940/acre
1950 1960 1974
2. Por Gov Lot 2 in Nl/2 of 11-
22-4 Code not coded 0501 1525
21250 Russell Rd., Kent Rate 46.10 75.00 43.46
date sold - 25 June 1969 Ratio 25% 25% 50%
purchase price - $0.24/sq. ft. or $10,454/acre
Rate = mils; one mil = $1.00/$1000 assessed value
Ratio = assessed value as percent of market value
Type 1950 1960 1974
Code 0140 Consolidated (State, 15.70 14.80 6.83
Auburn Area County, port)
Auburn (city services)16.80 17.50 8.76
School District 408 15.00 30.30 31.29
TOTAL 47.50 62.60 46.88
Type 1950 1960 1974
Code 1525: Consolidated (State, 15.70 14.80 6.83
Kent Area County, port)
21
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TABLE 6. (Continued)
1950 1960 1974
Code 1525: Kent (city services) 15.00 16.80 7.60
Kent Area School District 415 12.50 42.40 28.50
(Continued) Hospital H-l 2.90 1.00 .53
TOTAL 46.10 75.00 43.46
* Source: Mr. Wirth, King County Assessor's Office, 7-8 August, 1974,
by his courtesy.
HISTORIC BJVIROifEIT
Officially recognized historic properties in the vicinity of the
proposed interceptor construction are listed below, as identified on
the Washington State Register of Historic Places and the state inven-
tory of historic places:
Alvord's Landing: N47°22'01", W122014'08"
Maddocksville Landing: N47°24'16", W122016'20"
Langston's Landing: N47022'36", W122°14'52"
White River Massacre Site: N47°2V35", W122°13'23"
Downey Hop Barn: One mile west of Valley Freeway on Green River
Auburn Railroad Station
Seattle-Tacoma Interurban Right-of-way
The only Auburn site on the National Register of Historic Places,
the Aaron Neely Mansion, is considered to be outside the project's
direct impact area, as are all of the state historic sites except the
Seattle-Tacoma Interurban right-of-way. The old Interurban right-of-
way lies immediately to the west of, and generally parallel to, the
existing Chicago, Milwaukee, St. Paul, and Pacific Railroad track and
is coincidental with the Puget Power and Light Company right-of-way
and a partially developed recreational trail. Portions of the pro-
posed interceptor route are adjacent to this historic site and at one
point (29th Street N.W.) the interceptor would cross under the Inter-
urban right-of-way.
There is no known archeological site in the construction route.
22
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EXISTING HATER QUALITY
HYDROLOGIC CONDITIONS
The Green River Sewerage area is rich in water resources (see
Figure 2). Two major rivers, the Green and the White, traverse
the area as well as a number of important smaller creeks and streams
including Mill Creek and Big Soos Creek. About sixteen lakes, each
over 20 acres, are located in the sewerage area. Other lakes and
wetlands add to the diversity of water resources.
SURFACE DRAINAGE
Before 1906, the White River and its tributaries, the Green and
the Black Rivers, flowed northward through what is now called the
Green River valley, frequently shifting the river channel into var-
ious meander patterns„ Remnants of the old river channels left many
sand deposits, natural levees, and oxbow lakes (cut-off meanders).
In 1906, a flood changed the course of the White River, divert-
ing it into the Stuck and Puyallup Rivers. In 1915, a diversion dam
permanently blocked the former channel. With reduced flow through
the Green River valley, farming became more feasible on the valley
floor. To extend the growing season, farmers constructed low dikes
along the Green River. This allowed farmers to work their fields
for a longer season, but did not protect against major winter floods.
In 1962 Howard A. Hanson Dam was constructed on the Green River
about 30 miles upstream from Auburn. Major floodflows were reduced
to the maximum capacity of the river channel within its existing
dikes. Historically, floods have swept the low-lying lands of the
Green River valley; now, they are protected by upstream dam regula-
tion and a system of levees that constrict the Green as it passes
through the valley below Auburn. At Auburn, for example, flood flows
are now limited to less than 12,000 cfs (100 year flood).' The peak
flows that are permissible still pose a problem to these lands. Al-
though they no longer lie in the direct flood zone and in the path of
high-velocity flood waters, severe ponding occurs in some areas dur-
ing high water. Levees have allowed a broader range of land uses and
more productive farming. The system has also made discharge from the
Black River and Mill Creek impossible during peak flows unless aided
by lift stations as has been necessary on the Black River and as
proposed for Mill Creek.2 Because of the continued hazard from high-
waters in the fringe areas under flood conditions, construction in a
substantial portion of the sewerage area with regulations for
23
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AUIUSN INTEICEPTO*
(OMEN HIVEIl SEWEIAGE A1EA)
FIGURE 2
-------
designated flood hazard areas. Because of flood control and other
measures, the Green River valley is now largely an artificially-
altered flood plain. Future projects are also planned. See
Appendix E for information concerning the SCS Drainage project
and the Army Corps of Engineers Flood Control Study.
GROUNDWATER
The geology and groundwater resources of Southwestern King
County have been described by Luzier.3 in general, the tertiary
rocks that underlie the area have low permeability and are not im-
portant aquifers for storing or transmitting groundwater. This con-
dition results in little or no appreciable movement of groundwater
from the Cascade Mountains to the Green River valley.
Groundwater in the valley below Auburn is derived chiefly from
precipitation on the valley floor and on the adjacent Des Moines and
Covington Uplands. These uplands are composed chiefly of unconsoli-
dated glacial and glacial-fluvial deposits and have the capacity of
absorbing and transmitting large volumes of water.
Groundwater beneath these uplands is recharged or replenished
by precipitation during the wet winter months, moving west from the
Covington Uplands and east from the Des Moines Upland. It dis-
charges directly into the Green River, its tributaries, and the flood
plain. The discharge of groundwater to the Green River valley has
helped create wetland areas in some parts of the valley.
Groundwater resources of the Green River valley are used for
private and municipal water supplies. Shallow wells generally yield
adequate domestic supplies, and deeper wells may produce very large
quantities of water, depending on the coarseness of the sands and
gravels.
The entire alluvial Green River valley bottom functions as an
aquifer, replenishing the water supply of Auburn, as well as the
many small water supply systems, such as those adjacent to the Auburn
Interceptor's proposed corridor. For Auburn, two wells in the valley
yield 3 and 4 mgd, but a major portion of Auburn's supply comes from
Coal Creek Springs (6^ mgd) which is south of the White River. West
Hill Springs, due west of 15th St. N.W., is a minor contributor to
the supply (% to 3/4 mgd). Although the City of Kent also relies on
groundwater, the major sources are springs, located east of town on
the plateau. Renton obtains the majority of its municipal water
supply from wells near the Cedar River and a spring east of the city.
About one-tenth of its supply is obtained from the City of Seattle.
25
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Within the Green River valley, groundwater is, in general, of
excellent quality. Some wells do exhibit high chloride concentra-
tions from residual water trapped thousands of years ago in the
alluvial soils that settled in the valley. High iron concentrations
and natural gas odors in some well water may be due to some natural
peat and peaty sediments.^
GREEN RIVER AND DUW/WISH RIVER
The Green River rises in the steep, forested valleys of the
western slope of the Cascade Mountain range in King County and flows
about 80 miles northwest to the town of Tukwila in the glacial valley,
south of Seattle. There, it becomes the Duwamish River and continues
for another 11 miles through a heavily industrialized area to the
river mouth at Elliott Bay on Puget Sound. The total drainage area
of the river above Tukwila is 483 square miles.4 The Howard A.
Hanson Dam, operated by the Corps of Engineers, is located about 53
miles upstream of Tukwila and forms a flood control and conservation
reservoir of 106,000 acre-feet active capacity. Downstream of the
dam, the 15-mile long, rugged Green River Gorge contains a major
diversion structure for the City of Tacoma water supply with a capa-
city of 113 cubic feet per second (cfs). The main tributaries to the
Green River downstream from the dam are Newaukum Creek and the Big
Soos Creek. The Duwamish receives waters from the Green and the
Black River near Tukwila.
USES
Water resources in the Green River area are used primarily for
municipal and industrial water supply, recreation and aesthetics,
irrigation, fisheries, and wildlife. Downstream, the Duwamish is
used for navigation in the industrialized lower estuary. The largest
consumptive uses are for municipal and industrial water supply. Al-
though the City of Tacoma water supply is from a surface source, the
Green River, most of the smaller independent systems rely on ground-
water supplies.^
Because of high annual rainfall, irrigation is generally used
to prevent crop failure and maintain growth during the dry spells
rather than to provide total growing season moisture requirements.
Instream water uses include recreational fishing, boating, and water-
contact sports, as well as anadromous and residential fish propaga-
tion. In the Green River, important anadromous fish are chinook,
coho, chum salmon and steelhead, while resident species include rain-
bow and cutthroat trout. Valuable spawning grounds are located in
26
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the main stem of the river between Kent and the Tacoma diversion
structure, and in Newaukum and Big Soos Creeks 6 (see Fisheries
section). The Washington Department of Fisheries operates a hatchery
for coho and Chinook salmon on Big Soos Creek about two miles above
its confluence with the Green River.
FLOWS
The highest flows in the Green River usually result from winter
rains with lower peaks in April and May due to the snowmelt and
spring rains. Low flow conditions prevail from July through Septem-
ber (see Figure 3).'^ Where the river enters the broad floodplain
at Auburn, the mean annual discharge is 1,345 cfs.
The 100-year flood, as now controlled by the Howard Hanson Dam,
is about 12,000 cfs at Auburn. Reservoir releases during summer
months provide a minimum flow of 110 cfs downstream from the Tacoma
water supply diversion in accordance with an existing agreement with
the State Department of Fisheries. Inflow downstream from this point
increases the minimum flow so that a low flow of about 145 cfs at
Auburn would be expected only about once in ten years.
WATER QUALITY PROBLEMS
Existing water quality in the Duwamish-Green River drainage
system ranges from excellent in the upper reaches to relatively poor
in the Duwamish estuary. In the vicinity of Kent and Auburn, dis-
solved oxygen, temperature, nutrients, and bacteria have been of
concern.
Temperature. On the average, State water quality standards
are violated once in two years at Auburn and Tukwila during the summer
months. Low streamflows during months having long hours of sunshine
and a lack of adequate shading appear to be the cause.6 Annually
in July and August, the surface waters of the Duwamish estuary
violate temperature standards.
Dissolved Oxygen. Standards were violated at Tukwila (RM 12.1)
at least once every two years (during 1964-1971).° Diurnal variations
at this station may still result in violations. Benthic oxygen de-
mands and lowered saturation concentrations of dissolved oxygen with
higher water temperatures are among the causative factors, but bio-
chemical oxygen demand from point discharges of wastewater does not
27
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CD
C
m
co
Flow (Cubic Feet per Second)
4,000
3,000
2.000
1,000
RIVER FLOW
GREEN/DUWAMISH RIVER AT TUKWILA
iitifiiiiiiiififitiiiiiiiiiMii
7/66 TO 6/69
7/69 TO 6/72
\\
Jan Feb Mar Apr May Jun
Jul
Aug Sep Oct Nov Dec
-------
appear to be significant.^ At the Kent-Des Moines Bridge (Metro's
Station 315 - River Mile 21.85), dissolved oxygen concentrations
also continue to be below the standard during low summer flow due to
diurnal variations. 7
TABLE 7. VIOLATIONS* OF STATE'S DISSOLVED
OXYGEN STANDARD (8.0 mg/1)
DURING AUGUST AND SEPTEMBER 1974
AT METRO STATION 315
Dissolved oxygen (milligrams/liter)
August 1 7.66 August 16 7.86
1974 2 7.66 1974 17 7.52
3 7.50 22 7.72
4 7.38 23 7.72
5 7.36 24 7,74
6 7.60 25 7.52
7 7.83 26 7.50
9 8.0 27 7.46
10 7.58 28 7.26
11 7.82 29 7.22
14 7.92 30 7.48
31 7.86
Sept. 4 7.96
1974 6 8.0 and above
*Minimum observed value based on hourly measurements
Figure 4 shows the diurnal variation for August 28, 1974. In
August and September 1974, the lowest dissolved oxygen observed at
this station (River Mile 21.85) was 7.22 milligrams per liter (see
Table 7) In the Duwamish estuary, dissolved oxygen concentrations
violate the standards nearly all of the time during the sumner in
the saltwater wedge underlying the fresh water. At the bottom,
in the salt wedge, concentrations as low as 3.6 milligrams per liter
were recorded during very low summer flows in September 1974 at
Metro's continuous monitoring station at J6th Avenue South.8 jn
surface waters, decreases in dissolved oxygen following a summer
bloom of phytoplankton may violate standards. The phytoplankton
29
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o
c
DIURNAL VARIATION OF DISSOLVED OXYGEN AND TEMPERATURE
Dissolved Oxygen
Temperature, °C mg/l
22.0
21.0
20.0
19.0
18.0
TEMPERATURE
••• MIIIMI DISSOLVED OXYGEN,
MG/L
_._._._ DISSOLVED OXYGEN
% SATURATION
8.0 mg/l. State standard
for dissolved oxygen
4:00 a.m. 8:00 a.m. Noon 4:00 p.m. 8:00 p.m. Midnight
10.00
9.00
% Saturation
8.00
7.00
100%
90%
80%
70%
August 28, 1974 METRO Station 315 Kent / Des-Moines Bridge
-------
blooms appear to be related to low freshwater inflow. (The season-
al flow of the Green River at Tukwila is shown in Figure 3).
Bacteria. Total coliform standards are violated annually during
most of the year.° Sources of contamination appear to originate
upstream in the Green River system.
Nutrients. During any time of the year, nitrate-nitrogen at
Tukwila may exceed the level considered to be critical for algal
blooms (0.3 mg/1). Criteria are exceeded at Auburn only during
months of high runoff, indicating non-point sources.° Nutrient levels
are high enough to support algal growths. Upstream, algae are
probably limited by light rather than nutrients and are limited in
the Duwamish estuary by light plus the wash-out rate.9 Nuisance
aquatic growths have been observed downstream from the Kent-Highlands
land fill site and are thought to be associated with this source.
Toxia Materials. Polychlorinated biphenyls (PCB) have been
found in the Duwamish estuary in sufficiently high concentrations
to warrant additional study. Concentrations of PCB's in zooplankton
were greater than the criteria recommended by EPA. High concentra-
tions were also noted in sediments. The major sources of PCB's
have not been identified,6 although in 1974, an accidental leak
of transformer fluid discharged substantial quantities of PCB's.
High concentrations were noted in the estuary before this spill.
Recent (1973) toxicity bioassays indicate that chlorinated ef-
fluent discharged from Metro's Renton sewage treatment plant can be
acutely toxic to finger!ing coho salmon at dilutions that may occur
during one in ten year low flows in the Duwamish River. Total resi-
dual chlorine (which can be de-toxified by de-chlorination procedures)
appears to be the toxicity factor. Additional studies to examine
chlorine's chronic toxic effects are underway.° Dechlorination of the
Renton effluent is now being performed to control excess chlorine
discharge.
THE AUBURN SEWAGE TREATMENT LAGOON
The existing Auburn Sewage Treatment Plant discharges chlori-
nated effluent from a two stage stabilization and oxidation pond into
the Lower Green River. The facility is located south of 30th Street
Northwest and east of the Burlington Northern Railroad tracks. The
treatment plant is composed of approximately 38 acres of lagoons pre-
ceded by a lift station and a grit removal facility; its lagoons are
31
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arranged in five cells. Raw waste enters the first two aerobic
cells that contain floating aerators where it is held for an average
of five days; it then flows to the final aerobic cells where the
effluent is held for 20 to 25 days.1
PRESENT DISCHARGE
The annual average daily flow of sanitary sewage to the Auburn
lagoon system presently approaches 1.9 million gallons per day (mgd).
Peak daily flows during wet weather were less than 4.6 mgd during
1973 and 1974, but reached 7.0 mgd during February 1975. Instanta-
neous flow rates were less than 6.9 mgd during 1973 and 1974 but
reached 12.5 mgd in February 1975.10 The higher flows resulting from
inflow and infiltration of storm water into the Auburn system remain
a problem during the wet winter months.
On an annual average, the raw influent to the Auburn lagoon has
an oxygen demand equivalent to a population of about 22,000 people.
Lagoon treatment reduced the biochemical oxygen demand (BOD) by about
84% in 1974 and about 82% in 1973, on an annual average. The minimum
treatment provided in 1974 and 1973 was about 67% for the monthly
average reduction of 8005.
EPA's secondary treatment standards require that BOD and suspen-
ded solids are reduced by 85% (monthly average), and both reach con-
centrations of 30 mg/1 (monthly average) and 45 mg/1 (weekly average).
Efficiency checks by the DOE conducted in August 1973, found that
these standards were not met. Reductions in BODs and suspended solids
were 77% and 80%. Effluent concentrations were 36 mg/1 for BOD5 and
55 mg/1 for suspended solids. Most suspended solids in the effluent
are attributed to green algae.1
Although two additional aerators were installed in December 1973,
subsequent data reported by the City of Auburn to the DOE have shown
that EPA's secondary treatment standards are not consistently met.
However, reductions of BODs exceeded 85% during seven of the twelve
months in 1974, and during five months in 1973 (see Figure 5).
Monthly average concentrations of BOD5 were less than the standard
of 30 mg/1 during nine months of 1974, and during four months of 1973.
Suspended solids reductions are not routinely measured, but data
collected by Metro during the fall and winter of 1974 and early 1975
showed that secondary standards for suspended solids are seldom
achieved by the Auburn lagoon. Suspended solids were consistent with
the secondary standard in one of five months in late 1974 - early 1975.
32
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AUBURN LAGOON - FLOWS AND BOD$ REMOVAL
(1973 & 1974)
Flow (MGD)
5.0
PEAK DAILY FLOW
4.0
3.0
AVERAGE DAILY FLOW
I BODg REMOVAL
% ^—r \ / / % V J *****
*••••••„ \ J $ ***«».. ^w ^^ £
„ rt t * **""••»•••«•,. *+**^ f s \ ***^ ^^1*^^ %%**
20 4 ***»mMM««»*ilg* **^ X > **»«•««••«»!«•••*
/\ ,-,. ^ ^»^v ^X* % ** v
/\ ; \ 7; / s^ ^ T \
1 0 L | £ **** ^*^« ^85% Standard \ f \ ^
o y v/
BOD5
Removal (%)
& 100%
90%
80%
70%
F M A M
J J A
1973
S O N D
A*
J
M A M J
0 N D
60%
1974
-------
The lagoon does appear to be meeting the secondary treatment
criteria for bacteria and pH. EPA requirements for secondary treat-
ment are shown in Table 8.
TABLE 8. NUMERICAL CRITERIA FOR SECONDARY TREATMENT
Units of Measurement Monthly Average Weekly Average
BOD ( 5 day) mg/1 30 45
Suspended Solids 30 45
Fecal Coliform Bacteria 200 400
number/100 ml
pH Within limits of 6.0 to 9.0
In accordance with Section 301(b)(l)(B) of the Federal Water
Pollution Control Act Amendments of 1972 (PL 92-500), compliance with
the above level of treatment is to be achieved for all publicly owned
treatment works by July 1, 1977, It is generally recognized that
neither standard oxidation lagoons nor aerated lagoons by themselves
will be able to achieve the required level of treatment.
EFFECTS OF THE AUBURN LAGOON ON WATER QUALITY
The Green River, approximately six miles downstream of the dis-
charge of the City of Auburn, has experienced dissolved oxygen de-
pressions below the minimum applicable standard (8.0 mg/1) on numerous
occasions since July 1969.1 Data reported by Metro for the summer of
1974 for this sampling station were also below the standards (see
Table 1). These data do not indicate a continuing violation of
water quality standards, but do indicate that the Green River only
marginally meets the applicable standard.
In November, 1972, the DOE expressed its belief that the City
of Auburn in combination with other waste sources, contributes to
this depressed oxygen condition in the Lower Green River. DOE anti-
cipates that a low-flow year combined with an imbalance in the Auburn
lagoon could lead to severe violations of water quality standards
downstream .11
RIBCO studies, however, have concluded that a variety of factors
appear to be causing the violations of dissolved oxygen observed fur-
ther downstream at Tukwila. Both benthic organisms and higher down-
stream temperatures may significantly contribute to the decreased
level of dissolved oxygen. Point discharges of wastewater were not
thought to be significant.^
34
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The DOE suspects the nutrient load discharged by the Auburn
lagoon into the Green River may contribute to the dissolved oxygen
depressions downstream. However, DOE surveys of the Green River
below the lagoon's outfall have found no chemical or biological
damage attributable to the lagoon. One adverse impact on present
water quality, possibly associated with the Auburn lagoon's nutrient
load, may be aesthetic; stimulated biologic activity in the Green
River during late summer often creates excessive algae growths and
nuisance slime conditions. However, the principal location of these
excessive nuisance slimes is immediately downstream from the Kent
- Highlands Landfill, which is thought to be the major cause of
these growths.
At the present levels of discharge, no significant degradation
of water quality in the Green River directly attributable to the
lagoon effluent can be discerned. However, many other identifiable
pollution sources do exist in the area. For example, major sources
of typically high coliform counts within the Lower Green River appear
to be upstream dairy farms and manure sprayfields. Wastes from
the State Salmon Hatchery on Big Soos Creek and a fish hatchery near
Palmer contribute to the nutrient load within the Green River, and
meat packing operations in the sewerage area have added very high
BOD and coliform loads in the past. Many portions of the sewerage
area experience problems directly related to improperly sized, sited,
and/or maintained septic tanks.1 Urban drainage may also contribute
to localized water quality problems.l Leachate and contaminated
stormwater from the Kent-Highlands landfill (solid waste disposal
site) are measurably degrading water quality of the Green River and
a creek adjacent to the site.5 The treatment facility effluents
and other discharges from the landfill site do not meet the federal
requirements for secondary treatment and also exceed maximum concen-
trations specified for some heavy metals by DOE guidelines on ef-
fluents from sanitrry landfills.?
iRIBUTARIES TO THE GREEN RlVER
The smaller streams and creeks within the Green River sewerage
area vary in their existing quality. Most are used by anadromous
fish. The waters of the major tributaries, Newaukum Creek, Crisp
Creek, and Big Soos Creek are satisfactory for fish passage, but
would not be considered acceptable for water contact sports or human
consumption due to high concentrations of total coliform bacteria.^
NEWAUKUM AND CRISP CREEKS
Water in these tributaries, which are upstream from the sewer-
age area, is generally of poorer quality than the Green River just
35
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upstream. Although Newaukum and Crisp Creeks are of sufficient
quality to be adequate for fish passage and not detrimental to other
aquatic life, both exhibit unusually high coliform concentrations in
violation of Class A standards. High bacteria, solids, and turbidity
can be attributed to surface runoff from this agricultural area which
contains numerous dairy farms. Nutrients were generally at higher
than desirable levels. Dissolved oxygen levels were also high.
Based upon computer simulation, Newaukum Creek presently significant-
ly impacts the Green River. Nearly 10% of the BOD and ortho-phosphate,
one-third of the ammonia, and approximately one-half of the nitrate
and coliform mass discharges of the Green River above the confluence
with Big Soos Creek can be attributed to Newaukum Creek.6
SOOS CREEK DRAINAGE SYSTEM
Although the general water quality in the Soos Creek drainage
system is acceptable, bacterial contamination results in violations
of the State Class A coliform standards at most stations (Soos Creek,
West Branch Soos Creek, and Little and Big Soos Creek).12 Jenkins
and Covington Creeks are the exceptions. The Soos Creek system is
one of the most contaminated as far as sanitary conditions are con-
cerned. 12
Based on computer simulations, Big Soos Creek significantly
contributes to the mass discharge of nitrate in the Green River at
Tukwila.6
LAKES
The many lakes in the Green River sewerage area vary greatly in
their water quality conditions. Where problems have been identified,
they relate to bacterial contamination or eutrophication. Lakes
naturally undergo an aging process (eutrophication), gradually filling
with organic matter from biological growth and sediment carried by
inflowing streams. During the aging process, which may normally take
thousands of years, the originally clear, pristine lakes fill with
algae and water plants, and eventually become swamps and meadows.
Lakes become less desirable for swimming and boating as they become
more eutrophic and aged. The more desirable species of game fish may
disappear and the diversity of aquatic life forms tends to diminish.
On the other hand, amphibious life, water-dependent animals like
raccoons, beaver, and muskrat, and a variety of insects and birds
will be attracted by the plant growth and abundance of nutrients.
The lake will become more attractive for natural observation.4
36
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Although the aging of lakes is a natural process, it can be
greatly accelerated by artificial increases in nutrient inflow which
provide food for the algae. Phosphorus and nitrogen, the most im-
portant nutrients, are contained in sewage effluent, in runoff from
streets, lawns, cropland, and livestock.
Many of the lakes in the Green River Sewerage Area exhibit
poor sanitary conditions and/or high nutrient levels during some
period of the year. A study conducted in 1971-1972 concluded that
four of the lakes (Jones, Bass, Moneysmith, and Dolloff) were in such
advanced stages of eutrophication that attempts to reduce nutrient
inputs could not be recommended.12 Two lakes (Wilderness and Star)
were recommended for further study. Reductions in nutrient inputs
were recommended for the nine remaining lakes in this area (Meridian,
Deep, No. 12, Retreat, Morton, Sawyer, Lucerne, Pipe, and Shadow).
Excessive bacterial concentrations have been found in several of
the lakes during the summer. Jones and Bass Lakes were somewhat
worse in this respect than Sawyer, Morton, Meridian and Dolloff Lakes
during the 1971-1972 study.
Leachate from septic tanks has been suspected as a source of
both nutrients and bacteria in the lakes of the study area; however,
no data on the magnitude of these potential contributions are avail-
able. Health authorities suspect that Jones Lake may be affected by
septic tank drainage from Black Diamond. Metro noted that one lake,
Star, may be affected by highway drainage.
UATER QUALITY STANDARDS
The applicable water quality standards are the Washington State
Standards adopted June 19, 1973 (WAC-173-201-010 thru 173-201-170)
(see Appendix A). Under these standards each water body is classi-
fied (Lake, AA, A, B, etc.) and beneficial uses to be protected
are designated for each class. Specific numerical criteria have
been established for some parameters (see Appendix). Characteristic
uses to be protected for Class AA and Class A streams include but
are not limited to water supply (domestic, industrial, agricultural);
wildlife habitat; stock watering; general recreation and aesthetic
enjoyment (picnicking, hiking, fishing, swimming, skiing, and boating)
and fish and shellfish reproduction; rearing and harvest; and commerce
and navigation. Similar uses are protected for Class B water with
the exceptions of salmonid fish spawning, water contact recreation,
and domestic (drinking) water supply. Consequently Class B waters
may have higher bacterial counts, temperatures and turbidity and
lower dissolved oxygen concentrations than Class A waters.
37
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The classifications which apply to the Green-Duwamish River
system are shown in Table 9.
TABLE 9. DOE WATER QUALITY CLASSIFICATIONS13
Water
Green River
Green River
Green River
Duwamish
Duwamish
Tributaries
Lakes
Description Class
Headwaters to Nest AA
boundary of Sec. 13,
R7E, T21N
West boundary of Sec. AA
27, R6E, T21N to
West Boundary of
Sec. 13, R7E, T21N
Beg. to West boundary A
of Sec. 13, R7E, T21N
Upstream from the con- A
fluence with the Black
River to the limit of
tidal influence
From mouth South of a
line bearing 254° true
from the NW corner of
Berth 3, Terminal No. 37
to the confluence with
the Black River
In the Green River
Sewerage Area
In the Green River
Sewerage Area
Feeder Streams
to Lakes
A
Lake
AA
Comment
No wastes may be
discharged in this
reach.
Area of Auburn STP
discharge.
Special condition for
total coliform-less
than 1000 organisms/
100 nrilliliters with
less than 20% of
samples exceeding
2,400 when associated
with any fecal source
(Area of Renton Sewage
Treatment Plant Dis-
charge)
38
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REFERENCES
1 Auburn Interceptor EIS, Metro, January 1974.
2 Draft Copy, Final Report: Urban Runoff and Basin Drainage
Study - Green and Cedar River Basins of Washington, U. S.
Army Corps of Engineers, Seattle District, July 1974.
(for RIBCO).
3 Luzier, J. E., Geology and Groundwater Resources of South-
western King County, Washington, U. S. G. S. Water Supply
Bulletin No. 28, Department of Water Resources, Olympia,
Washington, 1969.
4 Final Draft, Water Quality Management Study, Main Report,
RIBCO, (Stevens, Thompson, and Runyan, Inc. - Consultants),
August 1974. (For RIBCO).
5 Final Alternatives, Conclusions and Recommendations, RIBCO
Water Quality Management Study, (Stevens, Thompson, and
Runyan, Inc. - Consultants), March 1974.
6 Review Draft, Appendix 2, Water Quality Analyses, (Appendix
to Water Quality Management Study, August 1974), (Stevens,
Thompson, and Runyan, Inc. - Consultants), January 1975.
(For RIBCO).
7 Personal Communication, Cecil Whitmore, Metro, March 1975.
8 Six Month Report (April - September 1974), Water Quality
Monitoring Review Board, Metro, December 20, 1974.
9 Personal Communication, M. Harper, Stevens, Thomspon and
Runyan, Inc. (RIBCO Consultants). March 1975.
10 Personal Communication, Everett Efflund, City of Auburn,
March 1975.
11 Letter from DOE to Mayor Kersey, City of Auburn, Nov. 1, 1972.
12 Quality of Local Lakes and Streams, Metro, December 1973.
13 Water Quality Standards, State of Washington. Department of
Ecology, June 19, 1973.
14 U.S.E.P.A., Puget Sound 305 - A Report, EPA 910/7-74-001,
Surveillance and Analysis Division, EPA, Region X,
Seattle, Washington. October 1974
38-A
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EXISTING AIR QUALITY
The 1970 amendments to the Clean Air Act (CAA) directed EPA to
set primary and secondary national ambient air quality standards for
the major air pollutants. The standards were to establish the maxi-
mum permissible level for each pollutant. The primary standards were
to be strict enough to protect public health; secondary standards
were to be strict enough to protect the public welfare. Each State
was then directed to formulate an implementation plan which would
assure that the standards would be attained and maintained arid prop-
erly enforced. EPA approved most of the implementation plans in
1972, but was later directed fay the courts to examine the plans again
and to disapprove those which did not have sufficient mechanisms to
assure that the standards would be maintained once met. Pursuant to
this court order, EPA directed States to identify those areas which,
due to current air quality and/or projected emission source growth
rate, were not expected to attain and/or maintain a national standard
by 1985. These areas are known as Air Quality Maintenance Areas
(AQMA).
In the State of Washington, the Seattle-Tacoma area, as defined
by the Washington State Department of Highways, is such an areaJ
Based upon both EPA and Washington Department of Ecology calculations,
the only pollutant expected to violate the standards is the total sus-
pended particulate (TSP).
It has been pointed out by the PSAPCA that the Agency's station
at Kent has recorded violations of the photochemical oxidant standard.
Indeed there may also be violations of ambient standards in the Kent-
Auburn Valley for some other pollutants which are not currently
monitored. The initial steps in the air quality maintenance planning
process, developed by the Washington DOE, examined the need for
maintenance strategies for all pollutants in the Puget Sound Region.
While there may currently be violations of standards for several
pollutants, it was determined that currently identified controls
(such as the Puget Sound Transportation Control Plan) would be
sufficient to attain such standards by the statutory deadlines and
to maintain the standards thereafter.
At the same time, EPA recognizes that current techniques for
determining ambient air levels and trends and the effects of anti-
cipated emission controls on such levels and trends is not foolproof.
Thus we are in a continuing process of evaluating the ambient levels
for all pollutants and examining the results of regulatory emission
control strategieso If such review indicates the need for more
stringent emission control plans, EPA will require a revision in
the Washington State Implementation Plan or require the development
of a maintenance plan for the subject pollutant.
39
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The State must now develop a program which will prevent viola-
tions of the TSP standards through 1985. The Puget Sound Council of
Governments will be working with the Puget Sound Air Pollution Control
Agency and the Washington Department of Ecology to develop this pro-
gram in response to the CAA requirement that national ambient air
quality standards be maintained once attained. The portions of the
implementation plan designed to assure attainment of standards are
being re-examined and will be revised accordingly if necessary.
Since the Auburn Interceptor Service Area is included in the
Seattle-Tacoma AQMA, a detailed examination of the impact of expected
growth in the service area on the TSP levels in the AQMA is needed.
Air quality monitors located in the vicinity of Auburn are used
to assess the current air quality in this area. One, located near
the city center of Auburn, indicates air quality in the urbanized
area. The other, located at the Sreen River Fish Hatchery about
three miles east of downtown Auburn, is an indicator of background
air quality for the immediate area since at this location there
is a minimum of human activity and other localized sources of parti-
culate matter.
The data from the Auburn monitor are shown in Table 10. The
data for 1973, the base year selected for analysis, show an air quality
level of 63 ug/m^, annual geometric mean, as compared to the secondary
standard of 60 yg/rn3. The 1973 data from the fish hatchery indicates
a background concentration in the area of 28 yg/m^.
The "background concentration11 of 28 yg//m3 annual geometric
mean, at the Green River Fish Hatchery, does not conform to the strict
definition of the term since there is probably some contribution to
this concentration from other than natural sources. A true natural
background is probably better represented by those values found at
the Tolt River monitoring station where an annual geometric mean of
13 yg/m3 was recorded in 1973. The difference between this natural
background and this apparent urban background around the Auburn area
is due to the increased human activity. Although the emission inven-
tory accounts for most of the emissions resulting from this human
activity, the inventory and emission estimating procedure is not
detailed or sophisticated enough to account for all sources contrib-
uting to the urban concentrations thereby resulting in an urban back-
ground which is elevated above the natural background and not accounted
for by the emission inventory. In using the Fish Hatchery data as
such an "urban background" the assumption is made that the contribu-
tions to this value from identifiable emissions from the surrounding
area are not significant. It is not known if this assumption is
completely valid but because of its proximity to the Auburn area,
the Fish Hatchery data should be a representative station for deter-
mining the urban background.
39-A
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TABLE 10. TSP AIR QUALITY DATA FOR THE AUBURN MONITORING SITE
Geometric Arithmetic Standard
Mean
1974
52
55
63
51
Mean
57
62
68
57
Geometric
Deviation
1.52
1.62
1.52
1.63
Standard
Arithmetic Number of
Deviation Maximum Days Exceeding
150
23.96
35.03
26.35
27.41
122
257
120
136
0
2
0
0
Meteorological influences on the air quality in the service area
differ somewhat from those in the general Seattle and Tacoma area.
Since the Green River valley is an interior valley, one would expect
a higher frequency of light winds and low level inversions than in an
area adjacent to Puget Sound. Data obtained by Puget Sound Air Pollution
Control Authority (PSAPCA) at their recently-installed wind station
in Kent seems to confirm these expectations on wind speed. A six-month
wind rose for the latter half of 1974 indicates that 49% of the winds
during that period can be classified as light and variable (less than
about 1.5 knots).2
The probable low wind speeds in the area, high frequency of low
level inversions, and the constraining effects of the valley walls
tend to trap locally-generated emissions. This results in poorer
air quality than in areas adjacent to Puget Sound having the same
emission density. Examination of the 1973 TSP patterns in the Puget
Sound area (Figure B-4, Appendix B) seems to confirm that the lower
emission density in the Auburn area results in the same air quality
as many other areas in Seattle and Tacoma with higher emission source
densities.
40
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Washington State Department of Highways, Planning Division,
"Urban Areas In Washington", 1972.
Puget Sound Air Pollution Control Agency, Letter, February 24,
1975, from A. L. Kellogg (PSAPCA) to Dean Wilson (EPA).
41
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EXISTING [JATURAL VEGETATION, WILDLIFE, AID FISHERIES
The Green River Sewerage Area contains richly diverse natural
vegetation, wildlife, and fisheries. There are several urban and
rural communities, as well as large areas of relatively natural
habitat. Many rivers and streams in the area support spawning
populations of anadromous and non-anadromous fish.
HABITATS
The study area falls within the Humid Transitional Life Zone
which extends from sea level to about 3,000 feet in elevation.
In the Green River valley permanent and seasonal wetlands are the
most important habitats. On the surrounding plateaus — the Des
Moines, Black Diamond and Enumclaw Plateaus — the dominant habitat
is a mixed (coniferous-deciduous) forest. Deciduous forests, brush-
lands and wetlands are also found on the plateaus. Some rare and
endangered species are found within the study area.
Terrestrial plant communities are shown in Figure 6. The map
shows developed land, open areas (pastures and fields), brushlands
and saplings (which includes early successional forests), woodlands
(mixed forests and deciduous forests) and some permanent wetlands.
On this map, most of the wetlands are included in the category ap-
propriate to their vegetation type -- open areas, shrubs or wooded.
Location of the wetlands is shown in Figure 7. Rare and endangered
species which might occur in the study area are listed in Table 11.
A list of representative species in the study area is included to
show the great diversity of flora and fauna represented (see
Appendix D).
WETLANDS
Wetlands (see Figure 7), which comprise approximately 8,100
acres, are of particular significance. They are important habitat
for many plants and animals and valuable water resources . In
the Green River valley, wetlands cover large areas of the flood
plain. On the surrounding plateaus, wetlands are smaller, more
isolated areas generally associated with lake basins, depressions
and stream water, and by vegetationJ Not all wetlands types
are represented within the study area. Many of the wetlands
within the study area were not classified by type since insuffi-
cient time was available for adequately identifying vegetation
and determining seasonality and depth of inundation. Wetlands
in the study area are:
42
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ENVItONMENTAL PIOTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 91101
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
PLANT COMMUNITIES
SCALE OF MILES
1
LEGEND
, Pastures, Grass, Open Areas
Permanent Wetlands
THIS MAP WAS PREPARED FROM
AERIAL PHOTOGRAPHS (15) AND
ALREADY EXISTING MAPS (17-19)
FIGURE I
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ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE. WASHINGTON 98101
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
FIGURE 7
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1845 acres of Type I wetlands
800 acres of Type II wetlands
33 acres of Type III wetlands
20 acres of Type VII wetlands
332 acres of Type VIII wetlands
5066 acres of untyped wetlands.
Generally, the untyped wetlands (2330 acres) in the valleys are
Type I and Type II. Untyped areas (2736 acres) on the surrounding
plateaus are Types I, II, VII and VIII. The plants and animals
found in wetlands are marked with asterisks in the species lists.
Type I Wetlands. These are seasonally wet, but are dry during
most of the growing season. Much of this land is covered with
grasses or is farm and pasture land. Type I wetlands serve as rest-
ing and feeding areas for large numbers of waterfowl during migra-
tory periods and during winter. The Washington State Department of
Game2 estimates as many as 30,000 waterfowl (primarily widgeons,
mallards, green-winged teals and pintails) use these temporary wet-
lands during migration periods and in the winter. These wetlands
are of considerable importance in the Pacific Flyway.
Type II Wetlands. These are inland fresh meadows which are
without standing water during most of the growing season, but are
waterlogged within a few inches of the surface. Sedges (Carex spp.)
are the indicator plants. The Type II wetlands are not generally
utilized by waterfowl.
Type III Wetlands. These are generally wet through most of the
growing season with water depths of 6 inches or more. Sedges, bull-
rushes and cat-tails grow here. Type III wetlands are used for feed-
ing and nesting by resident waterfowl. The Washington State Game
Department estimates that there are up to a few hundred pairs of
resident waterfowl.
Type VII Wetlands. The soils of this type are waterlogged to
within a few inches of the surface during the growing season. These
areas are covered with a growth of trees — red alder, willows and
Western hemlock — and can have up to a foot of standing water. They
are used for nesting and feeding by waterfowl and as nesting habitat
for hawks, owls and songbirds.
45
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Type VIII Wetlands. These areas are all peat bogs. The acid
conditions of these bogs provide specialized habitat for plants such
as Labrador tea, swamp-laurel, sundew, and nardhack. Relatively few
birds frequent the bogs.
Wetlands on the plateaus do not receive as intensive use from
migratory waterfowl. Most of these wetlands are probably Types I,
II, VII, and VIII. They are important and, in some cases, unique
(peat bogs) habitats for resident plant and animal species. In
addition, these wetlands are nursery grounds for many animals —
especially reptiles, amphibians and some small mammals — that in-
habit adjacent plant communities.
WOODED AREAS
Wooded areas of the plateaus comprise the largest natural habi-
tat (about 39,000 acres) in the service area. Originally the charac
teristic vegetation was dense forests with Douglas fir, Western hem-
lock and Western red cedar predominating. Logging and subsequent
regrowth have resulted in mixed coniferous-deciduous forests. In
addition to the conifers mentioned above, deciduous trees such as
red alder, white alder, big-leaf maple, madrona, black and cotton-
wood, and various willows are common.
The most common community (about 17,800 acres) in the study
area is mixed coniferous-deciduous forests growing on dry or well-
drained soils. Douglas fir and red alder, in a fairly even mixture,
are the dominant trees. Two other forest communities are found on
moist to wet soils which generally inhibit the growth of Douglas fir.
First, mixed forests, with hemlock, red cedar, and big-leaf maple as
the climax species, cover approximately 11,250 acres. These commun-
ities occur in riparian settings and in areas where drainage is in-
hibited. Also deciduous forests of about 10,000 acres are found in
the study area. The larger trees, from 50 to over 100 feet tall, in
clude red alder, white alder, various willows, poplar, madroria, big-
leaf maple, and black cottonwood. These forests are relatively un-
common in western Washington.
Considerable populations of birds and small mammals (see
Appendix D) inhabit forested parts of the study area. No census
information is available for non-game birds, however, the Washington
State Department of Game inventories of game species have estimated
the following population densities in the approximate service area:
black tailed deer, 690; California quail, 2420; and ring-necked
pheasant, 1180.
46
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AQUATIC AREAS
The project area includes several lakes, rivers, and streams
that, together with their characteristic shoreline vegetation, pro-
vide necessary habitat for waterfowl, herons, and osprey, mammals
favoring aquatic or semi-aquatic habitats (e.g. marsh shrew, Town-
send 's mole, beaver), amphibians and fish. Lake Youngs is a rela-
tively unspoiled area, being part of the City of Seattle watershed
and closed to the public. Development has adversely affected the
habitat around Lake Tapps; however, many birds, notably osprey, use
the lake. Although residential development along the shores of Lakes
Meridian, Sawyer, Morton, Wilderness, Lucerne and Pipe has reduced
its quality and quantity, some natural habitat still remains around
these lakes.
Other lakes -- eg., Moneysmith, White, Panther, Clark, Horse-
shoe, Black Diamond Lakes -- have little shoreline development. The
White and Green Rivers and the vegetation which borders them provide
important habitat. Mill, Big Soos, Covington, and Jenkins Creeks
provide valuable streamside habitats.
OTHER AREAS
Other natural habitats in the service areas include early suc-
cessional forests, pastures, fields and brushlands. Early succes-
sional forests include alder thickets and mature alder-willow-poplar
or alder-madrona stands that are progressing to the mixed forest
types. Trees range from 20 to 50 feet in height. Coniferous seed-
lings -- Douglas fir, red cedar or hemlock depending upon the soils -
are scattered throughout the understory. Pastures, fields, and
brushlands are natural and man-made areas of herbaceous or low,
shrubby vegetation found on adequately drained soils.
RARE AND ENDANGERED SPECIES
Presently the Washington State Department of Game has no offi-
cial list of rare or endangered species. The Game Department is now
developing such a list using information provided by sources includ-
ing the U. S. list of endangered fauna^; the Bureau of Sport Fisher-
ies and Wildlife^; the Audubon Society Blue ListS; the Game Depart-
ment's own rare^ and protected designations.7 Animals which occur
on all preliminary lists and range into the sewerage area8,9,10,ll
are shown in Table 11.
47
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Suitable habitat exists in the area for all animals on the
list. No systematic surveys have been made within the study area
to locate rare and endangered animals and identify their habitat.
In spite of this, most of the birds in Table 11 have been observed
in the study area by local biologists and birdwatchers.
Two species in Table 11--the Aleutian Canada Goose and the
Peregrine Falcon—are on the United States list of endangered animals.
These two species are dependent on the wetlands and riparian habitat.
Sixteen of the bird species (marked with asterisks) and all the
mammals are on the preliminary list of rare and endangered animals
in Washington State, prepared by the U.S. Bureau of Sport Fisheries
and Wildlife in Olympia. One habitat of particular note is a marsh
near the junction of Peasley Canyon Road and the West Valley High-
way. This area is active heronry currently being used by 12 breed-
ing pair of great blue herons. There are no known rare or endangered
plant communities within the study area; however, reconnaissance
data available for the study is poorJ2
48
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TABLE 11 . RARE, THREATENED OR ENDANGERED ANIMALS WHOSE RANGE
INCLUDES THE GREEN RIVER SEWERAGE AREA.
AMPHIBIANS
Northwest Pond Turtle
BIRDS
Western Grebe
Double-crested Cormorant
Great Blue Heron
*Green Heron
Whistling Swan
^Aleutian Canada Goose
Sharp-Shinned Hawk
Cooper's Hawk
Bald Eagle
Marsh Hawk
*0sprey
Gyrfalcon
*Peregrine Falcon
*Pigeon Hawk
Sparrow Hawk
Barn Owl
*Spotted Owl
*Black Swift
*Anna's Hummingbird
Clemmys marmorata marmorata
Aechmophorus occidentals
Phalacrocorax aun'tus
Ardea herodias
Butorides virescens
Olor columbianus
Branta canadensis leucopareia
Accipiter striatus
Accipiter cooperii
Haliaeetus leucocephalus
Circus cyaneus
Pandion haliaetus
Fa!co rusticolus
Falco peregrinus
FaIco columbarius
Falco sparverius
Tyto alba
Strix occidental is
Cypseloides niger
Calypte anna
49
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Endangered
BIRDS (Cont'd)
*Bank Swallow
Purple Martin
*Winter Wren
Bewick's Wren
*Western Bluebird
*Hermit Warbler
Western Meadowlark
*Purple Finch
*Pine Grosbeak
*White-winged Crossbill
*Golden-crowned Sparrow
MAMMALS
*Keen's Brown Bat
*Red Bat
*Townsend's Meadow Mouse
*Red Fox
Animals List (Cont'd)
Riparia riparia
Progne subis
Troglodytes troglodytes
Thryomanes bewickii
Sialia mexicana
Dendroica occidental is
Sturnella neglecta
Carpodacus purpureus
Pinicola enucleator
Loxia leucoptera
Zonotrichia atricapilla
Myotis keeni keeni
Lasiurus boreal is teliotis
Microtus townsendi
Vulpes vulpes fulva
*Species on preliminary list of rare and endangered animals in
Washington State, prepared by the U. S. Bureau of Sport Fisheries
and Wildlife (Olympia).
50
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FISHERIES
Although the Green River Basin contains both warm and cold
water fishes, data and information sufficient for critical evalua-
tion is available only on the cold water group. Anadromous salmon-
ids making up this group are chinook, coho, and chum salmon and
steel head, searun cutthroat, cutthroat, rainbow, and Dolly Varden
trout.
The following information has been extracted from the March 1970
Puget Sound Task Force, Pacific Northwest River Basins Commission's
publication, "Puget Sound and Adjacent Waters, Appendix XI, Fish and
Wildlife."
Chinook spawners along with steelhead and searun cutthroat trout
primarily utilize the Green River, from Tacoma City Light's diversion
structure near Kanaskat, downstream to the vicinity of Kent, and
Newaukum and Big Soos Creeks. Juveniles rear in the entire acces-
sible length of the Green River, in the above tributaries, and in the
estuarine waters.
Coho spawning occurs in some areas of the Green River. Tribu-
taries maintaining coho runs include Newaukum, Crisp, Burns, and
Big Soos Creeks, all upstream from Auburn; and Spring Brook and Hill
Creeks near Kent. Coho juveniles also rear within most areas of the
watershed throughout the year.
Chum salmon occur throughout most of the Green River drainage.
In the mainstem, the adults favor the channel split and slower velo-
city sectors from a point near Newaukum Creek downstream to the vici-
nity of Kent. Chums also spawn in the same tributaries and inde-
pendent drainages utilized by coho. The Green, lower Duwamish, and
the marine environment of Elliott Bay are essential rearing areas.
Significant spawning reaches in some streams are delineated in
Table 12.
Intragravel egg development occurs over an 11-month period be-
cause of the overlapping spawning period of various species.
"Out migration" for all species peaks during the period March-
June, corresponding with high flows during spring runoff. Some migra-
tion of coho and chinook as well as trout occurs throughout the year,
but this is a natural redistribution of juvenile salmonids within the
stream systems. Downstream migrants spend considerable time in fresh
water and the estuarine environment. The Green-Duwamish River is ex-
ceedingly important to the early fresh water rearing of chum salmon.
The lower 6 to 8 miles of the Duwamish River serve as the transition
51
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zone where the fry acclimate to salt water. Extremely vital to the
young are the brackish estuarine waters of the Duwamish waterway
and the marine environment of Elliot Bay. The juvenile salmonids,
after adjusting to the salt water environment, disperse into Puget
Sound, the straits, and the ocean.
Estimated number of anadromous fish produced within the Cedar-
Green River Basin waters and surviving to return as spawners are
presented in Table 13.
Resident fish species are distributed and spawn throughout
the Green River Basin. The upper Green River supports significant
populations of rainbow trout. They also occur in many lakes and
ponds and, to a lesser degree, in tributaries. Cutthroat trout are
more common in lower river tributaries and ponds, but are distri-
buted throughout most of the lakes and streams. Brook trout have
been introduced into lowland and alpine lakes in addition to tribu-
taries and connecting ponds. Dolly Varden, least common of the
native species, occurs in upper sections of the Green River.
TABLE 12. SIGNIFICANT SPAWNING REACHES FOR ANADROMOUS FISH
AND RESIDENT GAME FISH, CEDAR-GREEN BASINS1
Stream
Green River
Newaukum Creek
Big Soos Creek
Section
Kent area to
gorge
Gorge to Tacoma
diversion
Mouth to point
near headwaters
Mouth to point
near headwaters
Stream Mileage
22.0 - 38.0
38.0 - 52.0
0.0 - 11.0
0.0 - 9.0
Type Of
Spawning Area
Numerous broad rif-
fles, some beach
and patch gravel
Occasional rif-
fles, mostly patch
gravel sections
Many short rif-
fles, some patch
gravel areas
Numerous riffles,
many patch gravel
sections
Additional spawning area is provided by virtually all tributaries
entering within described reaches.
52
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TABLE 13. ANADROMOUS FISH SPAWNING ESCAPEMENT, NATURAL AND
(ARTIFICIAL), IN CEDAR-GREEN BASINS
Species Range Average (Annual)
Chinook 1,050-7,810 3,490
(16,720-22,220) (19,370)
Coho 11,380-59,390 32,480
(30,530-78,290) (50,890)
Chum 3,720-43,210 16,6802
Sockeye 45,400-190,000 90.0003
Summer Steel head4 20-180 905
Winter Steelhead4 28,400-52,700 39,4005
Searun Cutthroat4 32,900-60,400 45,800
Searun Dolly Varden6
Periods involved in determining fish numbers are: natural (1956-
1965), artificial (1961-1965), sockeye salmon (1964-1967), trout
(1962-1966).
2Green Basin only.
3Cedar Basin only.
4Totals include natural and (artificial) escapement.
5Does not include those fish utilizing independent drainages.
6No valid totals established.
53
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The Green River Basin is very highly developed industrially,
which has damaged streams and greatly reduced natural production.
Tacoma City Light's diversion structure near Kanaskat prevents ana-
dromous fish spawning utilization of the upper Green River. Stream
production is also limited by high elevation headwaters contributing
cold water during much of the summer growing season.
Intense artificial propagation programs, coupled with consider-
able high quality natural production habitat, produce exceptional
numbers of salmonids.
Fish production data are presented in Table 14.
TABLE 14. ANADROMOUS FISH NATURAL PRODUCTION (HARVEST
PLUS ESCAPEMENT), CEDAR-GREEN BASINS
Species Range Average (Annual)
Chinook 4,200-31,240 13,960
Coho 56,900-296,900 162,400
Chum 7,440-86,410 33,360
Sockeye 48,000-190,000 90,000
Summer Steel head 40-280 130
Winter Steelhead 42,600-79,100 59,100
Searun cutthroat 43,800-80,500 61,000
Searun Dolly Varden2
Iperiod involved in determining fish numbers is 1956-1965. Exceptions:
sockeye salmon (1964-1967), searun trout (1962-1966).
2production limited and therefore not determined.
The State maintains and operates the Green River Salmon Hatch-
ery on Big Soos Creek near Auburn. Fall chinook and coho salmon
and some chum are propagated at the Green River facility. The major-
ity of fish produced here are released in the Green River.
Salmon produced in Basin waters contribute to United States
and Canadian ocean commercial and sport fisheries, to commercial and
sport fisheries in the Strait of Juan de Fuca and Puget Sound, and
to Indian and sport fishing in fresh water areas.
Elliot Bay, which supports over 60,000 angler-days annually, is
a favorite salmon sport fishing area associated with the Green River
runs.
54
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Fresh water salmon angling is also permitted in the lower
Green-Duwamish Rivers. A unique night sport fishery for chinook
occurs in the Duwamish. The average annual salmon catch (1964-1966)
was 270, with more than 655 fish reported in 1966.
The annual utilization and harvest (1966 data) from the Green
River drainage consisted of 111,450 angler-days with 22,550 steel-
head taken. The 1974 Indian catch from the Duwamish-Green River
totaled 13,600 salmon, mostly chinook and Coho (Washington State
Department of Fisheries). Natural production contributes 35 percent
of the total steel head catch in the Green River drainage.
Fisheries information on other streams tributary to the Green
or its tributaries was requested from the Washington State Depart-
ment of Fisheries, and although unavailable at this time, will
shortly be forthcoming.
55
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REFERENCES
1 U. S. Department of the Interior, Wetlands of the United
States, Fish and Wildlife Service, Circular 39., 1971.
2 Stendal, Art, Washington State Department of Game, Mt. Vernon,
Washington.
3 U. S. Department of Interior, Fish and Wildlife Service, United
States list of endangered fauna, Washington D.C., May 1974.
4 U. S. Bureau of Sport Fisheries and Wildlife (Olympia), Prelim-
inary list of rare and endangered animals in Washington State,
in use by the Washington State Department of Game.
5 Blue list, American Birds, December, 1974.
6 Washington State Game Department, Rare Mammals of Washington.
7 Game Code of the State of Washington, Sections 77.12.010 and
77.12.020.
8 Larrison, E. J. and Sonnenberg, K. G., Washington Birds Their
Location and Identification, Seattle Audubon Society, 1968.
9 Larrison, E. J., Washington Mammals. Their Habits, Identifi-
cation and Distribution. Seattle Audubon Society. 1970.
10 Stebbins, R. C., A Field Guide to Western Reptiles and Amphi-
bians, Houghton MiffTin, Co., Boston, 1966.
11 Wahl, T. R. and Paulson, D. R. A Guide to Bird Finding in
Washington, Whatcom Museum Press, Bellingham, Washington, 1973.
12 Personal communication, Dr. A. Krukerberg, Department of Botany,
University of Washington.
13 Wetlands Map of The East Side Green River Watershed Projects,
King County, Washington, Soil Conservation Service, USDA,
Preliminary draft EIS. (This mapping was done in cooperation
with the USDI, Fish and Wildlife Service and the Washington
State Department of Game).
14 Wetlands map of parts of the Green River valley, prepared for
PSGC by Frank Wester!und, Remote Sensing Laboratory, Department
of Urban Planning, University of Washington using U. S. Depart-
ment of Interior EROS IR imagery.
56
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15 1965 aerial photographs, PSGC.
16 1973 aerial photographs, USDA, SCS.
17 Soil Survey of King County, USDA, SCS in cooperation with
Washington Agricultural Experiment Station, November 1973.
18 USGS, 7.5 minute series topographical map, Auburn, Black
Diamond, Buckley, Cumberland, Des Moines, Maple Valley,
Poverty Bay, Renton, and Sumner quadrangles.
19 Environmental Reconnaissance Inventory of the State of
Washington, (provisional) U. S. Army Corps of Engineers,
January 1973.
57
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The proposed action involves the construction by Metro of an
extension of its interceptor system from the City of Kent to the
City of Auburn. Basis of the design for this extension, identified
by Metro as the "Auburn Interceptor," is the projection of future
sewer extensions and population and industry to be served by the
year 2000, as developed during the RIBCO study.
The immediate purpose of the interceptor is to eliminate the
discharge to the Green River of inadequately treated wastewaters
from the Auburn lagoon system. For the longer term, the interceptor
is a segment of a network of additional interceptors and collection
systems planned to satisfy, in part, future needs for sewer service
anticipated within the Green River Sewerage Area.
The extension of Metro facilities to Auburn is consistent with
Metro's Comprehensive Plan, as currently revised; with that element
of PSGC's IRDP dealing with sewerage facilities; and with recom-
mendations contained in the RIBCO Water Quality Management Study.
Elimination of the Auburn discharge responds to recommendations in
Auburn's Comprehensive Plan, to provisions of the NPDES permit is-
sued by DOE for its Renton treatment plant and to directives issued
to Auburn by DOE. The section dealing with the relationship of the
proposed action to other projects and proposals can be found in
Appendix E.
59
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DESIGN CRITLRIA AND FLOW FORECASTS
Flow forecasts for the proposed action and for the alternatives
considered were developed by Stevens, Thompson and Runyan, Incorporated
(SIR), the consultants for RIBCO, in response to a request from Metro
to determine system modifications and estimated costs for a year 2000
design.
Procedures used in determining system modifications are described
by SIR as follows:
"In developing the modifications to Plans A, B and C, that portion of
the Auburn interceptor to be initially constructed was laid out in
accordance with the design shown for Sewage Disposal Project Contract
No. 74-2. The interim connection(s) and various sections of the Green
River Valley Interceptor (as shown in the "Auburn Interceptor Prelimin-
ary Engineering Report") were then added to the "Auburn Interceptor",
thus forming the general layout for Plans A, B and C".
"The total Auburn interceptor service area (as defined by the RIBCO
regional sewerage plan) was then broken down into six drainages,
each being tributary to various part(s) of the pipeline(s). These
basins were then analyzed, using RIBCO's interpretation of PSGC's
land use and demographic projections for the IRDP, to provide the
sewage flow forecasts necessary to size the various pipes that make
up Plans A, B and C".
"Each of the pipes making up the three plans were then sized, using
the aforementioned year 2000 peak wet weather flows. The slopes used
were obtained from the Sewage Disposal Project Contract No. 74-2.
In the case of the various sections of the East Green River Valley
interceptor for Plans B and C, those slopes used were from the Metro-
politan Engineers' analysis conducted for the "Auburn Interceptor
Preliminary Engineering Report". The RIBCO general design criteria
concerning items such as Mannings "n", etc., were also used. The
pipe sizes found to be necessary generally ranged in size from 36
to 72 inches".
Plans A, B and C referenced by STR are three alternative
interceptor configurations originally developed by Metro for a
year 2030 design. Plan A was determined by Metro to be the most
cost-effective alternative and was the project for which plans and
specifications were prepared. The proposed action is the single
interceptor concept of Plan A, scaled to a year 2000 design flow.
Plans B and C are staged construction designs and are discussed
in the following chapter of this statement.
As developed by STR, drainage area 1 includes essentially all
of the upland tributary area east of the Green River valley.
60
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including Black Diamond, Lake Sawyer and Lake Meridian. Drainage
area 2 includes Auburn and the area south to Lake Tapps. Drainage
areas 3, 4 and 5 include westerly portions of the valley and the
uplands on the west side of the valley. Drainage area 6 is the lower
Kent area. Although the total area is the same for all alternatives,
there are slight differences in individual drainage areas used in
the various plans.
The following sections, abstracted from the RIBCO report, were
submitted by SIR to Metro in defining the RIBCO interpretation of
PSGC land use and demographic projections for the IRDP. 2
LAND USE
For the purposes of the WQMS, all the land in the RIBCO basin
is classified under three general land use categories: developed
land, undeveloped available land and unavailable land. These
categories represent an overall general description of the land
use as opposed to a precise description of the use of each parcel
of land within the area. For example, an area described as developed
may actually have contained within it commercial, industrial and
residential lands; developed parks and streets, as well as vacant
land eligible for development. The developed area may also include
small water bodies which would actually be zero population areas.
Except for Lakes Young and Sawyer and the Green River, zero popula-
tion areas are included as part of the land use categories.
DEVELOPED LAND
This category described land that is judged to be generally
developed. The location of these developed areas was based upon
preliminary work completed by PSGC for the calibration of the Activity
Allocation Model. For the calibration, housing densities and devel-
oped land were determined from USGS quandrangle maps and aerial
photographs. In the WQMS the developed land is subdivided into
sewered and unsewered areas. For an area to be sewered or eligible
for sewering, it must be identified as developed. For those areas
not designated developed initially (1970), they will be so designated
(and, therefore, be eligible for sewering) upon reaching a population
density of three people per acre.
61
-------
UNDEVELOPED UNAVAILABLE LAND
The unavailable land, as defined in the WQMS represents the
area described by PSGC's Interim Regional Development Plan (IRDP)
as programmed open space and land severely restricted to development
due to hazardous factors. Development will not be allowed in this
area and residential densities were limited to a maximum of one
person per 10 acres. These areas were considered to never be sewered.
UNDEVELOPED AVAILABLE LAND
The undeveloped land is that land area remaining after the
developed lands and the unavailable lands have been identified.
They are considered available for development because they contain
none of the restricted open space or hazardous areas. In distribut-
ing population to this land category within the AAM, if the population
density reached three people per acre the undeveloped areas were
reclassified as developed and were considered eligible for sewering.
This system of describing land uses offers a means of handling the
complexities of regional land use descriptions in sufficient detail
to forecast regional wastewater flows and determine their location.
INDUSTRIAL
The industrial flows developed for the RIBCO project were based
on levels of industrial employment and were provided by Puget Sound
Governmental Conference (PSGC). The employee projections are based
upon preliminary output of the Activity Allocation Model dated
March 27, 1973. The data provided by PSGC consisted of total number
of manufacturing employees, segregated by 2 digit standard industrial
classifications (SIC) forecasted for employment during the years 1980,
1990 and 2000 and a similar listing for 1970 but broken down by 3
digit SIC's. Industrial flows for each sewage treatment plant service
area in the RIBCO study area were then computed using these employment
data and an array of multipliers called "per employee" flow factors
developed for each of the 2 digit industries.
In deriving these "per employee" flow factors, data contained in
the "1967 Census of Manufacturers" was used. This provided a flow
factor based on national averages in terms of gallons per employee-
day (gped) for each 3 digit SIC used by PSGC. Using this initial
estimate and PSGC's 1970 employment data, a 1970 industrial flow
was then computed for each sewage treatment plant service area.
62
-------
These flows were then compared with industrial flows that were known
to exist at the various sewage treatment plants in 1970. Where
differences in these flows existed, the "per employee" flow factors
were adjusted until the difference was eliminated. This adjustment
was made by changing the initial values of the flow factors, either
up or down, while still maintaining the same relative percent dif-
ference between each of them, as reported in the "1967 Census of
Manufacturers", unless further investigation into particular cases
indicated otherwise. The 3 digit SIC codes were then aggregated
into 2 digit flow factors using a weighted average. The 1970 "per
employee" flow factors thus derived are representative of the 1970
level of technology for those industries correlated in the analysis.
Since the RIBCO study involved long-range planning to the year
2000, it was necessary to compute industrial flows for the years
1980, 1990 and 2000. To accomplish this, per employee flow factors
which would be representative of each of the three years in question
were developed. In making such an assessment, consideration was
given to such factors as technological changes or advances that are
expected to take place in the manufacturing processes used by
respective industries in the coming years, the type of products
expected to be produced and effects of the current emphasis on
reducing industrial water usage.
To determine whether the 1970 "per employee" flow factors should
be increased or decreased to be representative of future years, an
analysis of industrial water usage from 1953 through 1967, as published
by the Department of Commerce "Census of Manufacturers", was used.
This analysis consisted of driving a linear regression of "per
employee" flow factors in gallons per employee per day versus time
(years) for each SIC. This regression curve was then extrapolated
to obtain the flow factors corresponding to the planning years 1980,
1990 and 2000.
63
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DESCRIPTION OF PROPOSED INTERCEPTOR
The projected peak flow to the interceptor is 69.6 mgd for the
year 2000. As shown in Table 15, this value for peak flow is based
on serving a population of 175,858 and an area of 22,769 acres, approx-
imately 27 percent of the tributary area. The pipe diameters shown
in Figure 3 are based on the projected peak flows, on the future
connection anticipated by Metro, and on the capacities provided at
the slopes available for construction.
With completion of the interceptor, all wastewaters entering
the system would be transported to Metro's secondary treatment plant
at Renton. A NPDES permit issued by DOE provides for discharge of
treated effluent to the river. Waste sludge is pumped to Metro's
West Point treatment plant for digestion. Interim disposal of de-
watered, stabilized sludge is by means of truck-trailer transport
to a research site near Eatonville. Routing of the trucks is through
Discovery Park and the Magnolia Bluff residential area. Ultimate
methods of sludge handling and disposal are being studied by Metro.
Construction drawings and specifications provide for the use
of reinforced concrete pipe, installed with an average of 10 to 15
feet of cover. Manhole rim elevations have been established so as
to be above the backwater curve predictions for a 100-year flood.
The construction documents also include general and special
provisions defining the scope, methods and quality of work to be
performed. Contractor compliance with these provisions would be
verified by Metro inspectors and a resident engineer. Additional
limits and controls could be imposed under the terms of permits
which must be obtained from the Milwaukee Railroad, Auburn, Kent,
King County, and the State Department of Fisheries, Game and High-
ways. Plans and specifications are subject to review and approval
by the DOE and the contractor is required to make application for
approval of the Puget Sound Air Pollution Control Agency (PSAPCA).
64
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TABLE 15. PROPOSED ACTION (PLAN A) - FLOW FORECAST SUMMARY
Basin
1
2
3
4
5
6
TOTAL
LAND USE (Acres) ^
Total
56941
10801
7139
4064
1270
2606
82821
De-
veloped
14474
6058
5063
1587
234
1526
27942
Unde-
veloped
Unavail-
able
21577
3278
1156
2006
1009
801
29827
Unde-
veloped
Avail-
able
20890
1465
920
471
27
279
24052
Sewered
Existing
21
1628 4/
3155
275
0
0
0
5058
1980
1652
2571
4788
1587
234
1431
1236:
1990
6265
2903
4788
1587
234
1431
1720^
2000
11731
2903
4788
1587
234
1526
22769
POPULATION
Total
1980
14585
26700
24573
84^4
1015
3627
78944
1990
53372
34377
28066
12092
1370
4317
13309-!
2000
117911
35852
30598
16872
1691
6275
209199
Sewered
1980
10495
26340
22733
4091
931
2793
67383
1990
43294
31447
26226
7739
1286
3483
11475
2000
91681
35852
28758
12519
1607
5441
17585*
Peak Industrial
Flow (mgd )
1980
Neg.
7.6
Neg.
Neg.
Neg.
Neg.
7.6
1990
Neg.
9.2
Neg.
Neg.
Neg.
Neg.
9.2
2000
Neg.
12.2
Neg.
Neg.
Neg.
0.5
12.7
Total Peak Wet
Weather Flow
(mgd)
3/
1980
4.6
23.0
8.4
2.1
0.3
1.9
40.3
1990
13.1
25.7
8.8
2.5
0.3
2.0
52.4
2000
25.0
29.5
9.4
3.1
0.4
2.2
69.6
CTi
cn
1 See Section on Design Criteria and Flow Forecasts.
2 Existing sewered area as of 1970 was selected as the point in time where allowance for peak inflow and infiltration into sewers
should be reduced from 3200 gallons/acre-day to 1100 gallons/acre-day.
3 Total peak wet weather flow for each basin was computer as follows:
1980 Flow - (Existing Sewered Area) (3200 gallons) + (1980 Sewered Area) (1100 gallons) + (1980 Peak Industrial Flow) +
Ac-day Ac-day
(1980 Sewered Population)(63 gallons)
capita-day
1990 Flow - (Existing Sewered Area) (3200 gallons) + (1990 Sewered Area) (1100 gallons) + (1990 Peak Industrial Flow) +
Ac-day Ac-day
(1190 Sewered Population)(67 gallons)
capita-day
2000 Flow - (Existing Sewered Area) (3200 gallons) + (2000 Sewered Area) (1100 gallons) + (1990 Peak Industrial Flow) +
Ac-day Ac-day
(2000 Sewered Population)(75 gallons)
capita-day
4 Considered as "new" sewers because of known low inflow and infiltration rates.
-------
I i I"*1"" ^ast Green River Valley Interceptor
Section A,
L—-— Kent Cross Valley interceptor
;Auburn Interceptor
\||is Street Cdflnei
........... Proposed 1975
s
Extension
' \
Proposed future
Extension
Scale 1:24000
«».>^— East Green River Valley Interceptor
, .•y;~<^>'^L
ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 98101
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
TITLE
PROPOSED ACTION
FIGURE 8
-------
ALIGlf EiT OF INTERCEPTOR
The proposed alignment of the interceptor is shown in Figure
8; details of alignment and construction are shown in Metro's
construction drawings,, Much of the route lies within or adjacent
to existing rights-of-way or utility corridors. Construction in
public right-of-way is subject to permit by the appropriate agency
of government; construction on privately owned land is subject to
granting of easment by the owner.
As noted in Metro's assessment, land uses adjacent to the pro-
posed route range from such rural classifications as open land,
pasture, and cultivated fields to such urban uses as residential,
industrial plants, automobile distribution yards, and an airport.
However, most of the land through which the interceptor passes in
Kent and Auburn has been zoned to allow more intensive uses than
now occurring. In Kent, this land has been zoned to allow indus-
trial use, with present rural use reflecting, in part, leases to
farmers until industrial development takes place. In other areas,
apparent rural use represents the partial development of large
industrially zoned tracts. The proposed route is near residential
neighborhoods in Kent.
The only formal recreation facilities near or in contact with
the construction corridor are the undeveloped Kent Park Department
trail system which utilizes the Puget Power right-of-way and the
Green River Levee maintenance road as trail routes. These trail
locations have not been improved with the exceptiion of signs
erected to mark their location. The Green River Levee is planned
to eventually become a part of the Lower Green River Trail of the
King County Urban Trails System. There are no other existing or
planned parks or recreation areas in or near the construction
corridors.
Other features of the proposed alignment include an inverted
siphon crossing of the Green River and the crossing of wetlands
areas just south of 216th Street and just south of South 277th
Street.
COST ESTIMATE
The basis for estimating the cost of the proposed action
(Table 16) andd the staged construction alternatives are described
by STR as follows:
A visual on-site inspection of all proposed routes.
An analysis of the soils survey report, prepared by
Metropolitan Engineers in October of 1974, to provide
estimates of soil conditions for Plans B and C.
67
-------
Preliminary profiles of Plans B and C, as supplied by
Metropolitan Engineers, were reviewed to estimate depths
of manholes and pipes.
Current unit costs were obtained from one of the contrac-
tors, which has participated in the original bidding of
the Auburn Interceptor.
A cost estimate for the Auburn Interceptor (Schedules 1 and 2)
was then made and compared with the previous bids. It was found the
new estimate was equivalent to the median bids previously reviewed.
Therefore, these unit prices were used to estimate the remaining
sections and alternate plans.
68
-------
TABLE 16
AUBURN INTERCEPTOR - PRELIMINARY ESTIMATE
(Based on Seattle ENR of 2198 for March 1975)
AUBURN INTERCEPTOR PLAN A
Quantity - Size Description Cost
31,809 L.F. 72 in. Pipe $ 5,598,385
36 L.F. 60 in. Pipe 5,760
2,044 L.F. 36 in. Pipe ' 204,400
501 L.F. 18 in. Pipe 25,050
850 L.F. Jacked Pipe 333,800
200 L.F. • River Crossing 175,000
1,355 L.F. 6 in. Water Pipe 21,000
Miscellaneous Appurtenances and Structures 1,457,435
CONSTRUCTION COST $ 7,820,830
Contingencies 10% 782,083
Subtotal $ 8,602,913
Washington State Sales Tax (5.3%) 455,954
Subtotal $ 9,058,867
Professional Services (Engineering
Legal and Administration 15%) 1,358,830
TOTAL CONSTRUCTION COSTS $10,417,697
EAST GREEN RIVER VALLEY INTERCEPTOR - SECTION Ax
4,000 L.F. 48 in. Pipe $ 520,000
200 L.F. River Crossing 175,000
100 L.F. Jacked Pipe 50,000
Miscellaneous Appurtenances and Structures 154,400
CONSTRUCTION COST $ 899,400
Contingencies 10% 89,940
Subtotal $ 989,340
Washington State Sales Tax (5.3%) 52,435
Subtotal $ i,041,775
Professional Services (Engineering
Legal and Administration 15%) 156,266
TOTAL CONSTRUCTION COSTS $ 1,198,041
EAST GREEN RIVER VALLEY INTERCEPTOR - SECTION A2
3,850 L.F. 54 in. Pipe $ 577,500
200 L.F. Jacked Pipe 50,000
Miscellaneous Appurtenances and Structures 77,400
CONSTRUCTION COST $ 704,900
Contingencies 10% 70,490
Subtotal $ 775,390
Washington State Sales Tax (5.3%) 41,096
. Subtotal $ 816,486
Professional Services (Engineering
Legal and Administration 15%) 122,473
TOTAL CONSTRUCTION COSTS $ 938,959
GRAND TOTAL PLAN A $12,554,700
69
-------
REFERENCES
1 Letter from Stevens, Thompson and Runyan, Inc. to Metro,
April 4, 1975.
2 Final Draft, Water Quality Management Study, RIBCO, (Stevens,
Thompson and Runyan, Inc. - Consultants), August 1974.
70
-------
. -
*'«.. .
-------
ALTERNATIVES TO TIE PROPOSED ACTION
Alternatives to the proposed 72-inch, 25-year interceptor design
include interceptor designs for the year 2030, staged interceptor
construction for the year 2000, construction of a secondary treat-
ment plant at Auburn, upgraded lagoon at Auburn and a no-action
alternative. To facilitate evaluation and comparison a brief
summary description of each of the year 2QOO alternatives and the
proposed action, together with estimates of cost and present worth
are presented at the end of this chapter.
INTERCEPTOR DESIGN FOR THE YEAR 2030
The preliminary engineering, environmental assessment and con-
struction drawings prepared by Metro were based on needs anticipated
for the year 2030. These needs were developed from Metro's evaluation
of future population and land use. Estimates of future population
were made by extrapolating the Puget Sound Governmental Conference's
projections for the year 1990.
Application of Metro's design criteria to projected population
increases and industrial development resulted in planning of facilities
capable of serving a population of about 255,000 and an area of some
55,000 acres within the Green River Sewerage Area.
Of the alternatives evaluated, Metro determined that a single
interceptor, with a maximum diameter of 78 inches, was the most cost
effective means of accommodating the projected peak flow of 114 mgd.
The location selected for this facility is the same as that of the
proposed action. Metro's construction cost estimate for this facility
was $6,333,350, based on a local ENR Index of 1680. With adjustmnet
of this estimate to the ENR of 2198 used by STR, the estimated cost
of this alternative, including construction, 10 percent contingency
allowance, 5.3 percent sales tax and 15 percent services allowances,
becomes $10,962,300,,
EPA review of Metro's planning documents resulted in a series of
meetings and discussions concerning the uncertainties of projecting
future sewerage needs in the Green River Sewerage Area to the year
2030. Subsequently, it was determined that funding of a 72-inch
interceptor was more appropriate than the original proposal. The
72-inch line would provide the capacity to accommodate the flow
projected in the RIBCO study for the year 2000.
72
-------
STAGED INTERCEPTOR CONSTRUCTION FOR THE YEAR 2000
Two alternative plans for staged interceptor construction were
considered by Metro for a year 2030 design. Evaluation of staged
construction for the year 2000 assumes the same configurations, with
pipe diameters reduced in accordance with the lower flow projected
for the year 2000. Design of staged interceptors is based on the
same year 2000 peak flow projection as that for the proposed action,
although the flows projected by STR from individual drainage areas
differ slightly (Table 17).
Each of the staged construction alternatives would allow the
Auburn lagoon system to be taken out of service with completion of
the first stage of construction. Wastewater would be transported
for treatment at Metro's Renton plant. Effluent would be discharged
to the river at the Renton plant and excess sludge would be pumped
to the West Point plant for digestion and subsequent disposal.
First stage construction of each alternative would follow the
same alignment as that of the proposed action. The location of
second stage construction is described in the following discussion
of each of the alternatives considered.
PLAN B
The first of these alternatives, designated by Metro as "Plan B",
is shown in Figure 9. First stage construction from the existing
Kent Cross Valley Interceptor south to the Green River, and from
30th Street N.W. in Auburn south to the Auburn treatment plant, is
identical with construction of the proposed action. The remainder
of initial construction is 60-inch diameter pipe, as compared with
the 72-inch diameter line proposed for the single 25-year interceptor.
Plan B anticipates 1980 construction of a 42-inch diameter inter-
ceptor to provide interim service to the east side of the Green River
and 1990 construction of about 20,000 lineal feet of 42 and 48-inch
diameter pipeline along the east and north side of the river. Also
anticipated is 1985 construction of a relief line connecting the
existing South Interceptor and the interceptor proposed to parallel
it to the Renton planto The cost estimate prepared by STR for this
alternative is shown in Table 180
73
-------
TABLE 17 PLAN B & C - FLOW FORECAST SUMMARY
Basin
1
2
3
4
5
6
TOTAL
LAND USE (Acres)
I/
Total
57414
10801
7139
4064
1270
2133
82821
De-
veloped
14569
6058
5063
1587
234
1431
27942
Unde-
veloped
Unavail-
able
21837
3278
1156
2006
1009
541
29827
Unde-
veloped
Avail-
able
21008
1465
920
471
27
161
24052
Sewered
Existing
2/
1628 4/
3155
275
0
0
0
5058
1980
1652
2571
4788
1587
234
1431
12363
1990
6265
2903
4788
1587
234
1431
17208
2000
11826
2903
4788
1587
234
1431
22769
POPULATION
Total
1980
14585
26700
24573
8444
1015
3627
78944
1990
53872
34377
28066
12092
1370
4317
13309^
2000
118574
35852
30598
16872
1691
5612
209199
Sewered
1980
10495
26340
22733
4091
931
2793
67383
1990
43294
31447
26226
7739
1286
3483
11475
2000
92108
35852
28758
12519
1607
5014
175858
Peak Industrial
Flow (mgd)
1980
Neg.
7.6
Neg.
Neg.
Neg.
Neg.
7.6 .
1990
Neg.
9.2
Neg.
Neg.
Neg.
Neg.
9.2
2000
Neg.
12.2
Neg.
Neg.
Neg.
0.5
12.7
Total Peak Wet
Weather Flow
(net!)
1980 | 1990
4.6
23.0
8.4
2.1
0.3
1.9
40.3
13.1
25.7
8.8
2.5
0.3
2.0
52.4
2000
25.2
29.5
9.4
3.1
0.4
2.0
69.6
1 See Section on Design Criteria and Flow Forecasts.
2 Existing sewered area as of 1970 was selected as the point in time where allowance for peak inflow and infiltration into sewers
should be reduced from 3200 gallons/acre-day to 1100 gallons/acre-day.
3 Total peak wet weather flow for each basin was computer as follows:
1980 Flow - (Existing Sewered Area) (3200 gallons) + (1980 Sewered Area) (1100 gallons) + (1980 Peak Industrial Flow) +
Ac-day Ac-day
(1980 Sewered Population)(63 gallons)
capita-day
1990 Flow - (Existing Sewered Area) (3200 gallons) + (1990 Sewered Area) (1100 gallons) + (1990 Peak Industrial Flow) +
Ac-day Ac-day
(1190 Sewered Population)(67 gallons)
capita-day
2000 Flow - (Existing Sewered Area) (3200 gallons) + (2000 Sewered Area) (1100 gallons) + (1990 Peak Industrial Flow) +
Ac-day Ac-day
(2000 Sewered Population)(75 gallons)
capita-day
Considered as "new" sewers because of known low inflow and infiltration rates.
-------
I
72"!
-i
54"
•East Green River Valley Interceptor
• Section B3
- Kent^ross Valley Interceptor
,-
•Auburn Interceptor
7*211
is Street
•I II
I • 42"
t.=m>
;s~a, ^
H '-^
,.
\48"
' 'A
-.-V.
\
Green P|vel"
' "
Interceptor Section 1|2x
Staticsn
isting
Ihl^rcep
,.,-,-,-,-, Proposed 1975
Extension
«
Proposed future
Extension
60"
Section B
•.
n*" '
42"
•36'?
Auburn Plant
Connection
ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 98101
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
TITLE
STAGED CONSTRUCTION
ALTERNATIVE PLAN B
FIGURE 9
-------
TABLE 18
AUBURN INTERCEPTOR PLAN B
Quantity Size Description Cost
14,373 L.F. 72 in.
17,436 L.F. 60 in.
2,044 L.F. 36 in.
501 L.F. 18 in.
850 L.F.
tf\r\ T T? — —
1,355 L.F. 6 in.
Miscellaneous Appurtenances
Pipe
Pipe
Pipe
Pipe
Jacked Pipe
River Crossing
Water Pipe
and Structures
$ 2,529,648
2,789,760
204,400
25,050
333,800
175,000
21,000
1,380,035
CONSTRUCTION COST $ 7,458,693
Contingencies 10% 745,869
Subtotal $ 8,204,562
Washington State Sales Tax (5.3%) 434,842
Subtotal $ 8,639,404
Professional Services (Engineering
Legal and Administration 15%) 1,295,911
TOTAL CONSTRUCTION COSTS $ 9,935,315
EAST GREEN RIVER VALLEY INTERIM CONNECTION - SECTION BI
4,000 L.F. 42 in. Pipe $ 460,000
200 L.F. River Crossing 175,000
100 L.F. Jacked Pipe 50,000
Miscellaneous Appurtenances and Structures 154,400
CONSTRUCTION COST $ 839,400
Contingencies 10% 83,940
Subtotal $ 923,340
Washington State Sales Tax (5.3%) 48,937
Subtotal $ 972,277
Professional Services (Engineering
Legal and Administration 15%) 145,842
TOTAL CONSTRUCTION COSTS $ 1,138,119
EAST GREEN RIVER VALLEY INTERCEPTOR - SECTION B2
15,500 L.F. 48 in. Pipe $ 2,015,000
4,000 L.F. 42 in. Pipe 460,000
367 L.F. Jacked Pipe 133,500
Miscellaneous Appurtenances and Structures 619,125
CONSTRUCTION COST $ 3,227,625
Contingencies 10% 322,763
Subtotal $ 3,550,388
Washington State Sales Tax (5.3%) 188,171
Subtotal $ 3,738,559
Professional Services (Engineering
Legal and Administration 15%) 560,784
\
TOTAL CONSTRUCTION COSTS $ 4,299,343
-------
TABLE 18 Continued
EAST GREEN RIVER VALLEY INTERCEPTOR - SECTION B
3,850 L.F. 54 in. Pipe $ 577,500
200 L.F. Jacked Pipe 50,000
Miscellaneous Appurtenances and Structures 77,400
CONSTRUCTION COST $ 704,900
Contingencies 10% 70,490
Subtotal $ 775,390
Washington State Sales Tax (5.3%) 41,096
Subtotal $ 816,486
Professional Services (Engineering
Legal and Administration 15%) 122,473
TOTAL CONSTRUCTION COSTS $ 938,959
GRAND TOTAL PLAN B $16,291,800
77
-------
PLAN C
Metro's revised "Plan C" is shown in Figure 10. As indicated
previously, first stage construction follows the alignment of the
proposed action. However, maximum pipe diameter is reduced to 60
inches. Future stages include 1980 construction of an interceptor
to provide interim service to the east side of the Green River, as
in Plan B, and 1985 construction of the 42 and 48 inch diameter,
East Green River Valley Interceptor, beginning at N.E. 30th Street
in Auburn and extending northerly and westerly along the east side
of the river to Kent, at which point the proposed alignment is
northerly through highly developed commercial area in Kent. As in
the proposed action and in Plan B, this alternative also anticipates
1985 construction of a relief line connecting the two interceptor
stages north of Kent.
The complete separation of facilities in Plan C does permit
greater flexibility in adjusting the timing and capacity of second
stage facilities to more closely correspond to future needs. How-
ever routing through the commercial area of Kent would be more costly
and disruptive than the single line skirting Kent in the proposed
action and Plan B. The cost estimate made by STR for this alternative
is shown in Table 19.
REGIONAL TREATMENT PLANT AT AUBURN
As an option to interception to Metro's Renton plant, this
alternative provides for a regional treatment facility at Auburn,
with continuation of effluent disposal to the Green River at Auburn.
This alternative assumes the dismantlement of the existing lagoon
system and construction of a conventional secondary sewage treatment
plant. Although not in conformance with Metro's Comprehensive Plan,
nor responsive to DOE's order, a properly operated facility of this
type is capable of producing an effluent which would meet the NPDES
requirements.
The alternative of providing regional waste treatment at Auburn
was evaluated during the RIBCO study and was included in two of the
four final configurations developed for the Metro service area. In
conjunction with treatment at Auburn, these configurations also
provide for a 5-1/2 mile interceptor extension to serve the lower
Kent area. The four final configurations resulted from a screening
process applied to a large number of alternative systems combining
various configurations of existing and proposed facilities.
78
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Kent|Cross Valley ^hterceptor
/—Auburrt Interceptc
I,
I 48"
r~"
i
V Willis Stret
!•<— East Green Riyer Valley Ifiterceptor Section
^Wft* ^, (- ^ >./,,v Xr^c '> cv* \
Propped 1975
I X
Extension
\
Pr'opojs^d future
Extension /
Auburn
Connection**' '
ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 9810]
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
TITLE
STAGED CONSTRUCTION
ALTERNATIVE PLAN C
FIGURE 10
-------
In rural King County, the study resulted in three final configu-
rations to serve the Lake Sawyer - Black Diamond area. One alternative
provided for a secondary treatment plant at Black Diamond, with
effluent disposal to the Green River; the other alternatives provided
for the construction of interceptors to Auburn. The recommended con-
figuration proposed that service initially be provided by constructing
a gravity sewer line to the existing Timberlane pump station on
Jenkins Creek and, about 1988-1990, constructing interceptors along
Covington and Big Soos Creeks to Auburn.
Construction of these interceptors would eliminate the need for
pumping Lake Sawyer - Black Diamond wastes through teh Cascade Sewer
District system and pumping again through the City of Kent system.
For the year 2000, design flows from the Lake Sawyer - Black
Diamond area are 1.4 mgd annual average and 3.0 mgd peak winter flow.
Year 2000 design flows for Auburn are 36 mgd annual average and 55 mgd
peak, including the contribution from Lake Sawyer - Black Diamond.
As planned, construction of a regional treatment facility at
Auburn, together with construction of an interceptor extension to
lower Kent, would provide capacity equivalent to that provided by
the proposed action and would permit essentially the same extension
of sewer service as permitted by the proposed action. The construc-
tion of the treatment plant at Auburn would result in the discharge
of 35 mgd of effluent meeting the limits defined for secondary
treatment. The possible effects this discharge might have on water
quality in the Green River are discussed in the Water Quality Impact
section.
With over three-fourths of the year 2000 wastes diverted to a
plant at Auburn, there would be correspondingly less wastewater
transmitted to Renton and less sludge pumped to West Point for
digestion than would occur with the proposed action. Fewer addi-
tional truck trips would be required to dispose of this material.
No application for funding this alternative has been made by
the City of Auburn or Metro; nor has it been placed on DOE's priority
list. At such time as these events occur, EPA grant regulations
require that a facilities plan and construciton drawings be prepared,
reviewed, and approved before a grant for construction can be made.
The facilities plan includes preparation of an environmental assess-
ment and the potential that an environmental impact statement would
have to be prepared by EPA. A delay of several years should be
anticipated before this alternative could be fully implemented.
82
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UPGRADING OF LAGOON SYSTEM AT AUBURN
In its present configuration, the Auburn lagoon system consists
of pretreatment units, two mechanically aerated cells, and three con-
vential aerobic cells. Total area of the aerated cells is six acres;
combined area of the aerobic cells is 32 acres. Each of the aerated
cells has three mechanical aerators. The engineering consultant for
Auburn, URS-Hill, Ingman, Chase, reports that the annual average
design flow of the lagoon system is 3.2 mgd, although it is possible
to pump over 10 mgd through the plant.
At the present time, the actual annual average flow is about
1.9 mgd. If it is assumed that the increase in flow to the 35 mgd
projected for the year 2000 occurs at a uniform rate, the capacity
of the lagoon system would be reached in approximately a year.
As noted previously, the Auburn treatment facility is typical
of other lagoon systems in its inability to meet suspended solids
limits for secondary treatment. A number of methods of reducing
suspended solids concentrations to acceptable levels have been in-
vestigated, including the use of physical-chemical treatment, rock
or sand filters, and screening. At the present time, however, an EPA
grant for any of these techniques except physical-chemical treatment
would have to be conditioned to require the grantee to assure the
taking of corrective measures if the selected technique failed to
produce the desired results.
Suspended solids concentrations in lagoon effluent can be re-
duced by either sedimentation or flotation of the algae, preceded by
chemical coagulation. In response to a request from EPA, Metro
reinvestigated the upgrading of the Auburn lagoon system. The air
flotation technique was selected by Metro for further evaluation.
For purposes of evaluation, Metro assumed an average flow of 2 mgd,
the use of alum as a coagulant, the use of sulfuric acid to reduce
alum requirements, and an alkaline neutralization step prior to
discharge of the effluent.
Utilization of the air flotation process would result in the removal
of an estimated 7 million gallons per year of 3% sludge at 2 mgd
average flow. An in depth study of methods of disposal of the sludge
was not made. In addition to treatment units necessary for air
flotation and removal of suspended solids, adequate chlorine contact
capacity also would have to be provided. Metro's preliminary eval-
uation also indicated the probable need for effluent pumping with
dissolved air flotation and the possible need for effluent dechlor-
inat.ion prior to discharge.
83
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Upgrading the Auburn lagoon system would not conform to Metro's
Comprehensive Plan or the RIBCO recommendations, nor would it be
responsive to the DOE order to eliminate the discharge of effluent
to the Green River at Auburn. However, the addition of an algae
removal process would result in an effluent meeting with the NPDES
limits as defined for secondary treatment. With no wastes transported
to the Renton plant, there would be no increase, attributable to the
Green River Sewerage Area, in sludge digestion and disposal at the
West Point plant.
Although there appears to be reserve capacity of approximately
1 mgd with an upgraded lagoon, this alternative must be considered
only a temporary solution to an identified water quality problem.
At such time as its capacity is reached, it is probable that DOE
will reimpose its restrictions. It should be noted that these prior
restrictions are only limited to the provision of sewer service.
Unless specific limits are implemented by all of the concerned muni-
cipalities, there is no assurance that growth and development will
not continue, utilizing other municipal systems or privately construc-
ted facilities for treatment and disposal of wastewaters. Since one
such method is the use of septic tanks and drainfields, it can be
anticipated that surface and groundwater problems related to this type
of facility can be anticipated to increase.
Metro has made a preliminary cost estimate for upgrading the
lagoon system, with no allowance for expansion of capacity. This
estimate was $750,000 including allowances of $250,000 each for an
air flotation process, chlorine contact and neutralization and
effluent or interstage pumping. Total annual operating and mainten-
ance costs for these additions was estimated to be $79,000.
This alternative does involve the least initial cost; however,
it does not represent a facility which allows for the provision of
service comparable to that of the proposed action or the other alter-
natives, nor does it consider the cost of providing treatment and
disposal of wastewaters at locations other than Auburn.
No ACTION ALTERNATIVE
Absolutely no action represents a decision not to fund any project
at all. Exercise of this option would result in the continued opera-
tion of the Auburn lagoon system and the discharge to the Green River
of inadequately treated wastewater. A decision to allow this discharge
to continue is contrary to the goals and provisions of Public Law
92-500, "Federal Water Pollution Control Act Amendments of 1972".
84
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COMPARISON OF PROPOSED ACTION AND ALTERNATIVES
For comparison purposes, SIR assumed the Auburn Interceptor to
be in service by 1975. Sections A], B] and C-] of the East Green
River Valley interceptor, regardless of their status as interim or
permanent connections were staged to be in-service by 1980 because
of the existing need for interceptor sewer service on Auburn's east
hill. Sections A2j B3 and C3 of the East Green River Valley
interceptor were staged to be in-service by 1985, based on assumed
flows in Metro's GR41A interceptor and the known capacity of the
GR41B interceptor. Sections 62 and G£ of the East Green River
Valley interceptor were scheduled to be in-service at such time
that the Auburn Interceptor "bottle necks" in that pipe lying
immediately north of the Auburn lagoon. The interim connections
BI and C] were then sized accordingly.!
Table 20 shows the total project costs for each plan and the
corresponding years that funds have been proposed for expenditure.
In addition, the table shows the 1975 present worth of the total
(comparative) project costs, at an interest rate of 5-5/8% for Plans
A, B and C.
Metro made a comparison of costs between the Plan A interceptor
initially proposed and a 35 mgd treatment plant at Auburn. These
costs have been revised by SIR to reflect current cost indices and
are shown in Table 21.
85
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TABLE 20. COMPARISON OF YEAR 2,000 INTERCEPTOR ALTERNATIVES
Plan
A
TOTAL
B
TOTAL
C
TOTAL
Description
Auburn Interceptor
Sec. A, (Interim)
Sec. A2 (East Green)
Auburn Interceptor
Sec. B^ (Interim)
Sec. 82 (East Green)
Sec. 63 (East Green)
Auburn Interceptor
Sec. C-^ (Interim)
Sec. C2 (East Green)
Sec. C-j (East Green)
Limiting
Capacity
(mgd)
74
32
38
54
24
27
38
54
24
26
20
Initial Ost ($xl,000)
1975 Base - ^a Index - 2,198
1975
10,417.7
9,935.3
9,732.1
1980
1,198.0
1,118.1
1,118.1
1985
939.0
939.0
759.5
1990
4,299.3
7,070.3
Present Worth
10,417.7
884.8
512.1
11,814.6
9,935.3
825.7
1,731.7
512.1
13,004.8
9,732.1
825.7
2,847.8
414.2
13,821.6
00
en
-------
TABLE 21
COST COMPARISON OF PROPOSED ACTION AND AUBURN STP
SECONDARY TREATMENT
PLANT
Auburn Interceptor
Expansion of Renton
Treatment Plant to
treat the additional volume
generated in the sewerage
area
Auburn Secondary
Treatment Plant
An Interceptor to
collect sewage between
Auburn and Kent (to
make up for the loss
of joint use of the
larger interceptor)
$20,925,100
3,945,600
TOTAL $24,870,700
OPERATING AND MAINTENANCE COSTS (20 years)
Renton Treatment
Plant
Auburn Treatment
TOTAL PRESENT WORTH
Capital, Operating and
Maintenance Costs
$ 935,000 per yr.
or present worth of
11,058,600
35,929,300
INTERCEPTOR
AS PROPOSED
$11,814,600
9,297,600
$21,112,200
$ 374,000
or present worth of
4,423,400
25,535,900
87
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Letter from Stevens, Thompson and Runyan, Inc. to Metro,
April 4, 1975.
88
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-------
LMD USE IfPACTS
The relationships between wastewater management systems and
land use patterns are largeely unknown. Numerous studies nationwide
have demonstrated that changes in land uses do occur as extensive
and advanced sewerage systems replace septic tanks or inadequate
existing systems. Without adequate control, these changes in land
use can bring about significant deterioration of environmental
quality.
Service and utility systems, such as wastewater management, trans-
portation, water supply, and energy systems, establish the structure
and boundaries for the land development process. The relationship
between these systems and development can be direct and immediate
(e.g., no construction without roads to transport building materials;
no occupancy permits are issued without water, sewer, and power hook-
ups), or it can be indirect, over the long term. The indirect in-
fluences of such systems on development are poorly understood and more
difficult to determine and assess. It is clear, however, that the
process of planning and regulating land use is a direct function of
the development of service and utility systems.
The Environmental Protection Agency recognizes that while
wastewater programs may lead to expeditious resolution of water quality
problems, the provision of sewerage systems also may remove land de-
velopment constraints. In this respect, EPA's decision to fund the
proposed project may be deemed a significant "land use" decision. The
provision of sewers, coupled with the inadequate exercise of land use
controls, can spawn land development patterns which may, in the long
term, be detrimental to environmental quality.
In view of these case histories and in recognition of the fact
that the planning and development of the various systems in the Green
River valley appear to have been influenced by development-oriented
land use plans and policies of local government, EPA (1) encourages
decision-makers to provide the opportunity for widespread citizen
participation in planning for the future; (2) recognizes that the
proposed action can provide the foundation for comprehensive solutions
to social, economic and physical environmental problems by proper
planning, and (3) also recognizes that the proposed action will provide
opportunities for the cities of Auburn, Algona, Pacific, Kent, and
Black Diamond, and King and Pierce Counties, to redefine their land
use goals and control their own patterns and rates of growth.
Historically, growth in the Green River Valley Sewerage Area has
taken place regardless of the presence or absence of sewerage utili-
ties. A report of the Task Force for Citizen Participation in the
90
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RIBCO planning program (The Growth Issue in the Green/Cedar River
Basins of King County, November T974) substantiates this by conclud-
ing, "Metro's development and extension of sewage interceptors (de-
pendent on the existence of sufficient customers to finance the
revenue bonding for these facilities) follows, rather than precedes
development."
Wastewater disposal systems in the Seattle metropolitan area
have not been a primary development-inducing factor. Other develop-
ment-generating conditions have predominated in King County. Sani-
tary sewer service has typically responded to, rather than preceded,
the "leapfrog" development experienced by much of the County. The
most important factors influencing the Seattle area's present land
use pattern have been speculative and political actions by private
industries, improved transportation facilities, and the provision
of water supply systems.
The proposed interceptor will not have significant primary ef-
fects upon land use. Since construction will take place within the
right-of-way corridor, the direct impacts on existing land uses will
be minimal. One residence has been removed and the resident assisted
in re-establishing elsewhere under Metro's relocation plan.
The most significant indication of the proposed project
will be the secondary impacts of the increased capacity for develop-
ment allowed by the expanded sewerage service. The issue raises
such questions as, how much growth will the interceptor allow, what
effects will the interceptor have on the semi-rural character of the
sewerage area; and is growth in the Green River valley area inevit-
able?
Expansion of sewering is one of the pre-conditions for continued
development of the Green River valley. The proposed action, if im-
plemented, will lift the present Department of Ecology ban on exten-
sions of the City of Auburn's sewer system and could increase develop-
ment pressures on available open land or on land currently developed
at low densities. The physical existence of the Auburn Interceptor,
in itself, will not create urban development, as growth and develop-
ment are the result of a broad set of interrelated phenomena such as
birthrates, economic conditions, and migration. The project will,
however, allow urban development dependent upon public sewerage faci-
lities to occur, if the local governmental bodies with existing land
use planning powers determine that such development is appropriate.
The proposed interceptor is consistent with Federal, State, re-
gional, and local utility planning policy and will allow the valley
cities to implement their local comprehensive plans. Only the local
governments retain the legal authority to control and direct the use
91
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of the land within their jurisdictions by such measures as zoning
actions. Because local comprehensive plans are adopted and approved
by elected representatives, the land uses proposed by the Green River
Sewerage Area local comprehensive plans represent the desires of the
study area residents. The comprehensive land use plans are the only
existing identifiable growth and development policy statements regard-
ing land use within the sewerage area which are implementable at this
time.
Projections indicate that growth will most likely continue in
the Green River valley. Any alternative solution which provides
Auburn with adequate waste treatment facilities will lift the Depart-
ment of Ecology's restrictions on trunk, lateral and collector sewers.
The availability of such facilities will allow growth in undeveloped
areas and the resultant impacts overall would be no different than
that provided by the proposed action. Because additional sewer ser-
vices must be made available to sustain the conditions for local popu-
lation and industrial growth, it would be unreasonable to assign the
proposed project any significant growth-constraining or growth-forcing
utility. A number of alternative engineering configurations could
supply the same services and provide the same capacity for expansion.
It is expected that staged interception or resort to local municipal
and industrial sewerage systems (beginning with upgrading of the
Auburn lagoon system) will have precisely the same impact on local
development as the proposed project. Funds for alternative projects
probably would continue to be available out of state and Federal sub-
sidies and, in all probability, the 10% local share of financial
requirements would not be withheld by communities that have proved to
be in active competition for development.
Given the opportunities for other solutions to drainage and sew-
age disposal constraints, then, the growth-stimulating role of the
proposed interceptor must be dismissed as a critical issue. More im-
portantly, attention should be directed to the issue of growth-rate
and the saturation development called for by local land use plans.
If employment and populations trends, which characterized the period
1961-1970 in the Green River valley, are allowed to continue without
policy constraints how much land can be expected to be consumed by
1990?
Table 22 describes the amount of land that may be consumed if a
continuation of trends exists in the Green River valley through 1990.
The allocation of population and employment is based upon a continu-
ation of trends, however, the densities or amount of land consumed
per employee or persons was based on the 1970 densities and does not
reflect a trend towards increased utilization of land by developers.
It does show that if development were to occur at 1970 densities how
much land by 1990 would be developed and for what type.
92
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TABLE 22 . GREEN RIVER VALLEY LAND USE TRENDS IN ACRES2
LAND USE
CATEGORY
Single Family
Multi-family
Total Residential
Retail/FIRES*
Manu./WTCU**
Gov't/Education
Total Employment
Total Employment 3874 11.6%
1961
2218
90
2308
124
766
676
1566
% of Total
Area
6.6%
TO/
.6/0
6.9%
.4%
2.3%
2.0%
4.7%
1970
2752
329
3081
549
1892
581
3022
% of Total
Area
8.2%
1.0%
9.2%
1.7%
5.7%
1.7%
9.1%
% Change
'61-'70
24.1%
265.6%
33.5%
342.7%
147.0%
-14.1%
93 . 0%
1980
3024
414
3438
770
2438
772
3980
% of Total
Area
9.1%
1.2%
10.3%
2.3%
7.3%
2.3%
11.9%
%Change
'70- '80
9.9%
25.8%
11.6%
40.3%
28.9%
32.9%
31.7%
1990
3441
650
4091
1912
3457
883
6252
% of Total
Area
10.3%
2.0%
12.3%
c 707
-J * / io
10.4%
2.6%
18.7%
% Change
'80- '90
13.8%
57 . 0%
19.0%
148.3%
41.8%
14.4%
57.1%
6103
18.3%
57.5%
7418 22.2%
21.5% 10343
31.0%
TOTAL AREA
33318 100.0%
33318 100,0%
0.0% 33318 100.0%
0.0% 33318 100.0%
39.4%
Public
Streets
Special
Total Development
Vacant
Water
341
2261
142
6618
26375
323
1.0%
6.8%
.4%
19.9%
79.2%
1.0%
401
4129
456
11089
21906
323
1.2%
12.4%
1.4%
33.3%
65.7%
1.0%
17.6%
82.6%
221.1%
67.6%
-16.9%
0.0%
572
4458
456
12904
20091
323
1.7%
13.4%
1.4%
38.7%
60.3%
1.0%
42.6%
8.0%
0.0%
16.4%
-8.3%
0.0%
952
5189
456
16940
16055
323
2.9%
15.5%
1.4%
50.8%
-18.3%
1.0%
66.4%
16.4%
0.0%
33.8%
-21.7%
0.0%
0.0%
* Finance, Insurance, Real Estate and Services
** Wholesale, Transportation, Communications and Utilities
CO
-------
The figures in Table 22 indicate that if the 1990 estimates of
land use in the Green River valley are at all realistic, then the
jurisdictions of the valley face two basic problems: overplanning
for residential and industrial land use and underpinning for commer-
cial, public and institutional and parks and open space. This dilem-
ma is not unique to the Green River valley. It is common to every
jurisdiction that prepares a comprehensive land use plan attempting
to achieve its objectives without considering how development is
staged over time.
Table 22 indicates that if no regionally imposed policy con-
straints are used in distributing expected growth throughout the
region and if growth continues as it has in the past, the Green River
valley will undergo relatively rapid urbanization. In 1961, approxi-
mately 80% of the valley lands were vacant. By 1990, open-space or
vacant lands will be reduced to under 50%. Urban business activities
will occupy a significant portion of the newly urbanized areas. In
1961, employment acreage accounted for 4.7% of the total valley area.
In 1990, this category is projected to consume 18.7% of the available
land. Manufacturing/WTCU (Wholesaling, transportation, communications
and utilities) land uses are expected to consume 10.4% of the valley
lands by 1990. Major increases are also expected to occur in retail/
service acreage and in the amount of streets necessary to service the
projected level of activity.2 See Figures 11 and 12 for 1990 land
use projections.
Although the level of activity projected for the valley in 1990
does amount to a substantial increase in growth, it represents only
a small portion of the optimistic land use forecasts which comprise
the valley comprehensive plans. Studies by Corff and Shapiro, Inc.l
and B. Beam2 of the PSGC show that the valley jurisdictions are over-
planning, and perhaps overzoning, for industry. See Table 23 and
Table 4.
In the 32,320 acre study area, it was found the number of acres
(11,610) planned for industry in the comprehensive plans reflects a
500% increase over the valley industrial land used in 1970. This
figure is also in excess of number of the industrial acres (3,457)
that the valley can reasonably expect to receive by 1990. "This vast
amount of planned industrial land (seems) to be out of balance with
the amount of land planned for commercial utilization. By 1990, the
valley can reasonably expect to receive 1,912 acres of commercial
development but only 1,230 acres have been reserved for that purpose"2
(and only 1,750 acres are zoned for that use).
The magnitude of overplanning for industrial land becomes more
apparent when viewed in a regional context. By 1990, the entire Cen-
tral Puget Sound Region will have a projected demand for 7,006 acres
of manufacturing land. Valley jurisdictions are planning for over
~[% times that much manufacturing land to be located just in the Green
River valley.2
94
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UONMIMTAI ft one not* AOINCY
•EQtOM X
I AVENUE UATTU WASHIMOTON »*1O1
AUBURN IKTERCCPTOR
(GREEN RIVER SEWERAGE AREA)
GENERALIZED INTERIM
REGIONAL LAND USE PLAN
ndustridl, Commercial A Airports
Medium Density Residential
Low Density Residential
Forestry & Watershed
Open Space, Agriculture, Rural
Residential, Parks A Recreation
FIGURE 12
-------
2OO SIXTH AVENUE IfAmt WASHINGTON «IO]
*U»U*N INTEICEFTOt
(GREEN HIVE* SEWEKAOE AtEA)
GENERALIZED LOCAL
COMPIEHEN5IVE LAND USE PLANS
LEGEND
ndustrial, Commercial 4 Airports
Medium Density Residential
Low Density Residential
Forestry A Watershed
Open Space, Agriculture, Rural
Residential, Paries & Recreation
FIGURE 11
-------
TABLE 23 . COMPREHENSIVE PLANS - TOTAL ACREAGE
Comp Plans
Land Use Category Acreage % of Area
Industrial 11,610 35%
Commercial 1,230 4%
Residential, SF 9,730 29%
Residential, MF 2,070 6%
Public & Institutional 760 2%
Parks and Recreation 500 2%
Non-Urban Land Use 7,420 22%
TABLE 24 . ACREAGES FROM ZONING AND COMPREHENSIVE PLANS
(1973 Zoned Acres) Comprehensive
Land Use Category Zoning Plans
Industrial 10,460 11,610
Commercial 1,750 1,230
Residential, Single Family 11,440 9,730
(Low-Medium Density)
Residential, Multi Family 1,075 2,070
(High Density, Trailer Parks)
Public and Institutional 770 760
Parks and Recreation Zoned under Public-
Designated Open Space) Institutionalized
Agriculture, Open & Rural,
Residential, Agricultural, 4,450 7,420
Open Space
General (a King County Zone)* 190 nothing comparable
Source: Measurements of composite zoning and comprehensive plan maps
of Green River Valley Study Area.
*General is defined by George McCallum of King County Land Use Manage-
ment as a holding zone, land likely to be rezoned for higher, more
developed uses.
97
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In other words, the land set aside for industrial purposes in
the Green River valley is enough to accommodate all of the manufac-
turing land use that can be expected to occur in the entire region
by 1990 with 4,534 acres left to spare. This unused portion alone
could accommodate all of the expected 1990 manufacturing land use in
King County (2,390 acres).
From these studies it is clear that (1) more land is planned for
industrial use than is zoned for it; (2) more land is zoned for single
family residential use than is planned; (3) less land is zoned for
agricultural-open space use than is planned; and (4) less land is
zoned for high density, multi-family residential use than is planned.
The question, then, that can be appropriately asked is "Can the
proposed interceptor be considered an incentive to urban development
when land is already planned for intensive uses?" EPA recognizes
that the proposed project per se is not the key to continuing growth
in the area simply because alternative dispositions of sewer demand
are possible. An absolute prohibition of incremental sewer service
will stifle growth -- with whatever environmental damages or benefits
it may confer -- but eliminating the Auburn Interceptor project will
not. The answer to the question may be a matter of timing -- a long
range view shows land already committed to industry but, at short
range, the availability of sewers may allow local jurisdictions to
hasten the rates of urbanization of the land.
If adverse impacts associated with uncontrolled urban growth is
to be avoided, growth must occur at a rate that is consistent with a
publicly supported growth policy that fully recognizes the potential
impacts associated with such growth. The interceptor will increase
the capacity of the sewerage area to accept development. In a posi-
tive sense, the interceptor will reinforce patterns of human activity
which have developed in the sewerage area during the past decade. The
development of new industry and business and an increased tax base can
be viewed as beneficial long term effects of the proposed action. In
contrast, urban growth will diminish the natural, rural character of
the Green River Basin if urbanization is encouraged according to the
level called for by present land use plans.
In summary, the proposed interceptor:
(1) will facilitate development in the Green River Sewerage Area.
(2) will enable the provision of sewer service to vacant lands
or to land currently developed at low densities.
(3) may stimulate land prices as pressures to develop the area
increase; major landowners, developers, and speculators will
98
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be financially benefited by the construction of wastewater
treatment systems, particularly sewage transmission facili-
ties, and the induced urban development local governments
may allow to occur.
(4) will provide local jurisdictions the opportunity to amend
their local plans and zoning ordinances so that plans are
consistent with growth policies and will allow plans to be
implemented without the constraints imposed by inadequate
wastewater collection and treatment systems.
If growth is allowed to proceed in an uncontrolled manner, any
excess input can contribute to the overtaxing of natural (water, air)
and man-made (transportation) systems. When such overloading occurs,
pollution is the visible result.
Urbanization is inevitable in the Green River Sewerage area—all
trends point in that direction. Urbanization does have beneficial
effects; however, these effects are often overshadowed by serious
social, economic, and other environmental problems associated with
such growth. EPA fully recognizes that comprehensive solutions to
these problems can be provided by proper planning.
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REFERENCES
Corff, Nicholas J. and Jill T. Shapiro, "The Green River Valley:
A Study of Demand, Capacity and Trends." Draft, September, 1974,
Beam, Brian, "The Green River Valley - A Discussion Paper,"
February 14, 1975.
100
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SOCIO-ECONGMIC If'PACTS
IMPACTS On EXISTING SOCIO-ECONOMIC ENVIRONMENT
Given the existing land use plans and the present planning frame-
work, the provision of adequate waste water collection and treatment
systems will be one factor in allowing urbanization to occur in areas
that are presently undeveloped. If urbanization occurs in an uncon-
trolled manner, the unplanned location of major industrial, commercial,
transportation, and residential facilities will have a direct impact
on the nature of neighborhoods, the opportunities for work and leisure,
and the quality of natural resources.
Like environmental costs, the public costs associated with
increased urbanization can be substantial. Sharp increases in popula-
tion will lead to increased demand for additional public services,
such as schools, fire and police protection, and other utilities.
These costs of providing services, facilities, and utilities to
developing areas presently accrue to the taxpayer.
Additional congestion, for example, created by the increased
development within the Green River area, could overtax the existing
circulation systems, requiring the construction of new transportation
facilities. The costs associated with controlling the increase in
runoff and surface ponding induced by urban development, are quite
high.
Since industrial and commercial development will be made possible,
long-term employment opportunities will increase in the sewerage area.
Uhile this, in itself, provides long term benefits to the people, the
construction of proposed projects such as the Auburn 400 Shopping
Center, which is contingent on the construction of the West Valley
Interceptor, could have adverse economic effects on the existing
"downtown" shopping districts in Auburn and Kent» Although the tax
base in these central business areas may decrease, the tax base of
Auburn, Kent, Algona, and Pacific should, in an overall sense, increase.
The construction phase of the project is expected to provide
about 160 man-years of employment over the two year construction
period. Once the project is completed and put into operation, it
will reduce the number of man-years of employment required to supply
sewerage service to residents of the valley by about 0.4 man-year
per million gallons of sewage throughput, as opposed to providing
sewerage service through individual community systems.
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Studies of employment and population trends in the valley indi-
cate that total employment is increasing two to three times faster
than population. B. Beam' indicates that if trends that character-
ized 1961-1970 continue to influence growth to 1990, employment
opportunities will continue to increase in the valley. As shown in
the forecast in Table 25, manufacturing will account for 46% of the
total employment in 1990. Retail employment is expected to increase
significantly between 1980 and 1990 with the anticipated construction
of the Auburn 400 Shopping Center.
As previously discussed (see section on Land Use Impacts), the
proposed project is only one of a number of alternative engineering
configurations that could supply the same services and provide the
same capacity for expansion. The stage for urbanization is already
set and the incentives to develop are many.
The Green River valley is a logical and favorable site for devel-
opment. It offers developers buildable land which is in close proximity
to major cities. Topography and physiography are such that they offer
little constraint to development. The large parcels of vacant land
in the valley provides the "elbow room" which developers find desirable.
While the tendency of new development will be to spread out rather
than up, increases in land costs should contribute to higher density
development. Development incentives provided by employment opportun-
ities and easy accessibility continue to increase the area's tax
base, but also tend to increase pressures on existing public facilities.
For example, increasing student enrollment in the Kent School
District 415 places greater pressures on schools that are presently
operating at saturation levels. Although schools are already operating
at 5-10% above program capacity, the Kent School District is experi-
encing an approximate 2.5% annual increase in enrollment. Although
national trends reflect decreases in birthrates, the Kent School
District does not anticipate a visible local decline for a while.
These enrollment increases are unique to Kent and other areas such
as Kirkland and Redmond. The general trend has been a decline in
student enrollment.
In the Auburn School District 408 the visible trend has been a
decrease in enrollment since 1969. Although secondary levels are at
or slightly beyond capacity, the elementary levels have been on a
negative trend that is expected to continue.
The anticipated growth will, therefore, have a greater impact on
Kent's schools than Auburn's. Although school districts have planned
for growth from the standpoint of site preparation, low success of
building bond issues can inhibit the expansion of facilities.
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TABLE 25 . GREEN RIVER VALLEY
POPULATION AND EMPLOYMENT FORECASTS1
YEAR
1961
1970
1980
1990
TOTAL
POPULATION
34,441
58,382
64,807
78,394
TOTAL
EMPLOYMENT
8,509
30,076
43,054
62,223
RETAIL
1,847
4,471
6,207
11,541
SERVICES
1,031
2,555
3,270
6,356
MANUFACTURING
2,082
14,663
22,113
28,381
WCTU
1,037
4,603
6,236
9,193
GOVERNMENT
EDUCATION
1,161
3,784
5,228
6,752
o
CO
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Of primary concern in the discussion of the socio-economic impact
are the following issues: (1) Is the policy decision to resort to
centralized treatment in fact cost-effective and (2) is the scale of
the project overly ambitious?
These issues are essentially economic since they do affect sewer
charges for residents of the metropolitan area and also the amount of
state and Federal budget outlays for sewerage purposes. Excessive
expenditures for sewerage can have unfortunate social ramifications
due to the essentially regressive nature of sewer service charges
(burden on the payee is inversely related to income) and the high
level of demand for governmental outlays for social services.
The proposed interceptor will allow for timely, well-planned
growth without excessive new costs through the orderly phased exten-
sion of sanitary sewerage services.
While the question of separate or centralized sewage treatment
is answerable on technical merits, the question of project size is
less certain.
Adopting the Puget Sound Governmental Conference projections of
population through the year 2000, Metro has designed for a population
consistent with that projection:
TABLE 26. PROJECTED CENTRAL PUGET SOUND POPULATION
1000's OF PERSONS 1970 - 2000
1970 T99Q 2000 GROWTH RATE
Seattle 525.6 453.2 428.5 -0.7%
Other King County 538.5 812.1 915.6 1.8%
Pierce and 800.9 1150.7 1408.0 1.9%
Snohomish Counties
Project Area 72.0 175.0 271.8 4.5%
TOTAL 1937.0 2591.0 3024.0 1.5%
The population projection for the year 2000 fails to take into
account the pronounced reduction in population growth that has taken
place in recent years. In the Seattle area (and to a significant
104
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degree, the State of Washington) growth in the post-war period was
extraordinarily related to a single industry, aerospace. The decline
of that industry since 1968 has caused a reversal of Seattle area
growth that does not appear to be reflected adequately in the projec-
tion of design population:
TABLE 27. ANNUAL RATES IN KING COUNTY VS. WASHINGTON
KING COUNTY WASHINGTON
1950-60 2.4% 1.9%
1960-70 2.2% 1.8%
1970-73 -0.4% 0.2%
The national rate of population growth has been declining
without interruption since 1957. Birth rates, with interruptions
imposed by the age distribution of population, have also generally
followed a negative trend. The fertility rate has been below the
population replacement level in each year of the 1970's. Since
continued population growth in Puget Sound is not inconsistent
with static or declining national population, the design projections
seem disproportionately ambitious and do not appear to adequately
reflect national demographic trends.
The discrepancy becomes very obvious if the Puget Sound Govern-
mental Conference population projections for Central Puget Sound
that served as the basis for Auburn Interceptor design are compared
to the Office of Business and Economic Research Services' 1973
distribution of the preferred (Series E) Census Bureau projection
of national population. (OBERS projections are for the Tacoma
and Seattle-Everett SMSA, substantially the same region as PSGC's
Central Puget Sound area.).
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TABLE 28 . COMPARATIVE POPULATION PROJECTIONS
THOUSANDS OF PERSONS
1950
1960
1970
1980
1990
2000
OBERS
Seattle-Everett
847.4
1107.2
1421.9
1522.1
1690.9
1822.4
Tacoma To
276.8 112.
321.6 142!
411.6 183;
385.9 190!
409.6 2101
424.6 224;
PSGC Difference
1196 71.8
1513 84.2
1937 103.5
2227 319.0
2591 490.5
3024 777.0
The significant differences indicate that there may be problems
with both sets of figures. It is appropriate to emphasize that the
PSGC figures are, at this time, the best available for the small area
which encompasses the Green River Sewerage Area.
Another issue that deserves attention is the incremental energy
demand that will result from the proposed project. The critical issue
is not energy consumption per se, but the difference in energy
consumption resulting from the various possible development configu-
rations that will occur if the proposed action is or is not implemented.
The critical issue is further limited to be net increments in fuel
consumption associated with population and industrial growth if the
growth should occur in the Green River valley or elsewhere in the
Seattle Metropolitan area or in the Pacific Northwest. Given the
overall level of development opportunities in the Seattle-Everett
SMSA, development of the Green River valley, with or without the
Auburn Interceptor, is neutral with respect to energy consumption
in competition with other parts of the SMSA, and is superior in
energy terms to additional development in other places such as the
Snohomish and Puyallup valleys.
IMPACTS ON HISTORIC AND ARCHAEOLOGICAL SITES
The National Historic Preservation Act (16 USC 470) and the
Archeological and Historic Preservation Act (16 USC 469) require,
for a Federally-assisted project such as the proposed Auburn Inter-
ceptor, an evaluation of potential impacts on historic properties.
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Identification and evaluation of national and state historic sites
in the Auburn area revealed only one site in the area of possible
direct impact. Further evaluation of the potential for impact on
this site, the Seattle-Tacoma Interurban right-of-way, and consulta-
tion with the State Historic Preservation Officer, resulted in the
determination that the proposed project would have no permanent
impact on this historic site. Because the interceptor will be under-
ground, with grade-level manhole covers being the only visible
evidence of its presence, it will not have a permanent impact on
the aesthetic, openspace, or historic values of this site. Any
impact during construction will be temporary since disturbed surface
areas will be restored.
Requirements exist for a similar evaluation of potential impacts
on archeological sites. Although there are no known archeological
sites along the proposed interceptor route, an archeological survey
of the route will be performed. Should any sites be identified in
this survey, or should anything of archeological significance be
discovered during construction, appropriate procedures for preserva-
tion will be followed.
Indirect impacts on historic properties in the proposed service
area need not result, since appropriate local land use controls could
preserve the historic value of these sites, should residential or
commercial development threaten them.
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REFERENCES
Beam, Brian, "The Green River Valley - A Discussion Paper",
Draft, February 14, 1975.
108
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WATER QUALITY IMPACTS
EFFECTS OF THE PROPOSED ACTION ON HATER QUALITY
The primary impacts of the proposed action result from the
elimination of a source of nutrients and biochemical oxygen-demand
at Auburn and subsequent increase in waste discharges at Renton
outfall, about 21 miles downstream. In addition, primary impacts
include those resulting from construction activities along the
interceptor corridor.
GREEN-DUWAMISH RIVER
With construction and operation of the Auburn Interceptor, the
existing Auburn Sewage Treatment Plant will cease operation. With
all waste intercepted, there will no longer be a potential for re-
lease of wastes during unset conditions, which might have a detri-
mental effect during low river flow. Lagoon discharges, averaging
about 590 pounds of BOD5 per day in 1974, will cease. This along
with the corresponding nutrient reduction may result in some slight,
beneficial impact on water quality in near-term. During low flow,
dissolved oxygen depressions, which appear to be primarily due to
benthic algae, and temperature/saturation dissolved oxygen relation-
ships, may occur less frequently. However, upstream sources of
nutrients and high stream temperatures would persist and little
improvement may occur in the reach between Auburn and Renton. Little
change would be expected in the bacterial concentrations in the
river. The major sources of coliform organisms are associated with
runoff and, in general, would probably not be eliminated by an
interceptor.
Although operation of the Auburn Interceptor will divert some
flow from the upstream reaches of the Green River, the impact of
this diversion on the critical low flow conditions should be insig-
nificant. During months when the river flow reaches critical levels
(about 150 cfs), the Auburn Lagoon would typically add only about
3 cfs (2 mgd) to the river or 2% of the flow. Peak lagoon dis-
charges (about 7 mgd or 10 cfs) occur during the winter months when
river flows are river flows are much higher (over 1000 cfs).
The very slight impact on low flow conditions, by eliminating
the Auburn Lagoon discharge would be further reduced, if low flow
augmentation procedures at Howard Hanson Dam were instituted. (See
p. 113A) Such augmentation has been cited at the only realistic
alternative for improving temperature and dissolved oxygen problems
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in the upper part of the Green River and has been recommended for
water quality improvement in the Duwamish estuary.
Intercepting Auburn's waste will increase waste discharges to
the Green River from the Renton Sewage Treatment Plant. The wastes
will receive a higher degree of treatment before discharge because
the Renton plant removes 96 percent and 95 percent of the suspended
solids and BOD in flows which do not exceed the dry-weather design
capacity, 36.0 mgd2. (The DOE notes that the plant has a high BOD
removal efficiency apparently because of the high sugar content of
whey waste from two major dairies). Currently, the plant can pro-
vide secondary treatment for an average dry-weather flow of 36.0 mgd
and a peak flow of 96 mgd. Average flows at the Renton plant during
June 1973 through March 1974 were 26.1 mgd. Discharges of BODs and
suspended solids averaged 765 and 1630 pounds per day. Influent BOD5
was equivalent to that from a population of 201,600 although the
actual population served was about 159,000 according to the 1973
NPDES permit application.-^
A comparison of the effluent quality for the Renton and Auburn
facilities is shown in Table 28A. Data were provided by Metro.
Although limited data were available for the parameters shown in the
table below (with the exception of BOD5), for the Auburn plant, the
data shown for Renton reflect the 1974 annual averages. For Auburn,
the months of September, October, and November 1974 are represented.
Poor BOD removal efficiencies were experienced by the Auburn facility
during part of this time.
Table 28A. Effluent Quality of the Auburn and Renton Treatment
Plants
(Pounds per million gallons per day)
Parameter AUBURN RENTON
Suspended Solids 737 62
Chemical Oxygen 1594 435
Demand
BOD5 307 38
Phosphorous 93 30
Ammonia-Nitrogen 157 87
Flows for the Renton plant averaged 26.1 mgd and for the Auburn
plant were about 2.1 mgd.
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Data for bacterial quality of the Renton treatment plant
effluent has been summarized by Metro in Table 28$. The secon-
dary treatment standard for fecal coliform monthly averages
was met throughout the year.
Table 28 B. Summary of Monthly Average*Coliform Concentra-
tions in the Renton Treatment Plant Effluent--
1974
Total Coliform Fecal Coliform
Average 462 13
Maximum 2800 24
Minimum 24 3
^Geometric Mean
As the influent loads to Renton increase, an additional
aeration channel will begin operation. This would reduce the
need to discharge during peak flows a portion of the effluent
that has undergone only primary treatment and chlorination. The
Renton plant can adequately treat the additional waste loads
from the Auburn area, and can accomodate future expansion and/or
the incorporation of advanced treatment facilities, if necessary.
in order to meet the goals of the 1972 Water Pollution Control
Act Amendments.2
110-A
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In summary, the additional discharges at Renton from the Auburn
area should have insignificant near-term impacts on the Green River
downstream or on the Duwamish. The Renton Sewage Treatment Plant
will provide a higher degree of treatment to waste loads which would
have entered upstream. Also, the additional effluent at Renton
would initially be a relatively small percentage of the existing
discharge. Intercepting Auburn's waste may have some beneficial
impact on the Green River between Auburn and Renton, but. it is
likely that violations of State water quality standards for dissolved
oxygen and total coliform bacteria would continue to occur.
Secondary impacts of the Auburn Interceptor are dependent upon
anticipated extensions of the Auburn sewerage systems to serve
existing needs and future growth.
By providing the opportunity for additional connections to the
Auburn sewerage system, the Auburn Interceptor will, in effect,
ultimately increase the waste loads discharged at Renton as existing
residential, industrial, and commercial needs are accommodated and
as future needs due to growth are satisfied. In the year 2000, for
example, some adverse impacts could occur in the Duwamish River, if
the Renton plant is operated in future as it is now.4 This conclu-
sion is based on studies undertaken by RIBCO.
RIBCO used mathematical models to simulate expected water quality
impacts. Their study was based on the following assumptions:
1) the waste loadings from land uses will correspond to the Puget
Sound Governmental Conference's Interim Regional Development Plan
land use projections, 2) that the Auburn Packing Plant (now out of
business) would connect to the sewer system, 3) that the existing
113 cfs diversion of water to Tacoma from the upper Green River
would continue, 4) that the Howard Hanson Reservoir levels would be
managed carefully, and 5) that no changes in water use would occur.
In the RIBCO study, uses of the Green River upstream from Renton
are not expected to suffer from unacceptable water quality in the
year 2000 during low flows. Although wastes discharged to the Green
River Drainage Basin would increase by the year 2000 with changes in
land use, no decreases in the Green River water quality are expect-
ed.2 These increased wastes would be associated primarily with
urban run-off. Smaller streams will be more affected by urban run-
off than the Green River.
The Auburn Interceptor would not significantly impact the
Duwamish estuary water quality in the near-term. Over the long-
term however, there may be adverse secondary impacts from continued
growth. There are three areas of concern as determined by the
RIBCO studies. The first is that the Renton effluent, including
Auburn's wastes, will become a relatively large part of the low
river flow as growth of the Green River sewerage area increases.
110-B
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The average dry weather flow of the Renton effluent is estimated to
become about 80 mgd by 1980, 110 mgd by 1990, and 138 mgd by the
year 2000.
During critical low-flow conditions in the year 2000, the
estimated dry weather flow from the Renton plant will be over half
the river flow about once in two years^, if there is no flow aug-
mentation from Howard Hanson Dam. If no action were taken, fish
would suffer acute toxicity from the chlorinated effluent. Metro
has made acute toxicity bioassays using finger!ing coho salmon.
Of the test fish, 50% survived 24 hours exposure in a mixture of 33%
Renton effluent and river water taken upstream from the discharge
(chlorine residual concentration -0.23 mg/1). Metro is presently
dechlorinating the effluent by sulfonation to reduce the total
residual chlorine which appears to be the major toxicant. Metro is
also determining the lowest effluent chlorine residual that can be
maintained and still meet coliform standards. Tests indicate that,
at the dilutions studied, the residual chlorine is the major toxicant
for acute effects. However, the chronic toxicity of other compounds hot
removed by dechlorination may be important. Metro is also testing
for chronic toxicity.
Problems with chlorine toxicity are not unique to the Renton
discharge and may occur, unrecognized, in other chlorinated munici-
pal discharges. Various alternative methods of achieving satis-
factory disinfection without residual chlorine toxicity in the
effluent are under investigation elsewhere. Dechlorination systems
are currently available to mitigate this potential impact.
The second concern with future Renton discharges is the deple-
tion of oxygen in the Duwamish estuary. Projections of potential
changes in water quality in a complex system like the Duwamish
estuary are difficult to make because the changes will depend not
only on the meteorological and hydrological conditions but also
upon the type and quantity of microbial organisms present to decom-
pose the wastes. Nitrogen-using microbial populations are normally
present in municipal discharges. These bacteria use dissolved oxygen
to decompose the nitrogen in ammonia and organic material. This
process is called nitrification. In many natural streams, these
microbial populations are small and, consequently, the over-all rate
of oxygen removed from the stream due to nitrification is insigni-
ficant. However, if a large population of these nitrifying bacteria
exists, oxygen removal will be more rapid.
RIBCO studies have assumed that, in the year 2000, a sufficiently
large population of nitrifying bacteria would exist in the Renton
wastes or in the estuary to significantly deplete the dissolved
oxygen. Results of these studies indicate that by the year 2000,
with no change in the operation of the Renton plant, the oxygen
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resources of the upper estuary may be insufficient to satisfy the
demands caused by nitrification of ammonia and organic nitrogen in
the effluent under critical conditions of low flow and poor flushing
actionJ Metro consultants have investigated three basic alterna-
tives (see Table 29) and low flow augmentation has been recommended.
Metro is evaluating these studies and the alternatives.
Also, Metro is evaluating results of another mathematical simu-
lation of water quality in the estuary which was based on different
assumptions. These assumptions make the nitrogenous oxygen demand
in the estuary less significant so that the projected dissolved
oxygen depression becomes less severe. However, potential toxicity
problems from the ammonia in the effluent would still be of concern.
Consequently, it seems likely that, in future years, increased
growth will make changes in waste treatment at Renton necessary to
preserve water quality goals. Low-flow augmentation or slower
growth than anticipated could delay the time for instituting these
changes in the absence of regulatory requirements.
Low-flow augmentation of the Green-Duwamish River discharges
has been recommended in the RIBCO studies to improve the lower
Duwamish by dilution of the Renton treatment plant discharge, reduce
the maximum temperatures in the Green River and increase the satur-
ation dissolved oxygen (See Table 29). (Planting of shade trees
was also considered to improve the temperature of the river, but
further investigation was thought necessary before this approach
could be recommended.) Because modifications to Howard Hanson
reservoir would be required, participation of the Corps of Engineers
must be sought by a local agency that is willing to sponsor the
project. Application to the Department of Ecology for the necessary
water rights must also be made. After receipt of the local spon-
sor's request, the Corps of Engineers would study the project
feasibility. This would typically include: 1)Determination of pro-
ject benefits 2) Solicitation of EPA views regarding the need,
value, and impact of the proposed water storage project pursuant to
Section 102 9(b) (3) of PL 92-500; and 4) Hydrology and reservoir
operating rules.
Low-flow augmentation was estimated by RIBCO to have capital costs
of $5 million and annual operation and maintenance costs of $30,000.
Modifications required at Howard Hanson reservoir, involve the in-
take structure, cleaning of reservoir banks and minor relocation of
an existing railroad. An additional conservation pool cf 70,000
acre-feet, could then be filled following flood control operations
in early spring each year. Water released during the summer from
this additional reservoir pool could augment low flows during two
or three months. However, there may be additional demands for this
water. (See p. E-ll for additional discussion)
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TABLE 29. COMPARISON OF ALTERNATIVES TO REDUCE FUTURE DISSOLVED OXYGEN DEFICIT IN DUWAMISH RIVER
ALTERNATIVE SOLUTION
COST ($106)
CAPITAL 0 & M
IMPACT
Nitrogen removal at Renton
treatment plant by
Nitrification
Lime addition (including
sludge handling)
15.4
11.0
2.5
0.5
Improve future D.O. in estuary to near
saturation concentrations.
May increase magnitude of phytoplankton
bloom in Duwamish (nitrification only).
Transport effluent to Puget Sound
21.5
0.3
Improve future D.O. in estuary to near
saturation concentrations.
Elimination of any constituents which
may be discharged to Duwamish.
Low flow augmentation
5.0
0.03
Dilutes nitrogenous BOD such that
future D.O. in estuary is 5.5 mg/1 .
May reduce size of phytoplankton
bloom in lower estuary.
Will cool the Green River 3 to 5°F.
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THE INTERCEPTOR CORRIDOR
Construction of the Auburn Interceptor may have short-term,
adverse primary impacts on water quantity and quality along the
interceptor path. These impacts, which include effects from de-
watering of the trench and crossing of drainage channels and the
Green River, are reversible and efforts will be made to mitigate
them through compliance with existing regulations and through
specifications in the contract for construction.5
Long-term, adverse impacts on groundwater or surface water
should not occur along the interceptor corridor because special
construction techniques will minimize infiltration, conduction,
exfiltration, and bank and streambed erosion in order to comply
with applicable regulations, grant conditions, and construction
contract specifications.
No beneficial impacts on water quantity or quality along the
interceptor corridor are expected to result from the construction
process. The only beneficial impacts along the corridor from the
operation of the interceptor are those which will improve water
quality of the Green River. This is discussed in the section on
the Green-Duwamish River.
The following discussion outlines the probable impacts of the
proposed action on the water quality and quantity along the inter-
ceptor corridor. Where high water tables persist during the
construction season, the trenches dug for the interceptor installa-
tion will probably fill with water.2 The water must be pumped out
of the trenches and disposed of. Disruption of the soil during
construction will create turbidity problems in the groundwater
locally and in the water which must be removed from the trench.
These waters must be properly disposed of to prevent adverse effects
on the receiving streams. What controls are used in each instance
will depend on associated regulations. Controls that could be used
include screened wells to prevent intake of soil particles by the
dewatering pumps, sedimentation basins to remove suspended solids
before discharge to streams, effluent monitoring, and pipe outfalls
and diffusers to reduce soil erosion and ditch bank slumping. The
grant applicant has stated that spawning channels will be protected
by using sedimentation basins, by periodic monitoring of the de-
watering near the wetland near South 277th Street.2
During dewatering of the trench, the local groundwater table
will probably drop slightly, but this should have no adverse impact
on the nearby wells because the deepest trench excavation required
is less than thirty feet and the shallowest wells near the proposed
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corridor range from forty-nine to sixty-five feet.2 Locally, the
short-term impacts increase groundwater turbidity and water level
decrease would be expected but this should not affect water sup-
plies from wells near the interceptor corridor.
After the interceptor pipe has been laid, conduction and in-
filtration could affect groundwater quantity and exfiltration
through cracks or breaks in the pipe could affect groundwater
quality. Groundwater may tend to be conducted along the pipe
through the porous material used as bedding and backfill, thereby
draining saturated, fine-textured soils. Natural drainage for areas
could be altered due to the diversion of water and conduction of
excess water along the pipe to lower elevations. Conduction effects
will be minimized by periodic backfill of fine-grained material to
prevent flow along the trench.2
Infiltration of water into the pipe should have an insignificant
impact on groundwater quantity. Infiltration can be a problem because
excess, additional volumes of water require treatment. Materials and
methods used to construct the Auburn Interceptor will minimize infil-
tration. Most infiltration, carried by the Auburn Interceptor, is
likely to originate in the small collector sewers. In a Seattle area
study, the newer collection systems were reported to have infiltra-
tion-inflow rates eleven hundred and four hundred twenty-five (1100
and 425) gallons per sewered acre per day during wet and dry weather,
respectively. These quantities reflect both groundwater infiltration
and surface inflow. Infiltration into the Auburn Interceptor is
expected to be less than the allowable limits set by EPA even after
some deterioration of the pipe.
Exfiltration is the movement of sewage out of the pipe through
cracks or breaks. All of the Auburn Interceptor pipe joints must
be tested for leaks. The limit on allowable leakage is less than
0.5 gallons per hour per inch of pipe diameter per 100 feet of pipe.
If much greater pressures exist inside the pipe than outside, ex-
filtration could occur. If this occurs, groundwater quality could
be adversely affected.2 However, the inspection and testing pro-
cedures in this project are designed to minimize this possibility.
Crossing watercourses may have short-term adverse impacts but
no significant ones are expected either in the long- or short-term.
Short-term impacts that may occur include pollution from oil and
grease, siltation, and erosion. However, contract specifications
and compliance with the requirements of regulatory agencies will
minimize impacts on water quality and aquatic life. For example,
the crossing of the Green River will follow the stipulations imposed
by the Department of Fisheries to protect spawning conditions; the
Department of Ecology will make routine construction inspections.
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OTHER CREEKS AND LAKES
Sewer service may have beneficial short-term impacts on the water
quality of other streams and lakes in the service area. However,
long-term effects are difficult to determine. The increased den-
sity of development accomodated by the proposed project may cause
adverse impacts. Both short-term and long-term impacts are diffi-
cult to quantify because they result from diffuse sources rather
than point discharges of pollutants. Providing sewer service to
areas which now rely on improperly sited or poorly functioning
septic tanks that drain into lakes or streams or the water table,
may have an immediate beneficial effect on the ground and surface
waters by removing nutrients, oxygen-demanding substances, bacteria,
and viruses. Possible health hazards from septic tank effluent
appearing at the ground surface or entering water supplies should
be reduced as sewage is provided.6 Inadequate septic tank systems
likely contribute to the unsanitary conditions and may also contri-
bute to the accelerated aging of some lakes. When sewage is pro-
vided to these areas, the rate of eutrophication may decrease and
sanitary conditions may improve. Whether or not the long-tern
secondary effects from urbanization will offset these anticipated
benefits is difficult to determine.
In general, unplanned urbanization will produce several types
of interrelated impacts on watercourses.7>8 These impacts are pri-
marily due to the increased runoff from impervious surfaces as with
higher density developments. Urbanization can affect hydrology by
altering: 1) the quantity of runoff, 2) the peak flow characteristics
of streams, 3) the water quality, and 4) the aesthetic value of water
courses.
How much runoff results from precipitation depends on the infil-
tration characteristics of the land. These in turn, depend on the
slope, the soil profile permeability, the vegetative cover, and the
percentage of land covered by impervious surfaces, as streets, roofs,
and parking lots.
Peak flows from rapidly draining impervious surfaces can have
several adverse effects. With increased urbanization, these peak
flows in small streams tend to be higher than under natural con-
ditions. The total quantity of runoff is also greater, because
more of the rainfall runs rapidly over impervious areas without
infiltrating into the soil. As a result, increased storm runoff
can severely affect the small streams, eroding and widening the banks
and destroying aquatic habitats. The high level of pollutants that
washes off the urban areas and the increased sediment load from
erosion create further problems for aquatic life, such as siltation
of spawning beds and smothering of bottom organisms. Overbank
flooding becomes a more common occurrence.
116
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Because runoff increases, groundwater storage and soil moisture
decrease; low flows become more pronounced because the moisture
storage which would normally recharge the stream is reduced. During
low flows, streams experience depletion of dissolved oxygen as stream
temperatures increase, due to the shallower depths in the widened,
eroded channels and, in some instances, the loss of natural shading.
The lower flows have less diluting capacity and less capacity to
withstand contaminant loads. Construction sediments can also add to
stream loads.
With careful planning, however, the potentially adverse impacts
of urbanization can be reduced. Trapping runoff in offstream holding
ponds to even out peak flows and reduce the floatable and settleable
loadings can partially mitigate the effects of urbanization.' Other
measures include land use controls, restrictions on structures in the
stream, special detention and treatment of runoff from large paved
areas, and restrictions on the sale and use of pesticides, fertil-
izers, and toxic materials. Proper cleaning of streets and catch
basins and regulation of construction activities can also reduce
potentially adverse impacts on water quality.
The quality of urban runoff may adversely impact water quality
if controls are not instituted. For example, there may be a long-
term increase in nutrient input to lakes from fertilizers and other
constituents of urban drainage. A local study found that the quality
of one lake in the Seattle area, would probably not improve even if
septic tanks were removed. The increased loads from urban runoff
with the anticipated population growth would essentially negate any
improvement from septic tank discontinuation .9
Urban runoff can also contribute to unsanitary conditions. High
concentrations of coliform bacteria are found in some urban streams
which traverse sewered areas. Thornton Creek, a stream outside the
study area, is local example which has been studied. Table 30 shows
some data on the quality of local urban runoff JO
If major developments install conventional storm drain systems
without proper planning, the Big Soos Creek basin may experience
increased erosion and flooding with damage to the salmon productivity
and aesthetic values of the stream. Computer simulations found no
improvement in bacterial loads in the Big Soos drainage in the Year
2000.4 The two water quality simulations for the Green River Basin
in the Year 1970 and Year 2000 had different point sources as well
as land use conditions, which made it difficult to isolate the
effects due to land use changes. However, the Big Soos drainage
basin simulation affords an opportunity to examine the effects of
urbanization in a case where point sources remained constant and
the only major land use changes were from low to higher density resi-
dential. In the Year 2000, the nitrate loadings increased 33% and
BOD concentrations more frequently violated the study criteria.
117
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TABLE 30. U^BAN RUNOFF POLLUTANT CONCENTRATIONS IN THE SEATTLE AREA
Parameter Single Family Multi Family Mean Concentration9./ Single Family Single Family Commercial
Residential Residential Industrial Commercial Residential Residential Central
Temperature, C°
Conductivity, 'j.Tiho/
Turbidity, JTU
Dissolved Oxygen
BOD
COD
Hexane Extractables
Chloride
Sulfate
Organic Nitrogen
Ammonia Nitrogen
Nitrite Nitrogen
Nitrate Nitrogen
Hydrolyzable
Phosphorus
View Ridge
13.1
cm 125
30
8.6
30
95
12
7.7
17
2.6
0.32
0.11
0.67
0.45
1 View Ridge 2
12.9
136
37
8.9
30
97
16
12
18
3.5
0.48
0.12
0.72
0.40
South Seattle
14.8
134
47
8.5
19
95
14
12.2
26.1
1.7
0.32
0.06
0.83
0.24
South Center L
13.3
99
18.7
9.5
15
70
11
6.6
18
1.4
0.32
0.04
0.64
0.17
ake Hill
14.6
51
15
9.6
8.5
68
7.3
5.3
7
1.4
0.19
0.03
0.51
0.24
s Highlands
10.7
132
22
9.4
8.0
57
8.5
7.5
18
1.4
0.09
0.02
0.76
0.35
Business District
16.6
210
43
7.0
22
66
6.8
24
25
1 .1
0.88
0.12
0.72
0.71
** Due to limited background data from this area, these values are approximate.
a. Concentrations are in milligrams per liter except as noted.
118
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TABLE 30. (CONTINUED)
Parameter
Single Family
Residential
View Ridqe 1
Multi Family
Residential
View Ridge 2
Mean Concentration!/ Single Family Single Family Commercial
Industrial Commercial Residential Residential Central *
South Seattle South Center Lake Hills Highlands Business District
Ortho Phosphorus
Copper
Lead
Iron
Mercury
Chromium
Cadmium
Zinc
Sett. Solids
Susp. Solids
IDS
Total Col i form*
org./lOO mis
Fecal Coliform
org./lOO mis
0.12
0.040
0.44
2.4
0.0003
0.025
0.005
0.18
51
85
134
28,000
3,600
0.12
0.056
0.32
2.0
0.0004
0.009
0.004
0.12
84
112
125
26,000
1,200
0.08
0.10
0.25
2.1
0.0004
0.010
0.005
0.43
60
80
170
4,200
30
0.05
0.081
0.40
0.75
0.0008
0.074
0.004
0.24
40
73
89
1,600
370
0.12
0.076
0.27
0.39
0.0003
0.010
0.004
0.082
40
54
72
37,000
1,400
0.10
0.12
0.08
0.44
0.0008
0.010
0.004
0.068
68
98
101
1 ,600
370
0.16
0.44
0.37
2.0
0.0005
0.28
0.013
0.86
113
190
208
4,600,000
440,000
* Median
** Due to limited background data from this area, these values are approximate.
a. Concentrations are in milligrams per liter except as noted.
119
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BOD increased about 36%, ammonia nitrogen increased about 50%, and
nitrate increased slightly when expressed in terms of pounds dis-
charged per year. The phosphate and BOD criteria, established in the
study, were violated more frequently and no improvment in the coli-
form loadings was found.4
The RIBCO studies also examined the effects of storm runoff on
small streams. For this study, RIBCO used land-use configurations
expected in the Year 2000 and the IRDP modified by drainage basin
boundaries. Two of these drainage areas, the Black River and Mill
Creek, are tributaries to the Green River. Drainage problems of
both were expected to intensify.8
Problems of urban drainage are being recognized by local regu-
latory authorities; new regulations may help prevent the secondary
adverse impacts from urbanized development which will be accomodated
by the proposed action. For example, King County recently passed an
ordinance requiring submission of drainage plans for any substantial
development and, in general, requiring that peak flows not exceed
those which would have been observed under natural conditions. Al-
though additional controls may be necessary to prevent water quality
problems, such measures indicate a recognition of the potentially
adverse impacts. Another approach to problems of storm drainage has
recently been instituted by the City of Bellevue. For the first time
in the State of Washington, a storm and surface water utility author-
ized to charge fees for drainage was created.22 Authority for this
utility approach is found in Chapter 35.67 of the Revised Codes of
Washington.
120
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GROUNDWATER
The construction and existence of an interceptor from Auburn to
Kent will have insignificant impact on the quantity and quality of
groundwater in the valley. Where the excavation has to be dewatered
during construction, there may be some lowering of the water table
immediately adjacent to the excavation. As previously discussed, this
condition would be temporary and local, and should not interfere with
existing water supplies.
Secondary impacts of the proposed project would result from any
changes in land use in Southwestern King County that could take place
more rapidly when utilities are provided. These changes in land use,
whether related to the interceptor, or not, will have effects on
groundwater recharge and ultimately on conditions in the discharge
area in the Green River valley. Land use changes consisting chiefly
of extensive suburban development in the recharge areas on the uplands
would be expected to:
1. Increase the total runoff from the area (runoff being the
combination of both surface and ground water).
2. Decrease the amount of groundwater recharge.
3. Increase stream flow in the wet season.
4. Decrease stream flow in the dry season.
5. Result in a lowering of groundwater levels.
6. Result in a reduction in the flow of springs in the
discharge area.
7. Result in the conversion of some wetlands to dry lands.
The above changes would develop over a long period and might not
be readily apparent without detailed, long-term monitoring.
SEPTIC TANKS
The Auburn Interceptor service area, a large proportion of the
present population (40% or more in Auburn) depends on septic tank
systems. When these are situated on unsuitable soils and where high
water tables exist, the septic tank effluent may rise to the ground
surface and create unsanitary ponding.
121
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Groundwater and surface waters can also be contaminated by per-
colation of subsurface drainage.
The high water table and soil conditions make much of the land
in the area generally unsuitable for septic tank systems.°>12 (See
Figure 13). Although soils may be unsuitable, septic tanks, in some
cases, can be properly installed. County regulations restrict con-
struction of alternative individual waste treatment systems and
require that drainfields and sewers by 48" above the high water
table.13 Recent regulations have denied the construction of drain-
fields on fill even though fill would raise such systems the re-
quired distance above the high water table. Some septic systems
now in use are covered by standing water during flood periods. This
creates a potential health hazard. Where improper systems create
health hazards, the county can require ceasing operation.
The potential for health hazards from septic tanks will be
eliminated when Auburn extends sewer services to those areas having
septic tank problems. Development can then proceed without needing
to construct waste treatment facilities. Under the current con-
straints, these facilities must either satisfy regulations on sub-
surface disposal or satisfy regulations on discharge to surface
streams.
SLUDGE
Sludge from the Renton secondary treatment plant will be
pumped to Metro's primary treatment plant at West Point, Metro's
sludge disposal policy, which is currently under evaluation in con-
nection with their planning effort for meeting requirements of
PL 92-500, calls for this method of sludge management. In the future,
as a strategy evolves, optimal sludge management will be determined
and may include future sludge digestion facilities at other locations.
After operation of the Auburn Interceptor, the sludge volume at
Metro's West Point facility will increase slightly. Adverse impacts
from sludge transportation and disposal are unavoidable at this time.
However, the present methods are viewed as an interim solution.
These may be altered when a final, long-term method of disposal is
implemented sometime prior to 1983.
Transportation of sludge through the Discovery Park and the
Magnolia community adversely impacts the noise environment. Impacts
on air quality through vehicle emissions are relatively insignificant.
Initially, the Auburn sludge will add about one extra truck-trailer
load per week through the Magnolia District. In comparison, about
40 to 50 truck-trailer loads per week are now required for West Point
sludge disposal. About 90% is hauled by truck-trailers of 16 to 21
tons capacity, but some smaller dump trucks are occasionally used.14
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ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 91101
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
SEPTIC TANK SUITABILITY
SCALE OF MILES
0
1
EGEND
rally Suitable Soils
rally Unsuitable Soils
FIGURE
-------
Estimates of sludge volumes J5 which are now being revised by
Metro, indicate that Auburn will account for 2.2% of the total sludge
output at West Point in 1977, and over 4.6% in the year 2000. (See
Table 31). If Auburn sludge grows faster than the assumed 8% annual
increase for the Renton system as a whole, then Auburn would account
for more of the output in the Year 2000. For example, a 10% annual
growth would increase the estimated Auburn contribution in the Year
2000 to 12.14 dry tone per day, or 7% of the total output at West
Point. Transportation needs are based on a moist sludge cake of
20% solids (five times the dry weight).
Table 31
Year
1977
1983
(8% Auburn
growth)
1983
(10% Auburn
growth)
2000
(8% Auburn
growth)
2000
(10% Auburn
growth)
ESTIMATED SLUDGE OUTPUT AT WEST POINT!/
(dry tons per day)
Due to
AUBURN AREA
0.75
(2.2%)
2.14
(2.8%)
2.40
(3.1%)
7.88
(4.6%)
12.14
(7.
Due to
RENTON!/
9.84
(29%)
28.11
(36%)
28.11
(36%)
103.94
(60%)
103.94
(60%)
Total Output at
WEST POINT2/
34.08
(100%)
77.24
(100%)
77.24
(100%)
172.73
(100%)
172.73
(100%)
a. Renton system includes Auburn
b. Due to West Point system plus Renton system
c. Estimates assume 2% growth for the West Point system and 8%
growth for the Renton system. Other assumptions are 1) West
Point captures 60% while primary treatment is used 2) Digesters
reduce volume 50% 3) West Point BPT multiplies sludge output by
1.8 4) additional treatment at Renton.
124
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Until a long-term method of disposal is chosen, long term im-
pacts from transportation and disposal of sludge due to Auburn cannot
be evaluated. Because estimated sludge output at West Point in the
year 2000 is about five times the 1977 levels, any long-term commit-
ment to trailer-truck transportation, which adversely impacts the
noise environment, seems unlikely.
In the near term, impacts of Auburn sludge on the ground and
surface waters near the present West Point sludge disposal sites
will be a small addition to existing impacts from present sludge
volumes. Most West Point sludge now goes to a demonstration area
at Pack Forest near Eatonville. Land application rates of as much
as 100 to 200 tons per acre (dry basis) are being studied, with mon-
itoring of potentially affected natural waters. So far, the spring
discharging below the disposal area has shown no increases in metal
concentrations or nitrogen levels that would be of concern, according
to Metro J6
Some sludge from West Point goes to the King County Cedar Hills
landfill which also receives many other kinds of solid waste. Adverse
impacts on water quality from leachate discharge to a surface stream
are apparent. Any adverse impacts due to Auburn sludge would be a
relatively minor addition to the existing water quality problems for
which solutions must be sought.
FLOOD AREAS
Evaluation of proposed, federally-funded projects that involve
construction or development in flood plains must specifically consider
flood-related impacts.'7 Evaluation of the valley areas that would be
flooded during a 100-year event is complicated by several factors;
1) artificial regulation of the Green River flood flows 2) impaired
drainage of some tributaries at high river stage 3) alteration of
drainage by fill and construction; 4) a proposed, but not yet imple-
mented, comprehensive drainage plan (SCS project) which calls for
pumped drainage to discharge runoff to the Green River; 5) uncertain-
ties regarding levee overtopping in some low-lying areas (particularly
in Tukwila), and the ability of some existing dikes to endure per-
mitted flood flows of the Green River with the addition of more
pumped drainage; and 6) uncertainty regarding implementation of the
Corps of Engineers Flood Control Study recommendations to increase
the river channel capacity (improve the levee system). (See p. E-ll)
A further complication is that, although a comprehensive drainage
for the valley has existed for many years, a detailed definition of
the extent of floodwaters during a 100-year storm for current condi-
tions in the Green River valley has not been prepared. Floodproofing
125
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measures (such as fill), have altered the topography (and drainage)
since the project was initiated. Although the approximate extent of
the flood hazard areas was mapped for the initial phase of the HUD
flood insurance program, this effort was not a detailed study. A
second phase of flood hazard mapping is planned. Although much of
Auburn was shown within the flood hazard area in the first phase of
the HUD mapping, the City has contested this designation.
According to the SCS, for the 100-year flood, without the SCS
pumped drainage, most of the valley floor would be subjected to flood-
waters or severely impaired use under the existing conditions. The
Corps of Engineers prepared a map for waters of the Green River
during a 100-year flood. This map assumes flows of 12,000 cfs at the
Auburn gage and added flows from operation of the proposed SCS pumped
drainage project causing levee failures in some places. Some areas
would flood when waters which overtop the levee or pass through a
break are blocked from returning to the main channel by local topo-
graphy and/or the levee system.
In the vicinity of the river crossing, the Auburn Interceptor
will cross this estimated 100-year flood plain of the Green River and
some frequently flooded areas. Present structural requirements in
the area are generally based on protection from the 100-year flood-
water elevations expected in drainage channels after the construction
of the proposed SCS drainage systemJ8,19 if the SCS project is not
funded and no equivalent drainage system provided, the probability
of flood damage to the interceptor would remain at about its exist-
ing level.
The Auburn Interceptor will allow the extension of Auburn's
sewerage system to serve both current and future needs. In so far
as provision of sewer service accomodates development, the operation
of the interceptor may have a secondary impact in areas now subject
to flooding by serving planned growth in these as in other areas.
Floods frequently innundate and damage the Green River valley.
Reported damages for 1972 and 1973 totaled $109,000 for 43 problems
in the Lower Green River, part of which is within the service area.8
Damages on Big Soos Creek were $3,000 for 5 reported problems." For
Mill Creek, one of the study demonstration areas (which also lies
within the service area), RIBCO estimated that annual damages from
flood and drainage waters were $42,920 or $4,100 per square mile.8
Major problems include extensive flooding of agricultural lands,
extensive road damage, reduced crop yields, and damage to tributary
and mainstream channels. However, future land use projections indi-
cate that industry and commerce will eventually occupy much of the
Valley (including the flood plain) and that suburban residential
development will increase in the uplands and around urban centers.
125-A
-------
With urbanization, storm runoff will increase because impervious sur-
faces cover more area. Open, unprotected areas will then experience
greater flooding problems unless proper drainage facilities are
provided.
Within the Green River sewerage area, the present problems are
chiefly from poor interior drainage, rather than high-velocity flood-
waters. RIBCO studies under the USCOE identified about 4600 acres in
the sewerage area as present problem flooding areas, of which about
3500 acres are situated in the valley. These might be flooded fairly
frequently (10-year frequency). For larger floods, as might occur once
in a hundred years, most of the valley in the Auburn Interceptor ser-
vice area would be subject to floodwaters or severely impaired use,
according to the Soil Conservation Service. Floodproofing measures
are required for developing much of the valley. Also a drainage pro-
ject has been proposed, but is not yet funded. An environmental
impact statement on this project is now being preparedJ9 (See
Appendix E).
No land in the slide hazardous area was planned for development.
Industrial-commercial and residential land use is planned adjacent
to some slide hazardous areas.
Because of the high water profiles of the Green River and preva-
lent flooding problems in the valley, pumped drainage (such as the
SCS West Side Watershed Project) would appear to be the only solution
if the valley is to be extensively developed, according to the RIBCO
studies.
RIBCO has proposed two approaches to urban drainage and runoff
for the lower Green River area.8 RIBCO's Alternative I, which does
not consider onsite runoff control , adequately protects developed
properties but disturbs many natural hillsides and valley streams.
This approach rapidly disposes the larger quantities of runoff into
the main channel of the Green River. Alternative II employs runoff
control and relies on holding ponds (possibly including wetlands,
bogs and lakes) in the upland areas to release runoff more slowly
and provide more opportunity to protect natural streams. However,
both alternatives utilize pumped drainage to accomodate the pro-
jected land uses in the valley. Another approach is to zone land
uses to reduce potential economic losses. For example, by preventing
construction of urban facilities in flood plains or areas of high
flood potential, possible economic losses are minimized and future
expenses for flood control may be reduced. The present approach is
to fill construction sites and flood-proof buildings. Extraction of
fill material from the valley walls could have adverse impacts on
water quality and aesthetic values.
126
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REGIONAL PLAN WITH STAGED INTERCEPTOR
The operation of an interceptor constructed in stages will have
essentially the same impacts on water quality as the proposed action,
However, for the construction phase of each stage, the short-
term, reversible construction impacts described for the proposed
interceptor may occur.
127
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REGIONAL PLAN WITH SECOfiDARY TREATMENT WORKS AT AUBURN
Primary impacts on water quality in the Green-Duwamish River
from this alternative depend upon the reliability of the process
selected and the quality and quantity of the effluent. Other pri-
mary impacts would result from construction of the physical facili-
ties.
GREEN-DUWAMISH RIVER
In the short-term, the lower suspended solids from secondary
treatment, though satisfying EPA's numerical criteria, may not signi-
ficantly impact the Green River. Required monthly average removal
efficiencies for biochemical oxygen demand would not be markedly
different from the annual average presently achieved (85% vs. 84%).
The chief potential beneficial, near-term, impact would be more con-
sistent performance and a reduced possibility of discharges of in-
adequatelyreated wastes during critical low flows. Upgraded
treatment will have little effect on the total coliform bacteria or
nutrient concentrations in the river.
No significant near-term impacts on the Duwamish estuary from a
secondary treatment facility at Auburn are expected because the up-
stream changes in average effluent quantity and quality would be
relatively minor. Any reduction in the accidental discharge of
inadequately treated waste would be a benefit, although other fac-
tors appear to more significantly affect the low dissolved oxygen
problem in the estuary.
Long-term impacts depend on the realization of growth in the area
and the increased discharges to the Green River. The year 2000 design
flows; 35 mgd for annual average; 25 mgd for summer flow; and 55 mgd
winter for peak flow; are slightly greater than the most probable
average flows. To design adequate hydraulic capacity for physical
components as pipes, a high estimate of infiltration/inflow into the
sewerage system was used. However, lower quantities are considered
more likely during the summer months. For the year 2000,, the probable
summer flow is 17.58 mgd (27.2 cubic feet per second) for the treatment
plant designed for an annual average flow of 35 mgd.
Flow augmentation of the Green River from a secondary treatment
plant at Auburn would have slight long-term, beneficial impacts on
low-flow problems. During the summer months of critically low river
flow (about 145 cfs), Auburn would probably add, by the year 2000,
about 27 cubic feet per second (.17.6 ngd) to the river. Although this
would increase the volume for aquatic life, the resulting 19% increase
in river flow would have no significant impact on temperature or
128
-------
dissolved oxygen.20 For comparison, low-flow augmentations of
approximately 550 cfs from a modified Howard Hanson dam, would
probably decrease the maximum diurnal temperature from about 68°
to 63°F and increase the saturation value of dissolved oxygen to
9.5 milligrams per liter.'5'*
By the year 2000, summer discharges could be 4400 pounds per
day of BOD, if effluent concentrations met secondary criteria
(30 mg/1) and flows were 17.6 mgd. This may adversely impact down-
stream water quality by contributing to violations of the dissolved
oxygen standard.
Impacts of a lesser waste discharge (about 2400 pounds per day
of BODs - summer) were simulated by RIBCO consultants, using IRDP
land use patterns for the year 2000. Modeled river flows were about
twice the one in 10 low flow of 145 cfs. According to the model,
downstream at Tukwila, summer violations (about 7.3 mg/1) of the
dissolved oxygen standard might occur in the year 2000. Because of
the diurnal nature of the violations, benthic oxygen demands appear
to be significant at this location. The largest decreases in dissolved
oxygen due to 6005 from the Auburn waste would probably occur further
upstream, only a few hours below the discharge point.
A simpler model was used to consider BOD and aeration for assumed
river conditions and another waste load. For a slightly larger waste
discharge (5200 pounds per day of BOD) and a lower river flow (150 cfs),
dissolved oxygen decreases about 1.4 mg/1, which is below state stand-
ards. However, low-flow augmentation of about 300 cfs could increase
the minimum expected dissolved oxygen by about 0.7 mg/1. See pages
109 and Appendix E for additional discussion of low-flow augmentation.
Because of expected high levels of nutrients from other sources
and other constraints on algae growths, the additional nutrients from
the Auburn facility may not significantly affect algal growths in the
river between the discharge site and the Duwamish estuary. However,
Auburn would be the principal source of increased ammonia in the lower
river above Renton, discharging perhaps 3000 pounds per day during
summer months.
Another concern with nitrogenous discharges, as ammonia, is their
potential role in oxygen depletion. Excessive nitrogenous substances
can cause a proliferation of decomposing, which can significantly de-
plete the dissolved oxygen supply. Discharge of nitrogenous wastes
upstream at Auburn might significantly increase populations of nitri-
fying organisms downstream in the Duwamish estuary. If nitrogenous
oxygen demands became significant, dissolved oxygen concentrations
during critical low flows could be affected. However, at this time,
comparisons of the relative effects on the estuary of discharged sec-
ondary wastes upstream (at Auburn) or further downstream at Renton
129
-------
are difficult to make. Some wastes would be assimilated during travel
between Auburn and Renton. This would slightly reduce the total load
entering the estuary in the year 2000. Based on RIBCO modeling, the
summer discharges of ammonia at Auburn for a 13.8 mgd plant were
about twice the summer river loads at Tukwila. However, significant
nitrogenous oxygen demands may become more likely in the estuary.
During the warm summer months when water contact sports are more
likely, high concentrations of coliform from upstream waste sources
would result in violations of the state coliform standard above
Auburn. The additional total coliform bacteria from the Auburn
Treatment Plant would not significantly affect the downstream con-
centrations if secondary criteria are met. However, if chlorination
continues, potentially adverse impacts may occur. Early investiga-
tion of possible chlorine toxicity could forestall this situation.
OTHER LAKES, STREAMS AND GROUNDWATERS
Implementing regional waste collection and treatment under this
alternative would be similar to that for the proposed action. Con-
sequently, with the exception of the Green-Duwamish River, the
expected impacts on water quality would be the same as for the pro-
posed action.
UPGRADED LAGOON
Upgrading the lagoon to meet secondary treatment criteria may
have only a slight beneficial impact on Green River water quality in
the near-term. However, this action does not provide sufficient addi
tional treatment capacity to serve the long-term needs of the area.
The long-term impacts of other waste disposal alternatives used to
satisfy growth requirements cannot be foreseen.
GREEN-DUWAMISH RIVER
The application of physical-chemical treatment technology would
improve the quality of the effluent, reducing the suspended solids and,
to some extent, the oxygen-demanding wastes and nutrients. The primary
beneficial impact on water quality would be a reduced probability of
discharge of inadequately treated wastes during critical low-flows.
In the near-term, downstream water quality improvements may be slight.
Dissolved oxygen depressions would probably continue to occur in the
river downstream. No improvement in total coliform bacteria would be
expected.
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OTHER LAKES, STREAMS, AND GROUNDWATER
Although some additional treatment capacity would be available,
the Auburn plant would not have sufficient capacity to serve the long-
term growth in the area. The capacity, 3.2 mgd, would provide an
opportunity for serving some local needs, such as service to nearby
areas in Auburn where septic tank problems are frequent. However,
because service would not be extended to the entire area, there would
be no impact expected on the existing septic tank problems in areas
such as Black Diamond. These would continue to experience problems
that, in some instances, may contribute to unsanitary conditions and
accelerated eutrophication in lakes.
Long-term secondary impacts from additional growth would par-
tially depend on how sewerage needs are met. Otherwise, the long-
term secondary impacts of urbanization upon water quantity and quality
would be similar to those described for the proposed action.
ib ACTION ALTERNATIVE
Taking absolutely no action would have no primary short-term
adverse or beneficial impacts on water quality beyond those from
existing conditions if no extensions of Auburn's sewer system were
permitted. Long-term secondary impacts would be determined largely
by what action the City of Auburn takes to comply with secondary
treatment requirements by July 1, 1977. Secondary impacts due to
urbanization without additional treatment capacity at the Auburn
lagoon are difficult to assess. These impacts will depend on what
methods are chosen to serve growing areas within the constraints of
existing regulations.
However, as previously stated, allowing continued discharge of
inadequately treated wastes from the Auburn lagoon would be contrary
to the provisions of PL 92-500 and the purpose of EPA's construction
grant program.
GREEN-DUWAMISH RIVER
Auburn discharges, not meeting secondary treatment numerical
criteria, would continue in the near-term. Continuing these discharges
should not have any significantly adverse impacts on aquatic life.
131
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However, dissolved oxygen depressions would probably continue to
occur in the river downstream. Although other factors appear to
contribute more significantly to these depressions, the Auburn
discharge would still contribute nutrients and oxygen-demanding
wastes. Little change would be expected in the coliform concen-
trations in the river.
Long-term secondary impacts on water quality would depend on
the technology selected to serve future needs and the actual popu-
lation and industries served. The long-term impacts of four available
alternatives, including the proposed action, have been discussed in
the preceding sections. These alternatives all involve discharge to
the Green-Duwamish River. At present, it seems unlikely that dis-
charges to other locations (land disposal site or to the White River)
will be selected.
OTHER STREAMS LAKES AND GROUNDWATERS
In the short-term, the no action alternative should have no
significant impact on the existing water quality of the other streams
and lakes in the Green River Sewerage Area. Long-term secondary im-
pacts from additional growth would partially depend on whether sew-
erage needs are satisfied by land disposal systems (e.g., septic tank
drainfields) or by secondary treatment with a discharge to surface
waters. Under existing regulations much of the land in the sewerage
area is generally unsuitable for drainfields. Figure 13 shows areas
where soil conditions are generally suitable; however, watershed use
and other types of limitations may limit actual use of these areas.
Where soil conditions and other factors make the proper installation
of septic tank systems more difficult, or in some cases impossible
under present regulations, the land is shown as generally unsuitable.
The Black Diamond plateau contains the largest amount of land generally
suitable for a drainfield use. It is likely that treated wastes from
the majority of the Green River sewerage area's expanding population
will enter surface waters. If one of the Regional treatment alterna-
tives were ultimately chosen, impacts in the year 2000 would be
similar to those previously described.
If those areas suitable for drainfields continued to rely on
land disposal rather than a Regional system, projected year 2000
waste loadings would be less than now anticipated for the Auburn or
Renton treatment plant alternatives. The impacts on groundwater
quality and quantity would depend on proper siting of subsurface
disposal systems.
132
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Other secondary impacts from urbanization (on peak flows, run-
off, and low summer flows, for example) would be essentially the same
as those for the proposed action.
SEPTIC TANK PROBLEMS
In the near-term, septic tank problems would remain essentially
unchanged. For example, areas near Lake Geneva, Star Lake, Shadow
Lake and Lucerne Lake would continue to rely on failing drainfields
and septic tanks. Jones Lake, a highly eutrophic lake which receives
drainage from Black Diamond's septic tanks, would probably continue
to have unsanitary conditions.
Long-term, secondary adverse impacts may be partly avoided by
existing regulations^> to forestall improper siting and installa-
tion of inadequate, subsurface disposal systems, and to eliminate
inadequate systems. Further development in problem areas would re-
quire compliance with regulations on subsurface or surface disposal
which are more stringent now than in the past. Under current regu-
lations, without an adequate sewerage system, much of the land in the
sewerage area is unsuitable for urbanized development. Urbanization
might be delayed in the short-term in some areas by the unfavorable
economic aspects of providing sewage treatment for buildings on soils
with severe limitations on their capacity for proper drainfield use.
For example, some areas along Big Soos Creek are unacceptable for
drainfield installation and it is unlikely that any denser residential
development near the creek will occur until some sewage collection
system is available.
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1 Final Draft, Water Quality Management Study, Main Report, RIBCO,
(Stevens, Thompson, and Runyan, Inc.-Consultants), August 1974,
pp. 327, 331, 276, 266, 86.
2 Auburn Interceptor EIS, Metro, January 1974.
3 Department of Ecology, NPDES Fact Sheet for Renton Sewage Treat-
ment Plant, June 1974.
4 Stevens, Thompson, and Runyan, Inc., Review Draft, Appendix 2,
Water Quality Analyses, (Appendix to Water Quality Management
Study, August 1974), January 1975. (For RIBCO).
5 Sewage Disposal Project Contract No. 74-2, Metro, King County,
Washington, August 1974.
6 Jensen, Anne (oral communication), King County Department of
Public Health, March 1975.
7 U.S. Environmental Protection Agency, EIS on a Wastewater
Treatment Facilities Construction Grant for the Central Service
Area of the Ocean County Sewerage Authority in Ocean County,
New Jersey, USEPA Region II, N.Y., N.Y., October 1974.
8 U.S. Army Corps of Engineers, Draft Copy, Final Report: Urban
Runoff and Basin Drainage Study - Green and Cedar River Basins
of Washington, COE Seattle District, July T974, (For RIBCO).
9 Stamnes, Robert, The Trophic State of Three Lakes Related to
Nutrient Loading, Thesis, University of Washington, Seattle,
1972.
10 Farris, Glenn, R. G. Swartz, and N. R. Wells, Environmental
Management for the Metropolitan Area, Part II: Urban Drainage
"Appendix C Storm Water Monitoring Program" (authorized by Metro
for U.S. Army Corps of Engineers, Seattle District), Seattle,
Washington, October 1974.
11 King County Ordinance No. 2281, An ordinance to establish a
surface water runoff policy in King County and requiring the
submission of drainage plans in conjunction with land develop-
ment proposals. King County Council, King County, Washington.
Approved January 14, 1975.
134
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12 United States Department of Agriculture, Soil Survey: King
County Area Washington, Soil Conservation Service in coopera-
tion with Washington Agricultural Experiment Station, November
1973.
13 Seattle-King County Department of Public Health, Rules and
Regulations for Construction and Installation of Sewage Disposal
Systems (authorized by King County Ordinance 931), Revised
September 1972.
14 Gabrielson, Gordon (oral communication), Metro, March 1975.
15 Gabrielson, Gordon (memorandum to C.J. Henry), Projection of
West Point Sludge Output, 1975-2000, Metro, February 1974.
16 Domenowske, Ralph, (oral communication), Metro, March 1975.
17 Johnson, Lyndon B., Executive Order 11296, Evaluation of Flood
Hazard in Locating Federally Owned or Financed Buildings, Roads
and Other Facilities, and in Disposing of Federal Lands and
Properties, (TTR. Doc. 66-8838), August 10, 1966.
18
19
20
21
Gibbons, L. (oral communication), King County Division of Hy-
draulics, King County, Washington, March 1975.
U.S. Department of Agriculture, Preliminary Draft EIS, The
East Side and West Side Green River Watershed Projects, King
County, Washington, Soil Conservation Service, Spokane,
Washington (In preparation).
Harper, Martin, (File Worksheet-RIBCO study). Stevens, Thompson,
and Runyan, Inc. (RIBCO consultants), October 1974.
State of Washington, Rules and Regulations of the State Board
of Health for On-Site, Sewage Disposal Systems, Department of
Social and Health Services, Olympia, Washington, June 1974.
22 City of Bellevue Ordinance No. 2003, An ordinance relating to
storm and surface water, establishing a storm and surface water
utility, and adopting a plan and system of storm and surface
water sewerage, Bellevue City Council, Bellevue, Washington.
Approved February 25, 1974.
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AIR QUALITY HP/OS
The following sections describe the methodology and results
of the air quality analysis of the service area.
LAND USE PROJECTION
Three possible procedures for the projection of future con-
ditions for the Auburn area were considered:
1. extrapolating existing emissions at an assumed growth
rate occurring at the identical location of present
sources;
2. assuming that emission changes occur in proportion to
the acreage planned or zoned for each individual use; and
3. assuming that emission changes occur in proportion to
various activity indices (e.g., manufacturing employment
is an indicator of industrial activity and hence emissions;
trip ends is an indicator of motor vehicle activity and
hence emissions).
Each of these approaches was examined and the following con-
clusions were reached. The "growth in place" concept is unrealis-
tic due to the large amounts of vacant land presently zoned for
higher intensity uses in the proposed service area. The second ap-
proach of using land acreages as an index of change in emissions is
also unrealistic since the mere designation of land for a given pur-
pose in no way assures that it will in fact be developed as desig-
nated by a given date. Further, according to Puget Sound Govern-
mental Conference (PSGC), there is enough land designated for in-
dustrial use in the Green River valley to accommodate all of the in-
dustrial growth projected for the entire Puget Sound four county
area to the year 2000. Since it is very unlikely that all of the
region's growth is going to occur in the valley, the use of acreages
as an index of emission changes would be unrealistic.
The third approach, using activity projections made by PSGC as
indices of emissions changes, appears to be the most realistic one
under the time constraints of the study. Baseline and projected
estimates of population, retail and industrial employment, and trip
generation on a sub-area basis (activity allocation zones) are used
to generate area-specific emissions estimates.
136
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Studies by the Argonne National Laboratory have confirmed the
conclusion that economic indices of growth provide better estimates
for emission projection purposes than either the land acreage method-
ology or the growth in place assumption.-*-
BussiON INVENTORY
The 1973 King County emission inventory for the area includes
all point sources located within the Green River valley area. Some
of these sources, those in the Renton area, are outside of the area
to be served by the interceptor. These, however, are located in
the Green River valley area and may make a significant contribution
to the ambient particulate concentration in the Auburn area.
The 1990 point source inventory is assumed to be the same as
the 1973 inventory. Data currently available from the Puget Sound
Governmental Council (PSGC) do not permit projecting the type and
size of point sources that may locate in the service area. However,
should any major point source locate in the area, it will be subject
to new source review procedures under PSAPCA Regulation I.
Thus, the emission projection to 1990 is concerned with the
impact of increased emissions due to "area sources" of particulate
matter. The King County area emission inventory includes residen-
tial, commercial and small industrial space heating units, motor
vehicle particulate emissions, railroad emissions, fugitive dust
(due to travel on dirt roads, construction activity, and structural
fires), incineration, open burning, and off-highway vehicle emis-
sions. The 1973 inventory and the PSGC activity allocation indices
were used to allocate area emissions to sub-areas within the service
area. The following steps were involved:
1. select the index most appropriate for each emission
source category (e.g., residential fuel combustion emissions are
directly related to the population projections and distribution);
2. Calculate the emissions per activity indicator index (EAI
factor). This is done by dividing the total county-wide emissions for
a particular area source category by the appropriate activity index
for the county (i.e., tons of particulates from motor vehicles in King
County divided by the motor vehicle trip ends in King County);
3. Allocate 1973 King County emission to PSGC activity alloca-
tion model sub-areas within the service area. This is done by apply-
ing the 1973 EAI factor to activity levels within each sub-area;
137
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4. Calculate 1990 EAI factor by assuming reductions due to
implementation of known control regulations by 1990 applicable to
the Auburn area (open burning and residential incineration prohibited,
and catalytic converters used on all automobiles); and
5. Compute 1990 district emissions by applying the 1990 EAI
factor to PSGC projected index allocations.
ESTIMATING CURRENT AND FUTURE AIR QUALITY
The Air Quality Display Model (AQDM) is used to estimate the
impact that growth-generated particulate emissions in the Auburn
area would have on the air quality in the Kent-Auburn Valley and on
Seattle and Tacoma in 1990.^ The AQDM generates a spatial distri-
bution of particulates on an annual basis. Required input to the
model is the estimated emission inventory for the year in question,
a representative annual stability wind rose, and the average annual
mixing depth.
To determine the impact of emissions in the service area on
the overall air quality, the AQDM is first run using the estimated
1973 emission inventory. A synthesized 1973 stability wind rose,
generated from meteorological data recorded at Seattle-Tacoma airport
and wind data recorded at the Puget Sound Air Pollution Control
Agency (PSAPCA) station in Tukwila^ is used in making these estimates.
The average annual mixing depth is derived from data contained
in AP-101.4 The average annual mixing depth was determined by averag-
ing the annual morning and afternnon mixing depths at Seattle/Tacoma
airport. While, intuitively, one might suspect that mixing depths in
the Kent Auburn valley would be somewhat lower than this value, there
is no data to support this, and assignment of a different value would
be arbitrary.
The estimated air quality from use of the model, in addition to
background concentrations is compared to the measured 1973 air quality
levels in the Auburn area. The difference between the measured values
and the combined figures of estimated concentrations and and back-
ground values is assumed to be the relative contributions of unquanti-
fied sources within and outside of the service area to the overall
air quality in Auburn.
The 1990 air quality can also be visualized as consisting of
three components: 1) contribution from service area emissions, 2)
background, and 3) unquantified sources. The contribution from the
service area emissions is determined by modeling using the 1990
138
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emissions and the 1973 meteorological conditions which are assumed
to be also representative of 1990. The background concentration
in 1990 is assumed to be the same as for 1973.
Since there is no measured air quality data for 1990, the con-
tribution from the unquantified sources must be estimated. This is
done by assuming that the 1990 contribution is a percentage of the
1973 contribution. Since we do not know the exact origin of the
unquantified contribution, the exact percentage cannot be determined.
However, through consideration of possible origins of such contri-
bution, attempts have been made to bracket this contribution on a
best case/worst case basis. Best case utilizes a set of assumptions
concerning the origin of the unquantified contribution that results
in the best air quality, while the worst case employs the assumptions
yielding the most severe impact. This best case/worst case analysis
only establishes limits on the impact of the unquantified emissions
and should not be construed as the limits on total predicted air
quality for the Auburn area.
RESULTS
The results of the air quality analysis are given in some detail
in Appendices B and C and will only be summarized here. Table 32
shows the 1973 base year and the 1990 projected populations and
emissions in the service area by PSGC activity zone. See Figure 14.
TABLE 32. SERVICE AREA POPULATION AND EMISSION ESTIMATES.
Activity Zone
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
1973
Population Emissions (T/Y)
1990
Population Emissions (T/Y)
1815
3112
3372
8577
10716
378
4934
4550
10127
3665
2400
2301
2264
2236
27.46
39.25
33.35
42.04
177.01
22.15
108.49
25.57
118.18
36.43
67.61
49.29
55.46
21.38
3720
5087
6372
13613
12071
2851
8164
5977
11140
7675
9261
3696
3355
4250
35.11
47.73
40.05
45.69
274.58
32.52
110.59
27.06
132.82
43.90
71.09
44.45
74.51
26.28
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33
ENVI«ONMENTA1 PROTECTION AGENCY
MGION X
1200 SIXTH AVENUE SEATTLE, WASHINGTON 9t]OI
AUBURN INTERCEPTOR
(GREEN RIVER SEWERAGE AREA)
ACTIVITY ALLOCATION MODEL
SCALE OF MILES
0
1
FIGURE V
-------
TABLE 32. SERVICE AREA POPULATION AND EMISSION ESTIMATES, (cont.)
Activity Zone
3420
3430
3440
3450
3460
3830
Total
1973
Population Emissions (T/Y)
6479
3684
4125
0
4554
3020
82309
48.39
59.22
20.86
29.96
41.20
7.27
1031.07
1990
Population Emissions (T/Y)
15860
11039
7797
0
9851
3970
57.33
66.82
26.71
33.89
51.03
7.50
145749
1250.16
ihese data show that the overall population can be expected to
increase about 77% between 1973 and 1990 while the total associated
emissions v/ill only increase by about 20% during the same time
period. This difference is accounted for by the additional emission
control expected by 1990 through compliance with both point and area
source regulations and through application of current technology in
future years. For example, motor vehicle activity was responsible
for about 35i of the total particulate emissions in the service
area in 1973. While a major increase in motor vehicle traffic can
be expected by 1990, the partial compensating effect on automotive
emissions through application of catalytic converter technology
results in only a 25% increase in emissions from this source cate-
gory.
FABLE 33.
EXPECTED ANNUAL GEOMETRIC (ymg/m3) MEANS FOR
PARTICULATES AT AUBURN.
1973
From Sources Within the Service Area (Model) 9.3
Background 28.9
From Unquantified Sources 23.2
Best
Case
11.9
28.9
19.3
1990
Worst Most
Case Probable
41.6
23.9
0
fotal
61.4 60.1 70.5
11.9
28.9
23.2
64.0
ihe results of the air quality modeling at Auburn, contained in
Appendix B are summarized in Table 33. The first column indicates
the results of the modeling for the base year 1973. For this year,
the model predicts that emissions from within the service area (Table
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32) would result in a 9.3 yg/m3 contribution to the air quality at
the Auburn monitor. Assuming a background of 28.9 yg/m3, derived from
1973 data at the Green River Fish Hatchery, the total suspended par-
ti cul ate (TSP) levels at Auburn would be about 38 yg/m3. This compares
to a measured 1973 TSP level of about 61.4 yg/m3. (The 61.4 yg/m3
differs slightly from the actual measured geometric mean of 63 jjg/m3
because of the method used in relating the arithmetic mean to the
geometric mean, see Appendix B). The difference between the iden-
tifiable contributions to the annual mean and the actual measured
mean we place in a category called "unquantified source contributions."
The unquantified contribution can be associated with several
factors: 1) unknown sources within the service area, i.e., those not
included in Table 32; 2) contribution from sources outside of the
service area, i.e., influx of airborne TSP from Seattle arid Tacoma;
3) use of unrepresentative meteorological conditions in the model, i.e.,
the unavailability of wind and stability data for the service area
mandated the use of data from outside the area; and 4) inadequacies
in the model, i.e., inability to incorporate parameters. Application
of the modeling to the entire Puget Sound region and calibration of
the model would identify some of these contributions and nay result
in an improvement in predictions.
The PSAPCA has suggested that EPA shoul consider a larger
area, to include Renton and Tukwila, in its air quality study thereby
allowing the use of three more TSP monitoring stations which would
constitute, perhaps, a minimum number for a crude model calibration.
This effort would no doubt improve upon the prediction scheme. In-
deed, the optimum approach would be to develop an overall workable
model for the entire Puget Sound region — such a model should be
developed in connection with the air quality maintenance planning
process. However, the primary purpose of the Auburn Interceptor
air quality study is to determine the impact of current and project-
ed emissions within the service area on the air quality inside as
well as outside of the service area. To this end it is not neces-
sary to explain the sources of all the contributors to the air
quality in the Auburn area. At the same time it recognized that
the application of an uncalibrated model on an even calibrated
model leaves some level of uncertainty in the relationship between
service area emissions and air quality. The analysis below is an
attempt to put bounds on this uncertainty factor.
The question of how to consider the unquantified contribution
for air quality estimates in 1990 is handled on a best-case, worst-
case basis. It is assumed that the 28.9 yg/m3 background concentration
would be the same for all cases in 1990. For the best-case analysis
(Column 2 in Table 33) it is assumed that all of the unquantified
contribution comes from sources outside of Auburn, primarily Seattle
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and Tacoma. Emissions from these sources are expected to decrease
17% between 1973 and 1990 as a result of a combination of compliance
attainment (decrease) and growth of area sources (increase). Thus,
a 17% reduction factor is applied to the 23.2 yg/nr3 unquantified TSP.
This, coupled with an increase in TSP associated with the area's
emission growth (model result), shows that the 1990 TSP levels in
the Auburn area should be 60.1 yg/m3.
For worst-case analysis, it is assumed that all of the unquantified
emissions originate in the Auburn area and will increase between 1973
and 1990 at the same rate as those in Table 33. For this case we
estimate that the 1990 TSP would be 70.5 yg/m3.
It is believed that the most probable situation is between the
best and worst case in that the unquantified contribution will be about
the same in 1990 as in 1973. This results in an expected TSP level of
64 yg/m3 which is essentially the same as the 1973 base year level.
In addition to the impact of the service area emissions on the
air quality within the service area, it should be mentioned that
these emissions will cause a slight impact on the TSP levels outside
of the area. The model estimates that these emissions will contribute
about 7 yg/m3 at Renton and less than 1 yg/m3 in Seattle and Tacoma.
The impact of these projected annual TSP levels on the 24-hour
standards can be determined by assuming a log normal distribution and
using Larsen's transformation to estimate the second highest daily
average.5 Using the standard geometric deviation of 1.572, derived
from the actual data collected at Auburn from 1971 through 1974, and
the modeling results described above, the second highest yearly values
were estimated to be 225, 205, and 190 yg/m3 for the worst case, the
most probable case, and the best case, respectively. These numbers
compare with a primary standard of 260 yg/m3 and a secondary standard
of 150 yg/m3.
CONCLUSIONS
The 1973 levels of TSP in the Auburn area indicate that the
secondary standard attainment is currently marginal. During 1973,
there were no measured concentrations in excess of the secondary
standard of 150 yg/m3 (61 observations); however, analyses of the
standard geometric deviation indicates that about seven concentrations
in excess of 150 yg/m3 would have been expected. With the addition
of an expected 20% increase in emissions in the service area in the
next 15 years, it seems reasonable that this secondary standard will
be exceeded between 7 and 16 days per year. The primary standard of
260 yg/rn3, annual geometric mean, is not expected to be violated.
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REFERENCES
Argonne National Laboratory Center for Environmental Studies.
Kennedy et al. "Air Pollution - Land Use Project — Phase I
Final Report," November, 1971.
National Air Pollution Control Administration, "Air Quality
Display Model," November, 1969.
Puget Sound Air Pollution Control Agency, Letter, February 24,
1975, from A. L. Kellogg (PSAPCA) to Dean Wilson (EPA).
Holzworth, George. "Mixing Heights, Wind Speeds, and Potential
for Urban Air Pollution Throughout the Contiguous United States,"
U. S. EPA Report No. AP-101, January, 1972.
Larson, Ralph. "A Mathematical Model for Relating Air Quality
Measurements to Air Quality Standards," EPA Report AP-89, 1971.
Washington State Department of Highways, Planning Division,
"Urban Areas In Washington", 1972.
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NATURAL VEGETATION, WILDLIFE, AND FISHERIES I11PACTS
PRIMARY IMPACTS OF THE PROPOSED ACTION
The primary impacts on terrestrial communities during construc-
tion of the Auburn Interceptor will be borne by the wetlands and
open fields which the proposed corridor passes through or skirts.
The impacts include the removal of vegetation, disturbance of soils,
and loss of habitat. Damage can be minimized, but not eliminated,
by restricting the size of the construction easement in critical
areas, by scheduling construction during low-rainfall periods, and
by starting restoration as soon as possible following construction.
GENERAL IMPACTS ON VEGETATION AND WILDLIFE
Construction will necessitate removing vegetation, and dewater-
ing and digging up of soils. Exposed soil surfaces will be subject
to erosion. Excavated or eroded material can crush and destroy
otherwise undisturbed vegetation. Though plants in the path of in-
terceptor construction will be removed, grassy vegetation should
rapidly reestablish itself within two years after construction.
Shrubs would take longer to reestablish themselves.
Some wildlife resting, nesting, and cover areas, as well as
food sources, will be eliminated during construction. Displaced
animals cannot be expected to move aside and reestablish elsewhere,
unless they do so at the expense of other animals with which they
successfully engage in intra- or interspecific competition. Noise
will increase significantly over ambient levels during construction.
Noise, traffic, and other construction-associated disturbances may
impact wildlife adjacent to the construction corridor to some un-
determined extent.1 When vegetation is reestablished, the construc-
tion corridor will be available for colonization by animals.
SPECIFIC IMPACTS ON WETLANDS
The Auburn Interceptor passes through and skirts extensive
wetlands. It is EPA policy that wetlands are unique, valuable and
irreparable water resources which require protection. Both the
Puget Sound Governmental Conference and the King County Environmen-
tal Development Commission have issued policy statements which dis-
cuss protection of wetlands.2>3
145
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The construction corridor passes through a 30-acre area of un-
typed wetland just north of South 228th Street in Kent. At this
location, a combination of fence lines, drainage ditches, and wet
soil conditions has prevented cultivation. As a result, plant
succession has continued undisturbed and a small grove of willows,
Indian-plum, Western crab-apple, and Oregon ash has become estab-
lished. Rushes, sedges, cattails and bullrushes are also found
there. Many bird species have been observed in this area, and it
is appropriate habitat for many small mammals.1
Immediately south of South 277th Street, the corridor passes
through the easterly limits of a 20-acre Type VII wetland, the only
wooded swamp in the valley section of the study area. This natural
perennial wetland has developed from an old cut-off river meander
which extends through the Puget Power right-of-way to a trestle at
the Chicago, Milwaukee, St. Paul, and Pacific/Union Pacific Railroad
tracks. Field observers have noted a great variety and number of
birds in this area of thick brush, shrubs, trees, and marshy vege-
tation.1 The interceptor corridor passes through 88 acres of untyped
wetlands south of South 228th Street.
Protection of the 20-acre Type VII wetland is important for
several reasons. First, it is the only wooded swamp in the valley
portion of the project area. Such permanent wetlands were never
extensive in the Green River valley and most have already been lost
to development. Second, wooded vegetation requires a long time
(approximately 10 to 15 years) to reestablish itself. Third, this
area is appropriate habitat for some rare and endangered animals.
The great blue heron, green heron, and Bewick's wren have been ob-
served in this Type VII wetland.1 This wooded swamp is also appro-
priate habitat for most of the rare, threatened, or endangered hawks;
owls; and songbirds presented in Table 11 .4
Construction will impact rare or endangered animals to the ex-
tent that it will temporarily eliminate habitat. The scarcity of
these animals may decrease the possibility of their re-colonizing
appropriate habitat after it is restored. Several endangered birds -
the whistling swam and Aleutian Canada goose - are migratory species
which use the wetlands seasonally. Rare and endangered birds utiliz-
ing wooded swamps are described above.
Limiting construction to the summer months would mitigate some
of the short-term adverse impacts. Waterfowl usage of the valley is
lowest during the summer. Less dewatering would be necessary and
fewer problems due to erosion would occur. However, temporary loss
of vegetation and habitat would still occur in the construction cor-
ridor.
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SECONDARY IMPACTS OF THE PROPOSED ACTION
The major secondary impacts resulting from growth and develop-
ment include loss of wetlands, vegetation, and wildlife habitat.
Also construction of future connectors to the interceptor can direct-
ly impact biological communities. Local comprehensive land use plans
were compared to maps of wetlands and plant communities to gauge
these impacts.
Loss of wetlands, vegetation, and wildlife habitat are inter-
related phenomena. Natural wetlands moderate stream flow. They
are responsible for the slow release of water into stream systems
during periods of low precipitation and the absorption of large
quantities of water at times of rainfall. The moist soils and dense
vegetation of wetlands also serve to filter water. Drainage of
marshes and river control have already decreased the wetlands within
the RIBCO study area which include the Auburn Interceptor service
area.-*
To develop many sites in the Green River valley floodproofing
is necessary and is required by ordinances of local governments.
Floodproofing is usually accomplished by landfill to a prescribed
minimum level.6,7 This filling buries and eliminates natural wet-
lands. It alters natural drainage patterns. In addition, during
the filling operation and until revegetatfon occurs, erosion can
lead to problems with turbidity and suspended solids. With develop-
ment, the increase of impervious surfaces (e.g., streets, roofs,
sewers) with development increases the rate of peak discharges.
Pollutants, which accumulate on these surfaces between rains, arrive
at streams in high concentrations during major storms.
In areas with intact natural vegetative cover, the evapo-trans-
piration activity of plants accounts for up to 70% of the recycling of
water into the atmosphere.^3 Streamside plant cover moderates water
temperature. Clearing this vegetation can increase temperatures
beyond the tolerance limits of anadromous fish, and also cause
silting and erosion.
The well-groomed vegetation of most landscaped urban areas has
less biomass and surface area than natural vegetative cover. There-
fore, it is less active in returning water to the atmosphere. This
leads to increased runoff. Pesticides and fertilizer usage charac-
teristic of residential areas can lower the quality of runoff.5
One of the conclusions of the RIBCO study of urban runoff and
basin drainage is that "the natural vegetative cover and wetlands
within the CRIBCO) study area act as effective moderators of storm
runoff when unaffected by urbanization. The loss of these elements
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and replacement by impervious surfaces represents a serious threat
to stream systems."5 The study suggests that one approach to urban
runoff problems is land use restrictions which would lead to the
preservation of wetlands.
Loss of wetlands and vegetation (in wetlands and in other plant
communities) directly eliminates wildlife habitat. Much of the wet-
lands in the study area, particularly the Type I wetlands in the
Green River valley, are important resting and feeding areas for
migratory and wintering waterfowl. Natural habitats in the study
area are utilized by a number of rare, threatened or endangered
species.
A comparison of the comprehensive land use plans with the wet-
lands map shows that approximately 2100 acres of wetlands in the
Green River valley would be lost to industrial and residential de-
velopment. The comprehensive land use plans show approximately 39%
of the valley is planned for industrial and commercial use; 31% of
this land lies within wetland areas. An additional 1230 acres of
wetlands in the rest of the study area are slated for residential
and commercial development.
An examination of the local comprehensive land use plans shows
that approximately 13,000 acres of wooded land is slated for indus-
trial and residential uses. This will eliminate much wildlife
habitat, including wetlands, riparian woods, and wooded swamp land.
Streams such as Mill and Big Soos Creeks are in areas planned for
development. If development adjacent to these streams results in
clearing streamside vegetation, some of the biological and water
quality problems discussed above can be expected.
IMPACTS OF THE ALTERNATIVES
The no-action alternative will have no beneficial or adverse
impacts on terrestrial biota.
Any sewerage treatment alternatives designed to service the
same population as the Auburn Interceptor would have impacts similar
to those described for the interceptor. It is impossible to comment
specifically on the impacts of, for example, building a secondary
treatment plant at Auburn since the exact location and acreage neces-
sary for such a plant is not known.
Construction of staged interceptors will subject an additional
construction corridor to primary impacts similar to those discussed
for the Auburn Interceptor. Metro has described two alternate routes
for a second-stage interceptor. Both of these routes pass through or
skirt several wetlands — a 21 acre Type III wetland and several un-
typed wetlands totalling 87 acres.
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IMPACTS OF THE PROPOSED ACTION ON FISHERIES
PRIMARY IMPACTS
There will be no significant primary impacts on the fisheries
of the Green - Duwamish River system as a result of the proposed
project.
SECONDARY IMPACTS
The secondary impacts of the proposed project as they relate
to fisheries would be a product of residential, commercial and in-
dustrial development permitted by local land use plans. Potential
impacts of this development on aquatic life are identified in the
following tables. These impacts will have a negative effect on
the Green River valley anadrornous fishery but to what extent is un-
known. Additional discussion of water quality effects on the
fishery is included on the section of Water Quality Impacts.
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Parameters
Quantity
suspended solids increase
TABLE 34. IMPACTS ON FISHERIES.
Effects on Salmonids
asphyxia of developing larval
salmonids by plugging inter-
stices of redds during winter
season. *
Cause
earth moving
activities;
negligent waste
Comment
Constituents: silt,
sand, clay, mulch,
leaves, paper, etc.
oil & grease
increase destruction of the osmotic
exchange characteristics of
the egg membrane kills or
deforms the developing
embryo. *
increased
density of
trucks, auto-
mobiles,
asphaltic parking
areas, etc.
Probable increase in
negligent disposal of
waste automotive oil
into storm drain systems.
water temperature increase
causes upstream migration
blockage of adults resulting
in late arrival on spawning
grounds for Fall and possibly
Summer run salmonids. Fre-
quently results in non-viable
spawn for native salmonids. *
would also stress and possibly
cause mortality to developing
fry of coho, chinook, and
resident species salmonids.
decreased
flow, shade,
and groundwater
recharge
causes decrease in
dissolved oxygen
concentration and
facilitates algal blooms
en
O
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Parameters
dissolved oxygen
Quantity
decrease
(during
low flow
season)
TABLE 34. Continued.
Effects on Salmonids
same as "water temperature"
above *
Cause
elevated water
temperature and
biochemical
oxygen demand
Comment
the biochemically
decomposable organics
in the Green River
should be reduced by
the project. These
however, in the Duwamish
River due to the project.
nutrients
decrease decreases tendency in the Green
River for algal blooms and
hence dissolved oxygen depres-
sion, but also reduces aquatic
insect density, thus reducing
available food supply.
collection and
removal of sani-
tary wastes;
reduction of agri-
cultural (live-
stock) waste
contribution by
conversion of land
use.
may contribute to
increased algal bloom
and associated dissolved
oxygen problems in the
Duwamish River.
groundwater
contribution
decrease will reduce cooling effect on
surface waters during low flow
season thus contributing to
upstream migrant dissolved
oxygen — temperature blockage
conversion of
agricultural and
undeveloped land
to "developed"
surfaced land.
-------
Parameters
peak flow
Quantity
increase
(in frequen-
cy and vol-
ume)
TABLE 34. Continued.
Effects on Salmonids
reduce natural propagation by
destruction of redds (and the
incubating salmonid eggs)
during winter high rainfall
flash flooding. *
Cause Comment
dense grid storm
drain system;
surfacing of pre-
viously agricul-
tural or undevelop-
ed lands.
hazardous or
toxic material
spills
increased
probability
deletorious, but to what
extent is unknown. *
accidental or in-
tentional waste
disposal in storm
drain systems.
cr,
>
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TABLE 34. Continued.
Parameter
channelization
and streambank
maintenance
Quantity Effect on Sal mom'ds
increase contributes to high flow
velocities destroying
redds and the incubating
eggs either by physically
removing the redds or plugging
the interstices of the redds
with scoured bottom materials;
also decreases stream shading.
Cause
public requests
for flood control
measures
Comment
Soil Conservation
Service existing
proposal
non-flotable
debris
increase unknown—probably insignifi-
cant impact on salmonids
public apathy
and disregard for
beauty of natural
resources
primarily aesthetic
impact
flow
augmentation
increase highly beneficial; reduces
probability of temperature
and dissolved oxygen migration
blockage; alleviates the
temperature stress created by
reduction of groundwater cooling
(by dilution) of surface waters;
reduces the probability of algal
blooms through nutrient dilution
and water cooling.
public request
and support
Fisheries Agencies
recommended use of
the water resource
Also has a profound deleterious impact on preferred salmonid food organism density, limiting the propagation
success of primarily the native salmonid species.
en
rv>
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IRENCES
1 Auburn Interceptor Environmental Impact Statement. Metro,
January 1974.
2 Puget Sound Governmental Conference Open Space Element of the
Comprehensive Plan: Policies Plan adopted November 17, 1965
and incorporated into Interim Regional Development Plan,
August 12, 1971.
3 King County Environmental Development Commission Report on Open
Space - Section II Wetlands Element Approved. December 21,
1972.
4 Personal communication, Leonard Steiner, Seattle Audubon Society.
5 Draft copy, final report, Urban Runoff and Basin Drainage Study
Green and Cedar River Basins of Washington, U. S. Army Corps
of Engineers"! 1974 (for RIBCO).
6 State Flood Control District Law RCN 86.16.
7 U.S.D.A, The East Side and West Side Green River Watershed
Projects. King County, Washington. Soil Conservation Service,
Preliminary draft EIS (in preparation).
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"i» *!*:*-
H
i!l iI!;Z,:; .
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This section describes, those adverse impacts resulting from the
proposed action and discusses measures which may be taken to minimize
or eliminate them. Also discussed ape potential adverse secondary
impacts and measures which might be employed to avoid them.
ADVERSE PKirAPY IflPACTS
Adverse primary impacts include those of short term, occurring
during construction, and long term, related to construction and
operation of the interceptor and related facilities.
SHORT TERM IMPACTS DURING CONSTRUCTION
Construction activity will result in some noise, dust and
erosion, with temporary lowering of air and water quality. Impacts
of this nature can be minimized by careful design and construction
practices and adequate on-site inspection to assure contractor
compliance with applicable specification and permit requirements,
including the crossing of the Green River during that time of year
which would be least harmful to the fishery.
Unavoidable adverse impacts on terrestrial communities within
the construction corridor include the removal of vegetation, dis-
turbance of soils, and temporary loss of habitat (both open fields
and wetlands). Some of this habitat is known to be, or is, appro-
priate habitat for some of the rare, threatened, or endangered
species shown in Table 11. The only permanent wetland along the
construction corridor is a Type VII area just south of 277th
project area and its wooded vegetation could require approximately
10 to 15 years to reestablish naturally to its present condition.
Development of a revegetation plan would lessen impacts along
the construction corridor. The plan would insure the establishment
of vegetation maximally suited to reducing erosional impacts, enhancing
wildlife habitat and adding to the aesthetics of the Green River
valley. Limiting construction to the summer months would mitigate
some of the short-term adverse impacts. Waterfowl usage of the valley
is lowest during the summer. Less dewatering would be necessary and
fewer problems due to erosion would occur. Narrowing the portion of
the construction easement which is actually utilized in wetlands
would also mitigate the impact on these areas. Other mitigation could
involve relocating the proposed interceptor to avoid the wetland near
South 277th Street. It should be noted, however, that a petroleum
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pipeline was constructed through this area several years ago, with
no apparent residual effects.
LONG TERM CONSTRUCTION IMPACTS
One occupied dwelling unit lies in the path of the proposed
project and has been removed. An acceptable relocation plan has
been prepared by Metro which provides for reasonable assistance to
the tenant in being reestablished elsewhere.
OPERATIONAL IMPACTS
Although construction of the proposed interceptor would result
in the elimination of inadequately treated wastewater discharges to
the Green River at Auburn, there would be an incremental increase in
the discharge from the Renton treatment plant of wastewater meeting
the limits for secondary treatment. By the year 2000, a. decrease in
water quality in the Duwamish estuary could be expected, due in part
to the projected increase in effluent discharged from the Renton
plant. Potential increases in ammonia toxicities and low dissolved
oxygen concentrations could be mitigated by altering treatment plant
operations to include chemical or nitrification treatment units.
Other mitigative measures could include low-flow augmentation by
modifying Howard Hanson Dam, disposal of effluent to the land or
extension of the Renton outfall to Puget Sound. Corps of Engineers
participation must be sought for low-flow augmentation to be insti-
tuted. (See pages 112A and E-ll).
Construction of the interceptor also would result in an increase
in the amount of waste sludge pumped from Renton to West Point for
digestion. There would be an attendant increase in the number of
truck loads of dewatered sludge hauled from the West Point plant, a
matter of concern to residents of the Magnolia Bluff area.
As noted previously, Metro is studying methods for ultimate
disposal. Subject to the results of this study, mitigation of truck
traffic impacts includes scheduling of trips so as to cause the least
annoyance. Other mitigation could include the provision of sludge
digestion facilities at other locations, including the Renton treat-
ment plant, or removing the sludge from West Point by barge.
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ADVERSE SECONDARY IMPACTS
Adverse secondary impacts essentially are those associated with
growth and development permitted by local land use plans. These
impacts are discussed in the context that a lack of sewerage facili-
ties can be one of many constraints to growth and the construction of
the proposed interceptor will reduce that particular constraint.
Also included is a description of mitigative measures which may be
taken. However, as noted throughout this statement, the key factor
in avoiding severe environmental degradation as a result of land
development is local governmental planning and control.
WATER QUALITY IMPACTS
As urbanization of the Green River Valley Sewerage Area continues,
surface water quality can be expected to decrease, stream flows probably
will decrease during dry weather and increase during wet weather, and
the potential for flooding will increase. Also, urbanization will
reduce the amount of pervious surface available for recharge of ground-
waters. Implementation of mitigative measures would depend on actions
by local authorities.
High surface water temperatures could be reduced by low-flow
augmentation (if this proves feasible after study by the COE) and by
planting shade trees along banks. Toxic material concentrations could
be reduced by restricting the sale and use of pesticides and other
toxic materials.
The impacts of urban runoff in tributaries to the Green River
could be reduced by providing ponds to retain surface drainage during
periods of high runoff. Control of the rate of discharge to surface
waters would reduce the potential for flooding and reduce the discharge
of silt and debris. Additionally, if located in pervious areas, re-
charge of groundwaters could be enhanced. Other measures to minimise
the effects of urban runoff could include frequent cleaning of streets
and catch basins to reduce the amount of debris reaching surface
waters, or regulations to restrict increased runoff for new developments.
Other methods have been evaluated in the RIBCO study and recommenda-
tions for each tributary basin are under public review at this time.
Flow augmentation to a Washington State Department of Fisheries
minimum flow level established by the Department of Ecology through
their Base Flow Program appears necessary to prevent upstream migra-
tion blockage. The hatchery program must be maintained at least at
its current level. Catch basins to intercept high Fall-Winter storm
drainage flows upstream of the major native salmonid spawning grounds
should be encouraged.
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higher by 1990. The assessment of air quality for 1990 incorporated
the anticipated effects of all existing regulations containing com-
pliance dates after 1973. Other measures which may further reduce
emissions in the service area could be implemented prior to 1990.
These potential measures were not included in the assessment since
the basis for their incorporation is not founded on existing regula-
tory authority or emission control technology. These measures could
include the following:
1. Elimination of slash burning.
2. Conversion from fossil fuel to electric heat.
3. Improved automotive emission control technology.
4. Paving of dirt roads.
5. Reduced usage of the automobile as a result of energy
constraints of improvements in mass transit.
6. Improved combustion source emission control technology.
Increases in particulate emissions within the service area could
also be limited by imposing constraints on the expansion of existing
sources and on the addition of new sources. In either case, land use
and transportation controls might be used. The air quality mainten-
ance planning process expected in the service area will examine the
need for this type of control. Examples of such controls are emission
allocation systems, emission density zoning, and emission fees. The
degree and type of emission growth control to be instituted in the
service area as required by EPA's AQMP requirement will not be known
for several years.
TERRESTRIAL IMPACTS
The major terrestrial impacts of growth and development in the
Green River Sewerage Area would be the potential loss of wetlands,
vegetation and wildlife habitat, including some potential habitat for
rare, threatened or endangered species. Given the present local
comprehensive land use plans, these impacts are unavoidable. However,
some measure of preservation of these areas could be achieved through
the imposition of constraints on development in the wetlands. In
addition to the imposition of such controls by the local agency of
government, other preservation measures could include the acquisition
of wetlands and other sensitive areas by conservation agencies, groups
or societies.
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For specific projects, zoning changes and building permits would
be subject to the same scrutiny as this proposed interceptor project
through the mechanism of the State Environmental Policy Act (SEPA)
and, if a Federal agency is involved, the National Environmental Policy
Act (NEPA). For areas in close proximity to larger streams and lakes,
development would have to be in compliance with requirements of the
State Shoreline Management Act.
LAND USE IMPACTS
Continuation of present trends toward increased urbanization of
the Green River Sewerage Area will result in the commitment of addi-
tional areas of vacant or relatively undeveloped land to industrial,
commercial and residential uses. The availability of sewer service
will increase the capacity of the area to accept development and could
permit it sooner than otherwise might occur. However, that portion
of the entire area which feasibly could be served initially would be
relatively small. Service to the remainder of the area would require
the construction of additional extensions to the system. An environ-
mental evaluation of the effects of these extensions would have to be
made before installation could be allowed.
As noted previously, decisions as to whether development occurs,
and the areas in which it takes place, are the province of local
government. The assurance that sewer service and other utilities and
services would be available could be of assistance to local government
in achieving more orderly development than might otherwise take place.
Mitigative measures which might be utilized in managing the
impacts of growth and development on land use eseentially are the same
as those cited for terrestrial impacts: local land use controls, SEPA,
and NEPA. Additionally, tax incentives by local government could make
continued agricultural use more attractive to property owners.
SOCIOECONOMIC IMPACTS
Increased urbanization will result in increased costs for the
expansion and improvement of community facilities and services
necessary to accommodate growth and development. Local comprehensive
plans could be amended from time to time to minimize these costs. In
developing areas, the availability of sewer service could eliminate the
duplication of cost involved if septic tanks and drainfields were in-
stalled initially only to be followed a few years later by a sewer system,
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ajB. S? W^V* *. > ; ' K*»
:^^*^ -f % "1 - w .„>' ' "
*Jk . • „ # ^.
. i<-.«a=
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The proposed action will involve the commitment of renewable
and nonrenewable resources. Some of these resources will be affec-
ted in and along the proposed route. During construction, some
existing soil and plant communities inside the pipeline corridor will
be destroyed or disturbed. The corridor itself covers approximately
forty to fifty acres. This action is not, however, entirely irrever-
sible because after construction is completed, the corridor could
conceivably be replanted with native vegetation or even utilized for
agricultural purposes.
The interceptor will probably commit future generations to
specific actions and resource uses in managing water quality in the
Green River Sewerage Area. The establishment of regional wastewater
collection and treatment systems, of which the proposed action is a
part, could result in a commitment of resources that is essentially
irreversible. The interceptor has been designed in such a way to
allow future interceptor and trunk sewers in the Green River Sewerage
Area to hook directly into the proposed project. Alternative waste-
water collection and treatment systems serving the sewerage area can
be precluded by the presence of the Auburn Interceptor. Though tech-
nology may develop new wastewater collection and treatment systems,
new facilities within the sewerage area will probably continue to be
built around the proposed interceptor facility and the Renton Sewage
Treatment Plant.
The proposed project could possibly be utilized as an element
of some alternative wastewater management schemes for the Green River
Sewerage Area or Metropolitan Seattle area. For example, if it would
become beneficial in the future to "plug-in" advanced wastewater
treatment plants for developing process water for flushing the Green
River and/or Duwamish Estuary, the proposed project could be utilized
for "plugging in and out" and transporting the residual solids. Such
alternative treatment configurations, considerably different than
Metro's Comprehensive Plan, are presently being evaluated as part of
the RIBCO study.
The long-term effects on land use resulting from the implementa-
tion of the proposed action have been described in previous sections.
It should be noted that most present trends are likely to continue
regardless of the proposed action.
Southwestern King County can be expected to grow in response to
the natural expansion of the Seattle and Tacoma metropolitan areas.
This growth is probably irreversible. Providing adequate wastewater
treatment and collection systems to the Green River Sewerage Area could
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accelerate the urbanization process within the sewerage area and
direct growth to areas provided with sewerage facilities. The present
character of much of the sewerage area is likely to be altered as a
consequence of its urban development. As these new developments
begin to locate in the Green River Sewerage Area, increased amounts
of land will be irretrievably lost.
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IrPACTS OF TIE PROPOSED ACTION
The Auburn Interceptor, an integral part of Metro's regional
sewerage plan, would have several benefits. Intercepting Auburn's
wastes will eliminate the discharge of inadequately treated waste-
water to the Green River, thereby improving the water quality and
ceasing the current violation of EPA's secondary waste treatment
standards. Furthermore, eutrophication of some lakes in the sewer-
age area, caused by septic inflow, may be slowed by the eventual
diversion of septic waste into a sewerage system. In addition, sub-
stitution of sewer service for septic tanks can significantly de-
crease the potential of septic tank failures or faulty drainage from
polluting groundwater, lakes, and streams.
The proposed action will provide jobs on the project itself and
in the community. For every $40,000 spent in EPA's construction
grant program, one man-year of work is created. In the community,
more jobs may materialize if growth and development occurs after
DOE lifts its ban on connections to and extensions of the sewer
system.
The proposed action, along with many other factors including
land use plans, other projects in the valley, and the economic cli-
mate, will allow growth. (The extent to which any sewerage system
will allow growth is the extent to which it will accommodate it.)
How well a sewerage system accommodates growth, planned and made
feasible by other efforts, depends on how much excess capacity is
built into the system. In this respect, the Auburn Interceptor is no
different from any of the other alternatives designed for similar
capacities.
The proposed action, which includes a certain excess capacity,
is sufficiently flexible to permit each municipality in the service
area to exercise its own land use options. (With adequate availabil-
ity of sewage treatment that meets State and Federal standards, out-
side involvement in local development and land use may be lessened.)
The evaluation of the local comprehensive land use plans and the dis-
cussion of potential social, economic and environmental impacts provided
in the text of this EIS should prompt the public and local officials
to re-examine their community goals and to prepare for anticipated
growth.
IMPACTS OF GR(WH AND DEVELOPS
With sound land use planning and zoning consistent with this plan-
ning, the adverse secondary effect of growth and development may be
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softened, or in some cases, may not occur at all. Growth must be
planned for and managed within a framework of sound growth policies
and laws, including those which safeguard the environment. If en-
vironmentally-sound decisions are made during future growth, long-
term decreases of productivity in man-made and natural systems may be
mitigated.
Projections indicate that growth will likely continue in the
Green River valley. Agricultural land is likely to be lost because
industrialization, land speculation, and other development pressures
will encourage high property taxes which the small farmer may not be
able to pay. Furthermore, farm land that is worth more as an indus-
trial park will tempt owners to sell.
However, inhibitions to farming in the valley do not just come
from developmental pressures and property taxes. Testimony provided
at the public hearing on the interceptor project (December 13, 1973)
by a farmer whose family has been farming the valley since 1920 des-
cribes the problems of farming land which is subject to ponding and
flooding. As discussed in PSGC's Regional Agriculture Report, (p.84),
farmers in the valley are also subject to such pressures as (1) LID
assessments inequitable to the benefits received from improvements,
(2) minimum wage requirements inconsistent with labor productivity,
(3) laws and regulations unnecessarily restrictive to normal agricul-
tural operations and (4) constriction of market outlets for production
through loss of processing operations and increased importation of
extra-regional produce.
Already, a transition is beginning in the valley. Between 1965
and 1973, approximately 30% of the agricultural land was taken out of
agricultural production. Much of this land remains open space, but
with a potential for development. Roughly, 11,500 out of 20,000 acres
within the corporate limits of Kent and Auburn are zoned commercial
or industrial. These and other valley cities control about 73% of the
land in the Green River valley.
As agricultural land use wanes and industrial, commercial, and
other urban-type uses take its place, the water runoff from the land
may degrade water quality. For example, increased construction and
road building can result in increased sediment loads and may intro-
duce such pollutants as petroleum products, pesticides, and miscella-
neous organic chemicals. Urban runoff contains all of these plus
fertilizers, traces of heavy metals, trash and debris.
Agriculture also has its own pollutants (nutrients, pesticides,
bacteria), however, its distribution may be limited. Taking the
Green River valley as it is today, we find some agricultural pollution
from runoff but only a minimal amount of the total potential since
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approximately only 10% of the valley is now devoted to agriculture.
This leads to a conclusion that the water quality in the valley is
now probably at optimum level since most of the land in the valley
now is unfarmed, open space. Any change in the future, including in-
creased agriculture, which would result in increased land use, could
result in runoff problems and a degradation of water quality.
Runoff from urbanized or developed areas, however, would tend
to be more significant. For example, soil which is paved over loses
such important functions as cooling and filtering runoff, and re-
taining moisture for recharging streams during dry periods. Further-
more, the pavement itself tends to collect a variety of toxic mater-
ials which after a dry spell can wash quickly into the nearest
stream after the first rainfall. This shock loading can be extremely
damaging to aquatic life.
Therefore, development and urban runoff could affect streams in
the service area by increasing sediment and toxic materials. Some
streams in the area, like Big Soos Creek, are important for fisheries,
and could be adversely impacted by urban runoff. However, the effects
of urban runoff could be mitigated by impounding runoff and also by
street cleaning.
Runoff is not the only problem. According to the RIBCO report,
acute chlorine toxicity to aquatic life in the Duwamish River is
expected in the future. Chronic clorine toxicity may now be a prob-
lem. As the Duwamish is part of the route for all anadromous fish
in the Green River valley, fisheries in the area could be greatly
affected. The proposed action will augment the flow from the Renton
Treatment Plant and thus make its contribution to the chlorine toxic-
ity problem. In addition, as the effluent increases from the Renton
plant, the decrease of dissolved oxygen could become excessive enough
to effectively form a barrier against all migrating fish species.
Any form of sewage treatmentwhich chlorinates its effluent, including
the Auburn lagoon, has the potential to cause chlorine toxicity prob-
lems in the river. Dechlorination techniques now exist to mitigate
this toxicity. Obviously, dissolved oxygen and other water quality
parameters, can be protected or upgraded by increasing the level of
waste treatment at the Renton S.T.P.
Any sewer system with built-in excess capacity which eventually
will accommodate development in the valley will help make the need
for development-oriented improvements, such as additional transpor-
tation and utility systems, and culverting and channelizing streams,
more feasible.
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This section contains letters of comment from individuals
and groups to the draft EIS on the Auburn Interceptor. These
letters have been printed as received by EPA, Region X. Wherever
a response is required of EPA to a letter, a response page
follows that letter.
On the following page is a table listing the comment letters
received, the page in this chapter on which they can be found,
and a general category listing of their contents. Comment
categories are shown in an attempt to indicate those aspects of
the proposed action about which the commentors were most
interested and concerned. This may serve to direct the interested
reader to those sections of the document which he may wish to
restudy.
Twenty-three letters of comment were received—not a
particularly heavy response to a project of this magnitude and
apparent controversy. Over half of these were received after
the close of the 45-day comment period. Interestingly, only
six letters from individuals were received. None of these
resides within the project service area. The remaining were
from units of government, governmental agencies, and environ-
mental groups.
None of the commentors was able to suggest an alternative
to the proposed action which was feasible and more cost effective.
Very few comments were directed toward further study of other
alternatives, and very few solutions were offered for the complex
questions raised by the draft EIS.
Many of the letters, however, were helpful to us in
creating a better document for the final. EPA, Region X, wishes
to express its appreciation to all commenting agencies, groups,
and individuals for the time and effort spent in reviewing the
draft EIS.
168
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-------
829 37th Avenue
Seattle, .
-------
The Di^IS implies that development and growth will occur
with or without the Auburn Interceptor, e.g. page l6l, "It
should be noted that most present trends are likely to
continue regardless of the proposed action," and " This growth
is probably irreversible." However, isn't it true that without
the interceptor only about 40/o of the land scheduled for
development can be developed1;
On page 1^5 » "the D^IS states that "it is SPA policy
that wetlands are unique, valuable and irreparable water
resources which require protection." Yet, aren't the
auburn ^00 shopping center and industrial park scheduled to
be built on v/etlands and without the completion of the
interceptor, they cannot, be built?
The Purpose _p_f .^L3 on page 5 states, "^PA must attempt,
in this ".Jlo, to evaluate impacts resulting from growth and
development." I do not think that the SPA dealt adequately
with these impacts nor that they gave sufficient attention to
the alternatives that could prevent or reduce damage to the
environment. A public agency given the mandate to protect
the environment should not simply wash its hands of an area
that could still be protected. The environment as it is now
in the Green Kiver Valley includes wetlands, wildlife
habitat, riparian woods, streams, and wooded swamp land. Once
they are wiped out, they will not return. Surely the jiPA
has a duty to protect that environment, not reliquish it so
easily to industrialization and maximum development.
Sincerely,
D.fu. Hartnett
172
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RESPONSE TO COMMENTS BY
D.M. HARTNETT
1. As indicated in EPA comments to the Washington Environmental Council
(#10) and to Mr. Aye (#3), the PSGC figures are the best available
for the affected area and are the forecasts which have been region-
ally adopted.
2. See p. 92. Because the comprehensive land use plans are officially
adopted by elected representatives and because the Auburn Inter-
ceptor is in conformance with these plans, it can be assumed that
the project is consistent with the needs and desires of affected
communities.
3. See revisions on pages 13, p. E-5 and E-6.
4. Whether 40% is the magic figure representing the amount of land that
would not be developable without the interceptor is questionable. As
discussed on page 98, however, an absolute prohibition of all
incremental sewer sources, including the proposed interceptor, will
stifle growth. Eliminating the Auburn Interceptor project will not
in itself stifle growth since a number of alternative dispositions
of sewer demand are possible.
5. Portions of the proposed site for the Auburn 400 shopping center and
industrial park are indeed wetlands. This site is presently not
sewered to accommodate commercial and industrial development such as
the Auburn 400. As the provision of sewer service accommodates
development, the operation of the interceptor or connectors to it may
have a secondary impact on development in wetland areas presently not
served by sewers by serving future development in these areas. In
fact, the Metro-Auburn Sewage Disposal Contract (see Exhibit A of the
Auburn Interceptor Environmental Impact Statement released by Metro
in January 1974) states that Metro shall construct that portion of
the West Valley Interceptor from llth Avenue North (in Algona) to
Main Street (in Auburn) within a reasonable time after the Auburn
Interceptor shall have been completed and the City of Auburn shall
have required such construction. Figure 8 of EPA's Environmental
Impact Statement shows the North portion of the West Valley Intercep-
tor as a proposed future extension. In any case, future shopping
centers could be built without an interceptor, by installing waste
treatment systems separate from the regional system.
173
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Grand Central on the Park • 216 First Avenue So. • Seattle, Washington 98104 • 206/464-7090
Puget Sound Governmental Conference
RECEIVED
May 29, 1975 JUN 9
Mr. Clifford Smith Jr. , Regional Administrator
Environmental Protection Agency - Region X
1200 Sixth Avenue
Seattle, Washington 98101
Re: Auburn Interceptor (Green River Sewerage Area)
Draft Environmental Impact Statement
PSGC File No. EIS/44/75
Dear Mr. Smith:
Thank you for the opportunity to review and comment on the above referenced
environmental impact statement. It is our determination that the proposed
interceptor can be considered an issue of regional significance and, as a
consequence, warrants an intensive review. This determination is based on
the potential of the project to accommodate growth with attendant multi-county
impacts affecting water and air quality, land -use patterns, and employment
distributions; and, the potential primary impact on critical natural areas as
designated by the Interim Regional Development Plan such as wetlands, marsh
and bog sites, and floodplains. A further consideration is the potential for
untimely urban development hastened by the provision of sewer service.
In the opinion of Conference staff, the draft environmental impact statement
is generally adequate in addressing the primary and secondary impacts that can
reasonably be expected to occur should the proposed interceptor be constructed.
The Conference is encouraged by the Environmental Protection Agency's acknow-
ledgment of the secondary effects of the project. In particular, Conference staff
agrees with EPA's conclusion that:
- As growth and development accommodated by the interceptor intensifies
". .. surface water quality can be expected to decrease, stream flows
probably will decrease during dry weather and increase during wet
weather, and the potential for flooding could increase" (DEIS p. 157).
It seems clear that the potential for flooding will increase as urbanization
continued in the Green River Valley.
17
-------
Clifford Smith jr.
May 29, 1975
Page 2
- Given present local comprehensive plans, the loss of wetlands,
vegetation and wildlife habitat, including some potential habitat
for rare, threatened or endangered species is unavoidable (DEIS p. 158).
- The availability of sewer service will increase the capacity of the area
to accept development; development which may occur in advance of
supportive infrastructure and services.
- "Any sewer system with built-in excess capacity which eventually
will accommodate development in the valley will help make the need
for development-oriented improvements, such as additional trans-
portation and utility systems, and culverting and channelizing streams,
more feasible. " (DEIS p. 166)
- The magnitude of overplanning for industrial land in the Green River
Sewerage Area is significant. "By 1990, the entire Central Puget
Sound Region will have a projected demand for 7,006 acres of manu-
facturing land. Valley jurisdictions are planning for over 1^ times
that much manufacturing land to be located just in the Green River
Valley" (DEIS p. 94)
While the draft environmental impact statement adequately addressed potential
impacts, the following are areas in which clarification or additional discussion
would be useful.
- The DEIS (p. 115) states that newer collection systems have an infiltration/
i nflow rate of approx. 1100 gallons per sewered acre per day during wet
weather , and that "... infiltration into the Auburn Interceptor is expected
to be less". If this is an accurate statement, why is the larger figure of
1,100 GPD used to forecast peak flow (DEIS p. 65) ? On what information
is the infiltration/inflow rate of 3200 GPD for 1970 existing sewered area
based?
- The DEIS (p. 164) states that the proposed line contains"... a certain
excess capacity". While one of the factors contributing to this judgement
of "excess capacity" apprears to be related to PSGC population projections
for the year 2000, it is not clear what other factors are involved. Will
the proposed interceptor serve a capacity beyond that projected by PSGC
for the year 2000?
- A secondary growth-related impact has not been considered in this
statement. The removal of gravel and other materials to be used as
fill for development in the Valley may have significant adverse water
175
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Clifford Smith Jr.
May 29, 1975
Page 3
quality and aesthetic impacts. It is suggested that the potential
effect of extracting fill material from the Valley walls should be
investigated.
We appreciate receiving the draft statement and hope that these comments
will prove useful to you in preparing a final environmental impact statement.
If you have any questions, please contact Barbara Hastings or Steve Holt at
464-7548.
truly yours,
Mart Kask
Executive Director
MK:ce
176
-------
RESPONSE TO COMMENTS BY
PUGET SOUND GOVERNMENTAL CONFERENCE
1. Attention is directed to pages 120, 125 and E-ll of the HIS. Although
the effects of increasing urbanization could result in greater
quantities of runoff and greater peak flows, proper planning and
implementation of measures to provide the necessary controls could
help prevent increased potential for flooding.
2. The 1100 gallons per acre per day for sewered areas, for newer sewer
systems, is an acceptable design allowance for wet weather flows in
a sewered area. As set forth in the draft EIS, p. 74, flow forecasts
are based on serving about 22,000 acres by the Year 2000 and include
infiltration/inflow allowances for interceptors, laterals, and side
sewers expected to be built. With only a few direct connections to
the Auburn Interceptor anticipated, it is expected that infiltration/
inflow will be less for the interceptor itself than acreages
containing more lineal feet of pipe per acre.
Flow forecasts were developed by Stevens, Thompson, and Runyan,
Inc. As stated on p. 65, existing sewered area as of 1970 was
selected as the point in time where allowance for peak inflow and
infiltration should be reduced from 3200 gpad to 1100 gpad. These
values, originally developed by Metro for systems built before 1960,
were used in the RIBCO study for systems built prior to 1970, although
it was reported in the study that the 3200 gpad appeared to be somewhat
high.
3. See our response the Aye letter, item 2.
4. Page 127 has been revised.
177
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Director / Carl !\! Crni/te
O/rft7orr / Ralph 11" Lar\on
Ronali X '\nJrc'.i i
Game Cnmmtsunii
OF1
600 Nor//; Cctpitnl Vi'jy Olympia, Washington 98,504
June 2, 1975
Richard R. Thiel, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Jerry Parker, Office of Program Planning and Fiscal Management
Dear Mr. Thiel:
Your draft environmental impact statement - Auburn Interceptor (Green
River Sewerage Area) King County, Washington E.P.A. Project C-530475-02 -
was reviewed by our staff as requested. Our comments follow.
Your efforts to address the secondary impacts surrounding the proposed
Auburn Interceptor Project, as well as more immediate primary effects, are
commendable. Your report provides some valuable information on current land-
use trends and planning endeavors. We concur with your contention that the
major impact of the proposed project will be realized in its facilitation of
growth in the planning area. Perhaps it is also the case that this particular
proposed action cannot be held "responsible" for the growth facilitated by the
project, since growth trends are already set by existing zoning and land-use
plans. But the implications upon land use, natural resources and people in
Puget Sound Basin must be considered in all decisions which affect this region's
future.
Wildlife resources are generally addressed in an appropriate manner in
your statement. The information you presented on wetlands and other valley
habitats is well documented (pages 42-50). We noted references to Washington
State Department of Game estimates on waterfowl use of wetlands (page 45) and
wooded habitats (page 46). If these figures are taken from data collected for
the Soil Conservation Service (SCS) Flood Control Program analysis, it should
be recognized that changes in habitats remaining in the valley have occurred
since those data were collected. Erosion of the habitat base has continued and,
thus, wildlife resources have been subjected to continuing stress.
RECEIVED
JUN4 1975
178
-------
Mr. Thiel -2- June 2, 1975
Information on existing fishery resources is also well documented. We
noted the bulk of data provided was taken from the Puget Sound arid Adjacent
Waters Study -- Appendix XI, Fish and Wildlife (page 51 through 55). It
should be noted that data contained in that report were compiled to meet rather
general objectives, and as such, has limitations. We acknowledge its usefullness
as a source of information, but stress that site-specific information is necessary
to augment data in PS&AW reports.
Wildlife and fishery losses expected with realization of anticipated
growth levels are discussed in a general way (pages 145-154). Although some min-
imizing measures are discussed for primary impacts, we understood the report to
say that habitat losses and degradation associated with growth, if they are
to be lessened, must be ameliorated through proper land-use planning. Since a
loss of 13,000 acres of wooded habitats, including 2100 acres of wetlands, is now
expected for the future (page 148), it is clear that significant fish and
wildlife resource losses would be involved in achieving currently forecasted
levels of economic growth.
We question whether you have had any indication that current land-use
trends and plans will be subject to future changes which will allow for a
significant reduction in the wildlife resource losses now anticipated.
This brings us to a central question which your report raised. If
current land use plans are unrealistic to some degree, as your report seems to
imply (see below), what are the consequences surrounding implementation of
sewerage improvements based on such plans? Does it follow that implementation
of such proposed improvements will contribute to realization of plans which are,
in part, undesirable? Your report indicated that sutdies by Corff and Shapiro
and B. Bran of PSGC show overplanning for industrial land-use in the valley
(page 94). It is stated, "...land set aside for industrial purposes in the
Green River Valley is enough to accomodate all the manufacturing land use that
can be expected to occur in the entire region by 1990 with 4,534 acres left
to spare. This unused portion alone could accomodate all of the expected 1990
manufacturing land use in King County (2,390 acres)" (page 98, paragraph 1).
We can do little more than raise these questions as they deal with matters
which are largely outside our areas of expertise. However as we submitted above,
the future condition of valley wildlife resources will be largely determined by
existing and future land-use plans. Therefore we hope you will give serious
consideration to our questions.
Thank you for the opportunity to review your draft. We hope our comments
will be helpful.
Sincerely,
THE DEPARTMENT OF GAME
1
Eugene S. Dziedzic, Asst. Chief
Environmental Management Division 17q
ESD:jb
-------
RESPONSE TO COMMENTS BY
DEPARTMENT OF GAME
1. Recognizing that the environmental impact statement is a valuable
planning tool and an important public - information document, EPA
found it appropriate to study the local land use plans and to
stress the potential adverse ramifaications of uncontrolled growth.
By discussing the problems inherent in the local land use plans
EPA hopes to inform the public of the need to re-evaluate local
growth policies and to take a closer look at what losses of re-
sources might occur if growth continues unimpeded at current rates.
Wildlife and fisheries losses can be expected if anticipated growth
levels are realized and if land use and environmental quality
controls are ineffective. Based on the information currently avail-
able, however, one cannot quantify the impacts urbanization will
have on wildlife and fisheries.
In response to your question regarding future changes in these plans
and trends, we submit (1) the land use plans are not static entities
- they must be subject to continual change if they are to be at all
effective (2) it is not likely that the optimistic plans for the
Green River Valley will be fulfilled. Studies have shown that
escalation and costs, fluctuations in the regional economy and pri-
vate market development decisions will collectively contribute to
the dispersion of industial and commercial development throughout
the region. It is likely that these developments will not be concen-
trated in the sewerage area. There is also every possibility that in
the year 2000 the Green River Valley will still be left with a great
deal of vacant and wooded land.
As indicated on p. 94, the problems of overplanning and underplanning
are common to comprehensive land use plans that are based on past
growth trends and which do not consider how development is staged
over time.
Attention is also directed to p. 98, paragraph three, which states
"An absolute prohibition of incremental sewer service will stifle
growth - with whatever environmental dammage or benefits it may confer
- but eliminating the Auburn Meterceptor project will not" (because
alternative dispositions of sewer demand are possible).
179-A
-------
May 29, 1975
Environmental Protection Agency
Region X
1200 6th -.venue
Seattle, Washington 98101
Re: Auburn Interceptor Draft EIS
Dear- Sirs,
I an taking this opportunity to comment on the draft ettvir oriental
impact statement issued by EPA on the proposzd Auburn Interceptor. It
is -hop^o that these comments will aid you in the drafting of the final
inn ret statement.
Cine- the EIS is itself NEPA ins >ired, it is perhrps appropriate
to include comments from the fifth annual report of the Council on
Environmental fuality, another 1TEPA creation. These are also irnportsnt
becru: e th reject in the EIS is in opposition to some of the recom-
mendations made by GEC .
CE" states that sewer inte ccptors have replcced highways a: the
m.aj-jr dete min-~nts of the location of d~ velopement. Interceptors often
lead to letp f : og type development a .id difficulties in planning othei-
services. Interce ;:tors are listed by th Council as a stimulus to de-
velop . ncnt .
The :: tand of the statement is that growtl in the Green River Valley
will 'ontinue. This might contradict a statement made by an assistant
egional EPA ac minis ti atoi that growth has slowed due to poor ambient
ai ruali ty in the valley. The statement continues by saying that
"ao~cuate"wastewr ter systems snd th" availability 01 sewer se.vice v/ill
inc.'/er re the ability to develope 3.nd "could" accelerate the rate of
growth and the appearance ol urbanization. The statement . emains in-
definite a: to th' p ohability of growth and speaks only of the porr.i-
bilitieSo V/hile C^r" believes that the p.oject will stimulate urban
growth, t" El', does not comr.it itself. As this point would be a sig-
nificant irapact, the cuention of probability not posribility r.hould
I- ^' '. c '",'•"" ^, Moreover, it should be the e;:ter>r of g- ovtb
'. Lie! Eh.juld b-? rxa^.incc] s'.nce th' area will sujely urbanize.
A point above meiitioreo "adecuate" wastewater sye terns. Y/hen the pro-
posal a_ .^ived at t^e projected 72 inc1' se:;er ar being adequate, it was
necessa y to rl:o project a 25 ,^'er r fr.tu.re growth. CEC rc-ys that
such, ov- sizing of sewers io. f utui e grovth migh be a reli fulfilling
prophecy. To alleviate this osr.ibility, CEr crlls for ? step' i; e growth
of se^'er sy: terns which would " significantly reduce advei-se land use
impacts" and provide fo better plarmin; ol related :ystems, allowing
them to better fill actual ne as. llte.nrte Plan C fits this
1
RECEIVED
JUH4 1S7S
180
-------
recommendati n but is dismis ed fo- being lesr cost effective and a
pos ibility that a future branch sewer voulc have to be put th/ough
downtown Zent. GEC say;: that it ic i portant fo. federal E {render to
lay r.ide cost and consider potential land ure impacts.
.tasonably, a significant portion of th -tat-meiib IT: devoted to
water rue lit;-. It is ir,port,-nt to riots that a considerably portion
of the -;at r'ruality degy adatlon of th o Green .\lver would not be controlled
In t::: po opo.ec action." The statement notes that "little improvement
nay o :cur in the r^acl c--v..v,en A Lurn and eriton." It cdd,o that little
charge in t".' brc^c-.ial concentration vouj-d bo expected and that coliform,
the major r.ovice of which ir runoff, would not b? eliminated by th - in-
tr.cepto.-. cince u; ban runoff is of such ^rert importance to ^/ater-
quality, it is el:o significant that the p oposec project :::rke" no pro-
visions for ru/ioff co:-rtrol though urbanization and i- Irted los:-es in
•/.r-ter cualit" are lifted as adve%iF:e ef ects of th- project.
Uoi.:f czr.pute" projections be.; d on oopulati ni esti. ate: uc-oc" to
size th into ceptor, Ooos Ci ek, a ...ajor source o^ brcte ic and nitrate,
is seen to, become more locd°d. The computer F--°R the 'lack aiver and
hill Creek havinr inciea ed diainage problems by the yeai- 2000.
LTeuv.r: ukur.i C-.-e-:-k half of Lr, e tot^l lord of coliform and nitrate
in the Green ..Iva . The statement projects urbanization of the creek
basin and channelization o.. thr- sorer..!. This v.'o^ld have the recognizec1
e- .ect of raising colifor;o, nit cte, phosphate and suspended solid
loadr,, increasing temperature, turbid.it/ and the HOD, and raising th-
pc- h flowinc: er sing th - chsnoe of downstream flooding.
r'or the conti-ol of tl^ese cecondai1" impacts, tho ct;tements lists
eorr.e very oft'n e lective .,.£ :-ui-es such as street v^ashing, storcvwcter
retention re/ infiltration galleries. Lo\: flov: : gmentation, another
measure, could be of -r&'t importance v;her the yerr 2000 effluent
discharge of the enton t^ertment plcnt ecuals th lov.1 flov/ of the Du-
v,re':ish. This vrO''ld p obc'oly seriously a_iect the r-etu.n cf anadromous
fish vrhich occurs at r ti e corr^sp :>ndinf; to low floir. The statement
proposes offoe tinj fish losre' b increased hr >.ch.ery p.roduction, though
it cannot di: ecthy i^.plement thio vie:sure.
The statement . ecognizes th ~ importance of the l:;pc:ct of runoff
but t.'r' project ts.hes no action to control t~~ environmental eff^^tp
of continued and i^icreased area ':ide source pollution.
Th^? slctement oiaintcins thet it ic the responsibility o. locr.l
govo. nnient and land planning to control i'jnoff ard the other adverse
i:prcts of th - project. But it nicy be a. f_ued that IOCF! planning is
unahle to control grov,Tth, developement and the related problems as
i~ d-OYions L.rc ted by th:- national problcni o_ urbon : pi-awl. The statement
mentions King County Orciooanc-o 2281 conce.ning th" establishment of
ctoinvjate/ i-etention plcns &: a local t,ns --.' to urban runoff p roblcrn...
But a reading of 2231 shows that ^r^le a plan of the oroposed frcilities
181
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is o-'ten i- r ui e'- pi-io to C-': lopiment, actual construction oi t; -,!• li-
ned f: ci ioic: ir no -O-'C'd. :ur her, l'2r:l does not aihfect -;? r ' n -1 e
: ^--at^ "•'•• o_ -ei'.ponsibility uc c by th' cLrtenent. Thi" r.i^n" inclj.de
ei:en:lvc c o , ..: c te runo- . o -oject i.. c n,i ncti \:itr. tbc int/"- -
c'/to . GE" r-yn "Ti'catir.ent o^ r.i.unicipr.1 r nd indurt;icl ciecbci^r-r
' ill not f;nerf.'ll" 'C r: f.'icient to provide clean v;£ te • i/i ur":n r. r
Ix , rnc bet^o chould. jebnapr t.: lie c ?coi:d loo rt thi" t."t" ent.
F ilip V,:on^
r~o,j"^ 1'i"1' ~"V
.ccatLle, Y/r in-t-n 9-105
7
182
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RESPONSE TO COMMENTS
BY
PHILP WONG
1. Growth in the Green River valley will surely continue with or with-
out an EPA-funded sewerage project. Recent growth probably has
been slowed by the national economic situation but that will change.
We stand by the statement the EPA support for the Auburn Intercep-
tor could accelerate the rate of growth.
2. See item 4 response to Miller letter and item 8 response to Foulks
letter.
3. As you note, urban runoff is important to water quality. However,
agricultural runoff can also be significant. At present, runoff
from agricultural areas is probably a major factor in the poor
sanitary conditions of some tributary streams (such as Mill creek
and Newaukum Creek). Although the proposed project makes no pro-
vision for future urban runoff or current agricultural runoff, some
treatment of existing urban runoff will be provided. Storm runoff
now enters portions of the Auburn sewer system resulting in possible
overflows at several locations. With the proposed project, the
Auburn Lagoon could become a temporary storage facility for storm
flow, help eliminate overflows, and reduce the peak flows. This
possibility is under consideration. New sanitary sewers will not
be intended to collect storm runoff for treatment.
4. According to RIBCO simulations, Newaukum creek accounts for about
half of the coliform and nitrate mass discharges to the Green River
above Big Soos Creek (which is also above the Auburn discharge).
Other sources and tributaries add to the river load further down-
stream. Although this tributary was projected to violate RIBCO's
study criteria for ammonia, nitrate, phosphate, and coliform on more
days in the year 2000 than at present, projected violations of the
study criteria for BOD were less frequent.
5. Discussion of low flow augmentation has been expanded in the EIS.
See pages 109, 112, 156, and E-ll.
6. Note revisions on page 120. No penalties were established by the
King County ordinance for non-conformance with the drainage plans
submitted. However, persons constructing retention/detention
facilities for runoff control are required to post construction and
maintenance bonds.
7. EPA funding of a comprehensive stormwater runoff project in the
Auburn area would be possible only if such a project were eligible
on the State Priority List. This list and the priority rating
system are prepared annually by the State of Washington and approved
by EPA. Priority considerations include project type, project phase
and water pollution control needs as well as miscellaneous considera-
tions. Projects to provide adequate treatment for existing municipal
wastewater discharges now take precedence in this priority system
over projects for control of potential problems of urban drainage. ]83
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DEPARTMENT OF THE ARMY
SEATTLE DISTRICT. CORPS OF ENGINEERS
4735 EAST MARGINAL. WAY SOUTH
SEATTLE. WASHINGTON 98134
NFSEN-PL-ER
2 JUN 1975
Richard R. Thiel, Chief
Environmental Impact Section M/S 437
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
RECEIVED
JUN 4 1975
Dear Mr. Thiel:
We have reviewed the draft environmental impact statement on the
Auburn Interceptor (Green River Sewerage Area), King County, Washington,
EPA Project C530475-02, with respect to the Corps of Engineers' areas
of responsibility for navigation, flood control, and hydropower.
We submit the following comments.-
We suggest expanding the discussions regarding the use of low flow
augmentation from Howard Hanson Dam to mitigate the impact of the
proposed Auburn Interceptor project on the water quality of the
Green-Duwamish River. (See pages xii, xiii, 109, 112, 129 and 156.)
This subject is of particular concern to the Corps of Engineers, which
is responsible for water storage and regulation of water releases
from Howard Hanson Dam. To date, we have not been formally contacted,
nor involved in the planning of such mitigative efforts in relation
to the Auburn Interceptor project.
In addition, the draft statement should include a discussion relating
the proposal of low flow augmentation for water quality control, to the
EPA's policy of not using water storage and water releases as a sub-
stitute for adequate treatment or other methods of controlling wastes
at the source. The use of low flow augmentation is a practical method
toward solving some water quality and associated fishery problems in
the Green-Duwamish River. However, this method will require extensive
study because it will affect, and be affected by other functions of
the dam and uses of the water.
To clarify the relationship of the proposed project to the Green-
Duwamish River environment, the draft statement should present more
definitively the planned action to minimize the adverse environmental
effects of the construction and operation of the Auburn Interceptor.
1
184
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NPSEN-PL-ER
Richard R. Thiel, Chief
The statement presents mitigative measures that could be taken, but does
not specify which, if any, of the measures will be used, or are planned
to be used.
Also, please refer to page 23, third paragraph, first sentence. The
word "permanently" should be deleted. The White River was permanently
diverted in 1915 when a diversion dam was constructed to block the
former channel. On page 26, second paragraph, penultimate sentence,
the "North Fork" should not be included because it flows into the pool
above the dam.
Thank you for the opportunity to review this statement.
Sincerely yours,
r: r-G of Engineers
185
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REPORTS TO COMMENTS BY
CORPS OF ENGINEERS
1. Pages 109, 129, 156, and E-ll have been revised.
2. It is EPA policy to treat municipal wastes to effluent limitations
established in our regs (BPT or Secondary) or to greater degrees in
water quality limited areas. Minimum water flows could have an
impact on degree of treatment in some areas of the State.
3. Note revisions on pages 155 and 157.
4. Pages 23 and 26 have been revised.
186
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Room 360 U.S. Courthouse, Spokane, Washington 99201
June 2, 1975
Mr. Richard R. Theil, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Theil:
Thank you for the extension of time in which to review your draft environ-
mental impact statement for the Auburn Interceptor (Green River Sewerage
Area), King County EPA Project #C-530475-02. Such a review has been
conducted at the field level by our personnel familiar with the area.
Figure 7 (map) is unclear to us as both Type I and untyped wetlands appear I 4
to have the same legend, making it difficult to determine the true type. I •
On Page 145, "General Impacts on Vegetation and Wildlife", the wording
indicates that the disturbed area will be left to reestablish itself to
either grass or shrubs. We would suggest that a plan for revegetating
all disturbed areas be developed to reduce possible soil erosion and
insure the establishment of desired vegetation. The plan may want to
address itself to reestablishing vegetation that will enhance wildlife
habitat and contribute to the aesthetic aspects of the valley.
The draft is well written and a great deal of preparation appears to
have gone into putting it together. If the Soil Conservation Service
can be of assistance to you on this or future projects, please call on
us.
Sincerely,
/'
ACTING
Galen S. Bridge
State Conservationist Ocr»cil/cr>
JUN4 1975
-------
RESPONSE TO COMMENTS BY
SOIL CONSERVATION SERVICE
1. Figure 7 has been corrected.
2. See revision on page 155.
188
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May 29, 1975
Richard R. Thiel, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: Draft Environmental Impact Statement on
Auburn Interceptor (Green River Sewerage
Area) EPA Project #0-530475-02
Dear Mr. Thiel :
Thank you for the opportunity to review this document. The coverage
on most areas of the statement appears quite complete and thorough,
indicating considerable forethought in preparation. You should be
complimented on the preparation of this Draft EIS considering the
magnitude of the project.
Review by our regional and headquarters staff members has produced
the attached comments. We hope the comments will be helpful to you.
Your effort in preparing the EIS will be of considerable benefit to
understanding of interested citizens and agencies.
We appreciate the opportunity to have reviewed your statement. If we
can be of further service to you, please contact Mr. David Thompson of
our Environmental Review Section at 753-6892.
Sincerely,
James P. Ben Ike
Executive Assistant Director
JPB:je
Attachment
CC: Stu Messman, N.W. Region RECEIVED
Norm Glenn, Headquarters
JUN4 1975
189
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May 29, 1975
Department of Ecology's Comments:
Draft Environmental Impact Statement
Auburn Interceptor (Green River Sewerage Area)
EPA Project #0-530475-02
The population projections could be questionable. It is indicated
that a constant rate of increase will occur over the next 20 years,
based on a 1960 to 1970 rate of increase. As population densities
increase there may be a tendency for the rate of population growth
to decrease.
The analysis of water quality could possibly be based on additional
and more representative data. The use of D.O. measurements taken
during periods of low flow, high temperature and during the depressed
period of the diurnal cycle would not truly be representative of ex-
isting conditions. Also, you cited measurements from a station
located well below the Auburn area.
More information would be useful on the fish hatchery at Palmer re-
garding the BOD waste loading to the river when flushing the ponds.
190
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RESPONSE TO COMMENTS BY
THE STATE OF WASHINGTON DEPARTMENT OF ECOLOGY
1. Discussion on pp. 104-106 indicates that population projections for
an area can vary depending on projection methodologies, the accuracy
of past population figures, the expanse of the area covered, and the
agency making these projections. EPA has used population projections
provided by PSGC because these figures are the best currently avail-
able for the area in which the Green River Sewerage Area is located.
EPA agrees that the rate of population growth may decrease as
population densities increase. However, at what point in time (and
density) such a change will occur is uncertain.
2. Existing water quality conditions were examined to identify the
severity of the dissolved oxygen depression during a critical period.
Although this approach does not define representative conditions, in
the sense that other conditions prevail during most of the year, it
is a way to determine the severity of existing problems. In the case
of tne Green-Duwamish River, this appraoch shows the lowest dissolved
oxygen values at the first Metro station routinely monitored down-
stream from Auburn during 1974 were only slightly below the State
water quality standard.
3. wastes from the fish natchery at Palmer may affect tne water quality
downstream (see p. 35 for revision). Computer simulations of water
quality by RIBCO consultants assumed tnat BOD concentrations in the
effluent were 2.3 milligrams per liter during September.
191
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5206 l NA
Seattle, Wash.
981U3
June 1, 1975
Dear Mr. Thiel:
The following comments are on the water quality impact sections in the
Auburn interceptor DEIS.
Overall-The water quality impact sections were hard to read. Data were
scattered and there was not enough tables to easily compare the data pre-
oented. Some of the flow data was presented in millions of gallons per day,
mgd, other data in cubic feet per second, cfs. It would have been easier
to compare values if all the units were the same,
un p.Ill the DEIS states that "in the year 2000, the estimated dry
weather flow from the Renton plant will be over half the river flow once
in two years". It would apnear that the percent of the river which is
effluent will increase rapidly once the interceptor is built. During
the month of September, 197U, the Renton plant effluent monthly average
was approximately 8$ of the Green itiver ( U.S. Army Corps of Engineers and
the September rtenton Secondary Treatment Plant Monthly report). The addi-
tional sewage of Auburn and vicinity could increase the effluent to the
point where oxygen depletion could become a problem fairly fast.
19;
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-2-
No er>t..imaticns of the amount of treated effluent from rtenton were
given for any future time. These flow estimations should have been included
to help assess the secondary impact of the nenton nlant whicn is tied direct-
ly to the Auburn Interceptor, Inese estimations were included for the i ro-
nosed secondary tre ,trnent olant in Auburn. If the percent of the effxuent
is con,Distantly high in the river, it could be more advantageous to have a
secondary treatment nlant at Auburn to furthur dilute tihe effluent, all owing
some assimilation before uenton. This ^•J^ould help increase the dissolved
oxy-'f" in to,; Duwairdsh waterway.
[n F-iblr il, sludge outout estimations are --*iven for ci,« and 10- Auburn
growth in t.h-- y-^ars 1^B3 and 20LO. However, the asG-jmntion was made r,nat
the Hen ton oe.conaary Treatment riant, including Auburn sev.age, would pro-
due-" tne c-jne ariiouni of sludge independant of the growth of Auburn. i.-iis
means '-.hat exLr'i Auburn p;rov,'th corresponds with less nenton growth. It
woulu sc-~m more realistic that the rtenton, Auburn, Kent region may grow as
a whole -t a difu.r. r.t rate thin another region rather than part of this
regionrr M-/'-II •• f-ast- • irvi therefore slov;inr down another part of UK. r^^'ion.
L c-. .t. - unvo::,'.. ''ji- th> t ,ble would be to snow lhe effect of difi'ei-ent
H'nt'-.n-'^r• "n Val '_<.-,j "-=?•• onal growtn rates and now they would effect ..he
amount of slim ' f'o' n ~ to ,-/est Point.
On U.ILJ it is stated that cnlorinated effluent was toxic to
fin \.rii n.- Goho j.ilmon. K--?tro is currently decnlorinatin,; to remove the
total T' sicnial v-u.lori.ne. oome '"luorinated compounac, tetrachlorool.^nol
and penLacnloronaenol (Characterization of tne Effluent from a Metroool-
itan ."cat.tie -'a3r/c---;;iter Treatment Facility, Sainmy Lee Archer, University
of .A/ashIn -t.or., 1.97^) ire not runov- d durin ~ tnr; dechlorinati jn. These
193
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-3-
comoounds could be a source of toxity when the effluent becomes a major por-
portion of the Green xiiver. Currently the compounds are found in trace quant-
ities.
Thank you for the opportunity to comment on the Auburn Interceptor DEIS.
Sincerely
Peter Thorn
194
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RESPONSE TO COMMENTS BY THORN
1. Growth Rates in the other areas served by the Renton sewage treatment
plan, as well as growth in Auburn, will determine how rapidly the
potential problems of oxygen depletion develop. Estimated future
flows from the Renton plant, including the Auburn area, have been
added to the EIS. See p. Ill, paragraph 4.
2. Whether there would be an overall advantage to the Duwamish estuary
from some assimilation of Auburn wastes in the river downstream from
a secondary treatment plant at Auburn has not been fully answered.
Although ammonia nitrogen may be converted to other forms of nitrogen
during the travel time downstream (and alleviate the possible problem
of ammonia toxicity), the likelihood of establishing a population of
nitrifying organisms to exert significant oxygen demands in the
Duwamish estuary may increase. This might increase the possibility
of oxygen depletion in the Duwamish waterway. At this time, no
answer is available.
3. The growth rate of 3% for all Renton treatment plant sludge was
used by Metro for these preliminary projections; however, much of
this growth is expected to take place in the relatively undeveloped
Auburn and Kent areas rather than in Renton. For this reason, we
felt it was appropriate to present an example estimate for Auburn's
share that was higher than that for the Renton plant's service area
as a whole. Although different regional growth rates would affect
the amount of sludge going to West Point, the operation of the Auburn
Interceptor and its impact on sludge depends only on the Auburn
growth rate. Thus, no attempt was made to show different growth
rates for sludge contributions for the region as a whole.
4. Toxicity from compounds not removed by chlorination is a recognized
possibility. See p. Ill, paragraph 5.
195
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416 N.E. Maplclcaf Pl^cc, Apt. 7
Seattle, Washington 98115
May 31, 1975
Mr. Richard R. Thiel
Environmental Impact Section M/S 437 RECEIVED
Environmental Protection Agency
1200 6th Avenue JUN 3 1975
Seattle, Washington 98101
EPA-EtS
Dear Mr. Thiel:
I have recently had the opportunity to review the Draft En-
vironmental Impact Statement (DEIS) for the Auburn Inter-
ceptor project and would like to make a few comments as a
concerned citizen. I have categorized my comments into
four groups and will attempt to discuss them in these groups.
The four groups are: (I) Air Pollution; (II) Population and
Employment Projections; (ill) Atlernative Growth Locations;
(IV) Conclusions.
I. AIR POLLUTION
(A) Somewhat Higher
I would like to take issue with the summarization of the
numerous sections about secondary air pollution impacts from
the proposed project. While the DEIS has a very detailed
analysis of projected secondary air pollution impacts which
would seem to be immune from criticism, this analysis is
clouded by subjective statements which summarize the results.
It is stated, on page 143 of the DEIS, that secondary air
pollution standards probably will be violated between 7 and
16 days in 1990 and that emissions will increase approxi-
mately 20%. Presumably these two statements are consistent
with each other. The real problem arises when these two
statements are translated into what appears frequently in
the DEIS as, "concentrations of total suspended particulates_
were found. . .to be somewhat higher by 1990." (see page xii).
The key modifier, somewhat, implies that someone had judged
the various possible levels of emissions, categorized these
levels and found that the projected emissions will be some-
what higher, as opposed to maybe finding that emissions would
be insignificantly or significantly higher. Anyone only
casually reading this document is left with the results of
someone else's subjective judgment and is not provided the
information necessary to make his/her own judgment.
(B) Mitigable Alternatives
In the discussion of possible measures to mitigate the pro-
jected emissions increases, one alternative mentioned was to
reduce the usage of the automobile as a result of energy con-
straints or improvements in mass transit, (see page 158).
196
1
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This is a very curious statement. Currently, growth in the
Auburn area is restricted: (a) by the size of plots necessary
to support drr.Lnage fields r.nd/or septic tanks; (b) the lack
of excess capacity in the Auburn lagoon. The Auburn inter-
ceptor will provide the necessary capacity for expected
growth, and will also allow more intensive development be-
cause of the removal of minimum plot size necessary to
support drainage fields. This expected growth has an implicit
activity pattern from which basic travel requirements are
derived, e.g., home to work trips. The alternative mentioned
above is supposed to affect the basic travel requirements,
i.e., reduce them, either by constrainting the amount of
travel or by shifting the travel to more efficient modes like
carpool or transit. It is hoped this will reduce the amount
of emissions. It seems that a more basic method to achieve
this end would be to reduce the level of activity patterns
allowed by scaling down the planned facilities like the
Auburn interceptor. A reduction in the size of the inter-
ceptor will limit the overall level of growth allowed which
in essence is what causes the i:ravel requirements. It does
not seem very appealing to allow certain activity patterns to
be established and then try to restrict these patterns at a
later time when the patterns themselves may be changed.
II. GROWTH PROJECTIONS
A. Reliability
This interceptor sewer project has been designed and evaluated
based upon the best available population and employment pro-
jections for the affected area, (e.g. PSGC projections).
These projections, as do any projections, contain certain
assumptions upon which rely the results. At this particular
time the regional growth projections for 1990 have already
been revised downward once due to a change in some of the
basic assumptions. This has occurred in the short time period
of 1965-1974. As reported in pages 104-105 of the DEIS,
there are two conflicting population projections for the study
area, those of PSGC and OBER. While the PSGC projections are
generally assumed to be more accurate, the difference still
is significant. Finally, recent evidence stated in page 104
of the DEIS and generally acknowledged, in the local planning
circles is that the achieved population and employment growth
for the region is behind the PSGC regional projections. The
Metro design plans were based on the PSGC projections and the
above three arguments cause several questions to arise. How
good are the projections? Will they also be modified in
another five to eight years? Will the residents and business
establishments be paying for an over-sized facility if these
projections are revised downward.
We are undergoing a period of rapid value change as a result
of the Arab oil embargo. Basic notions of growth being good,
197
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the real costs of growth and whether we can afford growth
from an energy standpoint are changing. With this value
change in mind and the seeming uncertainties of the popula-
tion and employment projections, maybe this is not the right
time to commit a project such as the Auburn Interceptor.
An associated question to that raised above is: How appro-
priate is it to select between alternatives which may have
uncertain futures? Specifically, while it appears the
proposed interceptor project is most cost-effective of the
alternatives investigated, it also seems possible that a
superficially expensive alternative that is implemented in
stages over a longer time period offers more flexibility to
meet the projected uncertainty. It could be that in the end
this staged project would be more cost-effective bacause if
the growth does not occur facilities need not be built."""
Operationally, this type of question appears in none other
than Metro's own literature, except for transit facilities.
At least with regard to transit it is thought to be desirable
to contain flexibility in plans, programs and projects.
Maybe this idea can further be applied to sewer facilities.
(B) Local versus Regional Projections
A second area of concern with respect to growth projections
involves the use of local versus regional projections. As
stated many times in the DEIS, (i.e. pages 164-165; Impacts
of Growth and Development), "With sound land use planning
and zoning consistent with this planning, the adverse second-
ary effect of growth and development may be softened or
may not occur at all." It is also stated in the DEIS that
this planning is the providence of the local planning agency.
The problem occurs when, as acknowledged on page 94 of the
DEIS, the local planning agencies are currently dramatic-
ally overplanning for development. In example, the local
jurisdictions are planning for over 1.5 times the manufac-
turing acreage forecast for the entire Central Puget Sound
Region to be located in their jurisdiction alone. The basic
question is can such land use questions be left to local
agencies, as proposed in the DEIS, when examples of their
lack of concern is so apparent?
III. ALTERNATIVE GROWTH LOCATION EVALUATION
This comment is a relatively simple one. On page 106 of the
DEIS the following statement is made: "Given the overall level
of development opportunities in the Seattle-Everett SMSA,
development of the Green River Valley, with or without the
Auburn Interceptor, is neutral with respect to energy consump-
tion in competition with other parts of the SMSA... My
comment is, when was such a comparative analysis investigated?
Where was It done and by whom? To my knowledge the only
applicable study in this area has generally come from theses
198
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completed as part of advanced degree programs in universities.
Oddly enough one such Master's thesis was conducted at the
University of Washington, in 1974, by James W. Clark and was
circulated to local agencies. But this thesis did not ad-
dress the specific question answered in page 106 of the DEIS.
IV. CONCLUSIONS
This project may seem environmentally insignificant, but it
involves many perplexing problems faced today, especially
tho.se involving growth. In my comments I have stressed cer-
tain ideas important to me and where possible, seemingly
important to EPA. The three areas my comments discuss are:
A. Simple criticisms of the DEIS, hopefully to be
improved in the final EIS, (Sections I.A, and
in);
B. Areas in which I think EPA has been specially charged
as part of the Federal Guidelines for EPA that ap-
peared in the Federal register (1-20-72). The most
specific is: "The analysis of different courses of
action shall include alternatives capable of sub-
stantially reducing or eliminating any adverse
impacts, even at the expense of a reduced project
objectives." (Sections 1.2, and II.1);
C. Areas with which I disagree with the contention
that it is not EPA's responsibility, especially
considering the language of NEPA itself. For ex-
ample, in section 2 of NEPA the following statement
is made, "The purposes of this Act are: ...to
promote efforts which will prevent or eliminate
damage to the environment." This statement may be
used to justify the use of the Auburn Interceptor
as a lever to get more environmentally sound
growth planning from the local planning agencies
by EPA. (Section II.B).
I thank you for your time and interest in reviewing my remarks.
Sincerely,
Donald G. Miller
199
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RESPONSE TO COMMENTS BY
UUNALU G. MILLER
Your point is well taken. The word "somewhat" will be deleted in
the final EIS.
Growth potential of the Auburn Interceptor has been significantly
reduced by scaling the project down from a 78" sewer to a 72".
However, growth will occur without EPA funding of the project because
economic pressures will exist in the Auburn area to stimulate growth.
The rate of growth may be affected by the project but not the level.
EPA encourages the use of mass transit as a positive way to control
air qua!ity.
The population projections used by Metro are the best available for
the affected area and, for design purposes, are good. PSGC's
figures are regionally adopted forecasts which are periodically
updated. In all probability, the pipe size and interceptor cost will
not change despite downward revisions of population figures since
population forecasts are only one element of pipeline design.
Consideration is also given to peak flows during wet weather and
infiltration/inflow rates.
The project initially proposed by Metro was a facility to accomodate
the flows projected for the year 2030. EPA believes it has recognized
the uncertainty of a 50-year growth projection in the Green River
Sewerage Area by limiting the alternatives considered to those based
on a design period reduced to a maximum of 25 years, approximately
one-half of the anticipated service life of this type of facility. In
responding to grant regulations requiring that treatment works be
designed to include adequate reserve capacity, EPA is unaware of any
methods of completely eliminating an element of uncertainty in
forecasting the course of future events. It is believed that the use of
a relatively short design period for this type of facility reduces
uncertainty to an acceptable level.
The fact that the comprehensive land use plans reflect a degree of
overplanning for some land uses and underpinning for others does not
necessarily indicate that the planners are not "concerned." This
problem is common to many jurisdictions which prepare saturation
development plans without considering the time elements involved. In
view of the public ambivalence over economic and environmental issues
it is difficult even for local planners to determine what constitutes
"orderly growth" within their jurisdictions.
200
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6. The statement on energy on page 106 was based on information provided by
EPA's regional economist who has had considerable experience in national
and regional economic and energy related studies.
EPA did not make a detailed comparative analysis of net energy consumption
effects of alternative growth patterns because the net differences were
not considered large enough to warrant a detailed study. The statement is
purely judgemental.
7. EPA believes that it has adequately identified a range of feasible
alternatives which were properly evaluated in accordance with the
cost effectiveness analysis guidelines set forth in 40 CFR 35,
Construction Grant Regulations for Waste Treatment Works.
8. The land use plans in the Auburn Interceptor service area were done
by local planning agencies and included opportunities for public
participation. There are those who now criticize some of the plans,
but it would be difficult to get 100% support for any plan. EPA
feels strongly that local government and local citizens should make
the local land use decisions. Our obligation is then to determine if
a sewerage project is compatible with those locally-developed plans,
and with Federal laws and regulations. We believe the Auburn
Interceptor project is.
201
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WASHINGTON ,- ;.- c ..:
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will induce construction in a designated floodplain, and (b) for
not complying with the EPA policy to protect tho nation's wetlands.
The reguirements of Section 6.304 (c) (4) of the EPA rules and re-
gulation for preparation of impact statements, 4O FR 16189, repro-
duced below, have not been met.
11 (4) A discussion of how socioeconomic activities and land use
conges related to the proposed action conform or conflict with
the goals and objectives of approved or proposed Federal reg-
ional, state and local land use plans, policies and controls
for the project area should be included in the EIS. If a con-
flict appears to be unresolved in the EIS, EPA should explain
why it has decided to proceed without full reconciliation.
(Emphasis added)
3. There is no mention of conditions to mitigate adverse en-
vironmental effects of the proposed action, such as we have alluded
to in the impact appraisal included with the letter of January 10, 1975
of Robert S. Burd, nor any mention of how any such conditions would
be implemented. The conditions mentioned in the letter are as follows:
"..., EPA will condition its grant to METRO in a manner which
will insure that wetlands will be protected."
"EPA will condition their grant to METRO reguiring they obtain
agreements with their constituents to comply with DOE and Puget S^ur
Air Pollution Control Agency regulations pertaining to new and
modified sources of air emisions. "
"EPA will condition the grant to METRO to insure that not only
those concepts of the Development Plan which impact the envir-
onment will be included in agreements between METRO and their
customers but provisions for protecting against nonpoint source
pollution will be included to protect the sewerage area's water
quality."
"Those avoidable significant adverse impacts on the noise levels
solid waste problems, habitats of rare, endangered, or threaten-
ed species of plants and animals, archeological and historical
sites, and the use of flood-prone and slide-prone areas, will
be eliminated by similar special grant conditions."
4. There is no identification or discussion of the overall pro-
jected costs to the public of the installation and maintenance of
the extensive waste water collection and treatment system which the
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sized capacity of the Auburn interceptor is to serve.
5. There is no mention of the projected increase in costs of
sewerage collection, treatment and disposal to the residential, com-
mercial and industrial users of the City of Auburn which will occur
as a result of the Auburn interceptor.
6. There is no meaningful cost comparison of all of the alter-
natives discussed in the impact statement. None of the alternatives
discussed include the costs of handling and disposal of sewage sludge
or the cost effectiveness of the various alternatives in relation to
existing EPA funding reguirements.
7. There is inadeguate treatment of the impacts of the proposed
action on the prime agricultural land in the Green River Valley.
8. There is inadeguate discussion of the proposed projects
for the Green River Valley such as the SCS drainage project and the
Corps of Engineers project, each of which will likely be justified
on the basis of continued urbanization of the Green River Valley
which the Auburn interceptor will facilitate.
9. There is inadeguate treatment of the METRO policy of con-
centrating all effluent discharge at one or two locations and diver-
sion of al1 sludge for digestion to the West Point Treatment Plant.
1C. There are no reasons given for using the PSGC projections
of population through the year 2000 as justification for the proposed
project when it, is recognized that they fail to take into account the;
reduced population growth that has taken place in recent years.
11. There is inadeguate justification of the proposed action
on the basis of improvement of water quality . No data are presented
which would indicate that the present discharge from the Renton
treatment plant is any more adeguately treated than the wastewater
presently being discharged into the Green River by the City of 204
7
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Auburn treatment plant.
EPA and the Region X administrator of EPA have the responsibil-
ity under the National Environmental Policy Act (NEPA), the CEQ and
EPA regulations developed pursuant to NEPA, the Federal Water Pollut-
ion Control Act (FWPCA) and EPA's regulations under FWPCA to assure
that construction award grants for wastewater treatment works "will
produce a project which will have maximum beneficial effects on man's
environment and minimum adverse effects." The primary purpose of
the construction grants program of EPA is one of water quality; how-
ever, water quality is not to be achieved at the cost of other envir-
onmental objectives. Grants should be made only for those projects
which are consistent with federal, state and local policies and reg-
ulations. If it is not, it should be not funded, or effective and
enforceable conditions should be imposed on the grant to reconcile
conflicts between the proposed project and such policies and re-
gulations. Throughout the draft impact statement , funding of the
Auburn interceptor is primarily justified on grounds other than
water quality. Justification is based on a) conformance to METRO'S
Comprehensive Plan and the RIBCO recommendation, b) meeting the
directive of the Department of Ecology and c) providing jobs in the
community. Such reasons cannot and should not form the basis for
funding of the Auburn interceptor. Although unstated in this draft
impact statement the justification for the proposed interceptor ap-
pears to be for producing revenue sufficient to fund downstream
facilities ( Renton Treatment Plant expansion) built in anticipation
of the Auburn interceptor. This is succinctly stated on page ix of
the "Environmental Assesment of the Auburn Interceptor", November,
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1973, prepared by Wilsey and Ham, Inc. as follows:
"The proposed action is, however, as much a response to policy
decisions made by federal, state, regional and local agencies
during the last fifteen years, as it is a response to a potential
or existing water guality problem. The proposed action repres-
ents a continuation of METRO'S policy to serve the needs of an
expanding urban area. An interceptor similar in size and locat-
ion to the Auburn interceptor has been a part of METRO'S Com-
prehensive Sewer Plan since 1958. Downstream facilities have
been designed and constructed in anticipation of the upstream
facilities, including the Auburn interceptor."
The Green River Valley through which the interceptor will extend
is a designated 100-year floodplain, contains some of the best prime
agricultural land remaining in Western Washington and 233O acres of
Type I and Type IT. wetlands. The federal government, by Executive
Order No. 11296, in part reproduced below, established a policy of
precluding, as far as practicable, construction of structures in de-
signated floodplains.
"(2) All executive agencies responsible for the administration
of Federal grant ...programs involving the construction of build-
ings, structures, roads, or other facilities shall evaluate
flood hazards in connection with such facilities and, in order
to minimize the exposure of facilities to potential floods and
the need for future Federal expenditures for flood protection
and flood disaster relief, shall, as far as practicable, pre-
clude the uneconomic, hazardous, or unnecessary use of flood
plains in such connection."
The EPA policy to protect the nation's wetlands of February 21, 1973
establishes a policy of not funding "waste-treatment associated ap-
purtenances which may interfere with the existing wetland ecosystem
except where no alternative of lesser environmenta/'damage is found
to be feasible.(Emphasis added) King County, recognizing the value
of prime agricultural land remaining in the Green River Valley has
recently proposed an ordinance to preserve the agricultural resources
of the Valley. Funding of the Auburn interceptor by EPA is in direct
opposition to the established policies ourline above.
Specific comments below are directed to the page or pages of
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the draft EIS.
p. xi (Paragraph 4). The project would result, not in elimin-
ation of the discharge to the Green River, but in transferring the
discharge further downstream. No data are included which would in-
dicate that the wastewaters presently being discharged into the
Creen-Duamish by the Renton treatment plant are any less inadequate
than the wastewaters presently being discharged into the Green River
by the City of Auburn. How and when would the project result in
discontinuation of septic tanks in the Green River Sewerage Area?
p.xii (b) Why isn't land disposal of the sludge considered by
EPA or METRO?
p.xiii(b) Why is the proposed project not being sized to pre-
vent or minimize air quality problems? EPA has, in other locations,
required size reduction because of potential air quality standard
violations.
p.xiii(c) Why not take mitigative measures now? EPA is alleged-
ley supposed to protect and enhance the environment , not fund pro-
jects which will result in or induce environmental degradation.
p.xiv Why not consider the alternative of pumping the effluent
from the Auburn treatment plant into Puget Sound on the basis that
the requirerr'nts for effluent disposal will be changed as presently
being advocated by METRO?
p.4 What was the basis and justification for the NPDES permit?
p.7. The sererage area boundaries include the Lake Meridian arec
already served by the Cascade Sewer District. A Black Diamond inter-
ceptor is also being proposed to serve the Black Diamond-Lake Sawyer
Lake Wilderness area for connection to the main METRO trunk line in
Kent. Nothing is mentioned in the EIS about this already serered
area nor is any reason given why this same area is included in the
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sewerage area to be served by the Auburn interceptor.
p. 11. No map is included in the EIS giving the present status
of land in Kent, Auburn and King County through which che intercep-
tor will pass. No data is included justifying the statement "Large
portions of the Green River Valley within the sewerage area, there-
fore, appear to be committed to open space or agricultural uses
when in re-.lity they are committed to industrial uses."
p.11. No identification of the designated 100-year floodplain
is provided for that portion of the Green River Valley area through
which the Aubrun interceptor will pass.
p.19. No data is included or referenced to justify the con-
clusion: "continued developnmt of the Green River Valley may cause
decreased employment elsewhere in the region."
p. 2O The relationship of the proposed interceptor to the SCS
project and the Corps of Engineers project is not adequately covered.
p. 27. The dissolved oxygen problems in the Duamish would likely
be made worse by the proposed action. These problems have not been
addressed.
p. 31. What is the contribution of coliform by the Renton treat
ment plant?
p. 31. The reference (6) mentioned is not noted in the EIS. On
p. 37 the reference (4) is not noted.
p. 38. Why the "special condition" for total coliform in the
area of the Renton treatment plant discharge?
p. 55. No description and identification of prime agricultural
lands which would be directly or indirectly affected by the presence
p. 60. The EIS is inadequate in not including a projection of
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2V
25
26
37
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3C
the costs of taking all of the waste water of Auburn and ultimately,
the wastes for the sewerage area for which it is sized, to the Renton
Treatment Plant, then piping all of the sludge to the West Point Treat-
ment Plant, and then trucking the sludge to one or more disposal
sites. On its face, the project does not make sense economically.
p. 78. No cost effective data are included for the alternative
of upgradinq the Auburn lagoon similar to that provided for the other
alternatives so that there can be a meaningful cost comparison of
each alternative. Further, none of the alternatives include pro-
jected operation and maintenance costs for handling and disposal of
sludge.
p. QO. The Eis is inadequate in that there is no acknowledge-
ment of the fact that in making a decision to fund the Auburn inter-
ceptor, EPA is making a "land use" decision for the area affected.
p. 91. The EIS is inadequate in not recognizing that a decision
to fund the Auburn interceptor weakens the power of the municipalit-
ies affected and King County to make future land use decisions con-
sistent with sound land use planning policies and principles.
p. 91. (4th paragraph) On p. 92 the EIS states: "...the growth
stimulating role of the proposed interceptor must be dismissed as
a critical issue." On p. 91 the EIS states: "Expansion of sewering
is one of the pre-conditions for continued development of the Green
River Valley. The two statements are contradictory.
p. 90-99. Additonal sewer service funded by EPA should, in
terms of its own rules and regulations, "produce a project which will
have maximum beneficial effects on man's environment and minimum ad-
verse effects." Funding the Auburn interceptor will tend to encour-
age rather than discourage further industrialization and urbanization
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of the Green River Valley. Providing funding for the interceptor
is not consistent with the requirements of Executive Order 11296,
and the EPA policy to protect the nation's wetlands, nor is the EIS
adequate in meeting the requirements of Section 6.2I4(b) (2) and 6.304
(b) (4) and 6. 304 (d) of the EPA rules and regulations f6r pre-
paration of environmental impact statements, 40 FR 16314 et seq.
With reference to sec.6.304 (D) the environmental impact appraisal
included with the letter of January 10, 1975 of Robert S. Burd, men-
tioned numerous grant conditions "to assure that EPA's objectives
are accomplished." No mention of any such grant conditions is in-
cludes in the EIS together with a discussion of how the conditions
would be enforced and how they would mitigate any adverse environ-
mental impacts. Se. 6.512 (6) requires delineation of steps to mit-
igate adverse environmental harm. It states:
11 This section shall describe structural and nonstructural
measures, if any, in the facilities plan to mitigate or eliminate
significant adverse effects on the human and natural environments.
Structural provisions include changes in facility desian, size and
location; nonstructural provisions include staging facilities as
well ad developing and enforcing land use regulations and environ-
mentally protective regulations."
p.101-107. The EIS is inadequate in not including reasons
justifying use of the PSGC population projections through the year
2OOO when there is a recognition that they are overly optimistic
in viev; of the 1975 actual population figures.
p. 136-144. The EIS is inadequate in that there is no relation
of the data developed to the present and projected requirements of
the Clean Air Act.
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p. 157. Local governmental land use planning and control cannot
be effective in avoiding severe environmental degradation if irrever-
sible committments, such as the Auburn interceptor, are made for them.
p. 159. There is no projection of the increased costs for sewer
service which will be intially borne by Auburn residential, commercial
and industrial users and ultimately by residents within the sewerage
area.
p. 161. Sec. 6.304 (f) of the rules and regulations of EPA re-
quires that the "need for any irretrievable and significant commit-
tments of resources shall be explained fully." Though the draft
EIS recognizes that the decision to fund the interceptor will result
in an irreversible committment of future resources, there is no ex-
planation of why EPA should fund the interceptor, other than state-
ments that the interceptor is consistent with the comprehensive plan
of METRO, the directive of DOE and the recommendations of RIBCO.
p. 164. (2nd paragraph) Is one of the purposes of the construct-
a
ion grant programs of EPA under P.L.92-5OO to provide jobs in the com-j '
munity?
p. 164 (4th paragraph) The EIS is unclear as to how municipalit-
ies will be able to update and strengthen their comprehensive land
use plans, zoning and other development ordinances and sewage facil-
ity plans by the "sewer system and the land use guidance identified
in this EIS."
p. 165. The EIS is inadequate in not considering the value of
prime agricultural land in the Green River Valley affected by the
presence of the interceptor. (See PSGC Agricultural study)
Appendix E-2 . Was the cost effectiveness of an individual
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treatment facility considered by EPA as an alternative to the re-
gional system proposed by METRO?
We appreciate the opportunity qiven us to review and comment
on the draft EIS. We will be following with considerable interest
EPA's course of action in the coming months. EPA thus far, has
failed *o justify funding of the project at all in view of its
own internal policies and regulations developed pursuant to NEPA
and FWPCA.
Seattle Audubon Society
Thomas 0. Wimmer
Director
Sincerely,
Washington Environmental Council
Mike Galvin
President
Friends of the Earth
Dale Jones
Northwest Representative
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RESPONSE TO COMMENTS BY
WASHINGTON ENVIRONMENTAL COUNCIL
1. We disagree. The project is fully compatible with federal laws,
regulations, and EPA policy.
2. The EIS contains a discussion of the floodplain and wetland issue.
3. The impact appraisal was written with the concept of using grant
conditions to force environmental evaluations and controls. The
decision to write an EIS changed that concept to evaluation and
selection as a function of the EIS conclusions. The EIS has looked
at alternatives, considered environmental factors and selected
the most acceptable project. The conditions specified in the
environmental appraisal are no longer required because each of the
areas of concern have been addressed in the EIS text. If grant
conditions are still needed, the authors of the various sections
who studied the situations should identify the unresolved problems
to us and we will try to assist in developing appropriate language.
4. While the costs of sewerage collection, treatment, and disposal can
be readily determined (see #5), the social and environmental costs
of sewer provision are more difficult to identify and quantify. If
the provision of sewer lines allows urbanization to occur in an
uncontrolled, unplanned manner, the public costs associated with
increased urbanization can be substantial. Though not expressed in
monetary terms, the social and economic impacts of the interceptor
are descriptively analyzed on pages 101-106. Attention is directed
to the discussion of socio-economic trends (p. 18-20) which analyzes
the tax burden on landowners, changes in land value, assessed valuation
per capita, and other economic effects attributable to increased
development. The discussion demonstrates that the costs of providing
services, facilities, and utilities to developing areas are accrued
to and paid for by the public.
5. At such time as the pending contract between Metro and the cities of
Auburn, Algona and Pacific becomes effective, the Metro charge for
each residential connection will be $3.55 per month. The charge for
non-residential connections is to be based on water usage, with the
standard residential charge applied for each 900 cubic feet of water
discharged to the sewer system.
The pending contract also provides for the reimbursement of more than
$713,000 to the City of Auburn for facilities no longer to be used.
This sum is available to the City for such purposes as sewer system
improvements, sewer system debt retirement or other legal uses.
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The additional cost for residential and non-residential connections
for maintenance and operation of the sewer systems owned and operated
by each of the municipalities will vary from one city to another,
depending in part on staffing and salaries, complexity of the sewer
system and whether any of the monthly service charge is applied to
the redemption of bonds sold to finance construction. Elimination
of the Auburn treatment plant would eliminate the costs presently
chargeable to treatment and disposal at that plant. Costs for
transmission, treatment and disposal at Renton would be included
in the monthly Metro charge.
If increases in treatment, operation and maintenance costs are experienced
by Metro and local governments, rates would have to be adjusted as
necessary to meet expenditures.
6. See item 6 in Aye letter.
7. See additions on p. 13 and EPA's response to letters from Christine
Foulks.
8. Additional discussion of the SCS and COE projects has been added to
this final EIS. See p. 125 and E-ll.
9. Effluent is discharged from five Metro treatment plants. All of these
plants divert sludge to the West Point facility. Although the Renton
treatment plant does divert sludge to West Point, the possibility of
alternative disposition of Renton's sludge is now being studied.
See p. 122.
10. The PSGC projection figures are the best available for the affected
area and are the forecasts which have been regionally adopted.
11. Additional information on the treatment achieved by the Renton
plant appears on p. 110. The possibility of failure of the Auburn
lagoon to provide adequate treatment during a critical low flow
condition would be eliminated by operation of the interceptor.
Because other sources exist, removal of the lagoon's discharge as
a source of nutrients may in itself have only slight initial benefits
on the general water quality in the reach of the Green River between
Auburn and Renton during normal river flows. Additional measures
will probably be required to achieve and maintain water quality
objectives in this reach. However, the interceptor will be a cost-
effective solution to the long-term sewerage needs of the area and
will eliminate future municipal waste discharges in this reach.
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12. As stated before, the project is fully consistent with federal,
State, and local policies and regulations. Meeting the directive of
the DOE--the State agency charged with protecting Washington's
environment—shouldn't be ignored. It is based on water quality
needs, now and in the future, and is in conformance with the Federal
Water Pollution Control Act.
13. Testimony received at the EPA public meeting held before the draft
EIS was prepared included statements that the sewer service area is
not prime agricultural land - one reason why so little farming is
undertaken today. Any EPA project would be protected from the 100-
year flood. Grant conditions would be applied to protect any unique
wetland through which the sewer would pass.
14. Data showing a comparison between the treatment achieved by the kenton
treatment plant and the Auburn lagoon are shown on p. 110. Hot all
septic tank usage is expected to be discontinued by the Year 2000.
It is anticipated that sewers will not be available in some areas.
When sewer service becomes available to an area, facilities relying
on septic tanks may be required to connect to the sewers. Thus,
many septic tanks would eventually be replaced as sewage collection
systems are extended.
Extension will require construction by Metro of planned interceptors
to connect the smaller collection systems in populated areas to the
Auburn Interceptor. The population, population density and special
needs of 1000-acre tracts are considered in planning interceptor
extensions (see Ref. 1 as listed on page 134 for additional information
regarding interceptor extensions). As local improvement districts are
formed to request sewer service, the smaller collection systems that
flow to interceptors would be constructed. According to county
regulations, a connection to a sewer must be made within 60 days after
notice of availability. This would phase out reliance on septic
tanks. However, it is expected that some areas with low projected
populations would continue to rely on septic tanks in the Year 2000.
As noted on p. 65 (Table 15), the proposed Auburn Interceptor is
sized to accept the flows anticipated from a sewered population of
175,858 in the Year 2000. This will include about 84% of the total
projected population and 27% of the land area. Projected extensions
of sewer service for each of the six basins are reflected in the
figures shown for sewered acreages. For example, the sewered acreage
for Basin 3, which is the West Hill including Lake Geneva, is planned
to increase from 275 acres to 4,788 acres by 1980.
15. Land disposal of sludge is now used. However, Metro is studying
several methods of sludge utilization. The feasibility of using
digested sludge as a soil conditioner, especially on forest lands,
is being evaluated now through research. EPA has participated in
this effort through a research grant.
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16. The EIS discusses environmental effects. EPA has required consideration
of a 72" sewer rather than the 78" sewer proposed by Seattle Metro.
Other agencies also have direct responsibility for protecting the
Green River valley environment, e.g. an air quality maintenance plan
is being prepared by local government, wetlands are best protected
by State and local government through land zoning and/or outright
purchases of the wetlands for permanent open space.
17. Unless the existing requirements for secondary treatment were met by
Auburn by July 1, 1977 or the requirements for effluent disposal are
changed, EPA could not participate in funding such an alternative.
Without federal assistance, this does not appear to be a feasible
alternative.
18. The Renton Treatment Plant NPDES permit was issued in accordance with
Chapter 90.48 RCW State of Washington and the Federal Water Pollution
Control Act Amendments of 1972, PL 92-500. The standards set forth are
based primarily on requirements of the State's Water Quality Standards
or on guidelines established by EPA.
19. Portions of the Cascade Sewer District are sewered at this time. Waste-
waters from this system are discharged into Metro's existing interceptor
in Kent and treated at the Renton plant. Discharge to Metro's interceptor
is through the City of Kent system and, as described on p. 82, the
wastes must be pumped twice before reaching the Metro interceptor. Also,
as described on p. 82, the proposed Black Diamond-Lake Sawyer interceptor
initially is planned to be connected to the Cascade Sewer District pump
station. However, this area is serviceable by gravity flow to the Auburn
area, and at such time as gravity service is available, it is planned
to eliminate pumping, which will no longer be necessary.
20. Without adequate lead time, a new map cannot be added to the final
EIS. However, a zoning map showing actual land use commitments is
available for perusal at PSGC.
21. Pages 125, 126, and E-ll have been revised. The map prepared by the
Corps which is discussed on page 125 was not available to EPA in time
for inclusion in this EIS, but may be viewed at the Region X EPA
office in Seattle, Washington.
22. The conclusion is a judgemental one based on the evidence that as
employment rose during the nine year period (1961-1970) in the Green
River Valley, employment declined in the Duwamish basin. Because
there is no detailed evidence to substantiate this conclusion the
sentence has been revised to read: "Based on these observations, one
may speculate that the desirability for industry to locate in the
Green River Valley may be one of the factors which has caused
employment to decline in the Duwamish basin and, perhaps, elsewhere.
23. Discussion of the SCS drainage project and the COE flood control
study has been expanded on pages E-ll and page 126.
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24. The potential dissolved oxygen problem in the Duwamish is addressed
on page 112. No immediate adverse impact on the dissolved oxygen
problem in the Duwamish is expected since better waste treatment will
be provided by the Renton treatment plant, as compared to the Auburn
lagoon. See revised page 110.
25. See page 110 for additional characterization of the Renton discharge,
including the bacterial loading.
26. See page 38A.
27. The area of the Renton Treatment Plant discharge and downriver sites
were not designated as water contact sport areas because of the treatment
plant and industrial waste discharges. The coliform standard established
by the Department of Ecology therefore was based on the normal use of
the water which was primarily fish passage and industrial use which do
not require as stringent a standard.
28. Attention is directed to discussion on pages 94-98. The identification
the exact acreages that may be lost through secondary impacts of the
proposed interceptor (by 2000) is beyond the scope of the project.
The primary agricultural land will be directly affected by the presence
of the interceptor line in such a way that it will be taken out of
production. Construction will take place within the right-of-way corridor.
29. See item 6 response to Aye letter.
30. See item 6 response to Aye letter.
31. The section has been revised to acknowledge the fact that EPA does
recognize that its decision to fund the project may be a "land use"
decision. See also discussion on page 92.
32. As expressed in paragraph four of page 90, it is EPA's intent that
the decision to fund the Auburn interceptor will provide the munici-
palities affected the opportunity to re-evaluate land use policies
and to develop comprehensive solutions to economic and environmental
problems. That EPA's decision will weaken the power of these governmental
bodies to do proper planning is extremely doubtful. Until National
land use legislation is passed, local governments retain, in its entirety,
the legal authority to control and direct the use of the lands within
their jurisdictional boundaries. Zoning, which is solely in the hands
of local governments, is and will continue to be the major mechanism
by which land use is controlled.
33. As stated on page 91, the expansion of sewering is only one of the
preconditions for continued development of the Green River Valley.
As discussed in the fifth paragraph, growth and development are the
result of a broad set of interrelated phenomena such as birth rates,
migration, and the state of national, regional, and local economy.
Clearly, therefore, growth is not solely dependent on the provision of
sewers.
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34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
Discussion on page 92, paragraphs 2 and
conclusion that the "growth stimulating
must be dismissed as a critical issue."
alternative engineering configurations
3, provides rationale for the
role of the proposed interceptor
Basically, there are several
aside from the proposed project
which can provide the same services and capacity for expansion in the
service area. The long term impacts of each configuration are expected
to be similar in scope and character.
In making a decision as to whether or not a
beneficial effects on man's environment and
all facets of those elements which comprise
taken into account. While, on one hand, it
project will have "maximum
minimum adverse effects"
man's environment must be
should not be void of open
space and aesthetic qualities, a good environment, on the other hand,
does not preclude urbanization, or industrial development. It should
reflect instead a harmonious and holistic integration of those amenities
necessary to fulfill man's needs.
The Auburn Interceptor project is compatible with Federal rules, regula-
tions and Executive Orders. The issue of grant conditions was previously
discussed as was the action to consider a 72" sewer rather than the 78"
sewer originally proposed by Seattle Metro. This reduction in size is
a significant step to mitigate adverse environmental harm that may result
from future growth.
As stated on page 106, there are potential problems with both sets of
figures presented in Table 28. EPA has chosen to use PSGC's figures
because these are the best currently available for the small area
which encompasses the sewerage area and are the regionally adopted
forecasts.
See page 39. It is not possible to project the requirements of future
amendments to the CAA.
As this comment is similar to that made in item 32, attention is
directed to EPA's response to that comment. See also response #5 to
comments by Don Miller.
See item 2 response to Hartnett letter.
The stated reasons for funding the interceptor are all valid. The
present Auburn sewerage system is in violation of the Federal law,
State directives and doesn't allow for future growth.
See item 5 response to this letter.
This sentence has been
comprehensive land use
economic, and
revised to read: "The evaluation of the local
plans and the discussion of potential social,
environmental impacts provided in the text of this EIS
should prompt the public and local officials to re-examine
community goals and to prepare for anticipated growth."
their
Attention is directed to EPA's responses to Christine Foulks' letters
and to revisions made on p. 13.
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44. The alternative of providing a secondary treatment plant at Auburn,
discussed on p. 78, is the alternative of an individual treatment
facility. Cost effectiveness of this alternative is compared with
this regional interceptor and treatment alternative on p. 87.
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jiiirl I I vans - (Governor
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St-crt'tarv
-------
Mr. Richard R. Thiel -2- June 2, 1975
Also a permit must be obtained from this Department prior to undertaking
construction within State Highway right of way. Coordination with the
Department may be initiated through W. C. Bogart, District Engineer, 6431
Corson Ave. So., Seattle, Washington 98108.
Sincerely,
G. H. ANDREWS
Director of Highways
j / S> / ,
.'- i L
£«>*" (( «
By: H. R. GOFF /,
Assistant Director for
Planning, Research and State Aid
HRG:eh
RA/RBD
cc: W. C. Bogart
22'
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RESPONSE TO COMMENTS BY
WASHINGTON STATE HIGHWAY COMMISSION
1. See our response to comment of U.S. Dept. of Transportation, Federal
Highway Administration.
2. As stated on p. 98 of the EIS, "the availability of sewers may allow
local jurisdictions to hasten the rates of urbanization of the land."
Also on p. 98 of the Draft, the following statement is made: "In
summary, the proposed interceptor: (1) Will facilitate development
in the Green River Sewerage Area —."
The proposed interceptor is consistent with the IRDP, which includes
a transportation plan as well as a sewerage plan, and which addresses
projected traffic facility needs. It is understood that the Puget
Sound Governmental Conference is making a study of impacts such as
noise and air quality, related to transportation facilities. Impacts
and mitigative measures related to a specific transportation project
would be covered in the environmental assessment or impact statement
prepared for that particular project, just as the Washington Department
of Highways has done in its Draft EIS on SR 167, Sumner Vicinity to
Auburn Vicinity, March, 1975, which project involves a portion of the
Green River Sewerage Area.
3. See our response to comment by the U.S. Dept. of Transportation,
Federal Highway Administration.
222
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RESPONSE TO COMMENTS BY
CHRISTINE FOULKS
1. Without growth policy constraints there is no guarantee that these
trends will not continue. By open discussion of the potential
effects of uncontrolled growth (which may, we might add, occur with
or without the proposed project), EPA hoped to prompt the municipa-
lities affected to re-evaluate land use policies and to develop
mechanisms to deal with these predicted problems before they occur.
For discussion of items a, b, c and d, see EPA's response #33 and
#36 (Washington Environmental Council), #3 (Robert D. Aye).
2. The PSGC report, "The Green River Valley - A Discussion Paper"
(Brian Beam) is available in its final form at the PSGC office. It
is not merely an "in-house" report.
3. As the area most directly affected by the proposed project, the City
of Auburn was selected as the most logical location for Metro's public
hearing and EPA's public meeting. Both the hearing and the meeting
were announced in a number of publications with wide distribution.
In addition, EPA sent direct notice of its meeting to over one hundred
agencies, groups, and individuals who had expressed interest in the
project. EPA believes that all concerned parties were given ample
opportunity to participate in the hearing and the meeting either by
attending or by submitting a written comment.
Records indicate that a representative of the Magnolia Community Club
was present at Metro's hearing and EPA's meeting, and spoke about
effects of the proposed action on the West Point treatment plant and
surrounding area. These effects are discussed in both Metro's
environmental assessment and in this impact statement.
4. Because of resource constraints, the "draining" effect the interceptor
may have Seattle's employment and population is qualitatively and
discriptively discussed on pg. 19. From what has been experienced in
the Duwamish basin, it can be expected that this "draining" effect will
be intensified by the interceptor.
5. EPA believes that it has adequately identified a range of feasible
alternatives which were properly evaluated in accordance with the cost
effectiveness guidelines set forth in 40 CFR 35, Construction Grant
Regulations for Waste Treatment Works. EPA is unaware of any "new
sewage waste technology" which could be identified as a feasible alternative.
225
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Mr. Clifford V. Smith
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Lear Mr. Smith:
Preserve Land for Agriculture Now
PLAN - King County
Box 5501, Seattle, WA 98105
Hay 30n 1975
}i
RECEIVED
JUN2 1975
EPA-EIS
Thank you for the invitation to comment on the recently completed Draft
Environmental Impact Statement on the Auburn Interceptor. PLAN-King County
formed in October of 1974 in response to concerns of county citizens over the
conversion of agricultural land to urban uses which was occurring at an increasing
and visible rate. It is appropriate that PLAN review the EIS for the Auburn Inter-
ceptor in light of this project's location in the center of a major King County
agricultural area,
The most obvious and serious defect of the EIS prepared on the Auburn Sewer
Interceptor is the absolute failure to address the importance of agricultural use
of the land in the Green River Valley. EPA teats agriculture consistently through-
out the EIS as a temporary, transitional use of minor, if any, importance to the
citizens of this rapidly developing urban area.
A typical EPA comment: "Kuch cf this land has been sold to investors and
developers who are leasing the land to farmers until industrial development is-
feasible. Large portions of the Green River Valley within the sewerage area,
therefore, appear to be committed to open space or agricultural uses when in
reality they are committed to industrial uses.i! EIS, p. 11.
On a later page, EPA indicates that these lands are probably "committed" to
industrial development which will never be feasible: "The magnitude of over-
planning for industrial land becomes more apparent when viewed in a regional
context. By 1990, the entire Central Puget Sound Region will have a projected
demand for 7,006 acres of manufacturing land. Valley jurisdictions are planning
for over ij? times that much manufacturing land to be located just in the Green
River Valley." EIS, p. 94.
This type of contradictory "evaluation" of the future of the Green River
Valley is found throughout the EIS. In addition, EPA has simply failed to
recognize the existence of or make use of important documents produced by local
a.ccncies which identify the value to the public of retaining agricultural uses
of the Green River Valley's prime agricultural soil.
EPA's ommissions in this respect include —
1. Failure to acknowledge the existence of or make use of the Regional Agriculture
Report of the PSGC which was adopted in July, 1974, as the basis for developing
regional policies for the preservation of the agricultural industry within all
P3C-C counties including King. Produced with the assistance of agricultural
experts from WSU, this Report is a major technical document which outlines the
extent and importance of agriculture in the Green River Valley and other farm
districts in the county. It is inconceivable that an environmental impact state-
ment could be developed in relation to a major public project in the Green River
Valley without using the information and conclusions in this study.
2. Failure to acknowledge the existence of or make use of the EIS developed by the
King County'Planning Dept. con 226
-------
p. 2 PLAN comments on EIS - Auburn Interceptor
2. Failure to acknowledge the existence of or make use of the EIS developed
by King County Planning Dept. concerning the pending adoption by King County
of Ordinance #1839 which would designate those areas of the county which are
highly suitable for agriculture as being within a county system of agricul-
tural/open space zones. Again, this is a major report which documents the
value to the public of retaining- agricultural uses of highly suitable land.
If is difficult to understand why EPA did not acknowledge the existence of
this report, especially in view of the over 3,000 acres in the Green River
Valley which are still within the zoning jurisdiction of the King County Council.
This acreage is currently zoned agricultural and is in agricultural use.
3. Failure to deal with the economic importance of agriculture in King County.
EPA deals with the agricultural industry in King County as if it should be
considered a "marginal use" of land, just one step above the land being
actually idle. No recognition is given to the economic and social values of
agriculture to the residents of the county.
4. Failure to deal with methods necessary to mitigate the adverse effects of this
project on the agricultural industry still remaining in the Valley. EPA does
not mention the effect that LIDs and other economic consequences of the project
will have on fanners near the project area. Nor does EPA suggest methods of
mitigating these adverse impacts on agriculture.
5. In relegating agriculture to the status of a transitional or marginal use of
the land in the Green River Valley, EPA has chosen to ignore some important .
facts.. .
...King County produced agricultural products worth over $22 million in 1969-70.
sib million of this production was from crops requiring prime agricultural soil
such as that in the Green River Valley; vegetables, berries, field crops, and
horticultural products. $6 million was produced by the dairy industry, another
current use of Green River Valley land. (PSGC Ag. Report, Appendix A, Table 3)
...The 12,550 acres of Class II soil in the Green River Valley which has not yet
baen converted to urban uses represents 22^ of the available prime agricul-
tural soil in King County. (PSGC AG. Report, p. 58)
...iling County residents consumed 59>053 tons of vegetables in 1970 of the
variety that are commonly grown in King County. In 1970, King County produc-
tion of those vegetables was 18,950 tons or 3^ °f "the estimated consumption.
(Consumption estimate based on national fig-ores) Considering King County
residents make up over 30>o of the state population, this indicates the impor-
tance of the productivity of King County cropland. (King County EIS on Agri-
culture as Open Space, p. 20-21)
...The major acreage currently being farmed in the Green River Valley lies
within unir.c orr. or at s d King County jurisdiction, not in the 73/J of the land
area controlled by incorporated cities. (Sec- EPA EIS, p. 165) Out of 4,614
acres currently being farmed in the Valley, 3010 is within the jurisdiction
of King County. (King County EIS, p. 17) while most of the available farm
coil does lie within the borders of the incorporated cities, it is now mostly
idle, being held out of agricultural use. The 3010 acres in King County jur-
isdiction is in agricultural zoning and is subject to hearings to discuss
Ordinance 1839 which would retain this zone.
...King County shares with Pierce County the entire stata production of rhubarb.
These two counties produce over 90>o of the U.S. rhubarb crop. (U.S. Census of
Agriculture, 1971)
22
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p. 3 PLAN comments on EIS - Auburn Interceptor
...King County's rank in state production of specific vegetables has not
changed much since 1964 —
Crop 1973
Snap beans 4
Broccoli
Cabbage 2
Carrots 10
Cauliflower 2
Celery 2
Sweet corn 11
Cucumbers 2
Lettuce 3
Green peas - -
Rhubarb 2
Turnips -
Spinach -
Tomatoes 6
1969
3
3
1
9
2
1
11
6
1
2
2
1964
1
3
1
8
2
1
9
3
1
1
2
2
2
2
Rank in relation to other ccur.tic:
in Washington state production
(Washington Agricultural Statistic
1973, 1969, 1964 Reports)
..King County has & longer growing season than counties east of the Cascades.
Frost-free days - (Atlas of the Pacific Northwest, p.34)
Seattle -268
Ephrata -190
Yakima -184
Oroville -172
Spokane -164
This long growing season is accompanied by a moist, mild climate which is
ideal for growing berry crops and leafy, green vegetables. This is why
of the heavy urbanization pressures farmei's here are subjected to. The
statement by EPA on p. 165 of the EIS ("Farming this valley is difficult
because of the weather conditions, etc.....) is incorrect and that section
should either be eliminated from the EIS or it must be documented. This
EPA statement is in direct contradiction of a conclusion of the PSGC study
of agriculture: "From the standpoint of physical factors, the soil and the
climate, agriculture appears to have a very viable base in this region,
capable of sustaining itsalf indefinitly into the future. In short, the
physical determinants of this region's agriculture have remained stable
and cannot account for the declines in the regional agriculture noted in
Chapter 1." (PSGC Ag. Report, p. 58)
In summary, PLAN recommends that EPA recognize the validity of agricultural
activicy in the Green River Valley, recognize the impact this sever
project will have on that activity, study the local agency documents
outlining the importance of agriculture to the public, and deal with
these issues in the EIS.
Thank you for your consideration.
Christine Foulks
PLAN -King County
228
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RESPONSE TO COMMENTS BY PLAN
The comments made by Ms. Foulks are both cogent and substantive.
The letter is, in itself, a valuable addition to the impact statement.
Changes have been made in the text (p. 13-14; 165) to recognize the
Regional Agriculture Report of the PSGC (July, 1974). While there is
no Congressional directive that allows EPA to determine what land should
be put to what uses, EPA does encourage elected officials and the public
to recognize the status of agriculture as a competing land use and to
support the development of effective regional policies for the preserva-
tion of this industry.
Attention is also directed to the section on Land Use Impacts as
there is a discussion of the possible extent of development by the year
1990 if growth is allowed to continue unimpeded.
229
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Advisory Council
On Historic Preservation
May 27, 1975
Dr. Clifford V. Smith, Jr., P.E.
Regional Administrator
Region X
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Dr. Smith:
This is in response to your request of April 18, 1975 for comments on
the draft environmental statement (DBS) for the Auburn Interceptor
(Green River Sewerage Area), King County, Washington. Pursuant to its
responsibilities under Section 102(2) (C) of the National Environmental
Policy Act of 1969, the Advisory Council has determined that the DES
appears adequate concerning compliance with Section 106 of the National
Historic Preservation Act of 1966.
However, with respect to evidence of compliance with the provisions of
Executive Order 11593, "Protection and Enhancement of the Cultural
Environment" of May 13, 1971, the Council notes that the undertaking as
proposed will result in an effect to the Seattle-Tacoma Interurban
right-of-way, a property which may be eligible for inclusion in the
National Register of Historic Places. Because this property may be
eligible for inclusion in the National Register, it is entitled to the
protection afforded it by the Executive Order 11593. Therefore, in
accordance with Section 800.4(a)(2) of the "Procedures for the Protection
of Historic and Cultural Properties" (36 C.F.R. Part 800), which sets
forth the steps for compliance with the Order, the Council requests the
Environmental Protection Agency (EPA) to request in writing an opinion
from the Secretary of the Interior respecting the Seattle-Tacoma Interurban
right-of-way's eligibility for the National Register and inform us of
the findings. Should the Secretary determine the property is eligible
for inclusion in the National Register, then EPA should follow the
remaining steps in Section 800.4 to evaluate the effect of the undertaking
upon the property.
In addition, the Council notes that an archeological survey of the project
area will be preformed prior to construction. The Council wishes to
remind EPA that should cultural resources be discovered which are subsequently
determined eligible for inclusion in the National Register, it is required
to afford the Council an opportunity to comment on the appropriate action
necessary to preserve those resources pursuant to the procedures .
RECEIVED
JUN2 1975
230
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Until the requirements of the Executive Order 11593 and the procedures are
met, the Council considers the DBS to be incomplete in its treatment of
historical, architectural, archeological and cultural resources. To remedy
this deficiency, the Council will provide substantive comments on the
undertaking's effect upon such resources through the process set forth in
the procedures. Please contact Michael H. Bureman of the Council staff at
P. 0. Box 25085, Denver, Colorado 80225, telephone number (303) 234-4946,
to assist you in completing this process as expeditiously as possible.
Your continued cooperation is appreciated.
Sincerely yours,
Louis S. Wall
Assistant Director
Office of Review and
Compliance
cc:
Sheldon Meyers-EPA:FLO
231
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June 10, 1975
10A Re: Metro Auburn Interceptor
Project No. C-53G475-J2
U.S. Department of the Interior
Office of the Secretary
Washington. 0. C. 20240
Dear Mr. Secretary:
An Advisory Council on Historic Preservation review of the
Region X Draft Environmental Impact Statement (DEIS) for tne Auburn
Interceptor* a proposed wastewater treatment works grant project
near Seattle, Washington, determined tnat the proposed project
would affect the Seattle-Tacoms Interurban railroad right-of-way.
This property may be eligible for Inclusion In the National Register
of Historic Places (Advisory Council consents attached). The property
Is presently on the State of Washington's Register of Historic Places.
Pursuant to Executive Order 11593 and Its Implementing regulations
(36 CFR Part 800), Region X requests the Secretary of the Interior
to conduct a review of the property's eligibility for Inclusion In
the National Register. If the property Is found to be eligible for
Inclusion 1n the National Register, Region X will evaluate the pro-
posed project's effect on the historic property pursuant to 36 CFR
Part 800, Section 800.4.
A similar effect analysis was conducted by Region X during the
environmental Impact statement preparation process. Though the
Interurban railroad right-of-way Is located within the "direct Im-
pact area" of the proposed project. Region X determined that no
effect would be likely. Because the proposed Auburn Interceptor will
be underground, with grade-level manhole covers being the only vis-
ible evidence of Its presence. It would not have any permanent Impact
on the aesthetic, open space, recreational, or historic values of the
property. Any Impact during construction will be temporary since
disturbed surface areas will be restored. No changes, beneficial or
adverse, 1n the quality of the historical or cultural character that
may qualify the property for Inclusion In the National Register will
result from the proposed ERA action. The Chief of the Washington
State Office of Archaeology and Historic Preservation has concurred
with Region X's evaluation that little direct Impact on the Inter-
urban railroad right-of-way will result 1f the Auburn Interceptor Is
constructed (State Historic Preservation Council comments attached).
232
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-2-
We have attached some representative pnotography and maps wnich
display the relationship of the proposed Auburn Interceptor and tne
interurban railroad right-of-way to assist 1n your evaluation of the
property. Adjacent to the proposed interceptor's corridor, rcucn of
the interurban railroad right-of-way consists of a marshy drainageway,
interrupted by crossroads on filled emDankments and fencelines with
accompanying shrubs and riparian vegetation. Portions of tne right-
of-way contain a dirt access road, which 1s planned to eventually
become a segment of the King County Trail System. Little recreational
use occurs at this time, however. The only notable feature of the
right-of-way near the proposed interceptor's route 1s the remains of
a trestle from the Interurban railroad, located Immediately south of
South 277th Street in King County. The Puget Sound Power and Light
Company utilizes the interurban railroad right-of-way as a transmission
line couridor, and the Olympic Pipeline Company utilizes the right-of-
way for an underground petroleum products pipeline transmission route.
An expedient review of the status of the interuroan railroad
right-of-way would be greatly appreciated as we are on a critical time
schedule for determination of the appropriate EPA administrative action.
Sincerely,
Clifford V. Smith, Jr., Ph.D., P.E.
Regional Administrator
Attachments
cc: Roy H. Sarapsel
Advisory Council on Historic Preservation (Louis
Wall and Michael Bureroan)
233
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Robert D. Aye, P. E.
i+1^5 llth Ave. N.E., Apt. 31
Seattle, Wash. 98105
May 31, 1975
Mr. Clifford V. Smith RECEIVED
Regional Administrator
U. S. Environmental Protection Agency JUN 2 1975
Region X
1200 Sixth Avenue EPA-EIS
Seattle, Washington 98101 ..
Subject: Draft Environmental Impact Statement
Auburn Interceptor
King County, Washington
EPA Project #0-5301+75-02
Dear Mr. Smith,
I have had the opportunity to review the subject Draft Invironmental
Impact Statement and offer the following comments for your consideration
in preparing the Final EIS.
While I feel EPA is to be commended for addressing the secondary
impacts of the project, there are some very essential issues which
have not been adequately evaluated:
1. Of utmost importance in making a decision on the Auburn Inter-
ceptor is the presentation and evaluation of METRO'S Comprehensive
Sewerage Plan for the Green River Valley including future interceptor
extensions; i.e. West Valley, Dolloff Lake, Lake Geneva and East Green
River Valley interceptors. The Draft EIS (pg. l6l) states that "the
interceptor will probably commit future generations to specific actions
and resource uses in managing water quality in the Green River Sewerage
Area." The Auburn Interceptor, therefore, will preclude consideration
of alternatives on future collection and treatment systems. How can
EPA rationalize treating these actions as independent projects when
they depend on construction of the Auburn Interceptor?
2. It is essential that EPA identify the excess capacity of the Auburn
Interceptor. Will the interceptor actually provide for capacity beyond
the ambitious PSGC projections for year 2000? The Draft EIS (pg. 16^)
states that the proposed action "includes a certain excess capacity"
and (pg. 105) that "the design projections seem disproportionately
ambitious." This oversizing can contribute to the extent of development
that occurs and, consequently, may become a self-fulfilling prophecy.
1
234
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Page 2
The Draft EIS (pg 106) states that "the PSGC figures are, at this
time, the test available for the small area which encompasses the
Green River Sewerage Area." I find this statement rather difficult
to accept considering the magnitude of the differences between the
OBERS and PSGC projections as shown in Table 28. If in fact the OBERS
projections are more nearly correct, the population for year 2000 for
the sewerage area would be approximately 130,000 rather than the 175>,858
projected by PSGC. Since the PSGC projections "fail to take into
account the pronounced reduction in population growth that has taken
place in recent years" and the interceptor is based on these projections,
this issue requires further examination. The PSGC projections are
also based on the assumptions that the Auburn Interceptor and associated
sewers would be in service prior to 1990- Here again construction of
the interceptor is self-fulfilling in insuring that the projected growth
will occur.
There appears to be an error in Table 26 (pg. lOii) in that two
estimates are indicated for the year 2000.
3. What will be the actual increase in cost to the taxpayer for
the sewerage service to be provided (sewerage rates)? How is this cost
affected if the projected growth does not occur as is likely? The
public costs associated with urban development can be substantial and
usually accrue to the taxpayer. What is the estimated cost to be incurred
as a result of providing other services, facilities and utilities to
accomodate the projected growth?
U. The alternatives presented are basically examples of the tra-
ditionally static design approach. The alternatives are not flexible
in that they either provide for the design year growth or no growth.
Staged construction of a regional treatment plant at Auburn might allow
future generations some choice on wastewater management and keep cost
in phase with growth.
5>. Stronger recommendations must be made for mitigating measures
(conditions of grant) to insure that adverse impacts are avoided.
The overplarming for industrial growth by local agencies and Auburn's
uncompromising position on conflicts between their land-use plan and
the Puget Sound Governmental Conference's IRDP are, in my opinion,
indications that the local agencies cannot be relied upon to implement
regulations which would limit adverse growth or devepment.
The remaing comments are more specific and deal primarily with
Water Quality and Vegetation, Wildlife and Fisheries Sections of the
Draft EIS.
7
235
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Page 3
WATER QUALITY IMPACTS;
1. Coliform organisms not only will probably not be eliminated
by an interceptor, but are likely to increase as a result of increased
runoff (pg. 109).
2. How will the percent removal of suspended solids and BOD
of the Renton Treatment Plant be affected by the increased load of
Auburn's waste? If BOD removal efficiency (pg. 110) is high because
of the high sugar content of whey waste as noted by DOE, this removal
will be reduced by increasing the waste load.
3. How does the insignificant benefit in the water quality of the
Green River between Auburn and Renton warrant transporting Auburn's
Waste to the Renton plant? Augmenting low flow conditions in the Green
River with the Auburn discharge may outweigh benefits of discharging
at Renton. The discharge of Auburn's waste at Auburn would have a
significant effect on the flow between Auburn and Renton in the year
2000.
5. With the growth and development that will stimulated by the
Auburn Interceptor additional low flow augmentation at Howard Hansen
Dam seems inevitable. Who will pay for this action? What impacts
will this action have on people outside the sewerage area?
10
Has the possibility of the City of Tacoma increasing diversion I //
from the upper Green River been evaluated? |
lat will stimulated by the
12
6. Urban drainage, in addition to increasing in quantity and
decreasing in quality, will become more significant in relation to
the water quality of the Green River as septic tanks and other point
sources of pollution are eliminated; therefore, this problem should be
addressed further. Detailed regulations to minimize the effects of
urban runoff should be made conditions of the EPA grant.
7. The Draft EIS (pg. 128) states that for design of the secondary
treatment works at Auburn "a high estimate of infiltration/inflow into
the sewerage system was used." Excess capacity of the plant and assoc-
iated interceptors, trunks, etc. increases the cost of this alternative.
Why would the infiltration/inflow rates of this system exceed those
anticipated for the Auburn Interceptor?
In my opinion, the alternative of secondary treatment at Auburn
has not been objectively evaluated. Why, for instance, would a secondary
plant at Auburn achieve less BOD and SS removal than the existing
secondary plant at Renton?
Since low flow augmentation by a modified Howard Hansen Dam will
probably be implemented, the impacts of the alternatives should be
compared under the same augmented flows.
13
IS
236
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Page k
NATURAL VEGETATION, WILDLIFE AMD FISHERIES IMPACT;
1. An alternative alignment avoiding the unique wetland
area south of South 277th Street should be evaluated and measures
outlined to avoid impacting this wetland. A statement (pg. 156)
that "a petroleum pipeline was constructed through this area several
years ago, with no apparent residual effects" is not substantiated
by fact since no study has been made of quantitative effects upon
the wetland. With increased growth and development since the pet-
roleum pipeline installation, the wetland is now more important
to preserve and probably more sensitive to change.
2. Considering the existing water quality problems in
the Duwamish Estuary, mitigation will be crucial to maintaining
the fishery and should be an integral part of any grant approval. It
is my understanding from a conversation with a representative of
the Washington Department of Fisheries that low flow augmentation
has been necessary in the past to flush out the Duwamish Estuary
to protect fish during salmon runs.
I would question the statement (pg. 1^7) that "water quality
impacts on native fishery could be mitigated by increases in
hatchery-produced fish." If the water quality results in the
decrease in the fishery, how are hatchery-produced fish to survive?
Also, who pays for the increased cost of producing fish? Will
the sewerage agency bear the cost and in turn pass it off on the
taxpayer?
17
I?
SUMMARY OF COMMENTS:
1. EPA should present and evaluate the entire sewerage
plan for the Green River Valley prior to deciding upon an alter-
native.
2. Excess interceptor capacity should be identified.
3. Actual cost to the taxpayer for sewerage service should
be presented.
1|. A dynamic alternative should be evaluated which would
allow future generations some choice in wastewater management
and keep costs in phase with growth.
237
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Page
5. Mitigating measures should be made an integral part of
grant approval.
6. Various impacts on Water Quality and Natural Vegatation,
Wildlife and Fisheries need further clarification.
Sincerely yours,
Robert D. Aye, P. E.
cc: Keith W. Dearborn
Barbara Hastings, PSGC
Martin Baker, WEC
238
-------
RESPONSE TO COMMENTS BY
ROBERT D. AYE
1. EPA's draft environmental impact statement has addressed the entire
area which could be served by the proposed action or by any of
several of the alternatives considered. Metro's comprehensive plan,
based on the drainage basin concept to minimize the need for pumping
and to limit point source discharges, was adopted in 1959 and re-
evaluated by Metro in 1968, by the consulting firm of Cornell, How-
land, Hays & Merrifield in 1972, and by RIBCO in 1974.
As found in these re-evaluations, Metro's comprehensive plan still
appears to offer the most satisfactory method of managing water
quality problems in the Green River Sewerage Area. The Auburn
Interceptor is consistent with the comprehensive plan and has been
identified as the focal point for gravity drainage of much of the
sewerage area. Although only a minor segment of the total facilities
which may be necessary if sewer service to the area is provided. The
interceptor does represent a commitment to continue with the
comprehensive plan and, unless new technologies are developed or the
factors affecting growth patterns are significantly altered, it is
probable that future extensions will conform substantially to the
present plan.
Since Metro's comprehensive plan is subject to revision if conditions
change, EPA deems it more appropriate to evaluate future projects
which their need and suitable alternatives can be more clearly identi-
fied.
2. In its entirety, the sentence on p. 105 referring to design projections
is as follows: "Since continued population growth in Puget Sound is not
inconsistent with static or declining national population, the design
projections seem disproportionately ambitious and do not appear to
adequately reflect national demographic trends." In context, this
statement is intended to relate an apparent difference in a local and
and national growth trend, not to identify an erroneous population
projection.
3. These comments are well taken as they do reiterate EPA's concern with
the different sets of population projection figures. As stressed on
page 106, there may be problems with both sets of figures. However,
both PSGC and RIBCO growth projections appear compatible at the year
2000.
4. The error in Table 26 has been corrected to read 1990 rather than 2000.
5. EPA determined that to attempt to quantify the costs of providing
other services, facilities and utilities to future populations in the
valley would be a formidable exercise in terms of time and money and
the end result of which may be questionable. Such a task is also be-
yond the scope of the proposed project and the expertise of the EPA
staff. See item 5 response to the WEC letter.
239
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A cost comparison, based on EPA's Cost Effectiveness Analysis Guide-
lines was made of all of the alternatives planned to meet projected
year 2000 flows. Estimates of current project cost were made for a
year 2030 design interceptor and for upgrading the existing lagoon
system at Auburn with no increase in capacity. A cost effectiveness
analysis was not made for the 2030 interceptor since it was determined
that uncertainties relating to long term growth projections made this
alternative unacceptable; cost effectiveness of the upgrading alterna-
tive was not made since it provided only a temporary solution, with
the probable future solution being provision of an interceptor
facility or treatment plant, similar to those alternatives which were
compared, unless artificial constraints on sewer service are reimposed.
As set forth on p. 78 of the draft EIS, the alternative of a regional
treatment plant at Auburn, with capacity of 35 mgd for the year 2000,
was one of the final configurations developed for the Metro service
area in the RIBCO study. These final configurations resulted from a
screening process applied to a large number of alternative systems
combining various configurations of existing and proposed facilities.
The cost comparison shown on p. 87 of the draft EIS includes estimates
of operation and maintenance costs for a secondary treatment plant at
Auburn and the proportional O&M costs for treatment at Renton.
These estimates, made by Stevens, Thompson & Runyan, Inc., were based
on the same cost curves used in the RIBCO study, adjusted to reflect
the present cost index. Although not shown separately, these costs
include allowance for treatment, sludge handling and sludge disposal,
as described on p. 114 of the RIBCO Main Report. No additional
construction cost would be required for transport of sludge to West
Point, since these facilities are already built.
The Cost Effectiveness Analysis Guidelines define the planning period
used for evaluation as 20 years. The present worth values shown on
p. 87 are for a period of 20 years, as are those shown for the staged
interceptor alternatives. Cost-effectiveness analysis is defined as
"An analysis performed to determine which waste treatment management
system or component part thereof will result in the minimum total
resources costs over time to meet the Federal, State or local require-
ments."
It should be noted, however, that inclusion of these costs for a 20
year planning period does not represent a commitment to continue
present sludge treatment and disposal for that period of time. As
set forth in the draft EIS, facilities planning to be conducted by
Metro will include the identification and evaluation of feasible
alternatives to the present method of sludge handling. .
Appropriate grant conditions will be made to eliminate or reduce ad-
verse impacts. It is our understanding that PSGC and local govern-
ments negotiated a resolution of the land use conflicts. The public
has an opportunity to comment on land-use plans and to elect
officials deciding land-use policies which affect growth and develop-
ment.
240
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8. Whether coliform concentrations increase or decrease will probably
depend on the degree of control instituted for non-point sources which
are thought to be the principal cause of poor bacterial quality in the
Green River.
9. The Rention treatment plant is capable of providing adequate secondary
treatment to Auburn's wastes even if BOD removal efficiencies were to
decrease with the addition of substantial loadings from the Auburn
area and/or the elimination of the whey waste.
10. Augmenting low river flows in the reach between Auburn and Renton with
effluent does not appear to substantially improve the dissolved
oxygen or temperature conditions in the river as discussed on page 129.
Construction and operation of the proposed interceptor is viewed as a
cost-effective solution to the sewerage needs of the area which will
eliminate the discharge of inadequately treated wastes from the
Auburn treatment plant.
11. The possibility of Tacoma's utilizing additional flow from the Green
River is recognized. Even if low-flow augmentation were instituted,
the subsequent re-allocation of water to the City of Tacoma for
municipal water supply could occur. One of the alternative measures
to meet water quality objectives might then have to be implemented by
the Renton plant.
12. Discussion of low flow augmentation has been expanded to clarify the
necessary steps before this action could be implemented. See pages
112 and E-ll.
13. Note revisions on page 120. Detailed regulations to control runoff
have not been made conditions of the EPA grant because such regulations
are the responsibility of local authorities.
14. For the design of both systems, the size of physical components was
based on the estimates of wet-weather infiltration/inflow. However,
for the conditions that would create critical low flows in the Green
River, it was inappropriate to use flow estimates for wet weather.
Instead, values for infiltration/inflow that were thought to be more
representative of the summer drier, months were used. See page 128,
next to last paragraph.
15. The level of treatment provided by the Renton plant surpasses the
secondary treatment requirements for removal of BODS and suspended
solids set by EPA. A secondary treatment plant at Auburn would not,
however, be required to achieve these same high levels.
16. Low flow augmentation by a modified reservoir depends on a number
of factors. See revisions on pages 112 and E-ll.
241
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17. On p. 156 of the draft, relocation of alignment to avoid the wetland
near South 277th Street was discussed as one method of mitigating
construction impacts. Although no apparent residual effects were
identified as a result of previous construction through this area,
EPA will require Metro to relocate this section of the interceptor
to avoid any possible impacts due to construction. This final EIS
has been revised to relect this requirement.
18. It is true that historically, low flow augmentation has been required
to achieve water quality adequate to permit fish passage. Considering
the probability of growth in the Kent-Auburn valley the problem which
you point out can perhaps be solved best by going to a METRO system
with treatment at the tertiary level, or discharge to a larger receiv-
ing water body. Another possibility is for the Department of Ecology
to set a base flow for the Green-Duwamish Rivers adequate to protect
the anadromous fisheries of the system, coupled with a public-financed
project increasing the impoundment capacity upstream from Auburn.
The State of Oregon has in the past 5 years set minimum flows on many
of their rivers requiring flow augmentation for protection of the
anadromous fisheries. Many of these minimum flow protected rivers
now have increased reservoir capacity or have it planned. Future
water rights are subject to curtailment or withdrawal if low flow
augmentation needs are determined by the State Water Resources Board.
A similar system is now being employed on some streams in the State of
Washington by the Department of Ecology. See discussions of low flow
augmentation on pages 109, 129, 156, and E-ll.
If the METRO system for treatment were adopted and low flow water
quality problems in the Duwamish River proved more frequent than in
the years prior to employement of the METRO system, and State water
quality standards were violated near and downstream from the discharge
point, steps would have to be taken to achieve these standards. This
would mean that (1) METRO would have to accelerate plans for
incorporation of tertiary treatment adequate to solve the water
quality problem, or (2) the State of Washington would have to set a
base flow for the Green-Duwamish system and obtain protected impound-
ment capacity adequate to maintain low flow water quality within
standards or (3) a cooperative effort between the Department of
Ecology and METRO would be employed.
If the METRO system were not adopted, waste treatment might be very
haphazard and comparatively uncontrollable as the Kent-Auburn valley
realized its full projected growth. If then a water quality problem
arose, which appears likely considering the low flow volume of the
river, the solution would be a Department of Ecology base flow
coupled with protected increased impoundment or a cooperative effort
between the Department of Ecology and a number of participants. If
the Valley residents want both economic growth and a fishery, the
best means of achieving it is to seek solution of waste problems
through a limited few agencies, and preferably one agency.
242
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19. See page 157. Water quality and seasonal quantity in the Green-
Duwamish under any economically feasible treatment alternative which
allows for full development of the Valley, could result in a decrease
in the fishery. The means of the decrease would be blockage of the
upstream migrants and destruction of redds and the incubating eggs.
The cause would be increased residential, commercial and industrial
development. The blockage would come in the lower Green River or the
Duwamish River and would be due to low flow in turn causing a low
dissolved oxygen and elevated temperature condition.
The impact or effect on native upstream migrating spawners would be
to prevent their timely arrival at the spawning grounds. If arrival
is late, water conditions may be adverse for spawning or the spawn
may not be viable. The relationship between water conditions and
condition of reproductive projects is a very critical one with very
close tolerances.
The destruction of redds and incubating eggs would occur upstream in
the spawning gravel areas of the mainstem and tributaries due to high
uncontrolled flows and siltation. Hatchery fish would be protected
from high flows and to some degree, siltation.
Hatchery produced fish would probably have shorter distances to travel
following removal of the blockage (by a heavy Autumn rain, for example)
and they could be artificially spawned shortly after arrival at the
hatchery. If the blockage is long-term and prevents hatchery-bound
spawners from reaching their goal, thus eliminating that years stock,
eggs or fry could be taken from hatcheries of adjacent basins and
incubated and reared to downstream migrant size at a Green River
system hatchery. They would not be subjected during their early life
history to the Summer low flow Duwamish River water quality problems
that the upstream adult migrants would encounter.
The public would most likely bear the added cost of producing more
hatchery fish--the route is uncertain.
243
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WASHINGTON
Department of
E RI E S
DANIEL J Ev
May 29. 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Thiel:
Your Draft Environmental Impact Statement, for administrative action, on
the Auburn interceptor has been reviewed. This document gives an excellent
presentation of the fisheries resources of the Green River for which we have
concern and responsibility. It does an excellent job of recognizing the
serious potential secondary impacts of growth and development in the valley,
and in discussing means for mitigating water quality degradation and related
fishery losses. We would like to make a few comments for your consideration.
1. Page 26 - Uses; Recent instream uses also have included commercial
fishing by Indians. It is anticipated that future management, based
upon a Federal District Court decision, will continue this usage.
2. Page 51 •• Fisheries; Coho spawning in the Green River and tributary
streams is mentioned. Coho juveniles also rear within most areas
of the watershed throughout the year.
3. Pages 54-55 - Fisheries; The Indian fisheries have become significant
resource users in recent years, and we suggest that mention be made
of this. The 1974 Indian catch from the Duwamish-Green River totaled
13,600 salmon, mostly Chinook and coho.
4. Page 55 - Fisheries - The information requested from the Washington
State Department of Fisheries will be available in our Stream Catalog
which is nearing completion.
5. Page 150 (Table 34) - Impacts on Fisheries; The impacts of water
temperature increase and dissolved oxygen decrease consider upstream
blockage of migrating adult salmonids and related impacts, while the
footnote addresses the impact on the salmon food organisms. These
changes in water quality would also directly affect rearing for coho
and chinook salmon, as well as resident species, which may suffer
direct mortality if conditions become sufficiently severe.
**»•**
244
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Mr. Richard R. Thiel
nay 29, 1975
Pane 2
It is clear that careful planninq throunhout all future developments within
the Green River area will he essential for protection of water quality that will
enable fisheries production to be maintained at its present level. Ue share the
concern of many aqencies and individuals relative to the secondary impact result-
inq from expanded development. Ue are particularly apprehensive about the lower-
inq of water quality in the Duwamish River where past and existinq problems have
occasionally been serious. The excellent consideration of mitiqative measures is
appreciated, and we believe it is imperative that they become an intenral part of
the development of the valley.
l/fiile it is true that water quality impacts on native fish could be mitinated
by increased hatchery production, we believe that this should be considered only
as a last resort. It is conceivable that such artificial production would have to
be released elsewhere if the Duwamish-Green River habitat became sufficient!"
deqraderi. This would he undesirable to this watershed and could possiblv tax
the productivity of the alternate release site.
Thank you for the opportunity to review the Auburn interceptor draft state-
ment. VJe hope that the comments will be helpful to you.
Ray C'. Johr
Actinq Fisheries Environmental
Coordinator
cc: E. S. Dziedzic - Dept. of Game
D. L. Lundblad - Dept. of Ecoloqy
245
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RESPONSE TO COMMENTS BY
STATE OF WASHINGTON DEPARTMENT OF FISHERIES
1. This information has been added to the EIS, see page 51.
2. See pages 54 and 55.
3. See page 55.
4. On p. 50, the Table has been changed to reflect this comment.
246
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410 West Harrison Street, Seattle, Washington 98119 (206) 344-7
May 22, 1975
KING COUNTY
410 West Harrison St.
Seattle, 98119
(206) 344-7330
KITSAP COUNTY
Dial Operator for Toll
Free Number Zenith 8385
Bainbndge Island,
Dial 344-7330
PIERCE COUNTY
213 Hess Building
Tacoma, 98402
(206) 383-5851
SNOHOMISH COUNTY
506 Medical-Dental Bldg
Everett, 98201
(206) 259-0288
Mr. Richard R. Thiel, Chief
Environmental Impact Section - M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Auburn Interceptor (Green River Sewerage Area)
Draft Environmental Impact Statement
Dear Mr. Thiel:
We have reviewed the Draft Environmental Impact Statement prepared
by your Agency for the Auburn Interceptor Proposal, and would like
to make several comments with respect to its air quality aspects.
Existing air quality is discussed in a section beginning on page
39. This section is restricted to a discussion of suspended par-
ticulate. We should like to point out that violations of the photo-
chemical oxidant standard have apparently occurred at the Agency
station in Kent, which is the only oxidant station in the Green
River Valley. Whether or not the problem exists in the Auburn area,
or is related to Green River Valley Sources, or is related to control-
lable air pollution sources at all, is open to question. However,
we believe that there is ample reason to make a further investiga-
tion of this problem, and that the Environmental Protection Agency
should see that an investigation is made to determine whether strat-
egies for oxidant control should be added to the State Air Quality
Implementation plan. The Green River Valley, because of its topo-
graphy, meteorology, and location with respect to the metropolitan
areas, provides a classic set of conditions requisite for an oxi-
dant problem.
A discussion of suspended particulate concentrations, shown by
this Agency's station as exceeding regional standards, is dis-
cussed. The conclusion is drawn that there is an area background
concentration of 28 micrograms per cubic meter. If "background
concentration" means that concentration which would remain after all
known (inventoried) sources were shut down, then the figure appears
to be on the high side. The figure may be a very good current
baseline reading however. There are a number of meanings which have
applied to the term "background concentrations", and it would be
a help if this were explained.
1
BOARD OF DIRECTORS
CHAIRMAN Everett Foster, Alternate for Patrick J Gallagher, Commissioner Pierce County,
Robert C Anderson, Mayor Everett, Glenn K Jarstad, Mayor Bremerton,
Harvey S Poll, Member at Large, John D Spellman, King County Executive,
MAY Z 7 ii,-/'b'
247
VICE CHAIRMAN- N Richard Forsgren, Commissioner Snohomish C<
Gordon N Johnston, Mayor Tacoma, Gene Lobe, Commissioner Kitsap C(
Wes Uhlman, Mayor Seattle, A R Dammkoehler, Air Pollution Control O
-------
Mr. Richard R. Thiel,
May 22, 1975
Page two
The air quality impact section beginning on page 136 and the air
quality impact analysis on Appendix B indicate that the AQDM model
was used to make projections of 1990 suspended particulate concen-
trations, although there was no calibration of that model. We
believe that it is extremely doubtful that any claim for valid
results can be obtained without calibration, which is clearly re-
quired in the procedures for the use of this model as set forth in
the User's Manual. Although the text of the statements says that
there are only two stations for measuring suspended particulate in
the service area, five high-volume air sampling stations can be
spotted in the area shown on figure 14. The three additional stations
are in activity zones 3840, 3820 and 3630. While five stations may
not be as good as fifteen or twenty, they exceed the minimum requirements
for calibration. It is true that the three additional stations are lo-
cated barely outside the sewerage service area, but this sewerage
service area is quite small; in fact it is an excessively small area
to use as a base for projection, which is shown clearly since there
was only a projection of 9.3 micrograms per cubic meter annual geo-
metric mean for 1973 based on that area.
The assumption that there will be no point source increases in the
area prior to 1990, which was made according to the text on page
B-8, does not appear reasonable. Contrary to the text on that page,
there are some large "point emitters" in the Kent area, and even
though this Agency does have the authority to deny a permit to
construct or establish a source that would cause a violation of an
ambient air quality standard, this does not preclude a gradual growth
or increase of point sources in that area.
The mixing depth of 940 meters which was obtained from a publication
by Holzworth, and used in the modeling process, is much too high
to be representative of the Valley, possibly by a factor of 2:1.
Minor changes are necessary as follows:
Page 141, Table 33, Column 1 under 1973: Either change 23.9 to
23.2 or adjust the total to 62.1.
Page B-30, next to last paragraph, the words "Figure B-5" should
be changed to "Figure B-6".
Your conclusion on page B-32 that the air quality situation in the
Auburn Interceptor service area is sensitive to contributions from
sources outside the area, we believe to be correct. Another conclusion
248
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Mr. Richard R. Thiel,
May 22, 1975
Page three
on that page, namely that a growth and development will result in
"marginal" air quality appears to be an understatement. We agree
that the AQDM, or preferably the COM, should be calibrated and
used for air quality maintenance planning as suggested on page
B-52.
Thank you Cor the opportunity to comment on this linv'ironnicntal
Impact Statement.
Yours truly,
A. R. Uammkoehlcr
Air Pollution Control Officer
'- /• • : L. •> i v L
By: .Jajnes R. Pearson
Senior Air Pollution lingineer
ARI):,IRP:et
249
-------
RESPONSE TO COMMENTS BY
PUGET SOUND AIR POLLUTION CONTROL AGENCY
1. See revisions on p. 39.
2. See revisions on p. 39.
3. See page 142.
4. See page B-8.
5. See page 138.
6. Corrections made in the text as noted.
250
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U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
412 Mohawk Building
222 S. W. Morrison St.
Portland, Oregon 97204
May 19, 1975
IN REPLY REFER TO
10ED.3
Dr. Clifford V. Smith
Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
ATTN: Mr. Walt Jasper
Re: DEIS-EPA, Auburn Interceptor
Green River Sewerage Area
King County, Washington
Dear Sir:
The Federal Highway Administration, Region 10, has reviewed the
subject DEIS and wishes to make the following comment:
A brief section should be added discussing the extent of disruption
during construction of the pipeline at its crossing of the major
highway at S. E. 240th, S.R. 516 and S. W. 277th.
Sincerely yours,
...-. _ _„..
nard C. Cowdery, Director
Office of Environment
251
-------
RESPONSE TO COMMENTS BY
THE FEDERAL HIGHWAY ADMINISTRATION
As noted on p. 64 and p. 67 of the EIS, construction in public
right-of-way is subject to permit by the appropriate agency, as well
as provisions of the construction documents. Highway crossings of
SR 167 at SE 240th and of SR 516 are to be jacked, augured, or bored
and are covered by permits issued by the State of Washington Department
of Highways. Crossings of Meeker Street in Kent and South 277th
Street in King County also are to be jacked, augered, and bored. There
will be no disruption during or after construction of these crossings.
Crossings of South 285th and 286th Streets are covered by a King
County permit and are to be in accordance with County standards. In
addition to any other permit conditions required for street crossings
in the Cities of Auburn and Kent, the specifications require that one
way traffic be maintained on all streets during working hours. See
response to the Washington State Highway Commission.
252
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May 15, 1975
Richard R0 Thiel, Chief
Environmental Impact Section
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
The draft environmental impact statement for the proposed Auburn
Interceptor has been reviewed by my staff. We have no comments
regarding this proposal,,
We appreciate having an opportunity to review this statement.
Yours truly,
BERT L. COLE
Commissioner of Public Lands
BLC:wbe
' WAY 1 6
253
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Tacoma - Pierce County Health Department
County-City Building • 930 South Tacoma Avenue
Taroma, Washington 98402 • Telephone 593-¥FW 4760
liar I an 1'. V1rM.it t, M. [X, M. P.M.
Ill rrrt or of Heal I h
May 5, 1975
Richard R. Thiel, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Re: Environmental Impact Statement
Auburn Interceptor
(Green River Sewerage Area)
Dear Mr. Thiel:
We have reviewed the statement.
We would encourage the full plan which would make provision
for serving the North Pierce County area, if the demand arises.
Yours very truly,
R. Clifton Smith, Director
Environmental Health Division
RCS:LCS:tg
254
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GOVERNOR
DANIEL J EVANS
COMMISSIONER:;
JEFF D DOMASKlN
THOMAS C OARRE'T
KAY GREEN
BEN HAYES
RALPH I MACKEY
EUSTACE VYNNE
WILFRED R WOODS
WASHINGTON
DIRECTOR
CHARLES H
ODEGAARD
WASHINGTON SXATE
PARKS & RECREATION COMMISSION
LOCATION THURSTON AIRDUS7RIAL CENTER
P O BOX 1128
April 22, 1975
PHONE 7^3-5755
OLYMPIA, WASHINGTON 98504
IN REPLY REFER TO-
35-2650-1320
Draft EIS -
Auburn Interceptor
(Green River Sewerage
Area) - King County •
EPA Project No.
C-530475-02
Mr. Richard R. Thiel , Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel :
The Washington State Parks and Recreation Commission has reviewed
the above-noted document and does not wish to make any comment.
Thank you for the opportunity to review and comment.
Sincerely,
David W. Heiser, Chief
Environmental Coordination
..
David Hansen, Chief of
Archaeology and Historic
Preservation
sg
25
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Mr. Richard R. Thiel • -2- April 22, 1975
King County Department of Public Works supports proper land use planning
to ensure environmentaly sound use of our land resources. We are also
concerned with existing land usage which may cause environmental damage.
It is our position that construction of the proposed Auburn Interceptor
will solve existing pollution problems, will be compatible with existing
sewer service planning and is a cost effective solution to a serious
pollution problem in the Green River Basin.
Very truly yours,
/'
. L. DeSl^IN, P.E,
Director
JLD/VSS:mr
cc: V. Sparling
256
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King County
State of Washington
John D. Spellman, County Executive
"?-* .
Department of Public Works Rc c D
Jean L. DeSpain, Director ....^ _ ,__
900 King County Administration Building Am 2 3 (13
Seattle, Washington 98104 ^ | ^
EPA --WOQ '
April 22, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section M/S 437
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Sir:
Re: Draft Environmental Impact Statement - Auburn Interceptor
We have reviewed subject document and have the following comments.
The Metro service area (King County) has received national attention for
the success of its regional approach to water quality preservation. More
importantly there is growing evidence of the effectiveness of that approach
in restoring the water quality of our lakes and rivers. It should be
remembered that even with "approved" local solutions to sewage treatment we
were in serious danger of losing Lake Washington and other waterbodies from
eutrophication caused by effluent discharges. Consequently the removal of
the present local treatment facility at Auburn would appear to have a high
potential for contributing to improve water quality in the Green River.
A decision to "do nothing" or preserve the present forms of treatment and
the use of septic tanks can only result in increasing pollution in the area
the Metro trunk will serve. The County is charged with monitoring the use
of septic tanks in most of the service area and is well aware of the high
incidence of failure and effluent leaching that has occurred as the result
of the types of soil prevalent in the area. Since the absence of the proposed
Metro interceptor would not guarantee that further growth would not occur the
County can only conclude that increased pollutional loads will be exerted on
the surface and ground waters within the service area if the Metro trunk is
not constructed.
King County Department of °ublic Works has been a participant and review
agency in comprehensive sewer planning for the entire Auburn-Black Diamond-
Enumclaw area of south King County. This involvement has included the RIBCO
program, Metro's Comprehensive Plan, the County's own plan for the Black Diamond
area and planning by the Cities of Enumclaw and Buckley. The proposed Metro
trunk is an integral part of the planned long range sewer needs of the area.
We believe it to be cost effective and environmentally sound. With completion
of the proposed Metro trunk the County, and other agencies in the area, can
proceed to implement the local facilities needed to mitigate existing pollution
problems.
257
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WASHINGTON STATE
ADVISORY COUNCIL ON HISTORIC PRESERVATION
P. O. BOX 1128, OLYMPIA, WASHINGTON 98504
April 16, 1975
Mr. Roy L. Ellerman, P.E.
Chief, Water Operations Branch
Environmental Protection Agency
1200 6th Avenue
Seattle, Washington 98101
Dear Mr. El lennan:
Thank you for your letter of April 7, 1975, providing the Environmental
Protection Agency's evaluation of potential impact by the Auburn Wastewater
Interceptor on known historic sites in the project area.
We would concur that the construction of the interceptor would have little
direct impact on the nature of the historic properties involved. Indirect
project impact is certainly more difficult to assess although we would
question the reliance on local land use controls - not now in existence
to the knowledge of this office - to mitigate expansion resulting from
the development.
Thank you for the opportunity to consult with you.
Sincerely,
David M. Hansen, Chief
Office of Archaeology and
Historic Preservation
jac
APR 2 4 1975
PRESERVING OUR HERITAGE
258
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*
1
^
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APPEIDIX A
EXCERPTS FROM
WATER QUALITY STANDARDS
OF THE
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
The following excerpts of the State of Washington water
quality standards, dated June 19, 1973, show the numerical criter-
ia and classification which apply to the waters of the Green River
Sewerage Area. Section WAC-173-201-080 is partially included.
The remaining sections, through WAC 173-201-140, are not shown
here.
Under the State-Federal water quality standards of June 19,
1973, the streams and lakes of the Green River Sewerage Area were
classified and criteria established to protect characteristic uses.
The Green River from above Auburn to the Black River conflu-
ence is Class A. But for the Green-Duwamish upstream from the
confluence of the Black River to the limit of tidal influence, a
special condition allows coliform concentrations of Class B
quality. Below the Black River, the Duwamish is Class B. Marine
and freshwater occur in the estuary. Class B criteria for dis-
solved oxygen, pH, and temperature are different for marine and
freshwater, but the criteria for dissolved oxygen for marine water
applies when salinities exceed one part per thousand. Other cri-
teria should be interpolated on the basis of salinity.
A-l
-------
NEW WAC 173-201-010 PURPOSE. The purpose of this chapter is
to establish water quality standards for waters of the state
of Washington pursuant to the provisions of chapter 90.48 RCW
and the policies and purposes thereof.
NEW WAC 173-201-020 WATER USE AND QUALITY CRITERIA. The water
use and quality criteria set forth in sections 030 through 050
are established in conformance with present and potential water
uses of said waters and in consideration of the natural water
quality potential and limitations of the same. Nonetheless,
the dynamic nature of the process is also recognized. Hence,
frequent review of these uses and criteria are anticipated and
revisions will be undertaken as additional information is
developed.
NEW WAC 173-201-030 GENERAL WATER USE AND CRITERIA
CLASSES.The following criteria shall be applicable to the
various classes of.waters in the State of Washington:
(1) jclass AA (Extraordinary) .
(a) General characteristic. Water quality of this class
shall markedly and uniformly exceed the requirements for all
or substantially all uses.
(b) Characteristic uses. Characteristic uses shall
include, but are not limited to the following:
(i) Water supply (domestic, industrial, agricultural).
(ii) Wildlife habitat, stock watering.
(iii) General recreation and aesthetic enjoyment (pic-
nicking, hiking, fishing, swimming, skiing, and boating).
(iv) General marine recreation and navigation.
(v) Fish and shellfish reproduction, rearing, and har-
vest.
(c) Water quality criteria.
(i) Total coliform organisms shall not exceed median
values of 50(fresh water) or 70(marine water) with less than
10% of samples exceeding 230 when associated with any fecal
source.
(ii) Dissolved oxygen shall exceed 9.5 mg/1 (fresh
water) or 7.0 mg/1(marine water).
(iii) Total dissolved gas - the concentration of total
dissolved gas shall not exceed 110% of saturation at any point
of sample collection.
(iv) Temperature - water temperatures shall not exceed
60* F. (fresh water)or 55" F. (marine water) due in part to
measurable (0.5° F.) increases resulting from human activities;
nor shall such temperature increases, at any time, exceed
t - 75/{T-22) (fresh water) or t - 24/(T-39) (marine water)?
for purposes hereof "t" represents the permissive increase and
"T" represents the water temperature due to all causes combined.
(v) pH shall be within the range of 6.5 to 8.5 (fresh
water) or /To to 8.5 (marine water) with an induced variation
of less than 0.1 units.
(vi) Turbidity shall not exceed 5 JTU over natural
conditions.
(vii) Toxic, radioactive, or deleterious material
concentrations shall be less than those which may affect
public health, the natural aquatic environment, or the desir-
ability of the water for any usage.
(viii) Aesthetic values shall not be impaired by the
presence of materials or their effects, excluding those of
natural origin, which offend the senses of sight, smell, touch
A-2
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or taste..
(Jf) Class A (Excellent).
(a) General characteristic. Water quality of this class
shall meet or exceed the requirements for all or substantially
all uses.
(b) Characteristic uses. Characteristic uses shall
include, but are not limited to, the following:
(i) Water supply (domestic, industrial, agricultural).
(ii) Wildlife habitat, stock watering.
(iii) General recreation and aesthetic enjoyment (pic-
nicking, hiking, fishing, swimming, skiing and boating).
(iv) Commerce and navigation.
(v) Fish and shellfish reproduction, rearing and harvest.
(c) Water quality criteria.
(i) Total coliform organisms shall not exceed median
value of 24~5(fresh water) with less than 20% of samples
exceeding 1,000 when associated with any fecal sources or 70
(marine water) with less than 10% of samples exceeding 230
when associated with any fecal sources.
(ii) Dissolved oxygen shall exceed 8.0 mg/1 (fresh
water) or 6.0 mg/1(marine water).
(iii) Total dissolved gas - the concentration of total
dissolved gas shall not exceed 110% of saturation at any point
of sample collection.
(iv) Temperature - Water temperatures shall not exceed
65*~'F. (fresh water)1 or 61° F. (marine water) due in part to
measurable (0.5° F.) increases resulting from human activities;
nor shall such temperature increases, at any time, exceed t =
90/(T-19) (fresh water) or t » 40/(T-35) (marine water); for
purposes hereof "t" represents the permissive increase and "T"
represents the water temperature due to all causes combined.
(v) pH shall be within the range of 6.5 to 8.5 (fresh
water) or 7.0 to 8.5 (marine water) with an induced variation
of less than 0.25 units.
(vi) Turbidity shall not exceed 5 JTU over natural con-
ditions.
(vii) Toxic, radioactive, or deleterious material
concentrations shall be below those of public health signifi-
cance, or which may cause acute or chronic toxic conditions
to the aquatic biota, or which may adversely affect any water
use.
(viii) Aesthetic values shall not be impaired by the
presence of materials or their effects, excluding those of
natural origin, which offend the senses of sight, smell, touch,
or taste.
<3) Class B (Good)
(a). General characteristic. Water quality of this class
shall meet or exceed the requirements for most uses.
(b) Characteristic uses. Characteristic uses shall
include, but are not limited to, the following:
(i) Industrial and agricultural water supply.
(ii) Fishery and wildlife habitat.
(iii) General recreation and aesthetic enjoyment (pic-
nicking, hiking, fishing, and boating).
(iv) Stock watering.
(v) Commerce and navigation.
(vi) Shellfish reproduction and rearing, and Crustacea
(crabs, shrimp, etc.) harvest.
(c) Water quality criteria.
(i) Total coliform organisms shall not exceed median
values of 1,000 with less than 10% of samples exceeding 2,400
when associated with any fecal source.
A-3
-------
(ii) Dissolved oxygen shall exceed 6.5 mg/1 (fresh
water) or 5.0 mg/1 (marine water) , or 70% saturation, which-
ever is greater. ;,;,:•„, :;->
(iii) Total dissolved ;!f*a,j* --thia (forieattfurat'&n of total
«**i :i¥Of*"-oC" *»tur«tid* at any
on »;-'•• i~ -..».>•>.•'- ^- --•.•. :;*.;:;:
(iv) Temperature - water temperatures shall ;not Exceed
iss-^'ff^ifiPSSiiriF^r 66 * , F . toja'rfyia .nr &^»r t dtie; in part to
measurabla/^0.; £4 •# . pflncPgases resulting from 'hunS&iV Captivities ;
sueti '1serapei?atSr«' f increases , at any -time, exceed t »
110/(T-15) (fresfc wa'tfr) 'or t - -5^/(T-32r > (marine water) ; for
ptfifpb*'Ss hereof "t" -re^ifeS'ent's "e»«f pernii'ssive 'increase and "T"
•r'ep¥es%rits; €he ; water > t"«M^era«ure Oue to all steause« 'cbmteined .
(v) pH shall be-1»i^hlhvtoe range "of 6.-5 to 8.5 (fresh
ii&&trf."'-6frfF?0 'ttf WiS'Hmfirlhe^vater)' wl*» an* 'induced variation
of less than 0.5 units .«""« ;J ;- Y-I'MT -„,.-? K ...r.
r. 31-1 fc:.,. -'' natural
delietferibug
ghall:':be ¥eloV ^tlfoaW wivlcfh adversely
public health durirtg^ -1th¥ e*B*ci*elKof -chafacteristic usa'ges,
'
'Or wWich may cauStf ::*5Ute' 'oF dirortlc. jtoxic conditions to the
aquatic biota, or which ' -rta^'adV'cfSe'iy affect character i'stic
' ' ' " ' ' "
.
!!;rg v ,s • -(vf i'^y - 'Ag^theti-c Valuea shall not be reduced by dissolved,
suspended, floating or submerged matter not attributable to
v riatur'al' cfauses, rfo'ds;^^ affect watt«r usage or taint the flesh
' -' o*" edible s'pefci'e's . ••-•-E^. •-,-.••, • t
' ' - fi) ' ciAss --C"
JSerie'ra-l^ characteristic. Water quality of this
class tfhal4j ftteet of' exceed the requirements of selected and
essenti'al" uses. "••'••"• • * '•" --• •"• • "• . '
(b) Characteristic uses. Characteristic uses shall
include, but: are: 'not -limited to, the following:
'(i) Cooling water.
(ii) Commerce and navigation.' , ? <
(iii) Fi'sh passage.
(iv) Boating.
-------
which may cause acute or chronic toxic conditions to the aqua-
tic biota, or which may adversely affect characteristic water
uses.
(viii) Aesthetic valuea shall not b« interfered with
by the presence of obnoxious wastes, »lime«, or aquatic
growths or by materials which will taint the flesh of edible
species
C5) Lake Class.
fa) General characteristic. Water quality of this class
shall meet or exceed the requirements for all or substantially
all uses.
(b) Characteristic uses. Characteristic uses for waters
of this class shall include, but are not limited to, the
following:
(i) Water supply (domestic, industrial, agricultural)
(ii) Wildlife habitat, stock watering.
(iii) General recreation and aesthetic enjoyment (pic-
nicking, hiking, fishing, swimming, skiing, and boating).
(iv) Fish and shellfish reproduction, rearing, and harvest.
(c) Water quality criteria.
(i) Total cpliform organisms shall not exceed median
values of 240 with less than 20% of samples exceeding 1,000
when associated with any fecal source.
(ii) Dissolved oxygen - no measurable decrease from
natural conditions.
(iii) Total dissolved gas - the concentration of total
dissolved gas shall not exceed 110% of saturation at any point
of sample collection.
(iv) Temperature - no measurable change from natural
conditions.
(v) pH - no measurable change from natural conditions.
(vi) Turbidity shall not exceed 5 JTU over natural con-
ditions.
(vii) Toxic, radioactive, or deleterious material
concentrations shall be less than those which may affect public
health, the natural aquatic environment, or the desirability of
the water for any usage.
(viii) Aesthetic values shall not be impaired by the
presence of materials or their effects, excluding those of
natural origin, which offend the senses of sight, smell, touch,
or taste.
NEW WAC 173-201-040 GENERAL CONSIDERATIONS. The follow-
ing general guidelines shall be applicable to the water quality
criteria and classifications set forth in WAC 173-201-020
through WAC 173-201-080 hereof:
(1) At the boundary between waters of different classi-
fications, the water quality criteria for the higher classifi-
cation shall prevail.
(2) In brackish waters of estuaries, where the fresh and
marine water quality criteria differ within the same classifi-
cation, the criteria shall be interpolated on the basis of
salinity except that the marine water quality criteria shall
apply for dissolved oxygen when the salinity is one (1) part
per thousand or greater and for total coliform organisms
when the salinity is ten (10) parts per thousand or greater.
(3) Except for the aesthetic values and acute biological
shock conditions the water quality criteria herein established
shall not apply:
(a) Within immediate mixing zones of a very limited size
adjacent to or surrounding a wastewater discharge;
A-5
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(b) In the case of total dissolved gas, when the stream
flow exceeds the 10-year, 7-day average flood;
(c) In a manner contrary to the applicable conditions of
a valid discharge permit.
(4) The total area and/or volume of a receiving water
assigned to a mixing zone shall be as described in a valid
discharge permit and limited to that which will: (a) not
interfere with biological communities or populations of impor-
tant species to a degree which is damaging to the ecosystem;
(b) not diminish other beneficial uses disproportionately.
(5) The criteria established in WAC 173-201-030 through.,
WAC 173-201-050 for any of the various classifications of this
'regulation may be modified by the director for limited periods
when receiving waters fall below their assigned water^quality
criteria due to_naftural causes or if in the opinion of the
director the protection of the overall public interest and'
welfare requires such modification. ?
(6) Except where the director determines that overriding
considerations of the public interest will be served, wherever
receiving waters of a classified area are of a higher quality
than the criteria assigned for said area, the existing water
quality shall constitute water quality criteria.
(7) Whenever the natural conditions are of a lower qual-
ity than the criteria assigned, the natural conditions shall
constitute the water quality criteria.
(8) Due consideration will be given to the precision
and accuracy of tho sampling and analytical methods used in the
application of the criteria.
(9) The analytical testing methods for these criteria
shall be in accordance with the most recent editions of
Standard Methods for the Examination of Water and Waste Water,
and Methods for Chemical Analysis of Water and Wastes (EPA
16020) , and other or superceding methods published or approved
by the department following consultation with adjacent states
and concurrence of the Environmental Protection Agency.
(10) Deleterious concentrations of radioactive materials
for all classes shall be as determined by the lowest practicable
concentration attainable and in no case exceed: (a) 1/3 of the
values listed in WAC 402-24-220 (Column 2, Table II, Appendix
A, Rules and Regulations for Radiation Protection) , or (b) the
1962 U.S. Public Health Service Drinking Water Standards as
revised, or (c) the Radiation Protection Guides for maximum
exposure of critical human organs recommended by the former
Federal Radiation Council in the case of foodstuffs harvested
from waters for human consumption.
(11) Deleterious concentrations of toxic, or other non-
radioactive materials shall be as determined by the department
in consideration of the Report of the National Technical Advi-
sory Committee on Water Quality Criteria, 1968, and as revised,
and/or other relevant information.
A-6
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NEW
WAC 173-201-050
-CHARACTERISTIC USES TO BE PROTEC-
TED. The following is a noninclusive list of uses to be pro-
tected by the various classifications in fresh and marine
waters:
USES
WATERCOURSE CLASSIFICATION
LAKE AA A B C
FISHERIES
Salmonid
Migration F FM F M FM FM
Rearing F F M F M F M
Spawning F F F
Warm Water Game Fish
Rearing F F F F
Spawning F F F F
Other Food Fish F F M F M F M
Commercial Fishing F F M F M F M
Shellfish F M M M
WILDLIFE F F M F M F M
RECREATION
Water Contact F F M F M
Boating and Fishing F FM FM FM FM
Environmental
Aesthetics F FM FM FM FM
WATER SUPPLY
Domestic F F F
Industrial F FM FM FM FM
Agricultural F F F F F
NAVIGATION F FM FM FM FM
LOG STORAGE & RAFTING F FM FM FM FM
HYDRO-POWER F F F F F
NEW WAC 173-201-060 WATER COURSE CLASSIFICATION. The
various waters of the State of Washington are classified as
follows, except as noted herein:
NEW
WAC 173-201-070
-GENERAL CLASSIFICATIONS. (1) All
surface waterslying within the mountainous regions of the state
assigned to national parks, national forests, and/or wilderness
areas, are hereby designated Class AA or Lake Class.
(2) All lakes and their feeder streams within the state
are hereby designated Lake Class and Class AA respectively.
(3) All reservoirs with a mean detention time of greater
than 15 days are classified Lake Class.
(4) All reservoirs with a mean detention time of 15 days
or less are classified the same as the river section in which
they are located.
(5) All reservoirs established on preexisting lakes are
classified as Lake Class.
(6) All other waters within the state are hereby desig-
nated Class A.
NEW WAC 173-201-080 SPECIFIC CLASSIFICATIONS. Various
specific waters of the State of Washington are classified as
follows:
A-7
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Coulee Dam (river mile 595). Special condition
from Washington-Oregon border (river mile 309)
to Priest Rapids Dam (river mile 397) . Temperature -
water temperatures shall not exceed 68° F. due in
part to measurable (0.5* F.) increases resulting from
human activities; nor shall such tomperaturo increase?*,
at any time, exceed t ™ 110/{T-15)j for purposes
hTfnf, "t" represents the permissive increase and
"T" represents the water temperature due to all
causes combined.
(25) Columbia River from Grand Coulee Dam Class AA
(river mile 595) to Canadian border (river mile
742).
(26) Colville River. Class A
(27) Commencement Bay from south and east Class A
of a line bearing 258° true from "Brown's Point"
and north and west of a line bearing 225° true
through the Hylebos Waterway light. Special
condition - total coliform organisms snail not
exceed median values of 1,000 with less than 20%
of samples exceeding 2,400 when associated with
any fecal source.
(28) Commencement Bay inner, from south and Class B
east of a line bearing 225° true through the
Hylebos Waterway light except the city water-
way south and east of south llth street.
(29) Commencement Bay, city waterway south Class C
and east of south llth street.
(30) Coweeman River from mouth to Mul- Class A
holland Creek.
(31) Coweeman River from Mulholland Creek Class AA
to headwaters.
(32) Crab Creek and tributary streams Class B
from confluence with Columbia River to head-
waters .
Decker Creek from mouth to head-
Deschutes River from mouth to head-
Dickey River.
Dosewallips River and tributaries.
Drayton Harbor, south of entrance.
Duckabush River and tributaries.
Dungeness River from mouth to Canyon
(33)
waters.
(34)
waters.
(35)
(36)
(37)
(38)
(39)
Creek.
(40) Dungeness River and tributaries from
Canyon Creek to headwaters.
(41) Duwamish River from mouth south of a
line bearing 254° true from the NW corner of
berth 3, terminal no. 37 to the confluence with
the Black River (Tukwila).
(42) Duwamish River upstream from the con-
fluence with the Black River to the limit of tidal
influence. Special condition - total coliform
organisms shall not exceed median values of
1,000 with less than 20% of samples exceeding
2,400 when associated with any fecal source.
(43) Dyes and Sinclair Inlets west of
longitude 122°37' W. Special conditions -
Sinclair Inlet and Port Washington Narrows
West of longitude 122°37' W. and south of lati-
tude 47°35'20" N. Total coliform organisms -
shall not exceed median values of 1,000 with less
Class A/i
Class A
Class A
Class AA
Class A
Class AA
Class A
Class AA
Class B
Class A
Class A
A-8
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(61) Hoquiam River from mouth to river Class B
mile 9.
(62) Issaquah Creek from mouth to head- Class A
waters.
(63) Kalama River from lower Kalama Class AA
River Falls to headwaters.
(64) Klickitat River from Little Class AA
Klickitat River to headwaters.
(65) Lake Washington Ship Canal from Lake Class
Lake Washington to Government Locks. Special
condition - salinity shall not exceed one part
per thousand (1.0 ppt) at any point or depth
along a line that transects the ship canal at
the University Bridge.
(66) Lewis River east fork, from Multon
Falls to headwaters.
(67) Little Wenatchee River from Lake
Wenatchee to headwaters.
(68) Methow River from Okanogan National
Forest boundary to headwaters.
(69) Mill Creek from confluence with
Walla Walla River to 13th street bridge in Walla
Walla. Special condition - dissolved oxygen
concentration shall exceed 5.0 mg/1 or 50% satu-
ration whichever is greater.
(70) Mill Creek from City of Walla Walla
waterworks dam to headwaters. Special condition -
no waste discharge will be permitted.
(71) Naches River from Snoqualroie National
Forest boundary to headwaters.
(72) Naselle River from Naselle Falls to
headwaters.
(73)
waters.
(74)
headwaters.
(75) Nooksack River from mouth to river
mile 4 (just below Ferndale) . Special condi-
tion - total colifpnn organisms - shall not
exceed a median value of 240 with less than 20%
of samples exceeding 1,000 when associated with
any fecal source.
(76) Nooksack River from confluence with Class AA
Maple Creek to headwaters.
(77) Nooksack River, south fork, from class AA
Skookum Creek to headwaters.
(78) Nooksack River, middle fork. Class AA
(79) Oakland Bay west of longitude 123* Class B
05' W. (inner Shelton harbor).
(80) Okanogan River from mouth to Oro- Class B
ville (river mile 80, confluence with Simil-
kameen River).
(81) Palouse River from mouth to Colfax Class B
(river mile 88, confluence with south fork).
(82) Palouse River from Colfax (river Class A
mile 88, confluence with south fork) to Idaho
border (river mile 110) . Special condition -
Temperature - water temperatures shall not
exceed 68° F. due in part to measurable (0.5* F.)
increases resulting from human activities; nor
shall such temperature increases, at any time,
exceed t - 110/{T-15); for purposes hereof,, "t"
Newaukum River from mouth to head-
Nisqually River from Alder Dam to
Class AA
Class AA
Class AA
Class B
Class AA
Class AA
Class AA
Class A
Class AA
Class A
A-9
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APPENDIX B
AUBURN INTERCEPTOR SERVICE AREA
AIR QUALITY IMPACT ANALYSIS
Prepared for:
Environmental Protection Agency Region X
1200 Sixth Avenue .
Seattle, Washington 98101^
by
Resource Management Department
Environmental Studies Center
Research Triangle Institute
P.O. Box 12194
Research Triangle Park
North Carolina 27711
March 1975
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TABLE OF CONTENTS
LIST OF FIGURES
LIST OF TABLES
Section 1:
1.1
1.2
1.3
Section 2:
2.1
2.2
Section 3:
Section 4:
4.1
4.2
4.3
Section 5:
5.1
5.2
References
Supplement 1
Supplement 2
Supplement 3
INTRODUCTION
Background
Basic Assumptions
Methodology
POINT SOURCE EMISSION INVENTORY
1973 Inventory
1990 Inventory
AREA SOURCE EMISSION INVENTORY
AIR QUALITY MODELING
AQDM
Input Data
4.2.1 Meteorological
4.2.2 Emissions
AQDM Analysis
4.3.1 Current Conditions
4.3.2 Projected Conditions
4.3.3 Impact on Seattle and Tacoma
CONCLUSIONS AND RECOMMENDATIONS
General
Conclusions and Recommendations
Page
B-4
B-4
B-5
B-5
B-6
B-8
B-ll
B-ll
B-ll
B-13
B-15
B-15
B-16
B-16
B-17
B-19
B-19
B-20
B-23
B-27
B-27
B-28
B-33
B-l-1
B-2-1
B-3-1
-------
LIST OF FIGURES Page
Figure B-l: Auburn Interceptor Service Area B-7
Figure B-2: Air Quality Analysis Procedures B-9
Figure B-3: Contributions to 1973 Suspended Particulate
Ambient Air Concentrations from Sources
within the Auburn Interceptor
Service Area B-21
Figure B-4: Suspended Particulates, 1973 Annual
Geometric Means B-22
Figure B-5: Projected 1990 Isopleths, Suspended
Particulate Geometric Means 13-24
Figure B-6: Estimated 1990 Second Highest Daily
Average at Auburn B-31
LIST OF TABLES
Table B-l: Point Source Inventory, Auburn
Interceptor Service Area B-l2
Table B-2: Area Source Emission Inventory, 1973
and 1990 B-l 4
Table B-3: SEATAC - Tukwila Stability Wind Rose B-18
Table B-4: Contributions & Growth in Auburn Inter-
ceptor Service Area on Particulate
Concentrations in Seattle and Tacoma B-25
B-4
-------
I . INTRODUCTION
1.1 BACKGROUND
The construction of the Auburn Interceptor represents implementation
of a proposed element of Municipality of Metropolitan Seattle (Metro)
Comprehensive Plan and is a portion of the second phase of the ultimate
development of an areawide waste water treatment system serving the
total sewerage needs of the Green River Sewerage Area and a portion of
the White River Watershed.
The proposed Interceptor will be a 42- to 72-inch reinforced concrete
pipe totaling 7.1 miles in length. The pipe will commence-at the influent
structure of the existing City of Auburn sewage lagoon and connect with
the existing Metro-Kent Cross Valley Interceptor.
The sewerage area to be served by the Interceptor encompasses the
Green River Sewerage Area and a portion of the White River Watershed. In-
cluded within this area is all of the Lower Green River Valley in the vicinity
of the cities of Kent, Auburn, Algona and Pacific, and Des Moines Plateau
(West Hill) to the west. The area to be served by the Interceptor in the
White River Watershed lies north of Lake Tapps and within both King and
Pierce Counties.
Upland plateaus incised by the valley trough and flood plain of the
Green River are the principal topographic features of the sewerage area.
The ascent to the upland areas is abrupt with differences in elevation
between the river bottom and the plateau in excess of 300 feet. The uplands
present a rolling glacial relief characterized by depressions and hummocks
in which stream courses and drainage patterns are often poorly defined.
Numerous local basins and depressions of retarded drainage are occupied
by small lakes and swampy areas and bogs. The Green River is artificially
controlled by an upstream dam and man-made levees, that parallel the stream
throughout most of its length within the sewerage area.
B-5
-------
In addition to its diverse topography, the sewerage area is char-
acterized by a variety of land uses: agriculture and sharply contrasting
industrial development in the Green River Valley, with retail, commercial
and residential uses in the cities and towns; and forestry, mining, open
space, recreation, and scattered rural residential and farming uses on
the eastern uplands. Recent photogrammetric interpretations of the sewerage
area reveal the following land use allocations: woodland, 37,700 acres
(40 percent); suburban land, including low-density residential, recreational-
home, and neighborhood commercial areas, 15,780 acres (17 percent); agri-
cultural land, 9,030 acres (10 percent); open and vacant land, 8,720 acres,
(9 percent); high-density residential and commercial areas, 6,300 acres
(7 percent); transportation corridors including railroad yards and freeways,
5,890 acres (6 percent); transmission line utility corridors, 4,140 acres
(4 percent); industrial areas, 1,140 acres (1 percent); and recreational
areas, 410 acres (.1 percent). The acreage designated as commercial
probably includes some light industrial and warehousing establishments.
The Green River Valley Area and the Auburn Interceptor Service Area
(AISA) are shown in Figure B-l.
1.2 BASIC ASSUMPTIONS
Two fundamental policy decisions were made at the outset of the
analysis in order to reduce the magnitude of the task to manageable pro-
portions. First, the year 1990 was selected as the target year for the
analysis, even though the interceptor was sized according to a projection
to the year 2000. This was done since it is not possible to project the
nature of efficiency of air pollution control technology twenty-five years
in advance; even a projection to 1990 is fraught with uncertainty. The
same may be said about land use, population, and motor vehicle travel pro-
jections as well. While errors in sewage capacity projections can be com-
pensated for through a variety of means such as the construction of additional
treatment facilities, or the under-utilization of installed capacity, the over-
all precision of the air quality analysis is crucial since the projected air
quality is related to a fixed, finite air quality standard. Therefore, it
B-6
-------
Auburn Interceptor Service A
Green Valley Sewerage
Figure B-l. Auburn Interceptor Service Area
B-7
-------
was not considered meaningful to attempt to project air quality in
the year 2000. In addition, the Puget Sound Governmental Conference
(PSGC) has made its most detailed projections of population, employment,
and motor vehicle activity up to the year 1990. If this resource was
to be utilized at all, 1990 would have to be the target year.
The second decision was that sources large enough to be considered
point sources would not be projected. Data currently available from the
PSGC do not permit projecting the type and size of point sources that
may locate in the AISA. Additionally, control technology that would be
used by the industry that would locate in the area cannot oe identified
at this time.
Existing point sources in the service area as well as other areas
were included in the emission inventory used in this air quality study.
However, without any definitive information on the expected emission
growth or emission configuration the same emissions were used both in the
1973 and 1990 projections of air quality. As can be seen in the results
sections (Figure B-5 and page B-l-20), the large point emitters in the
Kent and Renton areas do not significantly affect air quality within the
service area. In addition, as can be seen on page B-l-20, the point
sources within the Auburn area contribute collectively less than 2%
to the TSP levels within and outside of the service area. Therefore
the assumption of not projecting growth of point sources, while not
completely realistic, will not significantly affect the results since
even a twofold increase in emissions from those sources within the
service area would contribute less than 4% to the overall TSP levels.
However, should any major point source locate in the AISA, it will be
subject to new source review procedures under PSAPCA Regulation I.
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CD
I
1973 AIR
QUALITY DATA
AUBURN ARE;
1973 EMISSION
INVENTORY,
KING COUNTY
1970-1975
POPULATION/
EMPLOYMENT,
KING COUNTY
1990
POPULATION/
EMPLOYMENT.
AUBURN ARE/
DEVELOP 1973:
POPULATION/
EMPLOYMENT
rniiNTY
DEVELOP
EMISSION
FACTORS,
KING COUNTY
DEVELOP 1973
EMISSION
INVENTORY,
AUBURN AREA
DETERMINE/
1973 AIR /
.QUALITY,/
AUBURN /
DETERMINE
CONTRIBUTION
FROM OUTSIDE
AUBURN AREA
DEVELOP 1990
EMISSION
INVENTORY,
AUBURN AREA
\ DETERMINE*/
\1990 AIR
"^QUALITY,/
\ AUBURN/
DETERMINE
A EMISSIONS
1973-1990,
AUBURN AREA
V
DETERMINE*/
.^IMPACT ON
^SEATTLE//
,TACOMA;
= AQDM
Fig.B-2. Air Quality Analysis Procedures.
* Projections are made using an uncalibrated AQDM. While the use of a calibrated AQDM is
desirable, requisite air quality data for calibration are not available for the area under
-------
Under these programs any proposed source anticipated to cause a
violation of an existing air quality standard may be denied a permit
to construct.^ Thus, the emission projection and subsequent air quality
analysis are concerned with the impact of increased emissions due to
area sources of particulate matter. These sources include residential,
commercial, and small industrial space heating units; motor vehicle
particulate emissions; railroad emissions; fugitive dust (due to travel
on dirt roads, construction activity, and structural fires); incinera-
tion; open burning; and off-highway vehicle emissions.
1.3 METHODOLOGY
An overview of the methodology used in projecting the impact of
growth and development in the AISA on air quality is shown in Figure B-2.
Development of the 1973 and 1990 point source emission inventories is
Section 3, and the determination of impact of growth and development on
air quality in Section 4. Conclusions and recommendations are presented
in Section 5.
The analysis described here is the projection of the probable air
quality impact due to growth and urbanization in the proposed service
area of the Auburn Interceptor. Air quality impacts are determined for
the service area, and the Tacoma and Seattle areas.
-------
2. POINT SOURCE EMISSION INVENTORY
2.1 1973 INVENTORY
King County 1973 emission inventories provided by Region X,
Environmental Protection Agency, and PSAPCA were used as the basis for
developing the 1973 emission inventory for the AISA. These inventories
represent up-dated PSAPCA inventories and are considered to be the most
current information available.
The point source emission inventory for the AISA includes all
point sources located within the Green River Valley Sewerage area.
Some of these sources, those in the Renton area, are outside of the
area to be served by the new interceptor. They, however, are located
in the Green Valley Sewerage Area and may make a significant contri-
bution to the ambient particulate concentration in the Auburn area.
Point sources within the area under analyses were identified by
plotting the interceptor area boundaries on a U.S. Geological Survey
Map, scale 1: 24,000, and locating the sources by their UTM coordinates.
Other data required for AQDM (stack parameters and 1973 emissions)
were extracted from the PSAPCA-King County inventory provided by
Region X. The emission inventory developed by this procedure is
summarized in Table B-l.
2.2 1990 INVENTORY
As stated in Section 1.2, a basic assumption underlying this analysis
is that point sources would not be projected to 1990. Therefore, the
1973 point source inventory is used for making 1990 air quality projections,
It is not anticipated that major emitters will be located in the AISA.
Air quality impact of those that do will be evaluated through new
source review procedures required by PSAPCA Regulation I.
B-ll
-------
TABLE B-l. POINT SOURCE INVENTORY, AUBURN INTERCEPTOR SERVICE AREA
SOURCE
NUMBER
1
2
3
4
5
6
7
8
9
10
11
' o
1 L.
13
14
15
16
17
18
19
20
NAME
Boeing
Northwest Steel Rolling Mills
Washington Asphalt No. 34
Boeing
National Can Corp.
Associated Sand and Gravel #9
Associated Sand and Gravel #10
Associated Sand and Gravel #11
Howard Manufacturing Co.
Container Corp.
General Services Administration
Sternoff Metals
Segale, M.A.
Interpace Corp.
Black River Quarry
Auburn Packing
Fiorito Bros. Inc.
Burlington N.R.R. Switchyard
Segale, M.A.
Miles Sand and Gravel Co.
City
Auburn
Kent
Kent
Kent
Kent
Tukwila
Auburn
Auburn
Kent
Renton
Auburn
Renton
Kent
Renton
Seattle
Auburn
Auburn
Auburn
Auburn
Auburn
LOCATION
UT
Easting
558.0
558.4
564.4
570.0
557.9
555.7
560.4
553.0
557.5
557.0
558.5
557.6
556.0
560.6
556.5
562.4
555.7
557.5
560.5
559.6
M
Northing
5238.0
5250.3
5242.1
5249.0
5249.3
5253.7
5236.8
5247.5
5248. 2
5258.0
5238.5
5254.5
5254.0
5258.5
5258.3
5238.5
5234.7
5237.5
5235.4
5238.3
EMISSIONS
tons/^r .
10.5
92.8
116.2
4.0
1.0
2l'.8
4.2
1.3
8.1
0.7
1.6
55.1
84.0
7.9
191.0
2.0
20.0
3.3
9.0
14.8
Height
:n
13.1
12.2
6.1
14.0
9.1
12.2
6.1
7.6
18.3
15.2
15.2
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
STACK DAI
Diameter
m
0.9
1.4
1.2
1.2
0.5
3.0
0.5
1.5
0.9
0.6
0.9
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
"A*
Velocity
m
68.9
35.9
19.8
n.a.
9.4
25.5
10.9
9.4
n.a.
2.4
4.8
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
n.a.
Temperature
°K
422.
464.
355.
505.
422.
422.
422.
394.
422.
422.
422.
284.
284.
284.
284.
339.
n.a.
n.a.
n.a.
n.a.
*n.a.= Stack data not available
-------
3. AREA SOURCE EMISSION INVENTORY
Area source emission inventories for 1973 and 1990 were developed
by the Planning Environment International Division of Alan M. Voorhees
& Assoc. Inc., (AMV) under subcontract to RTI.
King County area emission inventory and PSGC indexes for activity
allocation data were used to allocate area emissions to sub areas within
the AISA. The following steps were involved:
• Select the index most appropriate for each emission source
category.
• Calculate baseyear emission factors from index totals for
King County.
• Allocate 1973 emissions on the basis of PSGC index allocations
for the zones within the sewerage area.
• Calculate emission factor reductions due to implementation
of known control regulations by 1990 (open burning and
residential incineration prohibited, and catalytic con-
verters used on all automobiles).
• Compute 1990 emission factors.
• Compute 1990 zonal emissions on the basis of PSGC
projected index allocations.
Detailed procedures used in the development of area source emission
inventories shown in Table B-2 are given in Appendix C.
B-13
-------
TABLE B-2. AREA SOURCE EMISSION INVENTORY, 1973 and 1990
AAM1
Zone
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
Total
2
UTM Coordinates
X
563.5
555.2
555.4
555.7
557.9
561.9
565.8
561.5
558.4
561.9
570.9
570.2
558.4
562.0
565.6
566.4
561.4
557.4
562.8
562.0
Y
5,232.8
5,236.8
5,241.4
5,244.8
5,236.5
5,235.1
5,238.6
5,237.7
5,242.0
5,243.6
5,240.6
5,245.7
5,245.5
5,246.9
5,246.1
5,251.1
5,249.9
5,249.1
5,253.1
5,255.3
Service
Land Area
(acres)
4,689
2,747
2,254
3,407
3,993
3,042
15,832
1,964
4,730
2,700
12,017
8,516
2,075
1,079
5,730
7,455
1,292
327
2,138
554
86,541
1973
Emissions
(tons/year)
27.46
39.25
33.35
42.04
177. Ol3
22.15
108.49
25.57
118. 183
36.43
67.61
49.29
55. 463
21.38
48.89
59.22
20.86
29.96
41.20
7.27
1,031.07
1990
Emissions
Ltons/year)
35.11
47.73
40.05
45.69
274. 583
32.52
110.59
27.06
132.823
43.90
71.09
44.45
74. 513
26.28
57.83
66.82
26.71
33.89
51.03
7.50
1,250.16
Activity allocation model sub areas within King County designated by PSGC.
?
"Centroid location of the AAM zone.
Includes contribution due to railroad activity.
B-14
-------
4. AIR QUALITY MODELING
4.1 AQDM
o
The Air Quality Display Model (AQDM) is a computer program
designed to estimate the spatial distribution of particulate and
sulfur dioxide concentrations.
Procedurally, the model is calibrated for each geographic region
being studied. In order to calibrate the model, a base year is
selected for which the following data are available:
a. Air quality data from several representative sampling
stations.
b. Meteorological data including average annual temperature,
pressure, mixing depth, and wind roses (frequencies by
direction and speed classes) for five atmospheric stability
categories ranging from extremely unstable to extremely
stable for a weather station representative of the wind
conditions in the study area.
c. Annual emissions, in tons, from both point and area sources,
and
d. Background pollutant concentrations (optionally included).
These data are seldom adequate and available and, therefore,
subjective compromises must be made. Conceptually and ideally a
statistically significant least squares regression fit can be made to
a plot of the concentrations mathematically estimated at each air
quality monitoring site as compared to the observed concentrations;
this then becomes the linear equation used to adjust the model's
calculated concentrations when emissions are estimated to change
(because of area growth, control strategies, etc.).
Existing air quality data within the AISA precluded the use of a
calibrated dispersion model. While valid air quality data for at
least three monitoring sites constitute the theoretical minimum air
quality data necessary for calibration, experience has shown that
valid data from 15 to 20 sites are normally required. Such data for
1973 (year for which baseline emission data are available) exist for
B-15
-------
4
only two monitoring sites within the interceptor service area —site
490100003101, located in Auburn, and site 490980002P03, located in
King County. While sufficient valid air quality data exist for the
calibrated analysis of the entire Puget Sound area, the degree of
resolution for the AISA would not be adequate. Consequently, it
was necessary to use an uncalibrated AQDM.
Input data used in the dispersion model are presented in
paragraph 4.2. Procedures and results of the three AQDM runs used in
projecting air quality are described in paragraph 4.3.
The uncalibrated AQDM generates air quality as annual arithmetic
means. The national ambient air quality standards (NAAQS) are
expressed as geometric means. While secondary particulate standards
are expressed in terms of not exceeding a daily average of 150 ug/m
more than once a year, attainment of an annual geometric mean of
60 yg/m is considered to be a guide to attaining the secondary
standard. Statistical procedures are used to demonstrate this in the
analysis appearing in section 5 of this report. Procedures also
exist by which geometric means can be estimated from arithmetic means.
These are also used in the analysis portion of this report.
4.2 INPUT DATA
4.2.1 METEOROLOGICAL
Meteorological data suitable for AQDM are available for the
Seattle/Tacoma International Airport (SEATAC), Boeing Field in
Seattle, and McChord Air Force Base in the Tacoma area. Wind data
for 1973 are available from a station in Tukwila at the northern end
of the service area. Partial 1974 wind data are available from a
station in Kent. Surface wind data are the most sensitive meteoro-
logical input to the AQDM; therefore it is desirable to use wind
data from within the area being analyzed. While the Kent data would
be more representative of the AISA, they cannot be used because they
represent only a portion of 1974 while the baseline year air quality
and emissions data used in the AQDM are for 1973. Tukwila surface
winds data, therefore, were selected for use in preparing the
stability wind roses. Other meteorological inputs to stability wind
B-16
-------
rose preparation, i.e., cloud cover, precipitation, temperature, and
pressure, are less sensitive. In general annual averages of these
data do not vary within an air basin. SEATAC data can be considered
to be applicable throughout the AISA. Consequently, it was determined,
considering local conditions and availability of meteorological data,
that the best approach would be the synthesis of stability wind roses
using Tukwila surface winds and appropriate supplemental data from
SEATAC.
Use of the synthesized stability wind roses is considered to
provide more realistic meteorological data than using SEATAC data alone.
The SEATAC weather station is located on high ground to the west and
approximately 400 feet above the valley floor. The winds at Tukwila,
located in the valley, are more likely to be typical of those
affecting pollutant dispersions in the Auburn area. Data, other than
wind speed and direction, from SEATAC are more apt to be representa-
tive of the service area than any other available data. It must be
noted, however, that the wind roses synthesized from the one year
(1973) of available data from Tukwila and corresponding SEATAC
data must be assumed to be typical and suitable for use as the long-term
average data required for projecting future air quality.
Consequently a program was developed by RTI for the IBM 370/165
system, to extract pertinent data for Tukwila (data furnished by
PSAPCA) in punched card form and from 1973 SEATAC data (provided by
EPA/Durham on magnetic tape) to develop the synthesized stability
wind roses. Table B-3 contains a description of the product. (A
copy of the Tukwila-SEATAC program is being delivered to Region X
under separate cover).
Other meteorological inputs used with the AQDM are:
5
Mixing depth - 940 meters (average of morning and afternoon)
Ambient temperature - 284°K
Ambient pressure - 1013 Millibars
4.2.2 EMISSIONS
The emission inventories, point and area sources, described in
sections 2 and 3 were used as input to the AQDM. The area sources
B-17
-------
TABLE B-3. SEATAC - TUKWILA STABILITY WIND ROSE
WIND
DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
A
TOTAL
.12
.08
.04
0
t
0
.04
0
08
0
.04
.04
.04
.04
0
.12
1.45
.72
.24
.12
.12
.08
.04
.48
1.37
.44
.56
.52
.36
.36
.44
.64
1.54
.81
.08
.20
.08
.20
.04
.29
1.84
.57
.89
.56
.28
.08
.68
.85
4.77
1.48
.50
.41
.69
.58
.90
2.23
16.97
13.58
6.80
3.01
.78
.21
.98
1.77
5.55
1.29
.66
.35
.65
.30
.48
.31
5.06
5.05
.62
.62
.54
.26
1.06
3.94
13.42
4.38
1.52
1.09
1.54
1.17
1.51
3.31
25.32
19.64
8.92
4.75
2.00
0.95
3.16
7.32
TOTAL
,64
7.96 9.0 55.64 26.76
100.
A. Extremely unstable
B. Unstable
C. Slightly unstable
D. Neutral
E. Slightly Stable - Stable & Extremely Stable
Total cases including calm 250.0
Calm 94
*includes calms
2920 abs @ 8 per day X 365 days. 2500/2920 = 85.62% data available.
3.76% Calm
Source: RTI generated
B-18
-------
listed in Table B-2 for PSGC AAM zones 3100, 3130, and 3140 were
subdivided into one kilometer squares in order to obtain more
resolution in the vicinity of Auburn, site of the highest reported
1973 concentrations in the AISA. Area emissions were distributed
uniformly in these one square kilometer areas. Area source emissions
for the other PSGC AAM zones were introduced to the AQDM as area
sources with centroid locations as shown in Table B-2. The AQDM
program converted these areas into equivalent squares and assigned
the emissions from the AAM zone to that area.
For determining the impact of growth in the Auburn area on air
quality in Seattle and Tacoma, the increase in emissions was
determined by subtracting 1973 emissions from 1990 emissions and
using the emission changes as input.
4.3 AQDM ANALYSIS
Three AQDM runs were used in estimating the air quality impact
of the Auburn Interceptor: 1) Current conditions based on 1973
emissions, 2) 1990 conditions based on 1973 point source emissions and
projected 1990 area source emissions, and 3) impact on Seattle and
Tacoma from growth in the AISA. These runs are described below.
4.3.1 CURRENT CONDITIONS
The 1973 air quality situation in the Auburn area is considered
to be that developed by PSAPCA. The highest reading in the AISA is
at monitoring site 490100003101 where the 1973 annual arithmetic mean
3
for particulates is reported as being 68 yg/m . This concentration
consists of three components--!) natural background, 2) contributions
from sources within the AISA, and 3) contributions from unquantifiable
emission sources.
Background concentrations are assumed to be those occurring at
site 490980002P03, at the Washington State Fish Hatchery, in King
County. The 1973 annual arithmetic mean at that station is reported
as being 32
Contributions from sources within the AISA are estimated by
AQDM using an uncalibrated model and a linear regression with a
slope of T and an intercept of '0'. Results of this modeling are
B-19
-------
shown in isopleth form in Figure B-3. The monitoring site at Auburn
was input to the AQDM as a special receptor. The model estimated that
sources within the AISA accounted for 10.3 yg/m at that site,
3
57.7 ug/m coming from natural background and unquantifiable sources.
Detailed input and output from this AQDM run are given in Supplement 1.
Unquantifiable emission sources fall into three classes,
1) emissions transported from outside sources, 2) emissions from
sources within the AISA and not included in the 1973 point and area
emission inventories, and 3) emissions equivalent to the errors
inherent in an uncalibrated AQDM. For 1973, contributions from
3
unquantifiable emission sources are estimated to be 35.7 ug/m
[68 (1973 mean) - 10.3 (contributions from sources within the AISA) -
32 (natural background)].
Estimated ambient air suspended particulate concentrations have
o
been developed by PSAPCA. These are shown in Figure B-4.
4.3.2 PROJECTED CONDITIONS
Using the 1973 contribution from other than sources within
the AISA as the intercept, the 1990 air quality can be estimated using
AQDM. It is recognized that the contributions from unquantifiable
sources should be adjusted by the degree that emissions transported
into the AISA would be changed due to growth or as sources come into
compliance with PSAPCA Regulation I. If NAAQS are to be attained
in the Puget Sound area, overall emissions must be reduced. PSAPCA
3
has reported annual geometric means of 111 and 82 yg/m in Seattle
Q
and Tacoma, respectively. The guide for attainment of secondary
standards is 60 ug/m . The magnitude of this change is subject to
the degree of additional control that may be applied and the impact
of growth. The uncertainties as to the impact of these factors on
1990 emissions as well as the problems of determining the magnitude of
other unquantifiable emissions suggest that the conservative approach
would be to assume, at least for the purposes of this analysis, that
1990 contributions to ambient air concentrations in the AISA will
not be greater than those for 1973. Consequently, an intercept of
3
57.7 yg/m (1973 contributions from other than known sources within the
AISA) will be used as the intercept in the AQDM analysis of 1990 air quality.
B-20
-------
Auburn Interceptor Service Area
Green Valley Sewerage Area
Figure B-3. Contributions to 1973 Suspended Particulate Ambient Air
Concentrations from Sources within the Auburn Interceptor Service Area
(micrograms/cubic meter)
B-21
-------
PLiGffT SOUND RIR POLLUTION CONTROL RGENCY
•v
v\\ /<0\ SUSPENDED PF1RTICULRTES
510.0 StS.O WO.O 57S-0 630-0 535 0 540.0 5*5 0 5bO-0 SLS.O ST^.O StS.D S70.0 575 0 MO.O 505-0 690.0 69d.O 600J HE^>
UTM (KILOMETERS ERST)
Figure B-4. Suspended Particulates, 1973 Annual Geometric
Means (Micrograms/CU Meter)
Source: PSAPCA
B-22
-------
Using the 1990 emission data developed in sections 2 and 3, the
synthesized SEATAC-Tukwila stability wind roses, and an AQDM the
estimated 1990 air quality in the AISA is as shown in Figure B-5.
Detailed AQDM input and output are presented in Supplement 2.
4.3.3 IMPACT ON SEATTLE AND TACOMA
The impact of growth and development in the Auburn area
resulting from the construction of the interceptor sewer can be
estimated using an uncalibrated AQDM and emission growth as input.
Six receptor sites in the Seattle area and six in the Tacoma area are
introduced into AQDM as special receptors. Results of this analysis,
shown in Table B-4, indicate that projected growth in the AISA will
have negligible impact on ambient air concnetrations of suspended
particulates in Seattle and Tacoma. Detailed AQDM input and output
are presented in Supplement 3.
B-23
-------
6868 66 64
62
60
MN
62
Auburn Interceptor Service Area
Green Valley Sewerage Area
Figure B-5. Projected 1990 Isopleths, Suspended Particulate Geometric Means
(micrograms/cubic meter)
B-24
-------
TABLE B-4. CONTRIBUTIONS & GROWTH IN AUBURN INTERCEPTOR SERVICE AREA
ON PARTICULATE CONCENTRATIONS IN SEATTLE AND TACOMA
^
OQ
TO
W
1
K>
H-
CO
O
ri-
ft
CD
SITE CODE
490120001101
490120002101
491840002F01
491840005101
491840006101
491840059F01
4921 40001 A01
4921 40001 F01
£ 492140001101
*" 492140004101
492140006F01
491560001101
City
Bellevue
Bellevue
Seattle
Seattle
Seattle
Seattle
Tacoma
Tacoma
Tacoma
Tacoma
Tacoma
Pierce Co.
LOCATION
Easting
564.5
560.4
550.3
550.6
554.5
554.8
542.8
542.1
542.1
545.0
545.3
549.0
Northing
5275.0
5273.6
5272.1
5269.0
5266.2
5267.7
5233.3
5233.4
5233.4
5234.4
5231.4
5231.7
Impact of Auburn Growth 3
On 1990 Air Quality yg/m
0.3
0.4
0.2
0.2
0.3
0.3
0.1
0.1
0.1
0.1
0.1
0.1
-------
5. CONCLUSIONS AND RECOMMENDATIONS
5.1 GENERAL
The conclusions derived from analysis of the 1973 contributions
to ambient air concentrations from sources within the AISA, and the
projected impact of growth on 1990 air quality must be considered in
light of the following assumptions and procedures underlying the AQDM
analyses.
a. Use of an uncalibrated AQDM because of the unavailability
of sufficient valid air quality data for the area under
analysis.
b. Use of stability wind roses synthesized from 1973 SEATAC
and Tukwila meteorological data, and assumption that the
synthesized data are typical of long term conditions.
c. Assumption that growth in the AISA would result in
development patterns similar to those currently existing
in the Kent area.
d. Method of estimating contributions from sources outside
the AISA (primarily from sources in Seattle and Tacoma)
and inclusion of this contribution in the background con-
centration used as the intercept for the 1990 AQDM analysis.
As mentioned in section 3, AQDM analysis produces concentrations
expressed as annual arithmetic means. To permit comparison with NAAQS,
expressed as geometric means, the arithmetic means must be converted.
Air quality data from receptor site 490100003101, located in Auburn,
show the following relationship between aritihmetic and geometric means:
yg/m
Year Annual Average Geometric Mean Geometric
Arithmetic Mean Standard Deviation
(m)
(mg)
51
63
55
52
(V
1.63
1.52
1.62
1.52
1974 57
1973 68
1972 62
1971 57
Average 61.0 55.3 1.572
B-27
-------
Arithmetic means can be converted to geometric means using the following
g
relationship:
m m
g
exp(0.5 In s )
y
Using the data presented above the relationship between m and m is
calculated as being:
m = m
9
1.1077
5.2 CONCLUSIONS AND RECOMMENDATIONS
In the discussions that follow, annual concentrations are expressed as
annual geometric means unless otherwise indicated. Arithmetic means
are converted to geometric means using the relationship developed in
paragraph 5.1 above.
Based on the uncalibrated AQDM analysis, the highest projected 1990 TSP
concentration will occur at monitoring site 490100003101 in Auburn. This
site also had the highest 1973 concentrations in the AISA. Projected ambient
3
air concentrations are estimated to be 64 yg/m «
centration consists of the following components:
Arithmetic Mean Geometric Mean
From sources within the AISA 13.2 11.9
Natural background 32.0 28.9
From unquantified sources 25.7 23.2
Total 70.9 64.0
Corresponding data for 1973 are: 2
Annual Averages yg/m
Arithmetic Mean Geometric Mean
From sources within the AISA 10.3 9.3
Natural background 32.0 28.9
From unquantifiable sources 25.7 23.2
Total 68.0 61.4
air concentrations are estimated to be 64 yg/m at this site. I his con-
3
Annual Averages yg/m
B-28
-------
It should be noted that the estimated total geometric mean in 1973 is
3
different from the 63 ug/m reported by PSAPCA. This is the result of
using a four year average geometric standard deviation in converting
from arithmetic to geometric means.
Potential reduction in contributions from unquantifiable sources
as they come into compliance has not been taken into consideration in
arriving at the preceeding air quality estimates. In actuality,
however, some reduction could be expected. Maximum reduction would
occur if all unquantifiable sources were assumed to be outside the AISA.
Based on data available at EPA Region X, 1973 and 1990 emissions from
point sources outside the AISA are estimated at 13,780 and 5,600 tons
respectively (Detailed calculations from which these data were obtained
are available at EPA Region X). Assuming the same change in emissions from
area sources as will be experienced in the AISA for sources outside
the AISA, (From data in table B-2, this is calculated as being 1.212)
the following estimated ration of total 1990 and 1973 emissions can
be determined.
Emissions, tons/year
Point sources -^ 1990
Point sources 13,780 5,600
Area sources 15,200 18,430
Total 28,980 24,030
Ratio 1990 to 1973 24,030 ; 28,980 = 0.83
Applying this ratio to the previously estimated 1990 air quality results
in the following:
3
Air Quality, yg/m
From sources within the AISA 11.9
Natural background 28.9
From unquantifiable sources 19.3 (23.3 x 0.83]
Total 60.1
This estimates probably represents the most optimistic one. The most
extreme estimate of 1990 air quality would result in assuming that the
1973 observed particulate concentrations at Auburn had only two com-
ponents, natural background and from sources within the AISA. Under these
B-29
-------
3
conditions estimates of 1990 air quality is 70,5 yg/m calculated as
shown below.
Concentrations, yg/m
1973 J990
From sources within the AISA 32.5^by difference) 41.6 [(32.5 x 11.9]
; 9.3]
Natural background 28.9 28.9
Total 61.4 70.5
The foregoing analysis indicates the 1990 projected air quality at
Auburn under worst case, best case, and probable conditions to be:
Worst case (no contributions from unquantifiable 3
sources) 70.5 yg/m
Most probable case (no reduction in contributions 3
from unquantifiable sources) 64.0 yg/m
Best case (reduction in contributions from ^
unquantifiable sources) 60.1 yg/m
The impact of these projected emissions can be determined by assuming
a log normal distribution and using Larsen's transformation to estimate
the second highest daily average. The geometric standard deviation of
1.572, calculated in paragraph 5.1 is used. The process is shown in
Figure B-6. Estimated second highest daily averages are estimated to be
3
225, 205, and 190 yg/m , for the worst case, most probable case, and best
case, respectively.
Isopleths, developed by the AQDM analysis indicate a high concentration
3 3
in the Renton area, 69.4 yg/m (arithmetic mean of 76.89 yg/m ). This
concentration can be attributed to the point sources in the vicinity of
the receptor site. When considered in the light of an earlier cal-
ibrated AQDM analysis of the Seattle area, including Renton, that
estimated air quality under full Regulation I control at approximately
3
50 yg/m annual arithmetic mean concentration, the concentration pro-
jected by the unclaibrated model appear to be on the high side. However,
this is expected using an uncalibrated AQDM . They also appear high
when compared with PSAPCA estimates of 1970 concentrations of 42 and
3
55 yg/m in the Renton/Tukwila area, (see Figure B-4)
B-30
-------
E
en
OT
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CO
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o
c
o
o
S-
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(13
400 r
300 -
200 -
Estimated Second Highest
Daily Average
0.01
Annual Mean
Geometric standard deviation = 1.572
Probable Case
0.05 02 05
10 20 30
Frequency
40 50 60 70 80
90
98
-------
The analysis indicates that the 1990 projected air quality at the
site within the AISA having the maximum reported 1973 concentration
3
falls between 60 and 71 yg/m . These concentrations correspond to
3
estimated second high daily averages of 190 and 225 ug/m , respectively.
The first figure assumes a contribution from unquantifiable sources within
and outside of the AISA, the second, no contribution from these sources.
This suggests that the air quality situation in the AISA is sensitive
to contributions from sources outside the area and sources that may not
presently be included in the emission inventory. The projected air
quality that would result from projected growth and development appears
to be marginal. The matter, however, should be continuously reviewed
and refined by the initiation of a program to collect valid air quality
data from representative sites within the AISA to serve as the basis for
further refinement of the AISA analysis. Collection of such data will
permit the use of a calibrated dispersion model. Such action will most
likely be required in the preparation of an air quality maintenance
plan for the Puget Sound Intrastate AQCR in which the AISA is located.
The generation of air quality data suitable for use in a calibrated
AQDM will also facilitate PSAPCA new source review for the evaluation of
air quality impact of new point sources that may locate in the AISA as
part of the projected growth and development.
B-32
-------
REFERENCES
1. The Municipality of Metropolitan Seattle, "Auburn Interceptor
Environmental Impact Statement," January 1974.
2. Personal communication with Mr. Art Dammkoehler, Air Pollution
Control Officer, Puget Sound Air Pollution Control Agency, on
February 26, 1975.
3. "Air Quality Display Model," National Air Pollution Control
Administration, November 1969.
4. 1973 Air Quality Data Summary, provided by EPA Region X.
5. Holzworth, G.C., "Mixing Heights, Wind Speeds, and Potentials
for Urban Air Pollution throughout the Contiguous United States,"
U. S. Environmental Protection Agency, January 1972.
6. Department of Commerce, Climates of the States, Vol. 2, 1974.
7. Personal communication with Mr. Dean Wilson, EPA Region X,
March 11, 1975.
8. Puget Sound Air Pollution Control Agency, 1973 Air Quality Data
Summary for Counties of King, Kitsap, Pierce, Snohomish,
June 1, 1974.
9. Larsen, Ralph I., "A Mathematical Model for Relating Air Quality
Measurements to Air Quality Standards," AP-49, U.S. Environmental
Protection Agency, February 1973.
10. Knechtel, K. Boyd, Application of an Urban Diffusion Model to
Modeling Suspended Particulates in the Puget Sound Air Quality
Control Region, 71-AP-21, Puget Sound Air Pollution Control
Agency, paper prepared for presentation at the 1971 annual
meeting of the Pacific Northwest International Section, Air
Pollution Control Association, November 21-23, 1971.
11. Busse, A.D., and J.R. Zimmerman, Appendix E., "An Evaluation of
Some Climatological Dispersion Models," in User's Guide for the
Climatological Dispersion Model, EPA-RA-73-024, U.S. Environmental
Protection Agency, December 1973.
B-33
-------
SUPPLEMENT 1
AQDM Input and Output Printouts,
1973 AQDM Analysis
1-1-1
-------
S30HCE DSTA
AOBUEN,WN, TNTEFCEP™05 SFRVTCF IP EA (1973 £>T C AREA, R5V)
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SOUFC3 CONTRIBUTIONS TO TIV? aAXIHDK PECSPTOF.S
Ain'UM. FASriCULATES
MICFOGiAMS PER CUBIC MtifEH
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SOUPCS CO:!T°.I'3'JTIO»S TO FIVE HAXIfU.1 SBCSPTOSS
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-------
SUPPLEMENT 2
AQDM Input and Output Printouts,
1990 Analysis, Auburn Interceptor Service Area
B-2-1
-------
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SO'J?CS DATA
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iUBRUN,WN, ISTEF.CEPTOH SESVICI ftHEA (1990 TOTAL BE?)
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PSC".?TDS DATA
LOCATIONS TO BE USED
IN ADDITION TO TH2 221 FECT HSGUiSR GRID LOC&TIOIIS
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co
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METEOROLOGICAL INPUT DATA
FOR THS
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-------
AUBBUN.HN, INTEaCE?T3H SSHVICE ASSA (1990 TOTAL FSV)
CD
00
METiOBOLOGICAL It
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CD
AU3BOH,HH, ISTERCHPTD
HETrOBOLOGICAL INPUT
STABILITY CLASS H
-
DATA
?. SERVICE APSi (1990
TOTAL
?OH THE AHHUAL SFASOH
KIND5PE2D CLASS
WIND DI5FCTIOK
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SUPPLEMENT 3
AQDM Input and Output Printouts,
1990 Analysis
Seattle and Tacoma
B-3-1
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-------
AIR QUAJLITY IMPACT ASSESSMENT OF
THE AUBURN INTERCEPTOR
SERVICE AREA
APPENDIX C
THE DEVELOPMENT OF PARTICULATE
EMISSION PROJECTIONS AND
SMALL AREA PROJECTIONS
March 31, 1975
Prepared for
Research Triangle Institute
Research Triangle Park, North Carolina
PLANNING ENVIRONMENT INTERNATIONAL
A DIVISION OF ALAN M. VOORHE^S & ASSOC.. INC.
1100 GLENDON AVE.-LOS ANGELES, CALI FORN IA 90024
-------
TABLE OF CONTENTS
Page
LIST OF FIGURES C-iii
LIST OF TABLES C-iii
I. INTRODUCTION C-l
II. METHODOLOGY C-4
Initial Policy Assumptions C-4
Alternative Methodologies for Area Source Projection . . C-5
Description of the Selected Methodology C-6
Emission Factor Development C-7
Area Source Emission Allocation Procedure . , . C-12
The Allocation of Motor Vehicle Particulate
Emissions C-14
III. RESULTS C-ZO
IV. SUMMARY C-26
V. REFERENCES C-27
C-ii
-------
LIST OF FIGURES
Page
C-l. Auburn Interceptor Service Area (Hatched) Overlaid
on PSGC Activity Allocation Districts C-l 3
LIST OF TABLES
C-l. 1973 Area Source Particulate Emission Factor
Development C-8
C-2. 1990 Area Source Emission Factors C-9
C-3. Particulate Emissions from New Cars Equipped with
Catalytic Mufflers (in Grams per Mile) C-ll
C-4. 1973 Activity Allocation Data C-15
C-5. 1990 Activity Allocation Data C-16
C-6. Trip Generation Estimates for the Auburn Interceptor
Service Area C-19
C-7. 1973 District Emission Calculation C-21
C-8, 1990 District Emission Calculation C-22
C-9. Area Source Emission Inventory, 1973 and 1977 C-23
C-10. Comparison of 1973 King County and Auburn Interceptor
Service Area Statistics C-2 5
-------
I. INTRODUCTION
The analysis described here is a projection of the particulate emissions
anticipated from growth and urbanization in the proposed service area
of the Auburn Interceptor.
Construction of the Auburn Literceptor represents implementation of
a proposed element of METRO's Comprehensive Plan and is a portion
of the second phase of the ultimate development of an areawide waste
water treatment system serving the total sewerage needs of the Green
River Sewerage Area and a portion of the White River Watershed.
The proposed Interceptor will be a 42 - to 72-inch reinforced concrete
pipe totaling 7.1 miles in length. The pipe will commence at the influent
structure of the existing City of Aubxirn sewage lagoon and connect with
the existing Metro-Kent Cross Valley Interceptor.
The sewerage area to be served by the Interceptor encompasses the
Green River Sewerage Area and part of the White River Watershed. In-
cluded within this area is all of the Lower Green River Valley in the
vicinity of the cities of Kent, Auburn, Algona and Pacific, and Des
Moines Plateau (West Hill) to the west. The area to be served by the
Interceptor in the White River Watershed lies north of Lake Tapps and
within both King and Pierce Counties.
Upland plateaus incised by the valley trough and flood plain of the Green
River are the principal topographic features of the sewerage area. The
ascent to the upland areas is abrupt, with differences in elevation be-
tween the river bottom and the plateau in excess of 300 feet. The up-
lands present a rolling glacial relief characterized by depressions and
hummocks in which stream courses and drainage patterns are often
poorly defined. Numerous local basins and depressions of retarded
drainage are occupied by small lakes and swampy areas and bogs. The
-------
Green River is artificially controlled by an upstream dam and manmade
levees, which parallel the stream throughout most of its length within
the sewerage area.
In addition to its diverse topography, the sewerage area is characterized
by a variety of land uses: agriculture and sharply contrasting industrial
development in the Green River Valley; retail, commercial and residen-
tial uses in the cities and towns; and forestry, mining, open space,
recreation, and scattered rural, residential and farming uses on the
eastern uplands.
Recent photogrammetric interpretations of the sewerage area reveal that
roughly 59 percent of the land is either undeveloped woodland and cpen
space or devoted to agricultural and recreational use. Residential and
commercial uses occupy 24 percent of the land, while only 1 percent is
currently used for industrial purposes. The remainder is used for other
miscellaneous purposes, such as transportation and utility facility corridors.
Land use trends for the majority of the sewerage area are toward more
intensive uses, particularly in the Green River Valley flood plain. The
annexation of valley bottom lands by Kent and Auburn, and the subsequent
zoning of these lands to industrial and commercial classifications, has
stimulated dramatic changes in land uses from the traditional dominance
of agriculture to more intensive uses, with consequent demands for
increased utility service.
Existing land use patterns in the Green River Valley area are depicted
on maps available at the Puget Sound Governmental Conference (PSGC).
Projected 1990 land use for the same area that would result if the land
use plans generated by local planning agencies are realized, are also
depicted on PSGC maps. Comparison of these maps indicates that much
of the land along the railroad and major road running along the valley
floor that is currently open space and rural is projected to become de-
veloped for industrial, commercial, and residential uses in 1990.
C-2
-------
Recent air quality data from the Puget Sound Air Pollution Control
Agency's (PSAPCA's) Auburn and Kent monitoring stations indicate
that levels of particulate matter in the proposed interceptor service area
are very close to the air quality standard. This fact, together with the-
levels of development and urbanization expected to occur in the area,
has led to the present concern over the potential air quality impacts of
such growth and, in turn, to the need for the present analysis.
C-3
-------
II. METHODOLOGY
INITIAL POLICY ASSUMPTIONS
Two fundamental policy assumptions were made at the outset of the anal-
ysis in order to reduce the magnitude of the task to manageable propor-
tions. First, the year 1990 was selected as the target year for the anal-
ysis, even though the interceptor was sized according to a projection to
the year 2000. This was done for two reasons:
o It is not possible to project the nature or efficiency of
air pollution control technology 25 years in advance;
a projection to 1990 is itself fraught with uncertainty.
The same may be said about land use, population,
and motor vehicle travel projections as well. Any
errors in sewage treatment capacity projections can
be corrected at a later date through a variety of
means such as the construction of additional treatment
facilities, or the under-utilization of installed capa-
city, whereas for an air quality analysis the overall
precision is crucial since the projected air quality
must be compared to an established air quality stan-
dard. Therefore, it was not considered meaningful
to attempt to project air quality in the year 2000.
o PSGC has made its most detailed projections of popula-
tion, employment, and 'motor vehicle activity up to the
year 1990. If this resource were to be utilized at all,
1990 would be the furthest possible projection year.
The second assumption was that sources large enough to be considered
point sources would not be projected since such sources would be re-
viewed individually under EPA's and PSAPCA's new source review pro-
grams. Under these programs, any proposed source found to cause a
violation of an existing air quality standard may be denied a permit to
2
construct. Thus, the emission projection and subsequent air quality
analysis are concerned with the impact of increased emissions due to
"area sources" of particulate matter. These sources include residential,
commercial, and small industrial space heating units, motor vehicles,
C-4
-------
railroads, fugitive dust (due to travel on dirt roads, construction activ-
ity, and structural fires), incineration, open burning, and off-highway
vehicle emissions.
ALTERNATIVE METHODOLOGIES FOR AREA SOURCE PROJECTION
In any projection of future conditions for a specific area, many uncertain-
ties and simplifying assumptions must be made, such that the accuracy
of the resulting projection may be questioned on many fronts;. In such a
situation, an important consideration is that the bases for estimating
both base-year and projected emissions are comparable. In this way,
the analysis may at least be considered internally consistent, and pro-
jected emissions may be compared with base-year emissions in a mean-
ingful way.
With this in mind, three alternative projection methodologies were
identified:
Extrapolate existing emissions at an assumed growth
rate, and assume that the growth occurs "in place"
(i.e., at the identical locations of present sources).
Assume that emissions changes occur in proportion
to the acreages planned or zoned for each individual
purpose.
Assume that emission changes occur in proportion
to various indices of "activity" appropriate to each
source category (e.g., manufacturing employment is
an indicator of industrial activity and hence
emissions).
The "growth in place" assumption is unrealistic due to the large amounts
of vacant land presently zoned for higher intensity uses in the proposed
service area of the Auburn Interceptor. The second approach--using
land acreages as an index of change in emissions--is also unrealistic
since the mere designation of land for a given purpose in no way guarantees
that it will actually be developed as designated by a given date. Private
C-5
-------
development decisions are influenced by many factors, with zoning being
only one consideration. Furthermore, according to PSGC, there is
sufficient land designated for industrial use in the Green River Valley
alone to accommodate all of the industrial growth projected for the
3
entire Puget Sound four-county area to the year 2000. Obviously,
not all of the region's growth is going to occur in the Valley, making
the use of acreages unrealistic as an index of emission changes.
The third approach—using activity projections (developed by PSGC) as
indices of emission changes--was judged to be the most realistic ap-
proach. Basically, PSGC has both baseline and projected estimates of
population, employment, and trip generation on a subarea basis (activity
allocation model districts). These estimates may be used as a measure
of emission changes; since the estimates are spatially disaggregated,
they may be used to generate area-specific emission estimates. Studies
4 12
by the Argonne National Laboratory ' have indicated essentially the
same conclusion--that economic indices of growth provide better esti-
mates for emission projection purposes than either the land acreage
methodology or the "growth in place" assumption.
DESCRIPTION OF THE SELECTED METHODOLOGY
The use of activity allocation data provided by PSGC proceeds as follows:
o Select the index most appropriate for each emission
source category (e.g., residential fuel combustion
emissions are directly related to the population pro-
jections and distribution).
o Calculate base-year emission factors from index
totals for King County. (The interceptor service
area lies almost entirely within King County.)
o Allocate 1973 emissions on the basis of PSGC index
allocations for the districts within the sewerage
area.
C-6
-------
o Calculate emission factor reductions due to imple-
mentation of known control regulations by 1990 (open
burning and residential incineration prohibited, and
catalytic converters used on all automobiles).
o Compute 1990 emission factors.
o Compute 1990 district emissions on the basis of
PSGC projected index allocations.
Emission Factor Development
Emissions due to residential fuel combustion, open burning and incinera-
tion, as well as structural fires, were allocated according to population
within each district. Commercial and institutional fuel combustion emis-
sions were allocated according to non-manufacturing employment while
industrial fuel combustion and process losses were allocated according
to manufacturing employment. Emissions due to off-highway vehicle
activity, dirt roads, construction, forest fires, and slash burning were
allocated according to land area (i.e., emissions were assumed to be
spread evenly across the entire county). Highway vehicle emissions
were allocated according to vehicle trip end data obtained from. PSGC.
(A more detailed explanation of this procedure is presented later.)
Finally, aircraft and ship emissions were not included in the analysis
since aircraft activity at the Auburn airport is negligible, and there is
no known ship activity in the service area.
Table C-l summarizes the development of 1973 particulate emission fac-
tors for each source category. Table C-2 summarizes the development of
1990 emission factors, indicating the percentage reductions in each
source category anticipated to result from the implementation of various
control programs. In the residential sector, open burning and incinera-
tion should be prohibited by 1990, resulting in a 20 percent reduction in
average residential emissions per person. The same regulations apply
to the commercial and industrial sectors, resulting in the changes indi-
cated. In the case of forest fires and slash burning, roughly 40 percent
of the service area is presently forested. Due to urban development
C-7
-------
TABLE C-l. 1973 AREA SOURCE PARTICULATE EMISSION FACTOR DEVELOPMENT
O
i
co
Emission
Projection Category
Residential
Commercial/ Institutional
1972-73
Tons/Year
King County
1,196
703
Projection Index
Population
Non- manufacturing
1973 Index Total,
King CourityZ
1,181,374
336,688
1973 Participate
Emission Factor
1.012 tons/103 pop.
2.088 tons/103 emp.
Industrial
Off-Highway
Aircraft
Vessels
Dirt Roads
Construction Land
Forest Fires/Slash Burning
Structural Fires
Highway Vehicle Emissions
employment
1,089 Manufacturing
employ.nent
280 District land area
120 N/A*
216 N/A*
1,036 District land area
120 District land area
709 Land area
629 Population
Trip ends
103,608
455,169
N/A*
N/A*
455,169
455,169
455,169
1,181,874
5,172,000
10.511 tons/10 emp.
0.615 tons/10 acres
2.276 tons/10 acres
0.264 tons/103 acres
1.558 tons/10 acres
0.532 tons/103 pop.
0.885 tons/10 trip ends
N/A = not applicable. No significant ship traffic in the service area. Also, aircraft activity is included
in the point source inventory.
Area source emission estimates "were obtained vsing a combination of EPA and PSAPCA data. 1973
emission data are available at EPA Region X, EPA data on fugitive dust emissions from dirt roads,
construction, and structural fires were used since PSAPCA did not include them in their inventory.
PSAPCA data were used in all other categories, with EPA data on the distribution of open burning and
incineration emissions among the residential, commercial, and industrial sectors.
2Provided by PSCG
-------
TABLE C-2. 1990 AREA SOURCE EMISSION FACTORS
O
Category
Residential
Commercial/ Institutional
Industrial
Off-Highway
Dirt Roads
Construction Land
Structural Fires
Forest Fires/Slash
Burning
Highway Vehicles
1973 Particulate
Ernission Factor
1.012 tons/103 pop.
2.088 tons/103 emp.
10.511 tons/103 emp.
3
0.615 tons/10 acres
3
2.276 tons/10 acres
0.264 tons/103 acres
0.532 tons/103 pop.
1.558 tons/10 acres
3
0.885 tons/10 trip ends
Reduction Factor
due to
Regulations, Controls
20%
17%
1
1
11%
none
none
none
none
50%2
33%3
1
1990 Emission Factor
0.810 tons/103 pop.
1.733 tons/103 emp.
9.355 tons/103 emp.
3
0.615 tons/10 acres
2.276 tons/10 acres
0.264 tons/10 acres
0.532 tons/103 pop.
0.753 tons/10 acres
0.593 tons/103 trip ends
Reduction due to anticipated prohibition of open burning and on-site residential incineration.
>
'Reduction due to increased urbanization of the forested areas.
Reduction due to the anticipated use of oxidizing catalysts on automobiles.
-------
and its associated improvement in fire services and reduction in forested
land, a 50 percent reduction in emissions per acre has been assumed
from this source category.
Finally, in the case of motor vehicle particulate emissions, by 1990 it
is anticipated that all cars will be equipped with oxidizing catalytic con-
verters. Exhaust particulate emission factors developed through studies
performed by ESSO Research and Engineering are shown in Table C-3.
Assuming that monolithic catalysts on Ford Motor Company autos coin-
prise roughly 25 percent of the operating vehicle fleet in 1990, the
weighted average exhaust particulate emission factor is .16 gm/mi. A
recent draft revision to AP-42 indicates that an emission factor of .1
gm/mi is appropriate for post-1974 catalyst-equipped vehicles. (In
either case, the emission factor for tire wear remains the same at .20
gm/mi.) When compared to the present exhaust emission factor of .34
gm/mi, the conclusion is that, by 1990, when the entire vehicle fleet
will consist of post-1974 vehicles, the total particulate emission factor
(including tire wear) should be about 55 percent to 67 percent of the pres-
ent value--a reduction of from 33 to 45 percent. A 33 percent reduction
has been assumed for the purposes of this analysis.
It must be noted, however, that the composition of the particulates
emitted differs dramatically from the composition of particulates emitted
from vehicles not eqxiipped with catalytic devices. Over 90 percent of
the catalyst particulate emission is in the form of sulfates, sulfuric
acid and water bound to the sulfuric acid, whereas from unequipped ve-
hicles, sulfates and sulfuric acid compose but a trace amount of particu-
late emissions. Unfortunately, since there is presently no air quality
C-10
-------
TABLE C-3. PARTICULATE EMISSIONS FROM NEW CARS EQUIPPED WITH CATALYTIC MUFFLERS
(IN GRAMS PER MILE)
Catalyst
Test Cycle
Fuel Total
Sulfur, % Particulates Sulfates Water Platinum
Monolithic Noble
Metal1
Pelletized
Oxidation
1972 Federal Test
Cycle 0.067:
1972 Federal Test
Cycle
0.065
0.287
0.118
0.1264 O.lll4 0.0002
0.036
N/A
0.0002
o
I
N/A = Not available
1
Characteristic of Ford Motor Company catalytic mufflers.
>
'Characteristic of General Motors Company catalytic mufflers.
This is the average content (percent by weight) of sulfur in Southern California gasoline.
Average.
-------
standard for sulfates, the emissions have simply been considered as
particulate matter.
Area Source Emission Allocation Procedure
The procedure adopted for allocating area source emissions to the activ-
ity allocation districts within the proposed service area was composed
of four steps. First, the appropriate districts lying within the service
area were identified. These districts are shown in Figure C-l, along with
the service area boundary. Second, of the twenty zones within the serv-
ice area, ten are only partially included. The fraction of these districts
lying within the service area was therefore estimated.
Third, the population and employment data provided by PSGC for each
district were modified to reflect the distribution of land uses indicated
by the composite land use plans of the local planning agencies in the Inter-
ceptor service area. The recent compromise between PSGC and the City
g
of Auburn concerning the land use plan for the Auburn area has under-
scored the weakness of PSGC's position in specifying land use in specific
areas of the region. This is distinct from PSGC's stronger position in
estimating population and economic conditions in future years. For the
purposes of the area source emission projection, it is more realistic
to assume that the local composite land use plan for the service area
developed from the local agency plans will be more representative
of future land use conditions than the land use element developed by
PSGC. With this in mind, PSGC's district projections of population and
employment for the Auburn Interceptor service area were distributed ac-
cording to the land use indicated in the local plans. Total population and
The Administrator of the Environmental Protection Agency recently
announced his support of a proposal to delay enforcement of 1977 auto
emission standards to 1982 to avoid the potential sulfate problem. How-
ever, no official action or decision on the matter has been made by
Congress. On the basis of existing regulations, the catalysts will be
used; hence, there is no formal basis upon which to modify this
as sumption.
C-12
-------
3000
Reference
JTM
Reference
UTM Coordinate 551.0
FIGURE 3. AUBURN INTERCEPTOR SERVICE AREA (HATCHED) OVERLAID ON
PSGC ACTIVITY ALLOCATION DISTRICTS
C-13
-------
employment projected for the service area were conserved during the
reallocation process by the following method: Any activity (such as manu-
facturing employment) which was projected by PSGC to occur in a given
area but which was not indicated by the land use designations for that dis-
trict under the local plans was tabulated separately and then added to the
districts which had the appropriate land use designations. Thus, 450
manufacturing employees in 1973 were displaced to other districts. They
were proportionately distributed to the other districts according to the
number of manufacturing employees already in those districts. The total
manufacturing employees not displaced was 8,497. Hence, in each dis-
trict, the number of manufacturing employees was increased by 450/
8,497 = 5 percent to account for those displaced. Similarly, displaced
non-manufacturing employees accounted for 19 percent of the non-
displaced employees in this class in 1973. In 1990, the "displacement
factors" are approximately 6 percent and 29 percent for manufacturing
and non-manufacturing employees, respectively.
Finally, the resulting land area, population, and employment by district
within the service area were tabulated for 1973 and 1990, and then mul-
tiplied by the appropriate emission factors to obtain total area source
particulate emissions by district within the Interceptor service area.
Table C-4 summarizes the district population and employment data for
1973. These data were obtained by a straight-line interpolation of 1970
and 1975 population and employment data provided by PSGC. The per-
cent of each "activity" estimated to be within the Interceptor service
area is indicated in parentheses next to each entry. Table C-5 summarizes
the same information for 1990, including the land area in acres for each
district. (The acreages are the same in 1973.)
The Allocation of Motor Vehicle Particulate Emissions
Tables C-4 and C-5 also indicate vehicle trip end data by district. The
basis for selection of these data for allocation purposes is described in this
section. To allocate motor vehicle travel emissions, it was first
C-14
-------
TABLE C-4. 1973 ACTIVITY ALLOCATION DATA
A AM
District
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
1973
Population
7,
6,
3,
8,
10,
4,
4,
10,
3,
4,
9,
4,
4,
6,
3,
8,
6,
9,
12,
259
223
372
577
716
378
934
550
127
665
801
202
528
472
479
684
251
970
109
081
(25)
(50)
(100)
(100)
(100)
(100)
(100)
(100)
(100)
(100)
(50)
(25)
(50) .
(50)
(100)
(100)
(50)
(0)
(50)
(25)
1973 1973
Manufacturing Non-Manufacturing
Employment Employment
26
300
17
139
6,606
0
47
135
355
6
19
5
408
3
0
0
0
9, 103
6
6
(0)
(0)*
(100)
(0)*
(100)
(-)
(100)
(100)
(100)
(0)=:=
(100)
(0)*
(100)
(50)
(-)
(-)
(-)
(5)
(50)
(0)
161
319
388
433
2,205
24
8
573
3,283
175
98
464
1,015
744
257
50
573
3, 156
476
833
(0)
(0)*
(100)
(0)*
(100)
(100)
(100)
(100)
(100)
(0)*
(100)
/?RI
\ — - /
(100)
(0)
(100)
(0)*
(0)*
(5)
(0)*
(0)
''Indicates percent of activity index within the service area.
* Denotes that this quantity will be shifted to other zones to
make PSGC data compatible with local agency land use plans.
C-15
-------
TABLE C-5. 1990 ACTIVITY ALLOCATION DATA
A AM
District
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
Gross Area
(Acres)
2,756 (25)
5,494 (50)
2, 254 (100)
3, 407 (100)
3,993 (100)
3,042 (100)
15, 832 (100)
1, 964 (100)
4, 731 (100)
2, 700 (100)
24,034 (50)
34,062 (25)
2,766 (75)
2, 158 (50)
5, 730 (100)
7,455 (100)
2,583 (50)
6,538 (5)
. 4,277 (50)
2,218 (25)
1990
Population
14, 882 (25)
10, 173 (50)
6, 372 (100)
13,613 (100)
12,071 (100)
2, 851 (100)
8, 164 (100)
5,977 (100)
11, 140 (100)
7, 675 (100)
9,261 (100)
14,782 (25)
6,711 (50)
8, 500 (50)
15, 860 (100)
11,039 (100)
15,594 (50)
10,241 (0)
19,701 (50)
15,880 (25)
1990
Manufacturing
Employment
130 (0)
1, 132 (0)*
98 (100)
377 (0)*
13, 376 (100)
12 (100)
274 (100)
225 (100)
316 (100)
9 (0)*
28 (100)
23 (0)*
409 (100)
0 (-)
0 (-)
0 (-)
0 (-)
14, 328 (5)
0 (-)
40 (0)
1990
Non-Manufacturing
Employment
508 (0)
500 (0)*
541 (100)
1, 149 (0)*
3,018 (100)
252 (100)
699 (100)
1,034 (100)
4,737 (100)
596 (0)*
282 (100)
718 (25)
2, 161 (100)
2,372 (0)
978 (100)
497 (0)*
1,533 (0)*
6,060 (5)
1,590 (0)=:=
1,174 (0)
0
*
Indicates percent of activity index within the service area.
Denotes that this quantity will be shifted to other zones to
make PSGC data compatible with local agency land use plans.
C-16
-------
necessary to prepare estimates of motor vehicle activity resulting from
urbanization within the Auburn Interceptor service area. Estimates
were desired for the 1973 base year and the 1990 target year.
To prepare a precise estimate of VMT resulting from urbanization of
the service area would require traffic counts, forecasts, and correspond-
ing roadway section lengths for all street and highway routes in the serv-
ice area. Such a set of data does not exist. Alternatively, VMT could
be estimated through use of the PSGC regional transportation computer
simulation models, using special techniques to cordon and evaluate the
Interceptor service area. A third method would involve the use of basic
PSGC trip generation data for the service area.
Since it is motor vehicle activity generated as a result of urbanization
of the service area which is desired, the trip generation data is a more
appropriate measure of such activity than link-by-link traffic count data.
Traffic count data include through travel in addition to travel having
origins or destinations within the service area. Through trips would
not be a result of urbanization within the service area, i.e. , they -would
occur whether or not the service area were further developed. Through
travel would likely account for roughly 10 percent of the total trips. In
addition, simply estimating travel within the service area would not
account for travel resulting outside the service area due to urbanization
within it (e.g., people commuting to employment centers within the
service area from outside of it, and vice versa). However, trip genera-
tion data are directly related to the nature of the trip origins and attractions
within the service area, and allocation of motor vehicle particulate
emissions according to the trip generation data gives a better indication
of emissions resulting from urbanization within a given subarea of a
region. Although not all of the emissions thus allocated to specific
zones will, in fact, be generated in those zones, it was considered
best to account for the emissions in this fashion, rather than to neglect
the emissions generated outside the service area due to urbanization
within the area.
C-17
-------
PSGC land use and transportation data are tabulated by small geographic
subareas of the four-county region. Two different sets of data sub-
division have been developed: (1) traffic analysis zones (TAZ's), of
which there are approximately 600 in the PSGC area exclusive of islands,
and (2) activity allocation model districts (AAM's), of which there are
approximately 240 in the mainland study area. Within the Auburn Inter-
ceptor service area, there are 40 TAZ's and 20 AAM districts.
Trip generation and travel forecasts by AAM districts have not yet been
completed by the PSGC. Hence, previous PSGC trip generation fore-
casts (quantified by TAZ) were utilized for the VMT analysis. These
forecasts were based on PSGC's 1972 population and employment
9
forecasts.
The 40 TAZ's in the Auburn Interceptor service area were aggregated to
correspond with the AAM district boundaries. The 1972 and revised
1973 PSGC population and employment forecasts for the service area
were compared and found to be approximately within 5 percent of each other.
Person-trips generated by TAZ areas were acquired from PSGC trip
generation data. These included 1975 and 1990 forecasts. Since popu-
lation and employment estimates in the service area differ by less than
2 percent between 1970 and 1975, the 1975 forecasts were assumed to
be representative of the 1973 baseline condition sought for this study.
Person trip ends were converted to vehicle trip ends using PSGC aver-
age vehicle occupancy factors. Table C-6 summarizes the results of
this analysis.
C-18
-------
TABLE C-6. TRIP GENERATION ESTIMATES FOR THE AUBURN
INTERCEPTOR SERVICE AREA
Person Trip Ends
AAM District
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
Total
King County
1973
7,400
37,900
28,900
22, 500
107,400
12,600
45,400
11,200
93,700
31,900
12,000
9,400
35,600
22,600
19, 800
32,500
14, 800
40,500
42, 500
628,600
8,068,000
1990
31, 500
80,400
54,700
37,600
198, 300
43,000
89,200
18, 100
151, 000
61, 500
28, 800
15,400
64,000
43,600
31,900
61,000
29,900
66, 200
78,600
1, 184, 700
11,431,000
Vehicle-Trip Ends*
1973
4, 700
24, 300
18,500
14,400
68, 800
8, 100
29, 100
7,200
60, 100
20,400
7,700
6,000
22, 800
14,500
12,700
20, 800
9, 500
26, 000
27,200
402, 800
1990
19,900
50,900
34,600
23, 800
125,500
27, 200
56,500
11,500
95,600
38,900
18,200
9, 800
40,500
27,600
20, 200
38,600
18, 900
41,900
49,700
749, 800
5,172,000 7,235,000
Average Car Occupancy (AGO): 1975, 1.56; 1990, 1.58.
(See Reference 11)
C-19
-------
III. RESULTS
Table C-7 summarizes the data used to allocate 1973 area source particu-
late emissions in the Interceptor service area. Combining these data
with the 1973 emission factors yields the particulate emissions per dis-
trict as indicated.
Table C-8 summarizes the analogous information for the projection and
allocation of 1990 particulate emissions. When compared to 1973 emission
levels, an overall increase of approximately 20 percent in area source
emissions is projected to occur within the service area. This relatively
modest increase in emissions may be attributed to two factors. First, the
anticipated controls lowered the emission factors in certain source
categories as shown in Table C-Z. Second, even though population and
employment are projected to increase by much more than 20 percent,
land area remains constant. By far, the largest single portion of this
growth is expected to occur in district 3100, due primarily to the growth
in manufacturing employment projected for tnis district by PSGC. While
it may be questioned whether such significant growth may be concentrated
in a single district, there is no objective basis for assuming an alternative,
more dispersed growth pattern. Since district 3100 encompasses an
already developing part of the service area, it is not unreasonable to
assume that further development would be attracted to the same vicinity.
The results of the emissions analysis which serve as inputs to the air
quality modeling analysis are summarized in Table C-9. The UTM
(Universal Transverse Mercator) coordinates of the geographic centroid
for each activity allocation district were obtained by overlaying the dis-
trict boundaries on U. S. Geological Survey maps of the Interceptor service
area. In addition, acreages per district were obtained from PSGC. The
emissions listed for districts 3100, 3140, and 3400 differ from those
shown in Tables C-7 and C-8 due to the addition of railroad emissions.
C-20
-------
TABLE C-7. 1973 DISTRICT EMISSION CALCULATION
Non-
AAM Manufacturing Manufacturing Land Trip Emissions
District Population Employment Employment Area Ends (tons/year)
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
Total
1,
3,
3,
8,
10,
4,
4,
10,
3,
2,
2,
2,
2,
6,
3,
4,
4,
3,
82,
815
112
372
577
716
378
934
550
127
665
400
301
264
236
479
684
125
0
554
020
309
0
0
18
0
6,936
0
49
142
373
0
' 20
0
428
2
0
0
0
478
3
0
8, 449
0
0
462
0
2, 624
29
10
682
3, 907
0
117
138
1, 208
0
306
0
0
188
0
0
9, 671
4,
2,
2,
3,
3,
3,
15,
1,
4,
2,
12,
8,
2,
1,
5,
7,
1,
2,
86,
689
747
254
407
993
042
832
964
731
700
017
516
075
079
730
455
292
327
138
554
541
4,
24,
18,
14,
68,
8,
29,
7,
60,
20,
7,
6,
22,
14,
12,
20,
9,
26,
27,
700
300
500
400
800
100
100
200
100
400
700
000
800
500
700
800
500
000
200
Lumped
402,
800
29.
39.
33.
42.
174.
22.
108.
25.
103.
36.
67.
49.
40.
21.
48.
59.
20.
29.
41.
I; 7.
06
26
36
04
64
15
52
57
20
44
61
29
47
]
39
i
89
23
87
97
21
27
1,000.43
As a result of the TAZ to AAM aggregation process, trip ends
for this district were lumped into district 3460
-------
TABLE C-8. 1990 DISTRICT EMISSION CALCULATION
Non-
AAM
District
1320
3020
3040
3050
3100
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
Total
Manufacturing Manufacturing Land
Population Employment Employment Area
3, 720
5, 087
6, 372
13, 613
12, 071
2, 851
8, 164
5,977
11, 140
7, 675
9,261
3,696
3, 355
4, 250
15, 860
11, 039
7, 797
0
9,851
3, 970
145, 749
0
0
104
0
14, 179
13
290
239
335
0
30
0
434
0
0
0
0
759
0
0
16, 383
0
0
698
0
3,893
325
902
1,334
6, 111
0
364
232
2, 788
0
1, 262
0
0
391
0
0
18, 300
4, 689
2, 747
2, 254
3, 407
3,993
3, 042
15, 832
1,964
4, 731
2, 700
12, 017
8, 516
2, 075
1,079
5, 730
7,455
1, 292
327
2, 138
554
86, 541
Trip Emissions
Ends (tons /year)
19, 900
50, 900
34, 600
23, 800
125, 500
27, 200
56, 500
11,500
95, 600
38, 900
18, 200
9, 800
40, 500
27, 600
20, 200
38, 600
18, 900
41, 900
49, 700
Lumped
749, 800
35.24
47.82
40.12
45.79
245.72
32.61
110.20
27.11
103.98
43.99
71.41
44.68
45.57
26.32
57.99
67.03
26.75
33.91
51.10
7.51
1,165.66
As a result of the TAZ to AAM aggregation process, trip ends
for this district -were lumped into district 3460
C-22
-------
TABLE C-9. AREA SOURCE EMISSION INVENTORY, 1973 and 1990
AAM
District
1320
3020
3040
3050
3 IGO
3110
3120
3130
3140
3150
3220
3300
3400
3410
3420
3430
3440
3450
3460
3830
Total
UTM Coordinates
X
563. 5
555. 2
555.4
555. 7
557. 9
561.9
565. 8
561. 5
558.4
561.9
570.9
570.2
558.4
562.0
565.6
566.4
561. 4
557.4
562. 8
562. 0
Y
5,232. 8
5,236. 8
5, 241. 4
5, 244. 8
5, 236. b
5,235. 1
5, 238. 6
5, 237. 7
5,242.0
5, 243. 6
5,240. 6
5, 245. 7
5,245. 5
5,246.9
5, 246. 1
5, 251. 1
5,249.9
5,249. 1
5,253. 1
5, 255. 3
Service
Land Area
(acre s)
4,689
2,747
2, 254
3,407
3,993
3, 042
15, 832
1,964
4, 731
2,700
12,017
8, 516
2,075
1,079
5, 730
7,455
1,292
327
2, 138
554
86, 541
acres
1973
Emissions
(tons/year)
29.06
39.26
33.36
42.04
189.65*
22.15
108.52
25.57
117.20*
36.44
67.61
49.29
55.47*
21.39
48.89
59.23
20.87
29.97
41.21
7.27
1,045.43
1990
Emissions
(tons /year)
35.24
47.82
40.12
45.79
274.72*
32.61
110.20
27.11
132.98*
43.99
71.41
44.68
74.57*
26.32
57.99
67.03
26.75
33.91
51.10
7.51
1,252.66
'includes contribution due to railrpad activity.
C-23
-------
According to PSAPCA approximately 180 tons of particulate were emitted
from railroad locomotives in King County, exclusive of station operations.
On the basis of estimated track-miles, 45 tons were assumed to be
generated in the Interceptor service area and were distributed equally
among the three districts. In 1990, the railroad emissions were pro-
jected to increase by 94 percent on the basis of total manufacturing em-
ployment growth in the service area.
Finally, Table C-10 is a comparison of key statistics for the service
area relative to King County for 1973, based on the data generated in
this study.
C-24
-------
TABLE C-10. COMPARISON OF 1973 KING COUNTY AND AUBURN
INTERCEPTOR SERVICE AREA STATISTICS
King Interceptor Percent in the
Parameter County Service Area Service Area
C-25
Population 1,181,874 82,309 7%
Land Area (acres) 455,169 86,541 19%
Manufacturing Employment 103,608 8,449 8%
Non-manufacturing Employment 336,688 9,671 3%
Number of Trip Ends 5,172,000 402,800 8%
Particulate Emissions 10,673 1,031 10
-------
IV. SUMMARY
Emissions of suspended particulate matter from area sources in the serv-
ice area of the Auburn Interceptor have been projected to the year 1990.
In addition, the emissions were disaggregated in both the base year (1973)
and the target year (1990) according to activity allocation districts de-
fined by the Puget Sound Governmental Conference (PSGC). Projections
of population, employment, and motor vehicle activity obtained from
PSGC on a district basis were combined with area source emissions esti-
mates provided by both the Puget Sound Air Pollution Control Agency
and the Environmental Protection Agency, Region X, to produce the
emissions estimates.
The results of the emissions analysis indicate that an approximately 20
percent increase in area source particulate emissions may be expected
to occur in the Interceptor service area by 1990. It ^houlrl be noted
that several key assumptions were made in order to arrive at the
emission estimates. Should conditions change in the future, or additional
evidence come to light concerning these assumptions, the results should
be modified accordingly.
C-26
-------
V. REFERENCES
1. The Municipality of Metropolitan Seattle, "Auburn Interceptor
Environmental Impact Statement," January 1974.
2. Personal communication with Mr. Art Dammkoehler, Air Pollu-
tion Control Officer, Puget Sound Air Pollution Control Agency,
February 26, 1975.
3. Personal communication with Mr. Ron McConnell, Puget Sound
Governmental Conference, February 25, 1975,
4. Kennedy et al., "Air Pollution-Land Use Planning Project--
Phase I Final Report," Argonne National Laboratory Center for
Environmental Studies, November 1971,
5. Campion, R. J., et al,, "Measurement of Vehicle Particulate Emis-
sions," Society of Automotive Engineers, Paper No, 740186, 1974.
6. Personal communication with Mr. Ron Malatesta, Environmental
Protection Agency, Region X, February 27, 1975.
7. Puget Sound Governmental Conference, "Puget Sound Governmental
Conference Interim Regional Development Plan Forecasts, 1970
1990," November 1973.
8. Wilsey &t Ham, Inc., "Environmental Assessment of the Auburn
Interceptor," Appendix to "Auburn Interceptor Environmental Im-
pact Statement," Municipality of Metropolitan Seattle, January
1974.
9. Puget Sound Governmental Conference, "Populafipn and Employ-
ment Forecasts and Distribution for the Central Puget Sound Re-
gion, 1975-1990," revised 1972.
10. Sachdev, L. S., and L. Karlfritz, " Trip Generation Update, " Puget
Sound Governmental Conference, 1972.
11. Sachdev, L.S., "Forecasting Travel Patterns," Puget Sound Gov-
ernmental Conference, 1972.
12. Baldwin, T. E., and A. S. Kennedy, "The Feasibility of Predicting
Point Source Emissions Using Industrial Land Use Variables: A
Path Analysis," presented at the 67th Annual Meeting of the Air
Pollution Control Association, Denver, Colorado, June 9-13, 1974.
C-27
-------
APPENDIX D
TABLE A. FAUNA OF THE SEWERAGE AREA
AMPHIBIANS AND REPTILES
*Northwestern Salamander
*Long-toed Salamander
*Pacific Giant Salamander
*Rough-skinned Newt
*Western Red-backed Salamander
*0regon Salamander
*Tailed Frog
*Western Toad
*Pacific Treefrog
*Red legged Frog
*Spotted Frog
*Bullfrog
*Western Pond Turtle
Western Fence Lizard
Northern Alligator Lizard
Rubber Boa
*Common Garter Snake
*Western Terrestrial Garter Snake
Northwestern Garter Snake
Ambystoma gracile
Ambystoma macrodactylum
Dicamptodon ensatus
Tan'cha granul osa
Plethodon vehiculum
Ensatina eschscholtzi oregonesis
Ascaphus truei
Bufo boreas
Hyla regilla
Rana aurora
Rana pretiosa
Rana catesbiana
Clemmys marmorata
Sceloporus occidental is
Gerrhonotus coeruleus
Charina bottae
Thamnophis sirtalts
Thamnophis elegans
Thamnophis ordinoides
* These species utilize wetlands
D-l
-------
BIRDS
Common Loon
Horned Grebe
Western Grebe
*Pied-billed Grebe
Double-crested Cormorant
*Great Blue Heron
*Green Heron
*American Bittern
*Whistling Swan
*Canada Goose
Brant
White-fronted Goose
Snow Goose
*Mallard
*Gadwall
*Pintail
*Green-winged Teal
*Blue-winged Teal
*Cinnamon Teal
*European Widgeon
*American Widgeon or Baldpate
*Shoveler
*Wood Duck
*Redhead
Gavia immer
Podiceps a_urjtus_
Aechmophorus occidental is
Podilymbus podiceps
Phalacrocorax auritus
Ardea herodias
Butorides virescens
Botaurus lentiginosus
Qlor columbianus
Branta canadensis
Branta nigricans
Anser albifrons
Chen hyperborea
Anas platyrhynchos
Anas strepera
Anas acuta
Anas carolinensis
Anas discors
Anas cyanoptera
Mareca penelope
Mareca americana
Spatula clypeata
Aix sponsa
Aythya americana
D-2
-------
*Ring-necked Duck
*Canvasback
*Greater Scaup
*Lesser Scaup
*Common Goldeneye
*Bufflehead
*Harlequin Duck
White-winged Scoter
Surf Scoter
Common Scoter
Ruddy Duck
*Hooded Merganser
*Common Merganser
*Red-breasted Merganser
Goshawk
Sharp-shinned Hawk
Cooper's Hawk
Red-tailed Hawk
*Bald Eagle
*Marsh Hawk
Osprey
Gyrfalcon
Peregrine Falcon
Pigeon Hawk
Aythya collaris
Aythya valisineria
Aythya marila
Aythya affim's
Bucephala clangula
Bucephala albeola
Histrionicus histrionicus
Melanitta decjlandi
Melanitta perspicillata
Oidemia nigra
Oxyu raj ama i c e n s i s
Lophodytes cucullatus
Mergus merganser
Mergus serrator
Accipiter gentilis
Accijjiter strlatus
Accipiter cooperii
Buteo jamaicensis
Haliaeetus leucocephalus
Circus cyaneus
Pandion haliaetus
FaIco rusticolus
Falco peregrinus
FaIco columbarius
D-3
-------
Sparrow Hawk
Ruffled Grouse
California Quail
Ring-necked Pheasant
Virginia Rail
*American Coot
*Killdeer
*Common Snipe
*Spotted Sandpiper
*Greater Yell owlegs
*Lesser Yell owlegs
*Pectoral Sandpiper
Least Sandpiper
Dunlin
Long-billed Dowitcher
*Western Sandpiper
*Wilson's Phalarope
*Glaucous-winged Gull
*Western Gull
California Gull
*Ring-billed Gull
*Mew Gull
Bonaparte's Gull
Band-tailed Pigeon
FaIco sparverius
Bonasa umbellus^
Lophortyx californicus
Phasianus colchicus
Rail us 1imicola
Fulica americana
Charadrius vociferus
Capella gallinago
Actitis macularia
Totanus melanoleucus
Totanus flavipes
Erolia melanptos
Erolia minutilla
Erolia alpina
Limnodromus scolopaceus
Ereunetes mauri
Steganopus tricolor
Larus glaucescens
Larus occidental is
Larus californicus
Larus delawarensis
Larus canus
Larus Philadelphia
Columba fasciata
D-4
-------
Rock Dove
Mourning Dove
Barn Owl
*Snowy Owl
Spotted Owl
*Short-eared Owl
Common Nighthawk
Black Swift
Vaux's Swift
Anna's Hummingbird
Rufous Hummingbird
*Belted Kingfisher
Red-shafted Flicker
Hairy Woodpecker
*Downy Woodpecker
*Traill's Flycatcher
Western Flycatcher
Western Wood Pee Wee
Olive-sided Flycatcher
Horned Lark
Violet-green Swallow
*Tree Swallow
Bank Swallow
*Rough-winged Swallow
Col urnba livia
Zenaidura macroura
Tyto alba
Nyctea scandiaca
Strix occidental is
Asio flammeus
Chordeiles minor
Cypseloides niger
Chaetura vauxi
Calypte anna
Selasphorus rufus
Megaceryl e alcyon
Culaptes cafer
Dendrocopos villosus
Dendrocopos pubescens
Empidonax traillii
Empidonax difficilis
Contopus sordidulus
Nuttallornis boreal is
Eremophila alpestris
Tachycineta thalassina
Iridoprocne bicolor
Riparia riparia
Stelgidopteryx ruficollis
D-5
-------
*Barn Swallow
*Cliff Swallow
Purple Martin
Steller's Jay
*Common Crow
*Black-capped Chickadee
Chestnut-backed Chickadee
*Common Bushtit
Winter Wren
*Bewick's Wren
*Long-billed Marsh Wren
*Robin
Varied Thrush
*Swainson's Thrush
Mountain Bluebird
Western Bluebird
Golden-crowned Kinglet
Ruby-crowned Kinglet
*Water Pipit
Cedar Waxwing
Northern Shrike
Starling
Solitary Vireo
Red-eyed Vireo
Warbling Vireo
Hirundo rustica
Petrochelidon pyrrhonota
Progne subis
Cyanocitta stelleri
Corvus brachyrhynchos
Parus atricapillus
Parus rufescens
Psaltriparus minimus
Troglodytes troglodytes
Thryomanes bewickii
Telmatodytes palustris
Turdus migratorius
Ixoreus naevius
Hylocichla ustulata
Sia 1ia currucoides
Sialia mexicana
Regulus satrapa
Regulus calendula
Anthus spinoletta
Bombycilla cedrorum
Lanius excubitor
Sturnus vulgaris
Vireo so Titan'us
Vireo olivaceus
Vireo gilvus
D-6
-------
Orange-crowned Warbler
Hermit Warbler
Yellow Warbler
Townsend's Warbler
Black-throated Gray Warbler
Yellowthroat
Wilson's Warbler
House Sparrow
Western Meadowlark
*Red-winged Blackbird
*Bullock's Oriole
Brewer's Blackbird
*Brown-headed Cowbird
Western Tanager
Black-headed Grosbeak
*Evening Grosbeak
Pine Grosbeak
Purple Finch
*House Finch
Pine Siskin
American Goldfinch
White-winged Crossbill
Rufous-sided Towhee
Slate-colored Junco
*Savannah Sparrow
Vermlvora celata
Dendrolca occidental is
Dendroica petechia
Dendroica townsendi
Dendroica m'grescens
Geothlypis trichas
Wilsonia pus ilia
Passer domesticus
Sturnella neglecta
Agelaius phoeniceus
Icterus bullockii
Euphagus cyanocephalus
Molothrus ater
Piranga ludoviciana
Pheucticus melanocephalus
Hesperiphona vespertina
Pinicol a enucleator
Carpodacus purpureus
Carpodacus mexicanus
Spinus pinus
Spinus tristis
Loxia leucoptera
Pipilo erythrophthalmus
Junco hyemail's
Passerculus sandwichensis
D-7
-------
Chipping Sparrow
*White-crowned Sparrow
Golden-crowned Sparrow
White-throated Sparrow
*Fox Sparrow
*Lincoln's Sparrow
*Song Sparrow
MAMMALS
*American Opossum
Cinereous Shrew
*Vagrant Shrew
*Dusky Shrew
Water Shrew
*Marsh Shrew
Trowbridge's Shrew
*Shrew-mole
*Townsend's Mole
Coast Mole
Various Bats
*Eastern Cottontail
Snowshoe Hare
*Mountain Beaver
Townsend's Chipmunk
*Eastern Gray Squirrel
Spizella passerina
Zonotrichia leucophrys
Zonotrichia artricapilla
Zonotrichia albicollis
Pas sere11 a iliaca
Helospiza lincolm'i
Melospiza melodia
Didelphis marsupial is
Sorex cinereus
Sorex vagrans
Sorex obscurus
Sorex palustris
Sorex bendirei
Sorex trowbridgel
iieurotrichus gibbsi
Scapanus townsendi
Scapanus oran'us
Chiroptera
Sylvilagus floridanus
Lepus americanus
Aplodontia rufa
Eutamias townsendi
Sciurus carol inerisis
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Fox Squirrel
Douglas's Squirrel
Northern Flying Squirrel
*Beaver
Common Deer Mouse
*Mountain Deer Mouse
Bushy-Tailed Wood Rat
Gapper's Red-backed Mouse
*Townsend's Meadow Mouse
*Long-tailed Meadow Mouse
Oregon Meadow Mouse
*Muskrat
*Norway Rat
*Black Rat
House Mouse
*Pacific Jumping Mouse
Porcupine
*Nutria
Coyote
*Red Fox
Black Bear
*Raccoon
*Short-tailed Weasel
Long-tailed Weasel
*Mink
Sciurus niger
Tamiasciurus douglasi
Glaucomys sabrinus
Castor fiber
Peromyscus maniculatus
Peromyscus oreas
Neotoma cinerea
Clethrionomys gapperi
Microtus townsendi
Microtus longicaudus
Microtus oregoni
Ondatra zibethicus
Rattus norvegicus
Rattus rattus
Mus rnusculus
Zapus trinotatus
Erethizon dorsaturn
Myocastor coypus
Cam's latrans
Vulpes vulpes fulva
Ursus americanus
Procyon lotor
Mustela erminea
Mustela franata
Lutreola lutreola
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Spotted Skunk Spilogale putorius
*Striped Skunk Mephitis mephitis
*River Otter Lutra canadensis
Bobcat Lynx rufus
Black-tailed Deer Odocoileus hemionus
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TABLE B. FLORA OF THE SEWERAGE AREA
TREES
Western Yew
*Western Red Cedar
Grand Fir
Sitka Spruce
Douglas-Fir
Western Hemlock
Madrone
*Quaking Aspen
*Black Cottonwood
Lombardy Poplar
Pacific Willow
Seouler Willow
*Red Alder
Hazelnut
Oregon White Oak
Black Hawthorn
Bittercherry
*0regon Crabapple
Sitka Mountain-ash
Big-leaf Maple
Vine Maple
Taxus brevifolia
Thuja plicata
Abies grandis
Picea sitchensis
Pseudotsuga menziesii
Tsuga heterophylla
Arbutus menziesii
Populus trernuloides
Pop u1 us tri c hoca rpa
Populus nigra
Sajjx lasiandra
Salix scoul en ana
A_T_nus_ rubra
Cory!us cprnuta
Quercus garryana
C ra ta egus dougla si i
Prunus emarcn'nata
Pyrus fusca
Sorbus sitchensis
Acer macrophyllum
Acer circinatum
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Cascara
Pacific Dogwood
*Red-osier Dogwood
*0regon Ash
SHRUBS
Sitka Willow
*Hooker Willow
Sitka Alder
Mettl e
Tall Oregongrape
Redflowering Currant
Serviceberry
Ocean-spray
Indian Plum
Pacific Ninebark
*Salmonberry
Himalayan Blackberry
*Thimbleberry
*Hardhack
Broom
flountain Balm
Devil's Club
Bristly Manzanita
Salal
Rhamnus purshiana
Cornus nuttallii
Cornus stolom'fera
Fraxinus latifolia
Salix sitchensis
Salix hookeriana
Alnus sinuata
Urtica dioica var. 1ya11ii
Berberis aquifolium
Ribes sanguineum
Amelanchier alnifolia
Holodiscus discolor
Osmaronia cerasiformis
Physogarpus capitatus
Rubus spectabilis
Rubus discolor
Rubus parviflorus
Spiraea douglasii
Cytisus scoparius
Ceanothus velutinus
Oplopanax horridurn
Arctostaphylos columbiana
Gaultheria shallon
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*Labrador Tea
Red Rhododendron
Evergreen Blueberry
Red Blueberry
*Black Twinberry
Blue Elderberry
Red Elderberry
High-bush Cranberry
*Water-parsley
*Swamp-laurel
OTHER FLORA
*Common Horsetail
*Scouring Rush
Dock or Sorrel
Columbia lewisia
Chickweed
Anemone
*Marshmarigold
*Various Buttercups
Fringecup
Youth-On-Age
Stink Currant
Little Wild Rose
Nootka Rose
Evergreen Blackberry
Ledurn groenlandicum
Rhododendron macrophyllum
Vaccinium ovatum
Vaccinium parvifolium
Lonicera involucrata
Sambucus cerulea
Sambucus racemosa
Viburnum var.
Qenanthe sarmentosa
Kalmia occidental is
Equ i setum arvense
Equjjsgt urn fl u v i a t i 1 e
Rumex var.
Lewisja columbiana
Cerastium var.
Anemone var.
Caltha var.
Ranunculus var.
Tel 1ima grandiflorum
Tolmiea menziesii
Ribes bracteosum
Rosa gymnocarpa
Rosa nutkama
Rubus laciniatus
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Pacific Blackberry
Various Clovers
Vetch or Wild Pea
Fireweed
Kinnikinnick
Loosestrife
Bittersweet Nightshade
English Plantain
Western Twinflower
Daisy Varieties
*Canadian Goldenrod
*Western Goldenrod
*Marsh Cinquefoil
*Spiked Willow-herb
*Sundew
*Water Plantain
*Various Rushes
*Various Sedges
*Various Spike-rushes
*Various Bulrushes and Tules
Various Grasses including;
Sloughgrass
Wheatgrass
Wildrye
Ryegrass
Rubus ur sinus
Tri folium var.
Vicia americana
Epilobium angustifolium
Arctostaphylos uva-ursi
Lysimachia var.
Solanum dukamara
Plantago lanceolata
Unnaea boreal is
Erigeron var.
Solidago canadensis
Solidago occ i den ta 1 is
Potentilla palustris
Ly thrum salicaria
Drosera
Alisma p 1 antago-aquati ca
Juncus var.
Carex var.
Eleocharls
Scirpus \/ar\
Gramineae
Beckmannia syzigachne
Agropyren var.
Elymus var.
Lolium var.
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Bluegrass
Wild Rice
*Various Bur-reeds
*Common Cat-tail
*Skunk Cabbage
*False Lily-of-the-Valley
*Lady-fern
Licorice-fern
Sword-fern
Bracken
AQUATIC PLANTS
Water-fern
American Water-lily
Spatterdock
Hornwort
Crowfoot
Broad leaf Arrowhead
Pondweed
Duckweed
Poa var.
Zizania var.
Spargam'urn var.
Typha latifolia
Lysichitum americanum
Maianthemum unifolium
Athyrium filix-femina
Polypodium glycyrrhiza
Polystichum muni turn
Pteridium aquilinum
Azolla mexkana
Nymphaea odorata
Nuphar polys epalum
Ceratophyl 1 um demersum
Ranunculus
Sagittaria latifolia
Potamogeton var.
Lemna var.
* These species inhabit wetlands.
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APPENDIX E
RELATIOfJSHIP WITH EXISTING AND PROPOSED, PROJECTS, PLANS,
POLICIES, AND REGULATIONS
In order to clearly understand the relationship of the proposed
action with existing policies, plans, and regulations, and other
proposed projects, the following descriptions are provided.
THE MUNICIPALITY OF METROPOLITAN SEATTLE (!%TRO) PLANS
In 1959, the Metropolitan Council adopted a comprehensive re-
port on sewerage and drainage of the metropolitan Seattle area as
the official Metro Comprehensive Sewerage Plan. The plan set forth
the comprehensive sewerage and drainage requirements for each of
the various areas making up the metropolitan Seattle area with re-
spect to trunk and intercepting sewers, main pumping stations, and
sewage treatment and disposal facilities. It contained long range
plans for stage or step construction, estimated costs of needed im-
provements, and factual data and conclusions relative to the phy-
sical, social, and economic conditions affecting the recommended
program.
The boundaries of the Comprehensive Plan extended well beyond
the constituted limits of the Municipality at that time (the present
boundaries are contiguous with King County), in recognition of the
importance of providing facilities to serve the ultimate development
of the entire drainage area. A facility quite similar to the pro-
posed Auburn Interceptor was included as a part of the original
Metro Comprehensive Sewerage Plan, and has remained in the plan to
the present time.
On February 16, 1961, the Metropolitan Council adopted a 10-
year schedule to construct certain facilities in its Comprehensive
Plan. These facilities constituted the central or "core" portion
of the metropolitan system. In keeping with the philosophy of
providing essential services to the entire metropolitan area as
contained in the legislative act authorizing formation of metro-
politan municipal corporations, the Metropolitan Council authorized
construction of core facilities with sufficient capacity to serve
the entire metropolitan area even though much of this area was
outside the boundary of the Municipality at that time.
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The first phase of the Metro program, which has been completed,
extended sewer service to many areas not previously served by
Metro. Metro believes additional facilities to be constructed
during the second stage program have now become necessary to main-
tain receiving water quality at the levels required by regulatory
authorities and the general public, as well as to keep up with the
growth of the metropolitan area. An interceptor running from Auburn
to Metro's Renton sewage treatment plant (S.T.P.) is such a facility.
The Metropolitan Council authorized the construction of the Auburn
Interceptor in 1974, subject to the execution of an Agreement for
Sewage Disposal with the City of Auburn. Such an agreement was
adopted by Metro and the city pending Metro acceptance of a grant
from EPA for construction of the interceptor.
The continued operation of the Auburn Lagoon does not conform
to Metro's existing Comprehensive Sewerage Plan, the Puget Sound
Governmental Conference's Interim Regional Development Plan, and the
Washington State Department of Ecology's Implementation and Enforce-
ment Plan for Intrastate Waters. The Federal Water Pollution Control
Act Amendments of 1972 place additional restrictions upon the contin-
uing operation of the existing Auburn Lagoon in that secondary treat-
ment at all sewage treatment plants is required by July 1, 1977.
Metro's Comprehensive Plan is based on gravity flow in natural
drainage basins and provides for a regional sewerage system running
from Everett to the north, the foothills of the Cascades to the
east, Puget Sound to the west, and the Pierce County line to the
south. The concept of such regional systems, known as "regionali-
zation", was inspired by the Federal Water Quality Act of 1970.
The intent of the regional service concept, as interpreted by
DOE, is to limit the number of point source discharges in order to
effect better control of water quality within a drainage basin.
According to DOE, "in a heavily populated area such as King County,
numerous small or medium size commercial and domestic discharges
receiving varying degrees of treatment impose an intolerable burden
upon the rivers, streams, and lakes of the region. The most ef-
ficient, and perhaps the only effective, means of controlling such
a situation is by interception, treatment, and discharge of these
wastes on a regional basis." Since the 1972 Amendment, however,
emphasis has shifted to cost-effective systems„ This directs EPA
to consider with equal weight individual treatment facilities,
as well as other alternatives to a regional system.
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In 1971, as the Federal government began to emphasize basin
planning programs, the water pollution control commission asked King
County and Metro together to suggest ways of developing such a plan.
Local governments and agencies in the Cedar and Green River basins
were invited to form a committee for conducting the planning effort
for Metro. Representatives from nine cities and agencies together
established the River Basin Coordinating Committee. As the river
basin program took shape under the direction of this committee,
it became apparent that funding and legislative responsibilities
for the program should be under the control of elected representat-
ives. At the request of the committee, the Metropolitan Council
assumed legal and financial responsibility for the effort. Under
the guidance of the River Basin Coordinating Committee, consultants
compiled a unique series of four environmental studies which deal
directly with all aspects of water and waste management in the
Cedar and Green River basins. The PSGC Interim Regional Development
Plan was used as the basis for population and land use forecasts.
These include the Water Quality Management, Water Resources Manage-
ment, Solid Waste Management and Urban Drainage Studies.
The Water Quality Management Study developed a management plan
to achieve and maintain high water quality in the major bodies of
water within the Green and Cedar River basins. Data on water quality
and existing and potential sources of pollution have been collected.
These pollutants result from urban runoff and industrial wastes, as
well as storm and sanitary sewer systems. This study utilizes water
quality and quantity models which simulate stream and river flows
for flood and drought conditions. Thus, it relies on the models
developed in the Water Resources Management Study. The Water Pol-
lution Control and Abatement Plan, resulting from this study, will
establish water pollution control needs including plans for sewer
trunk lines, pump stations, interceptors, and industrial treatment
plants. This will include a capital improvement plan as well as a
non-facility implementation plan.
The recommendations of the RIBCO studies are about to be pub-
lished and an extensive citizen and agency review is underway. The
Water Quality Management Study recommendation for sewerage facilities
in the Metro service area essentially follows the existing Metro
Comprehensive Plan, including the Auburn Interceptor. The resulting
information has been used by EPA in making an independent analysis
of Metro's proposals.
STATE OF WASHINGTON WATER QUALITY STANDARDS
On January 8, 1970, the Washington State Water Pollution Control
Commission (later reorganized and renamed as D.O.E.) adopted a regu-
lation relating to water quality standards for all intrastate surface
E-3
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waters of the State of Washington and a plan of implementation and
enforcement of such standards. This regulation classified the Lower
Green River, including the reach below the Auburn Lagoon's outfall,
as Class A Water (Excellent).
The City of Auburn was included in an earlier Implementation
and Enforcement Plan for Water Quality Standards and was advised by
letter dated February 17, 1970, that the interception of the Auburn
Sewage Treatment Plant to the Metro Sewerage System was required.
This directive letter included the following time schedule for com-
pletion:
Contract execution for engineering services - July 1, 1970.
Completion of engineering report - October 1, 1970.
Completion of construction plans and specifications -
April 1, 1971.
Arrangement of financing, advertising for bids, and
start construction - October 1, 1971.
Facilities placed in operation - April 1, 1973.
As early as August 11, 1969, the Water Pollution Control Com-
mission stated that the use of the Auburn Lagoon should be limited
to three years. The State Implementation and Enforcement Plan
supported this statement with legal enforcement powers, which the
DOE soon utilized.
To ensure compliance with its February directive, the DOE, in
May of 1970, stated that approval of future extensions of Auburn's
local sewerage system would be denied until such time as the City
consummated a service agreement with Metro. This ban on sewer ex-
tensions is no longer in effect, although it remained in force until
1974.
LAND USE AND SEWERAGE PLANS
Land use studies and plans are the basis of the planning process
of establishing guidelines for the orderly development of an area.
Their use serves as a guide for locating parks, schools, roads and
highways, and in the determination of utility requirements. Land
use plans are also a functional device directing the establishment
of zones for various units of residential, commercial, industrial,
and agricultural land uses of an area. Land use plans also form an
essential part of population projections, for future growth is typi-
cally allocated according to proposed land uses.
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Only the local governmental bodies within the State of Washing-
ton have actually been given the power to .control and direct the use
of the land within their jurisdictions, utilizing such measures as
zoning actions. Many governmental bodies which lack legal enforce-
ment powers nonetheless create plans which act as guides for devel-
opment and growth. Because local comprehensive plans are adopted
and approved by elected representatives, the land uses proposed by
the Green River Sewerage Area local comprehensive plans supposedly
represent the desires of the study area residents. The comprehen-
sive land use plans are the only existing identifiable growth and
development policy statements regarding land use within the sewerage
area which can be implemented and enforced at this time.
THE PUGET SOUND GOVERNMENTAL CONFERENCE (PSGC) INTERIM REGIONAL
DEVELOPMENT PLAN
This plan, adopted on August 12, 1971, integrates local govern-
ments' Comprehensive Plans with the Regional Open Space Plan adopted
by the cities and counties of the region in 1965 and provides a com-
prehensive statement of goals and policies for the region.
Within the Green River Sewerage Area, the land use element of
the Interim Regional Plan has generally supported the continuation
of existing land uses with the notable exception of the valley bot-
tom areas. In the Green River Valley, except for those areas pre-
sently committed to more intensive uses (those areas already provided
with public facilities encouraging urban growth and industrial-com-
mercial development), the Interim Regional Development Plan encour-
ages agricultural and open space uses. Tjiis feature of the IRDP
conflicted with portions of some local comprehensive and land use
plans. One major conflict area, involving over 1,740 acres of land
west of Auburn's city center, became a major regional issue associa-
ted with a great deal of debate and controversy since March 1972.
This conflict area was resolved and the IRDP amended to reflect the
compromise solution reached between Auburn and the PSGC. The utili-
zation of most of this conflict area for industrial-commercial uses
would now be consistent with the Regional Land Use Plan.
A sewerage element of the IRDP shows present and future (1990)
facilities. An Auburn Interceptor is consistent with this plan as
are subsequent interceptors and trunks serving the West Valley and
Big Soos Creek areas.
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COMPREHENSIVE PLAN FOR KING COUNTY
This plan, adopted in October, 1964, defines the goals and
provides general guidance for the continuing development of King
County. This plan proposes some industrialization of the Kent and
Auburn areas; however, open space areas are specified as being
valuable to preserve within the Green River valley. The impleinen-
tation'of the King County Plan has, however, been made ineffectual
by l^he planning policies and annexations of Kent and Auburn; today,
very little county jurisdiction remains within the Green River
valley bottom.
The King County Plan does give consideration to the value of
green-belt, agricultural, or open and recreational areas by desig-
nating portions of the Upper Green River valley and Enumclaw Plateau
as agricultural reserves or very low density (less than two dwelling
units per acre) residential areas. Though extreme developmental
pressures occur, King County favors a policy of retaining the agri-
cultural functions and open space areas of these unincorporated por-
tions of the county for as long as possible, rather than allowing
widely scattered subdivisions to develop between Auburn and Enum-
claw.
PIERCE COUNTY COMPREHENSIVE LAND USE PLAN
This plan, adopted on April 2, 1962, affects approximately
seven square miles in the extreme southern portion of the Green
River Sewerage Area. Much of this area, north and east of Lake
Tapps and south of the White River, is designated as rural residen-
tial. This classification identifies areas which lie outside of
the path of immediate urban expansion and beyond the areas of subur-
ban residential development provided with adequate public services.
Rural residential uses are recommended within the Pierce County
portion of the study area in order to avoid the premature and un-
economic extension of public facilities and services.
The reservation of potential residential land in sufficiently
large parcels to permit proper subdivision at a future date is also
a beneficial feature of this proposed land use. Pierce County has
also recognized that the provision of areas where rural living can
be enjoyed with a minimum of use restrictions within reasonable
commuting distance of major employment centers complements more ur-
ban and suburban residential areas.
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KENT'S REVISED COMPREHENSIVE PLAN
This plan, adopted October 18, 1971, designates most of the
valley flat-land north of the core area of Kent and lying between
the Green River and the Valley Freeway as industrial. The land
south of the core area, between the West and East Valley Highways
is also proposed to be developed for industrial purposes. Proposed
commercial districts are in the central business district, at the
intersections of major highways, and in areas where local neighbor-
hood shopping districts are determined to be needed and already
exist.
Agricultural uses are proposed in two areas presently south
of Kent's corporate city limits in King County. The plan notes
that many factors, mast of which are beyond the control of local
government, may require a change in this land's use to something
other than agriculture, and therefore, the designation as agricul-
ture may be regarded as desirable but transitional. The flat valley
ground west of the Green River and north of the Kent-Des Moines
Highway is proposed generally as Residential-Agriculture. Residen-
tial areas are situated primarily on the plateau areas east and west
of the Green River Valley and in existing residential areas on the
valley floor. The Kent planning area population projection for 1988
anticipates 145,000 residents. In 1970 Kent contained 16,275 resi-
dents.
The PSGC has determined that the industrial space requirements
for King County will be approximately 6500 acres in the year 2000.
Since approximately 3200 acres were estimated to be in industrial
use in 1970 this indicates that only an additional 3300 will be
needed by the year 2000. Because of the technique used in generat-
ing the King County employment forecasts and because the land per
employee ratios are calculated at the aggregated level of total
manufacturing, which is by no means a homogenous category, this
forecast of dustrial space requirements for King County must be
considered a gross approximation. The PSGC has therefore calculated
a range of industrial space requirements under the assumption that
the true requirements will be within 15% of those forecasted. The
range indicates that between 2,340 acres and 4,300 additional acres
will be required for manufacturing and wholesaling uses by the year
2000.
Kent, therefore, has enough already committed industrially-
zoned land, served by existing Metro sewer systems and an adequate
city water system, to provide for all of the projected industrial
development likely to occur by 2000 within King County. Industrial
development of the Kent vicinity would be consistent with all appli-
cable regional plans.
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Despite the fact that almost all of the Green River valley
north of Kent is comprised of agricultural soils, the Puget Sound
Governmental Conference has approved the Kent Comprehensive Plan.
Regional policy of focusing development in existing utility and
service areas seems to have been more important than the regional
policies which recommend the retention of naturally suitable open
space and the conservation of critical natural processes and re-
sources. The policy of encouraging self-sufficient, identifiable
communities and reducing the need for long-distance commuting also
seems to support the Conference's industrial designation of the
valley bottom north of Kent. When the City of Kent Planning Com-
mission attempted to revert some of the industrial areas on their
comprehensive plan to agricultural designations, property owners
(30% non-residents) of these areas prevented such action.
AUBURN'S COMPREHENSIVE SEWERAGE AND LAND USE PLANS
The Auburn sewerage plan was completed in November 1968.
Several recommendations for the enlargement and improvement of
Auburn's sewerage system were proposed, including the continued ex-
tension of sewer service to areas beyond the city limits. Nearly
the entire Southwestern quadrant of the Green River Sewerage Area,
including Auburn, Algona, Pacific, and portions of Pierce and King
Counties, was proposed to be served by the Auburn system. The plan
also recommended that the ongoing city sewer separation program be
continued. Various other improvements and enlargements to the
sewer collection and treatment system were detailed.
The plan determined that the existing Auburn Sewage Treatment
Plant, a two stage stabilization and oxidation pond, was loaded to
about ninety percent of its 1968^ design capacity. Information
available at that time indicated that its capacity would be exceeded
by 1970. The Comprehensive Plan recommended that the existing lagoon
system be improved by the construction of four additional six acre
aerated lagoon structures. This system was determined to be capable
of adequately treating the projected 1980 BOD loadings of 11,200
Ibs/day and average flows of 5.3 mgd, plus industrial waste water
flows averaging 0.6 mgd.
At the same time, the plan also recommended that the City of
Auburn begin preliminary planning and discussions that would lead
to Auburn's joining Metro for the treatment and disposal of its
sewage. After further study of alternatives to joining Metro, the
City of Auburn began negotiations with the Municipality. These
negotiations continued for nearly five years before an agreement
was approved.
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Auburn's Comprehensive Land Use Plan, which was adopted
February 17, 1969, suggests that a substantial amount of the pro-
jected growth of the Seattle Metropolitan area should be absorbed
by the Green River valley. Auburn's central location, and posses-
sion of major transportation systems and large quantities of un-
developed land, were viewed as an advantage to the Auburn area with
respect to its ability to compete for industrial and population
growth. The saturation population estimates for the Auburn Planning
Area range between 98,000 and 121,000 people according to the Com-
prehensive Plan. Auburn's 1970 population was 21,817. Implementa-
tion of Auburn's Comprehensive Plan would be consistent with the
PSGC's Interim Regional Development Plan.
ALGONA'S COMPREHENSIVE PLAN
This plan, adopted in March, 1972, supports the industrializa-
tion of the eastern third of the city. Residential land uses and a
small area devoted to commercial development occupy the remainder
of the city. Of the 770 acres of land in the City of Algona, almost
sixty percent remains devoted to some form of productive agricultural
use or is classified as nonproductive and vacant land. Much of the
Algona Comprehensive Plan continues to conflict with the Puget Sound
Governmental Conference's Interim Regional Land Use Plan, which sug-
gests that the combination of existing agricultural production and
open space uses is optimal. Algona and the Conference are working
to resolve differences.
Algona is presently served by the Auburn Treatment Plant. Under
a joint agreement with Pacific, a new sewer system was completed in
1973. About sixty percent of Algona is served by this system.
Algona officials note that the areas presently unserved are not yet
populated enough to justify sewer facilities. As development occurs
in the remaining agricultural or vacant areas, sewers would be con-
structed as required by the City of Algona.
PACIFIC'S PROPOSED COMPREHENSIVE PLAN
This proposed plan completed in November, 1969, stresses the
desired residential character of the town. Low density residential
areas are proposed to occur on the Des Moines Plateau, above the
probable future extension of the Valley Freeway, and separated from
it by an existing forested open space buffer zone along the valley
wall. Medium density and multi-family housing will comprise the
valley bottom portion of Pacific, according to the unadopted plan.
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Industrial development is limited to the area adjacent to the future
freeway route and that portion of Pacific between the White River
and the Chicago, Milwaukee, St. Paul, and Pacific Railroad main line.
The streamway and shores of the White River are designated as pro-
posed parks.
Pacific's wastes are treated by the existing Auburn Lagoon,
and approximately ninety percent of the town is served by a reason-
ably adequate sewer system. Only the southwestern portion of Paci-
fic and a small development along the Valley Highway are unsewered.
BLACK DIAMOND'S COMPREHENSIVE PLAN
This plan, adopted in May 1968, anticipates moderate growth
and development in the town, yet ignores the serious water quality
problems which have plagued the Black Diamond area for years.
Black Diamond officials do acknowledge that anticipated growth will
further degrade water quality without the construction of adequate
wastewater collection and treatment facilities. Therefore, sewers
are now a top priority need in this community. The lack of.an ade-
quate sewer system is hampering growth. Black Diamond presently
has three unrelated small community systems, one serving 7 houses,
another 9, and the largest serving twenty-two homes.
PROJECTS IN THE GREEN RIVER SERVICE AREA
The following are projects for the Green River Service area
which are now in various stages of planning and implementation.
s
These projects of both industry and government will greatly
influence the growth and development of the service area. In turn,
the kind of sewerage treatment system finally selected for Auburn
may have a significant impact on the feasibility of these projects.
COMMERCIAL PROJECTS
Commercial development planned for the valley includes the
Auburn 400, a 100 acre regional shopping center in Auburn with a
350 acre industrial park in Auburn and Algona; Trillium, a High-
rise business and recreational complex in Southcenter; Glacier Park,
56 acres owned by Burlington Northern filled and for sale to indus-
tries; Black River Junction Industrial Park, a now, partially-filled
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property owned by the Milwaukee Land Company; Uplands Industries
(UPRR), an industrial park approximately 1/2 square mile; and a
Shell Tank Farm in Renton.
SOIL CONSERVATION SERVICES'S (SCS) GREEN RIVER WATERSHED PROJECT
This proposed comprehensive drainage plan will provide a 55-
mile system of drainage channels which are designed to collect and
carry runoff to pumping stations where it will be discharged into
the Green River. If this system is supplemented by local feeder
canals and land treatment measures, it would afford 100-year protec-
tion against lowland ponding. Construction has been delayed by the
necessity under NEPA to assess the impacts of this project on the
environment. The SCS is preparing an EIS on this proposed project.
CORPS OF ENGINEERS PROJECTS
Involvement of the Corps would be necessary for two projects that
have been suggested for the Green River. Benefit and cost-sharing
studies would be required before either project could be implemented.
Utilization of unused summer storage capacity of about 70,000 acre-
feet at Howard A. Hanson Dam for low-flow augmentation, fisheries
enhancement, or for water supply would required modification to the
reservoir and its operation. However, the dam itself would not need to
be raised. The City of Tacoma has expressed an interest in using the
storage for future, long-term water-supply needs, but at the moment
is relying on the recently developed North Fork well system for its
growing demands. The Washington State Department of Fisheries is also
interested in using the storage to increase the minimum summertime
flows of the Green River. Preliminary RIBCO studies have indicated
that low flow augmentation would benefit water quality. The second
project concerns additional flood control on the Green-Duwamish River.
If the SCS project or a similar pumped drainage project is completed,
then the storm drainage discharge from this plus the normal flood
releases from Howard Hanson Dam would exceed the existing river channel
capacity. This would cause bank overtopping in some low areas, parti-
cularly in Tukwila, and would endanger existing dikes in many places
from Auburn downstream. The Corps evaluated several alternatives in
a flood control study and recommended improving levees where deficient
with setbacks where desired for riverside park developments. Continu-
ation of this flood control study depends upon a statement of willing-
ness of King County to sponsor construction of the project. Cooperation
and cost-sharing by the cities involved would presumably be coordinated
by the county as principal sponsor.
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STATE HIGHWAY DEPARTMENT PROJECTS
As funds become available, it is expected that the Valley Free-
way, SR 167, from Renton through Puyallup to Fife and the Port of
Tacoma will be completed. This will make the Green River valley
more accessible.
POLICY ON STORAGE FOR Low FLOW AUGMENTATION
IN A FEDERAL RESERVOIR
Any well-designed water quality management program must neces-
sarily be concerned with the quantity and quality of the receiving
waters as well as the waste discharge. Minimum receiving flows must
be of such quantity and quality that treated waste discharges will
not cause violations of water quality standards in the stream.
As noted, dry-season flows in the Green-Duwamish River are of
insufficient quantity and quality to adequately assimilate projected
future secondary effluent loadings at Renton. Low-flow augmentation
provided from conservation storage in the U.S. Army Corps of Engineers
Howard Hanson Dam and Reservoir has therefore been suggested as an
alternative to meeting water quality standards in that area.
Section 102(b) of the Federal Water Pollution Control Act Amend-
ments of 1972 requires, in part, that in the planning of any reservoir
by a Federal Agency, inclusion of storage for regulation of stream
flow for water quality control shall be considered except that such
storage shall not be provided as a subsititue for "adequate treatment"
or other methods of controlling waste as the source. The Act further
provides that the need for, value and impact of storage for water
quality control shall be determined by EPA. Costs of streamflow regu-
lation features incorporated in any Federal reservoir or other impound-
ment under the provisions of the Act shall be determined and the
beneficiaries identified and if the benefits are widespread or national
in scope, the costs of such features shall be nonreimbursable.
Advances in pollution control technology indicate that reservoir
storage for water quality control is generally a poor substitute for
point source pollution control measures, but would be a viable control
alternative particularly where both point and nonpoint pollutants are
involved. As a basic element of flow regulation policy, the best
available point source pollution control technology economically
achievable together with best available management practices for non-
point source pollution shall be provided prior to provisions for water
quality storage. The best available point source control technology
includes advanced waste treatment techniques, land disposal, process
and procedure innovations, changes in operating methods and other
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alternatives. Nonpoint source best management practices include
land treatment practices to control run-off, application practices
for pesticides and fertilizers control, water application practices
for irrigation return flow control, vegetation, and shading practices
for temperature control and efficiency and recycling practices to
control or minimize stream diversions and flow reductions.
Application of the best technology economically achievable may not
be sufficient, in all instances, to attain the desired water quality.
Additionally, pollution from natural or nonpoint sources may not be
amenable to effective control with the techniques that are, or are expect-
ed to be, available in the foreseeable future. In these instances, the
Federal government is authorized to give consideration to providing reser-
voir storage for water quality control as a means of meeting instream
water quality standards.
The environmental and economic gains obtainable from meeting water
quality standards, or in their absence the selected water quality goals,
cannot be fully evaluated in monetary terms. However, such benefits are
considered to be at least worth the cost of implementing the best water
quality management plan to meet the standards or goals. Where the plan
includes flow regulation from incremental water quality storage in a
reservoir project as a supplement to "adequate treatment", the value of
such storage, particularly downstream economic losses prevented, shall
be assessed in monetary terms to the extent practicable. Other environ-
mental values not subject to economic evaluation shall be accounted for
and described qualitatively. Water quality monetary benefits shall not
be credited to flow regulation storage designated for purposes other
than water quality control.
Beneficiaries of flow regulation for water quality enhancement be-
yond that produced by the employment of the best available pollution
control technology and management practices are primarily the dischargers
of the treated point or nonpoint source wastes that the augmented flow is
intended to assimilate. Without the augmented flow, losses in land and
water use values would accrue or higher cost alternatives (e.g., reduction
or relocation of the waste-producing activities or reconstruction of
industrial plants and facilities) would be required to meet the water
quality standards. Many beneficiaries should be identifiable from an
inventory of point waste source dischargers and nonpoint source land
and water users.
Section 102(b) of the FWPCA amendments of 1972 requires, for cost
reimbursement determination purposes, that an assessment be made of the
extent to which the benefits of flow regulation for water quality control
are widespread or national in scope. Generally, if a relatively large
area and population is involved and if Federal and State funds are being
provided to obtain "adequate treatment" or other controls at the source
to meet National Water Quality Goals, the benefits of flow regulation
needed to complement this program would be widespread and national in
scope.
E-H £GPO 698-8
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