MANUAL FOR PREPARATION OP
ENVIRONMENTAL IMPACT STATEMENTS
FOR
WASTEWATER TREATMENT WORKS,
FACILITIES PLANS, AND
208 AREAWIDE WASTE TREATMENT MANAGEMENT PLANS
Office of Federal Activities
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JULY 1974
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Manual for Preparation of Environmental Impact Statements
for Wastewater Treatment Works, Facilities Plans, and 208
Areawide Waste Treatment Management Plans
PAGE
List of Figures i
Foreword ii
Introduction 1
Author:'.ty and Responsibility 1
Purpos e., , o 2
Flexibility in Organization and Content of
EIS. . , 2
Content of the EIS 3
Relationship of This Manual to Guidance
for Facilities and 208 Planning 4
Format of Manual t 4
Flowchart of Content of EIS ,.. 4
I. Background . 6
A. Identification of Grant Applicants and/or
Planners 6
B. Description of the Proposed Action 6
C. General and Specific Location of the
Proposed Actions 6
D. Water Quality and Water Quantity
Problems in the Area 6
E. Water Quality and Water Quantity
Objectives in the Area Other Than
Solutions of Preceding Problems 6
F. Costs and Financing 7
G. History of the Application 7
II. The Environment Without the Proposed
Action. .^ 8
A. General 8
B. Detailed Description 8
1. Climate 9
2 . Topography 9
3. Geology 9
4. Soils 9
5 . Hydrology 9
6 . Biology 10
7. Air Quality (Air) 11
8. Land Uses 11
9. Identification of Significant
Environmentally Sensitive Areas 11
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10. Population Projections and Economic
Forecasts » .. . 12
11. oUvar rroqrnmn i n t ho Area 12
12 , Aesthetics 12
III. Alternatives 13
A. General * 13
1. Purpose 13
2. Difference in Alternatives in EIS's
on Treatment Works,Facilities Plans,
and 208 Plans 13
3. Constraints on the Consideration and
Selection of Alternatives 13
3. Analysis of Alternatives in EIS's on
Wastewater Treatment Works and
Facilities Plans 14
1. Facilities Planning 14
2. General Analytical Approach 14
3. Subsystem Alternatives to be
Considered • • 16
4. Comparative Analysis to be Performed
in Developing and Selecting the
Preferred System(s) 19
5. Additional Considerations 21
C. Analysis of Alternatives in EIS's on 208 Areawide
Waste Treatment Management Plans 21
1. 208 Planning 21
2. General Analytical Approach. 22
3. Alternatives to be Considered 22
4. Comparative Analyses to be Performed in
Developing and Selecting the
Preferred Plan (s) 24
5 . Additional Considerations 26
IV. Descriptions of Proposed Actions 27
A. General 27
B. Description of Subsystems 27
1. Flow and Waste Reduction Measures 27
2. Sewers - Collectors and Interceptors 27
3. Wastewater Management Techniques 28
4. Sludge Disposal...„.,.. 28
C. Description of Additional Alternatives in
a 208 Plan 28
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^ Environmental Effects of the Proposed Actions 29
A. General * 23
1. Primary • 30
2. Secondary * 30
B. Environmental Impacts ,...31
1. Water .31
2. Air 32
3. Land 32
4. Biology • 33
5. Environmentally Sensitive Areas 33
6. Aesthetics 33
C. Additional Impacts to Consider 34
D. "No-Action" Alternative 34
E, Summary. 34
VI. Federal/State Agency Comments and
Public Participation 35
ii
3
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List of Figures
Flowchart of Contents of EIS
Figure 1
Figure 2
Development and Evaluation of
Alternative Wastewater Treatment
Systems
Development and Evaluation of Alternatives
in 208 Plan EIS
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FOREWOFD
This manual provides the framework for preparing
environmental impact statements (EIS's) when required on
wastewater treatment works, facilities plans, or 208 areawide
waste management plans and should serve as a reference to
those who must prepare such EIS's. It is intended to provide
certain minimum standards of completeness and consistency in
those EIS ' s prepared by EPA in the above categories .
This manual has been prepared pursuant to 1500. 6 (c) (iii)
of CFQ's guidelines of August 1, 1973, which requires agencies
to issue substantive guidance to agency personnel in implement-
ing the impact statement process.
I expect this manual to serve continuously as an EIS
preparation guide. It will be updated when necessary to
incorporate changes and additional information as developed.
To improve the usefulness of this manual, we need constructive
comments and suggestions reflecting your experience in its
use. Such comments should be furnished to the Director,
Office of Federal Activities, 4th and M. St., SW. , Washington,
20460.
D.C.
Sheldon Meyers
Director .
Office of Federal Activities
11
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INTRODUCTION
Authority and Responsibility
The National Environmental Policy Act of 1969 (NEPA),
Public Law 91-190, requires all Federal agencies to, "...utilize
a systematic, interdisciplinary approach which will insure the
integrated use of the natural and social sciences and the
environmental design arts in planning and in decision-making which
may have an impact on man's environment...." Section 102(2) (C) of
that Act also requires the agency to prepare an environmental impact
statement (EIS) on, "...major Federal actions significantly affecting
the quality of the human environment..." This is to be accomplished
in consultation with the Council on Environmental Quality (CEQ),
established by Title II of the Act.
CEQ has issued, "Preparation of Environmental Impact
Statements: Guidelines," August 1, 1973 (40 CFR Chapter V,
Part 1500), to guide agencies in the fulfillment of NEPA's
requirements. In accordance with these guidelines, the Environmental
Protection Agency (EPA) has published regulations for 'the prepara-
tion of environmental impact statements (40 CFR Chapter I, Part 6)
on its own actions.
General criteria for deciding when to prepare EIS's are included
in CEQ's guidelines (40 CFR 1500.6). More specific criteria for
EPA actions can be found in EPA's regulation cited above.
One of the major EPA programs involving actions which are
candidates for EIS's is the construction grants program as
authorized by Title II - Grants for Construction of Treatment Works,
Section 201 (g) (1), of the Federal Water Pollution Control Act
Amendments of 1972 (FWPCA), (Public Law 92-500). The Act
authorizes the Administrator, EPA, "...to make grants to any bcate,
municipality, or intermunicipal or interstate agency for the
construction of publicly owned treatment works...." The regional
offices, in turn, have been delegated the authority to fund
State-approved wastewater treatment projects.
Concurrent with all of these authorities is the responsibility
to assure Federal funds will produce a project which will have
maximum beneficial effects on man's environment and minimum adverse
effects.
The public laws quoted above, along with the CEQ and EPA .
regulations, constitute the authority and responsibility for the
preparation of environmental impact statements on wastewater
treatment works or facilities or 208 plans when deemed necessary
by the regional offices of EPA.
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Purpose
The purpose of this manual is to implement the requirements in
1500.6(c) C.ii) of CEQ's guidelines that each agency issue
substantive guidance to agency personnel in implementing the impact
statement process. This manual provides the framework for the EIS's
prepared on wastewater treatment works or facilities or 208 plans.
Its use will ensure certain minimum standards of completeness
and a consistency in organization and content of EIS's. Standards
for completeness are needed to ensure that relevant, available data
and analyses are not omitted from the document. Consistency in
organization and content will facilitate public and headquarters
understanding of the information presented.
The manual will serve as a useful reference for those who
must prepare EIS's. Use of the manual should also expedite the
headquarters pre-release review of EIS's, and hopefully, as
a secondary benefit reduce the need for an in-depth review
at the headquarters level on every EIS prepared.
Adhering to the contents of the manual should help ensure clear and
objective EIS's — a candid discussion of the problems to be solved,
all feasible alternative solutions to these problems and the
environmental effects of these solutions. The CEQ guidelines
(40 CFR 1500.7} are clear on the intent of the EIS process —"
''.... statements are to serve as the means of assessing the
environmental impact of proposed agency actions rather than as
a justification for decisions already made..." The presentation
of facts must be made in a form and context which will allow
the public to reach a decision on the merits of the proposed
action on their own.
Flexibility in Organization and Content of EIS
Notwithstanding the need for uniformity in the preparation
of EIS's, the organization and content of the EIS that is specified
in the manual, may be altered provided that the Regional Administrator
determines that the proposed action or circumstances related to it
warrant such changes. The manual should not be applied so rigidly
that assembly line EIS's result. One must recognize that each
IJIstewater treatment works or plan is an individual case. EIS's
should be geared to the specific complexity of the environmental
problems associated with the wastewater treatment works or plan
under review.
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In this regard *T-'s should be as brief as practicable.
To this end, if a "c- ;-• •Q'J action has an obvious overriding environ-
mental problem, the pr^parer should make this clear in the beginning of
the EIS and concentrate on that problem and its analysis while
providing summaries of the other analyses required in this manual.
The manual does not recommend techniques for forecasting
the environmental effects of proposed actions. The preparers
should use any forecasting techniques(s) determined appropriate.
Content of the EIS
The preparer should attempt to provide the information required
by this manual to the best of his ability. However, special
circumstances may prevent the inclusion in the EIS of certain
data and analyses which the manual specifies should be included.
Some of these circumstances are:
1. the information may simply not be obtainable;
2. the analysis or information is prohibitively
difficult or expensive to obtain;
3. the available data is of questionable reliability; and
4. the material required by the manual is not applicable
to the specific project under review.
In each case of omission, a concise explanation of the rationale
for not having the data or analyses should be given.
Statements should incorporate relevant, analytical
disciplines and should provide meaningful and factual data,
information and analyses. The presentation should be simple
and concise, yet include all facts necessary to permit independent ^
evaluation and appraisal of the beneficial and adverse environ- •>•
mental effects of alternative actions. The style should not,
however, require extensive scientific or technical expertise Jto
comprehend or evaluate the environmental impact. "
Although it is not mandatory to select a single, alternative
solution to the wastewater treatment problem in the draft EIS,
when analysis leads a Regional Administrator to prefer a particular
alternative, he should not hesitate to make his preference known.
In all final EIS's, however, the Regional Administrator must
select and state a single proposed action or plan.
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Circumstances may occur in which it is necessary to consider
factors not included in the manual. When appropriate, the addi-
tion of this information is encouraged. Care should be taken
to integrate the additional material into that already suggested
by the manual .
All EIS's should contain a summary sheet as required by both
the CEQ guidelines and EPA's environmental impact statement
regulations.
Relationship of This Manual to Guidance for Facilities and 208
Planning
Sections 201 and 208, Federal Water Pollution Control Act
Amendments of 1972, require facilities and areawide planning
respectively. EPA has prepared guidance to assist
applicants and their design engineers in satisfying these
requirements. This manual has been prepared in conjunction with
the above guidance and a plan submitted in accordance with 'the
guidance should contain most of the material needed
for preparing the EIS. However,, the more extensive the
communication between the regional office and the applicant before sub-
mission of the plan, the greater the chance the planning
document will contain the information required for the EIS.
Chapter III, "Alternatives," of this manual discusses the
differences in the consideration of alternatives in EIS's on
wastewater treatment works, facilities plans, and 208 plans.
Format of Manual
The order of chapters in the manual does not follow the
specific order of the "Contents of EIS's" as stated in the
CEQ guidelines — the significant difference being the
Alternatives Chapter is located near the beginning, before
the discussion of the proposed action. This was done to place
more emphasis on the development of alternatives rather than on
the justification of the proposed alternative. The Alternatives
Chapter provides a logical exposition of the development of the
proposal — explaining the problems and constraints, the
subsequent evaluation of possible solutions and finally,
the selection of the proposed alternative. Because of the change*
order only a brief summary of the proposed action should be
provided in the Background Chapter of the EIS.
Flowchart of Content of EIS
1 is a flowchart to assist in visualizing the systematic
gathering of information for the EIS and the processing 0f that
information into the completed document.
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I. Background
A. Identification of Grant Applicants and/or Planners
Potential grant applicants should be identified as well as
the entity that prepared the facilities or 208 plan, if appropriate.
The identification of applicants should include the Grants
Administration digital identification number as shown in Chapter 12,
Part I, "Grants Administration Manual" if available.
B. Description of the Proposed Actions
A brief description of both structural and non-structural
actions should be provided. Specific details should not be given
here. These should be covered in Chapter IV, "Description of the
Proposed Action."
C. General and Specific Location of the Proposed Actions
To minimize the narrative, a clearly defined map of
the planning area or the general area in which the proposed
action will take place should be provided if available. All
relevant treatment works and other structural alternatives should
then be specifically located on the same map. The narrative should
briefly describe the location of the works, referencing river systems,
drainage basins and major surface and groundwaters.
D. Water Quality and Water Quantity Problems in the Area
A very brief summary discussion of the major water quality
and water quantity problems in the area should be provided.
(A more detailed description should be included in Chapter II).
Include those problems which occur within the area even though
the proposed action will not provide a complete solution at
this time. Where appropriate, summarize or reference water
quality standards or effluent limitations.
E. Water Quality and Water Quantity Objectives in the Area
Other Than Solution of Preceding Problems
Examples of additional objectives and goals are:
1. streamflow augmentation for enhancing water supplies
downstream, stream fisheries, recreation or aesthetic values;
2. preservation or development of recreation areas,
wetlands or attractive open spaces;
3. preservation or enhancement of high quality waters
with recreational, fish and wildlife or aesthetic values;
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4. groundwater recharge for augmenting water supply
and/or preventing salt-water intrusion;
5. alleviation of groundwater pollution; and
6. reuse of treated wastewater such as recycling of
nutrients in treated wastewater.
F. Costs and Financing
Enumerate the total anticipated cost, the amount eligible
for a grant under Section 201(g)(1), Public Law 92-500 and
the Federal and State dollar contributions and percentages of
the total cost each will pay if the proposed actions are
recommended and approved.
G. History of the Application
If a grant application >>as been received, briefly
describe the origin of the application, its priority determination
and State certification.
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II. The Environment Without the Proposed Action
A. General
The social, economic and environmental setting of the
area of the proposed action is important tor the decision maker
and the public. The environmental setting is the starting
point from which forecasts of the environmental impact of the
proposed action must be made. The same environmental categories
used in this chapter to describe the environmental setting are
used in Chapter 5, "Environmental Effects of the Proposed Action,"
to describe the environmental impacts after implementing the
proposed actions. While the focus should be on the immediate
area of the proposed actions, where appropriate, parts of the
surrounding area should also be included to avoid the risk of overlookin<
any important interbasin or regional impacts.
The importance of using maps to illustrate topics is
stressed—especially where environmentally sensitive areas are
concerned. The narrative should be concise, not exhaustive.
Only those characteristics of the social and environmental setting
which are most important in relationship to the proposed action
should be discussed in any detail, and those which are not
particularly relevant should be omitted.
B. Detailed Description
The environmental description should include the following
items when they are relevant to the analysis of alternatives or
determination of environmental impacts of the proposed action.
Note that in many instances certain of these items will not be
relevant to the decisions to be made, or their significance
can be appropriately covered by a very brief description.
See the note below for mandatory items.
NOTE: Only those items with asterisks need be included in all EIS1s,
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1. Climate
Describe the climatic conditions for the general
area of the proposed actions including temperature,
precipitation, humidity, and wind direction and velocity.
List any specific weather conditions, such as inversions,
fog, tornadoes, and hurricanes, and the frequency at which
they may be anticipated. Also describe any topographic features
which influence the weather.
2. Topography
Describe the topography of the area of the proposed
actions delineating the major and minor drainage basins
along with their characteristics—area, slope, elevation,
natural and artificial drainage nets, erosion, and
deposition.
3. Geology
Describe the geology of the appropriate area.
Geologic structures or formations that have a direct
influence on either groundwater or surface water resources
should b'c. specifically mentioned. Areas which are particularly
susceptible to earthquakes, landslides, subsidence or other
earth movement should be located on an area map and described
briefly.
4. Soils
Identify soil types and their permeability, erosion
potential, expansion, compaction and other characteristics
in the appropriate areas.
5. Hydrology (Water)
a. General
Describe the relevant surface water bodies and
groundwater aquifers in the area.
b. Water Quality
Describe the existing surface and groundwater quality
using physical, chemical and biological parameters.
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c. Water Quantity
. Describe the existing surface and groundwater quantity and
relate to water uses in section e below. Include a discussion
of surface water volume, stream flow rates and the frequency
and duration of seasonal variations (specify the 7-day 10-year
low flow, groundwater storage volume or extent and depth of
the major aquifers, and their rate of recharge and/or depletion.
Where relevant to decision making the following material should
also be included. If regulating (dams; locks) or diversion (dams;
tunnels; canals) structures are in place, or proposed, these
should be identified. Structures influencing stream-flow
should be located on an area map; the recharge areas for
replenishing ground water should also be identified on this map.
*****
d. Water Quality and Quantity Problems
Identify existing and potential water quality and quantity
problems in the area. Address specifically the relevant
point and non-point sources of pollution such as those arising
from industry, municipalities, combined sewers, storm water
run-off, agriculture, silviculture, aquaculture, mines or mine
drainage, and salt water intrusion.
*****
e. Water Uses
Describe the type and extent of existing and
future surface and groundwater uses. If reuse or reclamation
of water is practical in the area, this should be explained.
Regulatory and administrative procedures in force to reduce
water consumption (thereby reducing waste volume) should be
noted if significant.
*****
f. Water Quality Management
Describe or reference all pertinent areawide or
basin water quality management plans, court ordered allotments
or interstate compacts involving water quality/quantity in the
project area. If State or local water pollution control agencies
have issued permits or orders on specific water resources,
these should also be identified.
g. Flood Hazards
Indicate the 25, 50 and 100-year flood levels for the area.
Identify any Corps of Engineers flood-plain plan or proposed
project.
6. Biology
a. Indicate those species in the area which have been
designated rare or endangered, either at the State level or
nationally.
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b. Describe wildlife habitat or portion thereof
which might be affected by the project.
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7. Air Quality (Air)
To the extent pertinent discuss the major factors
directly affecting air quality and the current and anticipated
future air quality in the project area. Identify and reference
the air implementation plan ^or the area.
3. Land Uses - The following should be provided any time
interceptors or collectors are being proposed to service
presently undeveloped areas or will be routed through
such areas. The material should be prepared in conjunction with
that required in Chapter V, Section B.3.
a. If available, include a map of existing land uses
such as residential, commercial and services, industrial,
cluster housing, strip development, extractive (mining, etc.),
transportation, communications and utilities, institutional,
open space and outdoor recreation, agricultural, forest land,
water, archaeological, historical and other points of interest
in the area of the interceptors.
b. If available, include a map of land uses, both
private and public, for those categories listed above, which
are currently being proposed by local, State, national or
regional governments in the areas of the interceptors.
c. Describe the extent and effectiveness of current
land use planning by all levels of government.
/•
d. Describe the administrative and regulatory land
use controls now in effect.
e. Describe development trends for the industrial,
agricultural, commercial, residential, and recreational
sectors — especially those near or around bodies of water.
f. Describe any aspects of these trends which might
threaten air or 'water quality or bring about other environmental
problems.
*** ^• identification of Significant Environmentally
Sensitive Areas
Identify and show on a map any of the following
which may be significantly impacted by the proposed action, and
which are not described elsewhere in this chapter:
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1. surface waters,
2. marshland, wetlands, and estuaries,
3. flood plains or flood-retention areas,
4. groundv>*ater recharge areas,
5. steeply sloping lands,
6. forests and woodlands,
7. prime agricultural lands,
8. habitats of rare and endangered species,
9. public outdoor recreation areas,
10. sensitive geologic areas, and
11. archaeological and historic sites.
10. Population Projections and Economic Forecasts
Designate the current and projected population
levels (5, 10, and 20 years). In discussing these population
trends, the rates of growth for the region contained in reports
for the Water Resources Council by the Bureau of Economic
Analysis, Department of Commerce and the Economic Research
Service, Department of Agriculture (the OBERS projections)
should be considered. The reasons for using a particular
projection or forecast should be stated briefly.
***** 11. Other Programs in the Area
Describe local, State, and Federal projects, planned
or underway which have or will have an impact (social, economic,
or environmental) on the area, if there will be a major
interaction between these projects and the proposed water
quality action. Also discuss the interaction.
12. Aesthetics
Describe the area's general aesthetic quality.
Where appropriate, discuss noise levels, man-made objects,
other items not handled elsewhere, and the overall "composition"
mirrored by the total aesthetic picture.
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1. Purpose
The chapter on "Alternatives" should contain:
a. a systematic development of all feasible
alternatives for the solution of the identified water quality
problems; and
b. a rational comparison of all feasible alternatives,
including the identification of critical differences leading to
the selection of one (or more) alternative(s) over another.
Both the development and comparison should be presented
in a clear and concise manner so the reader can follow the logic
of the Agency's decision-making process. A single preferred
alternative representing the Agency's proposed action does not
have to be selected in the draft EIS but must be selected in
the final EIS.
The type of information to be included, how it should be
presented to the reader, and guidance for the alternative to be
developed and comparison processes are contained herein.
2- Differences in Alternatives in EIS's on Treatment Works,
Facilities Plans, and 208 Plans'
The types of alternatives that should be included in
an EIS will depend in part on whether it is an EIS on a treatment
work, facilities plan, or 208 plan. A description of what should
be considered in the alternatives section in each of the above
kinds of EIS's is discussed in Sections B and C below.
3. Constraints on the Consideration and Selection of
Alternatives
Regardless of the type of EIS, the alternatives section
should contain a discussion of limiting factors, assumptions, or
conditions that affect the scope of alternatives considered
or analyses performed. These constraints may be sufficient
reason to reject a large number of alternatives outright,
eliminate a portion of the analysis without further consideration,
or they may reflect on the effectiveness or scope of available
alternatives. Examples of such constraints include:
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a. the proposed treatment work is intended to
demonstrate a particular technology (example: nitrogen removal);
b. a substantial investment in existing facilities may
preclude certain alternatives;
c. the treatment work is limited in scope and only a
partial analysis is necessary (example; modification rf an existing
facility); and
d. an EIS has already been prepared adequately
covering certain portions of the facility, problem, or area and
need not be repeated in this evaluation, except by reference
(example: EIS on the effects of ocean outfalls — over an
extensive portion of a coastline). The region may in fact, wish
to prepare similar standard or generic EIS's to preclude
having to repeat the same material in each EIS to be prepared.
B. Analysis of Alternatives in EIS's on Wastewater
Treatment Works and Facilities Plans
1. Facilities Planning
Facilities planning is designed to provide for
cost-effective, environmentally sound and implementable
treatment works which will meet the applicable requirements of
the Federal Water Pollution Control Act Amendments of 1972.
The major emphasis is on the prevention and solution of point
source water quality problems. Alternatives developed to accomplish
this are technical alternatives, and include both structural and
non-structural alternatives.
2. General Analytical Approach
Alternatives for EIS's on treatment works and facilities
plans should be systematically developed and selected through a
combination of subsystems and systems analysis. The analysis
should be broken down into the structural and nonstructural
subsystems specified in section 3. For each subsystem there
are a number of alternatives available to the design engineer.
These subsystem alternatives should be screened and compatible
subsystems should be combined into system alternatives. Finally,
a preferred system(s) is selected after a more detailed comparative
analysis or screening process. The entire process is shown
schematically in Figure 2.
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Tb simplify the alternatives section, the Regional Adminis-
trator may wish to provide a standard document on subsystem alternatives
which must be rejecter! for a particular area. For example,
shallow well injection of treated effluent may be unacceptable
due to groundwater formations. This document could then be
referenced in the individual project EIS.
* One alternative which should always be included
is that of "no action" — allowing the existing wiiStewater
treatment works or septic tanks to continue in use — so that
the public will understand the environmental implication of
allowing the status quo to continue.
1 3. Subsystem Alternatives to be Considered
The four major subsystems and the alternatives within
each that should be considered are:
a. Flow and Waste Reduction Measures
1) infiltration/inflow reduction by sewer system
rehabilitation and repair and elimination of roof and foundation
drains;
2) household water conservation, measures, such as
household water saving appliances and fixtures as well as; designing
more appliances for less water consumption;
i
3) water and wastewater rates that impose costs
proportional to water used and wastewater generated and use of
water meters; and
..-- 4} educating the prJslic on the value of their water
resources., in order to reduce the if consumption.
b. Sewers - Collectors and Interceptors
1) Constructing new sewers - alternatives should be
developed which differ in the following characteristics:
- routing
- service area
, - design capacity
- design period
- phasing of construction
2) Rehabilitation of existing sewers
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c. Waste Management Techniques
Alternative waste management techniques should be
evaluated to determine the BPWTT1 for meeting applicable effluent
limitations including those related to wasteload allocation.
Information pertinent to this evaluation is contained in an EPA
document entitled, "Alternative Waste Management Techniques for
Best Practicable Waste Treatment" (Proposed in March 1974).
Selection of a waste management technique relates closely to the
effluent disposal choices that are available. Preliminary alternative
systems featuring at least one technique under each of the three
categories below (treatment and discharge, wastewater reuses,
and land application or land utilization) will be identified and
screened, unless adequate justification for eliminacing a technique
during the screening process is presented.
1) Treatment and Discharge to Surface Waters
Treatment techniques are specified below. Alternative
sizing, phasing of construction, and location of treatment works
should also be compared.
- Biological treatment including ponds, activated
sludge, trickling filters, processes for nitrifica-
tion, and denitrification.
- Physical-chemical treatment including chemical
flocculation, filtration, activated carbon,
break-point chlorination, ion exchange, and ammonia
stripping.
- Systems combining the above techniques.
- The "no action" alternative such as using septic
tanks or not upgrading an existing treatment plant
should always be considered for the sake of
comparison.
Surface waters can include: rivers, streams,
lakes, estuaries, bays, and the ocean. In EIS's where surface
discharge is the most promising alternative, a number of different
discharge points should be considered.
Reuse
In comparing waste management techniques and alterna-
tive systems, wastewater reuse applications should be evaluated as
a means of contributing to local water management goals. Such
applications include:
I/ Best practicable waste treatment technology.
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»?*$•»«*.•**•
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- Industrial processes
- Groundwator recharge for watur Hupply unlianuumunt
or preventing salt-water Intrusion
- Surface water supply enhancement
- Recreation lakes
- Land reclamation
Wastewater reuse needs should be identified and
defined by volume, location, and quality. These needs may influence the
location of the treatment facilities, the type of piocess selected,
and the degree of treatment required.
3) Land Application
The application of wastewater effluents on the land
involves the recycling of most of the organic matter and nutrients
by biological action in the soil plus plant growth for the break-
down and disposal of nutrients. Such treatment generally provides
a high degree of pollutant removal. Planning of the land applica-
tion techniques should reflect criteria and other information contained
in the EPA document on "Alternative Waste Management Techniques for
Best Practicable Waste Treatment." Different locations for land
application should be considered in the analysis.
Land application techniques include:
- Irrigation including spray, ridge and furrow,
and flood
- Overland flow
- Infiltration-percolation
- Other approaches such as evaporation, deep
well injection, I/ and subsurface leach fields.
d. Sludge Disposal 2/
The alternatives in each of the categories below
should be considered. Alternative sites should also be compared.
IT Refer to Administrator's Decision Statement No. 5, Feb. §T,
for guidance.
2/ The letters identify the various stages in sludge handling and
disposal. The alternatives available for each step are arrayed
below each stage.
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1) sludge stabilization
-- aerobic and anaerobic digestion
— composting
— chemical treatment
— physical processing
2) other processes
— thickening
— conditioning
— dewatering
— heat treatment for disinfection
— drying
3) final disposal
— incineration
—• land spreading/ or other land application
methods
— landfill
— pyrolysis
— composting
— ocean I/
— deep well injection
4. Comparative Analysis to be Performed in Developing
and Selecting the Preferred SystemTsil
A number of comparative analyses or screens should be
conducted during the systematic development of system alternatives.
The basic comparisons to be made in each screen are discussed below.
Refer to EPA - "Ocean Dumping" - Final Regulations and Criteria,
Federal Register, Vol. 38, No. 198, Part II (40 CPR, Chapter I,
Subchapter H, Part 220 - 227), October 15, 1973.
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All comparisons should be discussed in narrative form and displayed
in a summary chart. The major reasons for acceptance or rejection
of an alternative should be stated in each case.
a• Subsystem elimination Screening
Subsystem alternatives should be initially screened
to eliminate those that are not feasible. The screening should
consist of a comparison of the subsystem alternatives with respect
to:
1) solution of major water quality problems and
progress toward other identified objectives or
goals;
2) significant adverse environmental effects; and
3) rough capital, maintenance and operating costs. I/
In many instances, the interaction of subsystems
will be such as to require their selection on the basis of a
preferred combination rather than on the basis of an individually
preferred subsystem. For example, the method of effluent disposal
will determine the level of treatment needed. A few of these
interactions are shown in Figure 2 as arrows between the subsystems.
b. Development and Preliminary Screening of Systems
Following the selection of a set of subsystems
and subsystem locations, subsystems should be combined into feasible
system alternatives. A preliminary systems screening should then
be conducted to identify the best of the system alternatives.
The same comparisons made during the subsystem screening should be
made for this screening.
c* Final Detailed Systems Screening
The systems remaining after the preliminary screening
will be compared in more detail on the basis of:
£pr
I) contributions to water quality goals and
objectives;
2) present value or average annual equivalent value
of capital and operating costs for overall
alternative and subsystem components;
3) significant environmental effects of each
alternative including a specific statement on
future development impacts; and
4) operability, reliability and flexibility of
each alternative and any subsystem included in
each alternative.
I/ Unless subsystem alternatives have been rejected on a cost basis,
it is not necessary to prepare cost comparisons until system
alternatives are considered.
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5. Additional Considerations
When there are overriding and obvious reasons
for rejecting an alternative, it is not necessary to develop all
of the above comparisons. *
When there is no perceptible difference between
alternatives during the comparison process, a statement to
that effect is sufficient.
If a system contains a subsystem component
designed for a period less than the life of the entire facility,
at which time it will be replaced or upgraded, the comparative
analysis should reflect this. The discussion should also
emphasize those alternative sv,':tems that appear promising in
terms of environmental protection. Different designs for systems
that are essentially identical with respect to environmental
effects should be considered only if their costs are appreciably
different.
The concept of centralized vs. decentralized
systems is receiving increased attention in current system
proposals. When evaluated on the cost of the facilities alone,
the analyses often neglect to discuss adequately the residential,
commercial and industrial development that a centralized project
can induce. Their vast network of collectors and interceptors
often open up many new areas for development, or more rapid growth.
The final system screening should specifically speak to these
environmental implications of each system.
C. Analysis of Alternatives in EIS's on 208 Areawide Waste
Treatment Management Plans~
1. 208 Planning
208 planning entails both technical planning, which
includes identifying water quality problems and developing
alternatives to solve them, and management planning, which includes
determining jurisdictional, management, or authority problems,
and developing a management system to implement, the proposed
technical alternatives. The EIS on a 208 plan should concentrate
on the technical alternatives, although some outputs of the
management planning are likely to be included as objectives or
constraints.
The technical alternatives considered in an EIS on a 208
plan should include those designed to solve or prevent both point
source and non-point source water quality problems. These
technical alternatives should encompass both structural and
non-structural alternatives. Land use considerations play an
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important part in this planning. An important difference between
the alternatives considered in an EIS on a 208 plan and a facilities
plan is that the letter's f,l eernatives are limited primarily to
point source alternatives.
2. General Analytical Approach
The analysis of alternatives in an EIS on a 208 plan
will be much more extensive -than that required on a facilities plan.
The entire process for a 208 plan is shown in Figure 3.
The analysis is broken up by types of sources. Alternatives
are compared and developed in the categories where there are
identified problems. Preliminary comparisons are conducted in
two categories - municipal wastewater treatment facilities and
nonpoint source discharges. For the former the preliminary
analysis is identical to that which would be performed in a
facilities plan. For the latter, unfeasible options are eliminated
with a preliminary screening analysis. After the preliminary analyses,
the remaining systems or options within each of the categories
are combined into subplans, which are screened to select the best.
Finally, the subplans remaining after the screening are combined into
areawide plans. These are then screened to yield the proposed plan.
3. Alternatives to be Considered
Alternatives to be considered are specified below.
a. Point Source Alternatives
The point source alternatives associated with
municipal wastewater treatment facilities, both structural and
non-structural, that should be discussed in an EIS on a 208 plan
are the same ones that should be discussed in an EIS on a facilities
plan. Similar alternatives should be compared for industrial
am? other facilities when appropriate. Alternatives for intermittant
ooint sources should be developed on a case by case basis.
A minor difference in terminology between the facilities and 208
planning guidance exists; the term systems alternative used in this
manual and the facilities planning guidance is referred to as point
source subplan in the 208 guidance.
b. Nonpoint Source A1 t*:rn_atives
A number of nonpoint source alternatives both
structural and non-structural, designed to prevent or alleviate
nonpoint source water quality problems, should be considered in
an EIS on a 208 plan. The Alternatives that should be considered
are those that are included in the "Guidelines for Areawide Waste
Treatment Management" under the following categories,
when those categories arc applicable to problems that have
been identified:
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1) Urban storrawater runoff
2) Construction activities
3) Hydrographic modification
— channelization
— water impoundments
— urbanization
— dredging and dredge spoil disposal
4) Land and subsurface disposal of residual waste
— land and subsurface disposal of liquid wastes
— land and subsurface disposal of solid wastes
5) Agricultural activities
6) Silvicultural activities
7) Mining activities
8) Salt-water intrusion
4. Comparative Analyses to be Performed in Developing
and Selecting the Preferred Plant's)
A number of comparative analyses or screens should
be conducted during the systematic development of areawide plans.
The basic comparison to be made in each screen are discussed below.
All comparisons should be discussed in narrative form and displayed
in a summary chart. The major reasons for acceptance or rejection
of an alternative should be stated in each case.
a. Preliminary Comparisons of Subsystems and Systems
for Wastewater Treatment Facilities
The same screening analyses included in an EIS on
a facilities plan shall be included in an EIS on a 208 plan.
b. Preliminary Comparison of Nonpoint Source Options
Nonpoint source options shall be screened to
eliminate those that are not feasible. The screening shall consist
of a comparison of the following:
1) contributions to major water quality goals and
objectives of each alternative;
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2) rough costs;
3) significant environmental effects of each
alternative;
4} operability, reliability and flexibility of
each alternative; and
5} waste load characteristics of each alternative
expressed in appropriate units for relating
to the water quality prediction model.
c. Development and Screening of Subplans
Systems and other options remaining after any
preliminary analyses shall be combined into subplans for each
category of pollution source.. The subplans shall then be screened
to select the best. The screening shall consist of the following
comparisons:
1) contributions to water quality g"oals and
objectives;
2) present value or average annual equivalent
yalue of capital and operating costs for overall
alternative and any subsystem components;
3) environmental effects of each alternative
including a specific statement on future
development impacts\
4) operability, reliability and flexibility and
5) wasteload characteristics of each alternative
expressed in appropriate units for relating
to the water quality prediction model.
d. Development and Screening of Areawide Plans
The subplans remaining after the subplan screening
shall be combined into areawide plans. These in turn shall be
screened to select the preferred plan(s). The screening shall
consist of a comparison of the same factors used to screen
subplans with the addition of:
&
.r
*
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1) economic and social effects; and
2) public acceptability.
5. Additional Considerations
It is not necessary to repeat the same comparisons
in the narrative with each screening process. They need only be
briefly noted in the summary chart. The major reason for favoring or
rejecting an alternative should always be stated, however.
\
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IV. Description of Proposed Actions
A. General
Both structural and non-structural proposed
actions should be described. Depending on the type of EIS,
the description should be approached in different ways.
For EIS's on wastewater treatment works and facilities plans,
the actions should be described in terms of their subsystems.
For EIS's on 208 plans, subsystem descriptions should be
used when the alternatives making up the plan are like those
in a facilities plan. Other alternatives making up the 208
plan should be described in any fashion that is appropriate.
B. Description of Subsystems
The content of the description of each subsystem
comprising the proposed action is discussed below. When
applicable, the reliability of unit processes should be noted
(reference EPA-430-9974-001), especially those design features
involved with controlled diversions. If a site plan is available
for a structural subsystem it should be provided.
If energy conservation features have been included
in the proposed action, these should be described. Examples are
the use of processed digester gas as a fuel source or the
selection of equipment which minimizes energy consumption.
The Regional Administer may wish to prepare standard
descriptions of widely accepted subsystems for use in EIS's.
This would reduce the amount of repetitive writing needed
for individual EIS's.
1- Flow and Waste Reduction Measures
Describe how the proposed action(s) will be
implemented and what the likelihood of success is.
2. Sewers - Collectors and Interceptors
Provide a map of the collector and interceptor
network which can be easily compared with the land use map
provided in Chapter II. If collectors or interceptors, or
both, are planned for an area which is not currently developed,
the reason for providing service should be discussed. Include
the capacity, size, design period, any phased construction,
and other features.
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3. Wastewater Management Techniques
Describe the treated effluent disposal system
including the location,, type, size, design period and other
features. If disposal is to the ocean or by well injection,
applicable regulations must he considered. Effluent quality,
water quality standards, effluent limitations and the maximum
daily load of pollutants for receiving waters should be
adequately discussed.
Describe the basic wastewater treatment plant with
a minimum of engineering detail to avoid confusing a lay
audience. Include the size, type, location, design period,
any phased construction and other features. Describe influent
to the plant and the treatment and hydraulic capacity of
the plant in relation to water quality standards and the
current population of the community, include the explanation
of any excess capacity. Identify any recirculation systems
which v I increase plant efficiency.
4. Sludge Disposal
Describe the sludge treatment, conditioning and
disposal processes, including the location, type, size design
period and other features. If disposal is to the ocean,
applicable regulations must be considered.
c* Description of Additional Alternatives in a 208 Plan
Discuss the additional alternatives that make up the proposed
areawide plan in any fashion that is appropriate.
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V. Environmental Effects of the Proposed Actions
A. General
This chapter of the EIS is second in importance only
to the chapter on Alternatives. Both the beneficial and
detrimental environmental effects of the proposed action
should be discussed in detail. Where the action will
measurably improve or enhance the environment, the effects
should be explained. Where an adverse environmental effect
is probable, the steps taken to mitigate the results should
also be discussed.
While there is no optimum approach for systematically
identifying and describing the complete environmental effects
of the proposed action, the approach outlined below is
Teconmven&e5.. Tn \3c\is appxoadh, t*xe enviroiatvent is &ivi&e5.
into natural categories—the same as those appearing in
Chapter II, "The Environment Without the Proposed Action":
—- Water
— Air
— Land
— Biology
— Environmentally Sensitive Areas
— Aesthetics
By using the same natural categories appearing in
Chapter II, a direct comparison can be made between the
environment before and after the project is installed.
In narrative form this chapter should describe the
environmental impact of the proposed structural and
non-structural actions on each natural category and its
subsections. In many cases, the impact on a category and
subsection may be associated with a single option,
alternative or subsystem. However, if more than one
subsystem or alternative impacts a category, the
cumulative impact should be described. The subsystem or
alternative contributing to the impact should always be
identified. Impacts should be characterized as:
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— beneficial or ailverse;
— short or lonq-term;
-- reversible or irreversible; arid
— primary (direct) or secondary (induced).
Examples of adverse, long-term, irreversible impacts
that should be carefully reviewed are:
1. Primary
a. destruction of historical, archaeological,
geological,cultural, or recreational areas;
b. contamination of groundwater aquifer from
failure or through saltwater intrusion;
c. destruction of sensitive ecosystems (e.g., wetlands);
d. materials consumed in construction and operation:
chemicals in treatment process, consumption of energy,
construction materials;
e. eutrophication of a body of water;
f. jeopardizing an endangered species;
g. displacement of population; and
h. operational accidents (e.g. chemical spills).
2. Secondary
a. changes in the rate, density, or type of development,
including residential, commercial, industrial, or changes in the
use of open space or ether categories of land;
b. air or water quality standard violations stemming
from secondary development; and
c. damage to sensitive ecosystems (e.g. wetlands) or
jeopardy to endangered species, resulting from the secondary
growth.
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B. Environmental Impacts
To reduce the length of this chapter, only selected
natural categories will be explored in detail with examples.
1. Water
a. Water Quality
The wastewater treatment plant and treatment effluent
disposal subsystems affect water quality, as explained
in the following example: The improvement of surface water
quality by a higher degree of wastewater treatment would be
an environmental benefit. The same high degree of treatment
might reduce turbidity and BOD to the point where algae
could grow (possible detriment) while the nutrients
(nitrates or phosphates) that had not been removed might
accelerate this growth. Consequently, there could be
a short-term improvement in water quality which would
result in a long-term adverse impact. Both would most
likely be reversible, however.
The sludge disposal subsystem also affects water
quality, as explained in this example. Proper sludge disposal
on land would prevent surface water quality degradation over
the long-term. If the water table were overlain by pervious
strata, however, the quality of the groundwater might suffer
over the long-term. Once contaminated the effect would
probably be irreversible.
b. Water Quantity
The treated effluent can affect water quality, as
explained here: The return of treated effluent to the
surface watercourse might produce sufficient flow to allow
several beneficial downstream uses over the long-term
(recreation, fishery, water supply). By not selecting
groundwater recharge as a treated effluent disposal method,
threaten future supply (detriment). While depletion can
be reversed, once contamination of the aquifer occurs it
is not easily corrected.
The same review can be performed on the remaining
subsections of this natural category (see below). The
relationship between the project environment and the
subsystem becomes clear rather quickly. Experience in
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writing the EIS will probably reduce the individual number
of assessments to be made.
c. Water Quality problems - examples will not be
provided,
d- Water Uses - examples will not be provided.
e. Water Quality Management - examples will not be
provided.
2. Air
An important factor to consider here is the effect on
air quality of the increased availability of sewers in undeveloped
areas. High population densities bring improved roads, more motor
vehicle miles and finally a decrease in air quality. If the air
quality in the project area is marginal, the project may produce air
pollution while solving a water quality problem. The air pollution
impacts may be adverse, of long-term duration, and irrever-
sible. The proper incineration of sludge (without violation of air
quality standards) is a complex problem. The design of air quality
standards) is a complex problem. The design and operation of the unit !
must also consider the water quality (scrubbers) and solid waste I
(ash) problems involved. Impacts here might be reversible with an |
appropriate process change.
3. Land
The total picture of land use and the inherent
environmental impacts should be explored. This category is
especially impacted by new treatment capacity and sewers.
Where excess capacity or where sewering of undeveloped areas
may encourage population increases, the full importance of
this development on air and water quality should be detailed
in those categories. Site selection for the proposed actions
should be discussed and mitigating steps explained where
adverse impacts are involved.
It is especially important to evaluate the effects of
collector and interceptor sewers on the probable growth »
within the project area when the proposed sewers will
service or must traverse undeveloped or sparsely developed
areas. If these conditions exist the following material should
be provided. It should be prepared in conjunction with that
in Chapter II, Section B. 8.
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a. Maps
If these are available, include in the EIS maps
1) existing land uses with existing and proposed
sewers, and
2) planned land uses.
These maps may be presented as overlays or any other suitable
display technique.
b. Analysis of Land Use
With the above maps, determine those areas where
the greatest probability exists for sewers to induce a
change in land use either existing or proposed. The evaluation
should discuss the anticipated rate of change of development
both existing and proposed, population densities and how the
design capacity of the sewers and the phasing of construction
thereof might influence these considerations. Relate these
possible changes in land use to the probable environmental,
economic and social effects of the change. Discuss the
reliability of existing or proposed zoning to adequately control
development in the open space or lightly developed land areas.
c. Identification of Potential Problems
Where a land use plan for the area exists, there
should be a brief discussion of the consistency of anticipated
growth within the project area and the growth forecast by
the plan.
Where land use plans and maps are sketchy or
unavailable, an evaluation of the above factors should be
made — within the ability of the region to do so.
**• Biology - examples will not be provided.
5. Environmentally Sensitive Areas - examples
will not be provided.
6. Aesthetics
Aesthetics is an elusive quality, difficult to
evaluate and virtually impossible to value. However,
aesthetics is a very essential part of a quality environment
and society has become increasingly critical of- those
actions which will erode that quality in any way. This part
should advise the public and the decisionmaker what the
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consequences of the action will be on the aesthetics of
the area. This will necessarily be a subjective analysis.
C. Additional Impacts to Consider
The outlines provided in (B) above are not all
inclusive. The preparer may find it appropriate to expand
or decrease the factors to be considered in each category.
The process of project site selection should be
examined in detail. This determination cuts across and
impacts several categories. For example, some European
countries have felt it was important enough environmentally
to place the entire wastewater treatment plant underground.
This was admittedly brought about by severe population
densities, but points out that techniques are available
to effect some very unconventional approaches to solve
potentially adverse environmental impacts.
Where the engineering design has incorporated
important environmental benefits, these should be given
credit through an adequate exposure in the narrative.
For example, energy conservation design for fuel.
D. "No Action" Alternative
The environmental impact (short and long-term)
of allowing existing wastewater treatment works to continue
without modification, upgrading or replacement, should be
discussed, so the reader can compare the impacts of the
proposed action to this alternative.
E. Summary
In addition to the narrative, the environmental
impacts occurring in each environmental category should be displayed
in a summary chart.
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VI. Federal/State Agency Comments and Public Participation
The partiripation of looal, State, and Federal
imH vichi.i I ritl/omi .ind lnt.c*rt*tit.«'
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breakdown and decomposition of detritus, thus
contributing to detrital food chains, detrital
transport, and nutrient cycling. Estuarine
systems are particularly important because of
their high productivity and their role as nursery
areas for benthic species.
A. thermal discharge may have a variety of effects
on macroinvertebrates. Aquatic insects having
an emergent stage may enter, the atmosphere early
as a result of artificial heating of the water.
The adults may emerge into cold air and die
because of exposure, because food items are not
in phase, or because normal egg laying conditions
do not exist. Larval forms of marine inverte-
brates may develop at such high metabolic rates
that the survival of individuals may be reduced
during settling or maturation. Thermal discharges
may stress ecosystems and cause shifts in community
structure such that although the total biomass
may not change significantly, desirable species
may be replaced by less desirable species not
involved directly in the food chain. The dis-
charge of heat may cause stratification, which
may diminish dissolved oxygen in the bottom
layer and possibly eliminate benthic fauna.
Specific types of data are useful for the
following reasons:
A. Standing Crop Estimates. These estimates
are useful in determining the importance
of macroinvertebrates to the productivity
of the river or stream being impacted by
the discharge. As previously discussed,
the productivity of the affected portion
of the system is a key factor in defining
low and high impact areas.
B. Community Structure. The total number of
species and the relative abundance of
individual species (both components of
diversity) in an aquatic system are a
function of the physical, chemical, and
biological characteristics of the system.
Because diversity is sensitive to signif-
icant changes in the characteristics of
the system (such as introduced heat)„ it
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can be an indicator of environmental stress.
Additionally', a reduction in the diversity of
a system frequently results in a diversion
of production into non-useful forms.
C. Drift. In flowing waters, drift is an important
survival mechanism for many species of macroin-
vertebrates. Since it is a passive function,
the drifting organisms are subject to lethal
temperatures occurring in a thermal plume.
Drift is a stepwise downstream phenomenon, and
many aquatic insects have a concomitant upstream
movement of reproducing adults. The plume may
thus affect populations both upstream and
downstream from the area where mortality
actually occurs.
D. Mapping. Mapping is necessary for a detailed
representation of the distribution of substrates.
This graphic information is important in the
design of sampling studies, evaluating the
suitability of the system for various benthic
forms »
5- Fish. The discharge of waste heat can affect fish
populations in many ways. The various data required
are necessary in order to provide characterization
of the indigenous fish community for the development
of the RIS concept, to identify habitat utilization
by the various populaf-ns, and to provide baseline
information for comparison with post-operational
studies.
Specific data parameters are related to possible
adverse impacts from thermal discharge:
A. Species Level. Information on the spawning
habits of individual species are necessary
for assessing impact because spawning times
may be shifted by chermal additions or
habitats may be altered by scour or by
changes in the habitat former community.
Habitat use by any life stage may similarly
be affected. Migration is an important
factor to consider because thermal discharges
can block upstream migration routes of
spawning adults and downstream movements
of small fish. Condition factors are
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useful in evaluation because heat additions
may cause a loss of condition in certain
species, especially in winter when their
metabolic rate is still high but food supply
is low.
The incidence of disease and parasitism may
increase with a rise in water temperature.
Age and growth data are helpful in comparing
affected and non-affected areas, pre- and
post-operational conditions.
B. Community Level. Data on species composition,
relative abundance, and principal associations
will define the dominant fish species at the
site* Any appreciable change in these parameters
signals an imbalance in the community and may
indicate an adverse impact resulting from the
thermal discharge. Species information is also
necessary for developing thermal limits for
the effluent.
C- Mapping. Maps are required in order to represent
habitat areas (used for spawning, migration* etc.)
is relation to the configuration of the discharge
plume.
6. Other Vertebrate Wildlife. Data will be required in
relatively few eases for this b_-.£ic category. In
those cases where data is required, the type of data
needed is decided by the applicant. The data
selected should be the least amount of data necessary
to complete this section of the demonstration.
7, Representative Important S-»eeies. Making predictions
about "what will happen" are difficult without detailed
information on the environmental requirements of
communities or at least many populations and species.
As mentioned in section 3.5.2, it is not economically
feasible to study each species in great detail at each
site. Therefore a few species are selected for
detailed laboratory and literature survey. The data
requirements of Tables A and B (section 3.5.2.2) are
recommended as being helpful to those making 316(a)
decisions for the following reasons:
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A. They allow an estimation of the size of the
areas which will be excluded for key biological
functions and the duration of the exclusion.
B. They provide the basis for at least rough
predictions of high temperature survival, heat
and cold shock» and effects on reproduction
and growth.
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3.6 Type III Low Potential Impact Determinations
If the Regional Administrator/Director determines, after early
screening studies, that the site is one of low potential impact for all
biotic categories, the applicant may elect to do a "short form" demon-
stration, Che "Low Potential Impact Type III Demonstration." The basic
concept is that those applicants which have sites and proposed facilities
which obviously pose little potential threat to the balanced indigenous
population should be required to do less extensive (and expensive)
aquatic studies than other (more poorly sited or otherwise having more
potential for adverse impact) applicants.
Type III demonstrations in general are essentially any alterna-
tive demonstration type agreed upon by the applicant and the Regional
Administrator/Director. The Low Potential Impact Type III demonstration
proposed here is simply a recommended "short form" demonstration which
considers information from each biotic category. This ensures that no
major biotic category is ignored altogether and thus ensures that both
the regulatory agencies and the applicant have examined and made
judgments for each biotic category, but discourages collection of
excess or unneeded data-
After the preliminary screening studies and determinations that
all biotic categories are of low potential impact, the applicant
summarizes this information (along with engineering and hydrological
data and any other pertinent information) in one master rationale and
submits the demonstration to the Regional Administrator/Director.
The format of the submittal should be similar to that suggested
in section 3.5.5 except that the RIS sections should be deleted.
J
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3.7 Other Type III Demonstrations (Biological,
Engineering, and Other Data)
Those applicants not qualifying for a Low Potential Impact demon-
stration and not desiring to do a Type II demonstration, may (with the
written concurrence of the Regional Administrator/Director) do a regular
Type III demonstration. A. Type III demonstration provides for the
submittal of any information which the Regional Administrator/Director
believes may be necessary or appropriate to.facilitate evaluation of a
particular discharge. This demonstration also provides for submittal of
any additional Information which the applicant may wish to have considered.
Each Type III demonstration should consist of information and data
appropriate to the case.
Detailed definition of a generally applicable Type III demon-
stration is not possible because of the range of potentially relevant
information; the developing sophistication of information collection
and evaluation techniques and knowledge, and the case-specific nature
of the demonstration. Prior to undertaking any Type III demonstration,
the- applicant should consult with and obtain the advice of the Regional
Administrator/Director regarding a proposed specific plan of study and
demonstration. Decision guidance may also be suggested.
If the site is one of low potential Impact for most biotic
categories and/or there are other factors (small size or volume of
water impacted, low percentage of cross section of receiving water
affected, etc.) suggesting low potential for aquatic impact, the demon-
stration may not need to be completed in much more detail than the Low
Potential Impact demonstration outlined in section 3.6. For most other
sites, the demonstration should reflect a degree of detail and degree
of proof comparable to the Type II demonstration (section 3.5). While
Type III information may be different in thrust and focus, proofs should
be generally as comprehensive as in Type II demonstrations and should
result in similar levels of assurance of biotic protection.
Each item of information or data submitted as a part of a Type
III demonstration should be accompanied by rationales comparable to
those outlined in sections 3.5.1 and 3.5.4. The format of the
demonstration should be similar to that outlined in section 3.5.5
except that the RIS sections should be deleted.
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3.8 Decision Criteria
3.8.1 Biotic Categories
Decision criteria for each biotic category are given in section
3.3. The Regional Administrator/Director will compare the rationales
(and other data) for each biotic category with the decision criteria in
section 3.3 and determine if the decision criteria have been met.
3.8.2 Representative Important Species
The Regional Administrator/Director will find the Representative
Important Species Rationale and other RIS information to be unacceptable
if the information presented:
1. is too incomplete to allow a clear assessment; or
2.. suggests (or does act provide a convincing argument
to the contrary) that the balanced indigenous popu-
lation may suffer appreciable harm because of:
A., high temperature survival factors;
6. heat or cold shock;
C. improper temperature for growth, development,
and reproduction; or
D. the exclusion of areas and volumes of water
from the above functions in critical combina-
tions of time and space.
3.8.3 Resource Zones in Aquatic Systems
The strategies for reproduction, growth, and survival of the
indigenous biota of freshwater, estuarine, and marine ecosystems are
keyed to spatial and temporal variations in the structure (physical and
chemical) of the environment. This structural variation in the environ-
ment, as it relates to the biota and to uses by man, has led to the
concept of resource or "value zones" for use in evaluating or predicting
the level of damage to aquatic systems from human activities. Since
such zones vary in location, size, season of utilization, and criticality
of function, their identification is also useful in planning purposes
such as the siting of mixing zones for heated discharges. Application
of this concept involves the identification and mapping of resource
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zones and critical functions* so that nixing zpnes can be sited in
areas having minimum adverse impact on aquatic resources. Basic precepts
necessary to application of the resource zoning concept include:
1. All discharges in the water body segment must be
considered.
2. The acceptable area of damage is related ,to the
resource value of the impacted area.
3. In cases where the effects of the discharged waste
are transitory, the timing of mixing zone use is
related to seasonal utilization of the impacted
area.
4. The acceptable area of damage is related to the
total amount of equivalent area available in the
water body segment.
5- Areas supporting "critical functions" should be
avoided (note item 3 above).
6. Acceptable damage is related to species generation
time and/or fecundity.
7. For a given location, the smaller the damaged area
the better.
3.8.3.1 Typical Resource Value Zones.
The following annotated list includes resource value zones
which should be considered in the designation of mixing zones for
heated discharges:
1. Spawning Sices. Reproduction is obviously a
critical function in the survival of a species.
Two factors of importance in designating mixing
zones are the often limited area of habitat
suitable for the spawning of a species and the
limited time during which spawning occurs.
* A zone having a "critical function" is one that provides a major con-
tribution to primary productivity or is one that is limited in extent
and necessary for the propagation and survival of a species.
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If che availability of spawning sites for an Impor-
tant species is limited in extent, then such areas
can generally be avoided and should not be designated
for the disposal of waste heat. If it is totally
impossible to avoid such sites, then the use for
mixing should be timed to avoid the period of
spawning. Seasonal avoidance is only feasible if
the effects of the discharge are transitory.
2. good-Producing Areas. The productivity of aquatic
systems is directly related to the inputs of
organic matter from green plants. The free-floating,
relatively imotile microscopic plants (phytoplankton)
are short-lived with rapid turnover rates and thus
may not be critical in terms of mixing zones for
heated discharges. The rooted vascular plants and
macroalgae (macrophytes) which, with suitable
substrate, grow from the shoreline to the depth of
the photic zone (depth to which 1 percent of
incident light penetrates) are relatively long-
lived and perform a number of "critical functions"
including:
A. The production and export of vast quantities
of organic fuel in the form of detritus-
some are among the most productive plant
communities known.
B. As a result of an abundance of food and
cover, they serve as nursery areas for the
immature stages of many finfish and shell-
fish.
C. The trapping and recycling of nutrients.
D. The stabilization and building of substrate.
Included in the category of food-producing areas are
the wetlands—the interface between terrestrial and
aquatic environments—which, in addition to the
above enumerated functions, serve as freshwater
recharge areas that meter freshwater inputs to lakes,
rivers, and estuaries.
Because of the many important and critical functions
performed, the wetlands and other areas of macrophyte
production in aquatic systems should be avoided when
planning and designating mixing zones for heated
discharges.
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3. Nursery Areas. These are areas having an abundance
of food and cover for the growth and development
of the early life stages of many finfish and shellfish.
Since the early life stages are the periods of maximum
growth rates and maximum vulnerability to predation,
the availability of suitable nursery areas may be the
limiting factor determining the abundance of a species.
Thus, the zones of freshwater, estuarine, and marine
ecosystems identified as nursery areas have high
resource value and should generally be avoided when
designating mixing zones. :'
4. Migratory Pathways. Included'in this category are
routes utilized for movement to and from spawning
grounds, feeding grounds, and nursery areas; thus,
the life stage involved may be adult, egg, larval, or
juvenile. In some cases, these pathways are very
circumscribed; and total blockage could result in
extermination of a population in the water body
segment. Since these pathways serve a "critical
function," they have high resource value and should be
avoided when planning the discharge of waste heat.
In situations where the usage of pathways is seasonal'
and the effects of the discharge are transitory,
deleterious effects may be avoided by proper timing
of disposal. In terms of power plants, this seasonal
usage is important in evaluating the feasibility of
seasonal mode operation of cooling devices.
A consideration of zones critical to endangered species,
usage by waterfowl and wildlife, and shellfish beds are additional
resource values that' must be considered when selecting mixing zones
for heated discharges.
3.8.3.2 Methodology.
As discussed above, discharge sites should be selected
which will have the least impact on important resource zones and
"critical functions." The application of this concept to the
selection of mixing zones is a stepwise procedure Involving:
- A definition of the water body segment.
- Selection and listing of RIS in the water body segment
and an enumeration of their strategies for propagation
and survival.
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- Preparation of a map of the water body segment shoving
zones of resource use, including areas supporting "critical
functions."
- Assignment of a numerical value, per unit area,, to each
resource use.
— Superimpose predicted plumes on resource maps and select
sites having least adverse impact on resource values*
I. Water Body Segment. In lakes and estuaries having
discrete and easily definable physical boundaries,
the designation of the water body segment will be
a straightforward process. In large water bodies
such as the Great Lakes, open coastal sites, and
major river systems having no definable and reasonably
sized physical boundaries, the selection of the water
body segment may pose a difficult problem. Where they '
have been defined, the water body segments determined
by the State Continuing Planning Process under section
303(e) of the Act will apply.
The seasonal movements of important species of aquatic
life must be considered when defining a water body
segment. The spawning sites, nursery sites, and adult
habitat sites of many freshwater and marine species
(examples include salmonids, shrimps, crabs, spot,
croaker, flounder, white bass, walleye, etc.) may
be widely separated and include physically different
water bodies. Seemingly slight impacts in the different
areas used by such species may result in effects
which, if considered cumulatively, would be intolerable.
To avoid the potentially disastrous consequences
of piecemeal consideration of adverse impacts, the
water body definition should be sufficient to consider
potential impacts throughout the contiguous range of
populations of important species.
2. Representative Important Species. In general, this
should include all species and communities of
species that are critical to the functioning and the
productivity of the aquatic system defined by the
water body segment. Specifically included are
species or communities which are:
- Commercially and/or recreationally valuable.
- Threatened or endangered.
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~ Primary producers—particularly those communities
supporting relatively long-lived, fixed-location
species that perform multiple services (form and
stabilize habitat, produce organic matter, provide
cover).
- Necessary (e.g., in the food chain) for the well-
being of species determined in 1 and 2 above.
Included here are the scavengers and decomposers
critical to the breakdown and utilization? of
organic matter.
3. Map Preparation. Maps of the water body segment.
should, as a minimum, include depth contours, adjacent
wetlands, tributaries and, in estuarine situations,
the average salinity gradient and salinity stratification
should be visually expressed in cross section. Resource
zones and. areas performing "critical functions" should
be superimposed on the same or on a similarly scaled
map. To avoid overlapping detail, it may sometimes be
desirable to prepare separate maps for selected
species »
4. Assignment of Values. Once the resource zones and.
zones supporting "critical functions" have been
identified and mapped, then values per unit area
can be assigned. If the effects of the discharge
are transitory and the use of the resource zone is
seasonal, the values may change throughout the year.
If the zone supporting a "critical function" is
li—'ted in extent and is a function which limits
the abundance and/or survival of a species, then
that zone should be given a value of infinity and
thus excluded from mixing zone use. Other zones may
be assigned values according to their area and their
importance in maintaining different species.
3.8.4 "Master" Rationale, Demonstration As a Whole
The Regional Administrator/Director will find the demonstration
successful if:
1. It is found to be acceptable in all of the considerations
outlined in steps 20-25 of the decision train (section
3.3.2).
2. There is no convincing evidence that there will be damage
to the balanced, indigenous community, or community com-
ponents, resulting in such phenomena as those identified
in the definition of appreciable harm.
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3,. Receiving water temperatures outside any (State estab-
lished) mixing zone will not be in excess of the upper
temperature limits for survival, growth, and reproduction,
as applicable, of any RIS occurring in the receiving water.
4. The receiving waters are not of such quality that in
the absence of the proposed thermal discharge excessive
growths of nuisance organisms would take place*
5. A zone of passage will notrbe impaired to the extent
that it will not provide for the normal movement of
populations of RIS, dominant species of fish, and
economically (commercial or recreational) species of
fish, shellfish, and wildlife.
6. There will be no adverse impact on threatened or
endangered species.
7. There will be no destruction of uaique or rare habitat
without a detailed and convincing justification of why
the destruction should not constitute a basis for denial.
8. The applicant's rationales present convincing summaries
explaining why the planned use of biocides such as
chlorine will not result in appreciable ham to the
balanced indigenous population.
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4.0 Definitions and Concepts
The definitions and descriptions in this section pertain to a
number of terms and concepts which are pivotal to the development and
evaluation of 316(a) studies. These are developed for the general
case to aid the Regional Administrator/Director in delineating a set
of working definitions and coiaciae endpoints requisite to a satisfactory
demonstration for a given discharge.
Adverse EnviroT|'ffl*ntal Impact
Adverse aquatic environmental impacts occur whenever there will be
damage as a result of thermal discharges. The critical question is the
magnitude of any adverse impact.
The magnitude of an adverse impact should be estimated both in terms
of short term and long term impact with reference to the following factors:
(1) Absolute damage (# of fish or percentage of larvae
thermally impacted on a monthly or yearly basis);
(2) Percentage damage (Z of fish or larvae in existing
populations which will be thermally impacted,
respectively);
(3) Absolute and percentage damage to any endangered species;
(4) Absolute and percentage damage to any critical aquatic
organism;
(5) Absolute and percentage damage to commercially valuable
and/or sport fisheries yield; or
(6) Whether the impact would endanger (jeopardize) the
protection and propagation of a balanced population of
shellfish and fish in and on the body of water to which
the cooling water is discharged (long term impact).
Aquatic Maeroinvertebrates
Aquatic macroinvertebrates are those invertebrates that are
large enough to be retained by a U.S. Standard No. 30 sieve (0.595-om
openings) and generally can be seen by the unaided eye.
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Area of Potential Damage
The area of potential damage for RIS•is defined as that area
of the thermal plume enclosed by the isotherm which coincides with the
appropriate (designated by the Regional Administrator/Director) water
quality criteria for that particular RIS. This area can be determined
from the plume rose data, specified in section 3.5.3.
Balanced; Indigenous Community
The term "balanced, indigenous community" as defined here is
consistent with.the term, "balanced, indigenous population" in section
316(a) of the Federal Water Pollution Control Act and 40 CFR section 122.9.
A balanced, indigenous community consists of desirable species of fish,
shellfish, and wildlife, including the biota at other trophic levels
which are necessary as a part of the food chain or otherwise ecologically
important to the maintenance of the community. In keeping with the
objective of the Act, the community should be consistent with the restora-
tion and maintenance of the biological integrity of the water. (See
section I01(a).) However, it may also include species not historically
native to the area which:
1. Result from major modifications to the water body
(impoundments) or to the contiguous land area
(deforestation attributable to urban or agricultural
development) which cannot reasonably be prevented,
removed, or altered.
2. Result from management intent, such as deliberate intro-
duction in connection with a wildlife management program.
3. Are species or communities whose value is primarily
scientific or aesthetic.
For purposes of a 316(a) demonstration, distribution and composition of
the indigenous population should be defined in terms of the population
which would be Impacted by the thermal discharge caused by the alternative
effluent limitation proposed under 316(a). A determination of the
indigenous population should take into account all impacts on the population
except the thermal discharge. Then, the discrete impact of the thermal
discharge on the indigenous population may be estimated in the course of
a 316(a) demonstration. In order to determine the indigenous population
which will be subject to a thermal discharge under an alternative 316(a)
effluent limitation, it is necessary to account for all non-thermal impacts
on the population such as industrial pollution, commercial fishing, and Che
entrapment and entrainment effects of any withdrawal of cooling water through
intake structures under the alternative 316(a) effluent limitation. The above
considerations will then make it possible to estimate the true impact of
tl.e thermal discharge on the population.
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Balanced, Indigenous Population (SIP)
For £he purposes of 316(a) demonstrations, the term "balanced,
indigenous population" is synonymous with the term "balanced, indigenous
community" as defined above.
Community
A community in general is any assemblage of populations living
in a prescribed area or physical habitat; it is an organized unit to the
extent that it has characteristics additional to its individual and
population components, and functions as a unit through coupled metabolic
transformations.
Critical Function Zone
A zone that provides a major contribution to primary productivity
or is one that is limited in extent and necessary for the propagation and
survival of a species.
Director
The Director of the State NPDES permit program in those States
which have been delegated the program by EPA.
Discharge Vicinity,
The "discharge vicinity" is that area described by a radius
that is 1.5 times the maximum distance from point of discharge to
within 1°C of ambient. The area of the discharge vicinity is based
on a 30-50% variation in the predictive thermal plume modeling.
Dominant Species
Dominant species are defined as any species representing five
percent of the total number of organisms in the sample collected according
to recommended sampling procedures.
Estuary
An estuary is defined as a semi-enclosed coastal body of water
which has a free connection with the open sea; it is thus strongly
affected by tidal action, and within it sea water is mixed (and usually
measurably diluted) with fresh water from land drainage. It may be
difficult to precisely delineate the boundary of estuarine and river
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habitats in the upper reaches of a fresh water river discharging into
marine waters. The interface is generally a dynamic entity varying
daily and seasonally in geographical location. In such cases, determina-
tion of habitat boundaries should be established by mutual agreement on
a case-by-case basis. Where boundary determination is not clearly
established, both estuary and river habitat biological survey requirements
should be satisfied in a combined determination for environmental
effects and best available technology for minimizing adverse impact.
Far Field Effect
A far field effect is any perturbation of the aquatic, ecosystem
outside of the primary study area that is attributable to, or could be
expected, from the thermal discharge (taking into account the interaction
of the thermal component with other pollutants).
Far Field Study Area CFTSA)
The far field study area is that portion of the receiving
water body, exclusive of the primary study area, in which Impacts of
the thermal discharge and its interaction with other pollutants are
likely to occur. The area shall include:
1. The zones where the habitats are comparable to
those existing in the primary study area, and
2. The zones inhabited by populations of organisms
that may encounter the thermal effluent during
-heir life history.
The actual boundary of the far field study area should be agreed
upon by the Regional Administrator/Director.
Habitat Formers
Habitat formers are any assemblage of plants and/or animals
characterized by a relatively sessile life stage with aggregated
distribution and functioning as:
1. A living and/or formerly living substrate for
the attachment of epibiota;
2, Either a direct or indirect food source for the
production of shellfish, fish, and wildlife;
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3. A biological mechanism for the stabilization and
modification of sediments and contributing to
the development of soil;
4.. A nutrient cycling path or trap; or
5. Specific sites for spanning and providing nursery,
feeding, and cover areas for fish and shellfish.
Macroinvertebrates
Far this document, the term "macroinvertebrates" may be
considered synonymous with "aquatic macroinvertebrates" as defined
above.
Meroplankton
For the purposes of this document, meroplankton are defined as
planktonic life stages (often eggs or larvae) of fish or invertebrates.
Migrants
Migrants are nonplanktonic organisms that are not permanent
residents of the area but pass through the discharge zone and water
contiguous to it. Examples include the upstream migration of spawning
salmon and subsequent downstream migration of the juvenile forms, or
organisms that inhabit an area only at certain times for feeding or
reproduction purposes.
Nuisance Species
Any mlcrobial, plant or animal species which indicates a hazard
co ecological balance or human health and welfare that is not naturally
a dominant feature of the indigenous community may be considered a
nuisance species.
Nuisance species of phytoplankton include those algae taxa
which in high concentration are known to produce toxic, foul tasting,
or odoriferous compounds to a degree that the quality of water is
impaired.
Other Vertebrate Wildlife
The term "other vertebrate wildlife" includes wildlife which
are vertebrates (i.e., ducks, geese, manatees, etc.) but not fish.
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Phytoplankton
Plant microorganisms such as certain algae, living unattached
in the water.
Plankton
Organisms of relatively small size, mostly microscopic, that
either have relatively small powers of locomotion or drift in the
waters subject to the action of waves and currents.
Primary Study Area
The primary study area is the entire geographic area bounded
annually by the locus of the 2°C above ambient surface isotherms
(determined in section 3.5.3.5) as these isotherms are distributed
throughout an annual period. The reference ambient temperature shall
be recorded at a location agreed upon by the Regional Administrator/
Director.'
Principal Maerobenthie Species
Principal macrobenthic species are those dominant macroin-
vertebrates and plants attached or resting on the bottom or living
in bottom sediments. Examples include, but are not limited to,
crustaceans, mollusks, polychaetes, certain macroalgae, rooted
macrophytes, and coral»
Regional Administrator (Director)
This tern refers to the Regional Administrator of the U.S.
EPA except that in those States which have been delegated the NPDES
permit program, the term refers to the Director of the State NPDES
permit program.
Representative. Important Species (RIS)
Representative, important species are those species which
are: representative, in terms of their biological requirements, of
a balanced, indigenous community of shellfish, fish, and wildlife
in the body of water into which the discharge Is made. Specifically
included are those species which are:
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-79-
1. Commercially or recreattonally valuable (I.e.,
within the top ten species landed—by dollar
value);
2. Threatened or endangered;
3. Critical to the structure and function of the
ecological system (e.g., habitat formers);
4. Potentially capable of becoming localized
nuisance species;
5. Necessary in the food chain for the veil-being
of species determined in 1-4; or
6. Representative of the thermal requirements of
important species but which themselves may not
be important.
Shellfish
All mollusks and crustaceans (such as oysters, clams, shrimp,
crayfish, and crabs) which, in the course of their life cycle, con-
stitute important components of the benthic, planktonic, or nektonic
fauna in fresh and salt water.
Threatened or Endangered Species
A. threatened or endangered species is any plant or animal
that has been determined by the Secretary of Commerce or the
Secretary of the Interior to be a threatened or endangered species
pursuant to the Endangered Species Act of 1973, as amended.
Water Body Segment
A water body segment is a portion of a basin the surface
waters of which have common hydrologic characteristics (or flow
regulation patterns); common natural physical, chemical, and
biological processes, and which have common reactions to external
stress, e.g., discharge of pollutants. Where they have been defined,
the wager b_gdy_jjgmgjptaL jjjgeg&aed jy £b& j^j>ftg^^ff jai^v-^LggajLaa-.
«="-5i?65;£=?=it-S" "..-^S^iT- '_- -^.——S=~5>'sS^SE%3Sr"SSS55i^i-&-«»^-c».-=Ts-=s». vs»t tX^W
regulation patterns); common natural physical, chemical, and
biological processes, and which have common reactions to external
stress, e.g., discharge of pollutants. Where they have been defined,
the water body segments determined by the State Continuing Planning
Process under section 303(e) of the Federal Water Pollution Control
Act apply.
Zooplanktou
Animal microorganisms living unattached in water. They
include small Crustacea such as daphnia and cyclops, and single-
celled animals such as protozoa, etc.
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PB-235 280
MANUAL FOR PREPARATION OF ENVIRONMENTAL
IMPACT STATEMENTS FOR WASTEWATER TREAT-
MENT WORKS, FACILITIES PLANS, AND 208
AREAWIDE WASTE TREATMENT MANAGEMENT
PLANS
Peter L. Cook, et al
Environmental Protection Agency
Washington, D. C.
August 1973
DISTRIBUTED BY:
National Technical Information Service
U. S. DEPARTMENT OF COMMERCE
5285 Port Royal Road, Springfield Va. 22151
-------
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^^SSMsMSi^
q!>J*?fH
"'#££$$£*&?*]
BIBLIOGRAPHIC DATA
SHEET
4. Title ant ubtitle
\. Report No.
PB 235 280
Manual for Preparation of Environmental Impact Statements
for Wastewater Treatment Works, Facilities Plans, and
208 Arefcwide Waste Treatment Management Plans
f. Report Date
August 1973 - Date of
6.
ssu
7. Author(s)
Peter L. Cook and Ned Cronin
8. Performing Organization Rept.
No. N/A
9. Performing Organization Name and Address
Environmental Protection Agency, A-104
Office of Federal Activities
401-M Street S.W., Rm. 537WT
Washington, D^C. 20460
10. Ptoiect/Task/Work Unit No.
T/l
11, Contract/Grant No.
N/A
12. Sponsoring Organization Name and Address
Same as above.
13. Type of Report & Period
Covered
Final
14.
15. Supplementary Notes
16. Abstracts
"The volume presents detailed guidance for the preparation of ^environmental
impact statements on wastewater treatment works and related plans.
17. Key Words and Document Analysis. 17o. Descriptors
Environmental Impact Statement
Wastewater treatment work
Facilities Plan
208 Areawide Waste Treatment Management Plan
Environmental Assessment
Primary or direct Impacts
Secondary or indiiced Impacts
17b. Identifiers /Open-Ended Terms
17c. COSATI Field/Group
Reproduced by
NATIONAL TECHNICAL
INFORMATION SERVICE
U S Department of Commerce
Springfield VA 22151
18. Availability Statement
Rleease unlimited
19. Security Class (This
Report)
Security Slass (This
PagUNClJASSl/IED
21. No. of Pages
22. Price
FORM NTIS-35 (REV. 3-72)
THIS FORM MAY BE REPRODUCED
USCOMM-DC I49S2-P72
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