MANUAL FOR PREPARATION OF
ENVIRONMENTAL IMPACT STATEMENTS
FOR
WASTEWATER TREATMENT WORKS,
FACILITIES PLANS, AND
103 ARE/-v\7IDF 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
Authority and Responsibility 1
Purpose 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 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
n. History of the Application 7
II. The Environment Without the Proposed
Action „ 1 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. Other Programs in the 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
B. 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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V. Environmental Effects of the Proposed Actions 29
A. General 29
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
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List of Figures
Figure 1 — Flowchart of Contents of EIS 5
Figure 2 — Development and Evaluation of
Alternative Wastewater Treatment
Systems 15
Figure 3 — Development and Evaluation of Alternatives
in 208 Plan EIS 23
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FOREWORD
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, D.C,
20460.
Sheldon Meyers
Director
Office of Federal Activities
11
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INTRODUCTION
Authority andResponsibility
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
•chat Act also requires the agency to prepare an environmental impact
statement (F.IS) 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.
CEO has issued, "Preparation of Environmental Impact
Statements: Guidelines," August 1, 1973 (40 CFR Chapter V,
Parr 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 SPA 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 (q) (!) , 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 State,
iViunicipality, or ir.terrr.unicipal 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 effecrs 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 otfices of EPA.
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Purpose
The purpose of this manual is to implement the requirements in
1500.6(c) (iii) 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 anc
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
o€ 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
wastewater 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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Jn this regard, EIS's should be as brief as practicable.
To this end, if a proposed action has an obvious overriding environ-
mental problem, the preparer 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 to
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 changed
order only a brief summary of the proposed action should be
provided in the Background Chapter of the EIS.
Flowchart of Content of EIS
Figure 1 is a flowchart to assist in visualizing the systematic
gathering of information for the EIS and the processing of 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 has been received, briefly
describe the origin of the application, its priority determination
and State certification.
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II. The Environment_Wirhout the Proposed Action
A. Genaral
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 EIS's
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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 tne 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
i:-ifluv?nce on either groundwater or surface water resources
should be 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. Welter" Qua-l-ity
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.
***** 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 for the area.
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.
f
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 .
***** 9. 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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i. surface waters,
2. marshland, wetlands, and estuaries,
3. flood plains or flood-retention areas,
4. groundwater 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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III. Alternatives
A. General
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 leadingxto
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 of 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 impleraentable
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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To simplify the alternatives section, the Regional Adminis-
trator may wish to provide a standard document on subsystem alternatives
which must be rejected 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 wastewater
treatment works or septic tanks to continue in use — so that
rhe public will understand the environmental implication of
allowing the status quo to continue.
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;
3) water and wastewater rates that impose costs
proportional to water used and wastewater generated and use of
water meters; and
4) educating the public on the value of their water
resources in order to reduce their 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 BPWTT^- 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 eliminating 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.
2) Wastewater 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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- Industrial processes
- Groundwater recharge for water supply enhancement
or preventing salt-water intrusion
- Surface water supply
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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 System(s)
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.
I/Refer to EPA - "Ocean Dumping" - Final Regulations and Criteria,
Federal Register, Vol. 38, No. 198, Part II (40 CFR, 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.
k- 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 screenim
will be compared in more detail on the basis of:
1) 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.
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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,
a-; which time it will be replaced or upgraded, the comparative
analysis should reflect this. The discussion should also
emphasize those alternative systems that appear promising in
•cerms 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,
ccromercial 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,
ctr.a developing a management system to implement the proposed
technical alternatives. The EIS on a 208 plan should concentrate
or, 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 latter's alternatives 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
and 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 Alternatives
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 are applicable to problems that have
been identified:
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I) Urban stormwater runoff
2) Construction activities
3) Hycirographic 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 Plan(sT
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 goals and
objectives;
2) present value or average annual equivalent
value 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:
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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 be 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 rainimum 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 will 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
recommended. In this approach, the environment is divided
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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t-
— beneficial or adverse;
-- short or long-term;
-- reversible or irreversible; and
— 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 other 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. Environir.er.c^ 1 .impacts
To reduce tha 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
•che 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 downs-cream 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 HIS 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 un:'
must also consider the water quality (scrubbers) and solid waste
(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
•che 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.
4. 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 che 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 derail. 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 participation of local, State, and Federal
agencies, individual citizens and interested environmental
groups, in the review of environmental impact statements
is of the utmost importance. Their suggestions, criticisms
and objections should be given full consideration.
In general;
1. the EIS should cite and discuss each substantive
suggestion, criticism or objection;
2. the author(s) of each comment should be identified;
3. if a comment has resulted in a change in the project
or the EIS, the impact statement should say so and identify
the change;
4. if a comment has been rejected, the EIS should
explain the reason for rejection; and
5. a copy of any substantive comment (or summary
thereof if the comment is voluminous) received on the draft
statement must be attached to the final statement.
Agency and public participation in the review of the
proposed action, through formal public hearings, should be
identified and briefly discussed. If public hearings have
not been held, or are not anticipated, this fact should also
be noted.
The EIS should contain a complete reference of any
hearings related to the proposed action. The reference
should state the official title, time, date and place of
•-lie hearing and the specific reason why it was held.
A summary of the hearing should be appended to the .EIS.
If a public hearing is anticipated subsequent to the
publication of the EIS, this should also be noted.
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