-------
bocio-Economic Systems SES Project No-
|""j CateJory: Socio-Cultuial Impacts
[[] Sub-Category: Social Impacts
[xj Criterion:Population Size and Density
DEFINITION:
The degree to which the proposed project promotes
desired (General Plan, Zoning Laws) local popula-
tion size and density without overtaxing the local
infrastructure.
ASSESSED BUT NOT RATED
BOUNDARY: Kitsap County
Alternative 11
METHOD OF ANALYSIS: Review of "Amendment to Kitsap County Comprehensive Plan,"
"Planning Policies Outline for the Future Growth of Kitsap County, Washington—
An Element of the Kitsap County Comprehensive Plan," Planning Policies, Project
Plan, Staff Analysis.
DISCUSSION: The "Amendment" document referred to above outlines the planning
policies with respect to intensity of development of rural, transitional, urban
and redevelopment areas. The plan outlines an approach to the management of
growth which will encourage higher densities in and around urban centers (urban
and transitional areas), while maintaining the rural character of other areas.
In addition to preserving existing attractive qualities of rural and semirurai
areas, the control of urban growth will promote more efficient delivery of public
services to the present and expected population.
The proposed project gives county planners the opportunity to channel growth
toward selected areas in conformity with local goals. The growth itself has
become inevitable as a result of the :ecision to proceed with the Trident Base.
Assuming that access to the sewer lines will only be permitted in designated
growth areas, and that the project selected alternative will provide service
in those areas, population size and density should conform to planning goals.
While local infrastructure will be taxed (and perhaps overtaxed) by expected
growth, the proposed project, rather than causing this situation, will be a
major component of the effort to enable the infrastructure to cope with the
growth.
One characteristic of alternative 11 which makes it preferable to the others is
that it does not include the Clear Creek corridor in its pipeline route. This
relieves the corridor of development pressure. Population growth in this area,
which is generally designated "Rural" in the Kitsap County Proposed Planning
Policy Map, is not encouraged by present county policy.
SOURCE OF REFERENCE: Arrie Bachrach, Environmental.Analyst
SIR Form HI 016/
Copyright 1973
IV-59
-------
Socio-Economic Systems
fl Category:
LJ Sub-Category:
0 Criterion: Population Size and Density
LJ Sub-Criterion: _____________________
SES Project No.
Socio-Cultural Impacts
Social Impacts
Population size will be minimally increased by the proposed project, regardless of
alternative, since it will employ between 20 and 40 people.
Population density will be increased by the proposed project, inducing concentration in
.those areas served by the facility that will be greater than the more random dispersal
that could be expected if no sewage collection service is available in the planning
area. This will be compatible with local planning if the service, hence the increase
it. density, is available in the urban and transitional areas designated for growth, and
if actual development is not permitted to violate zoning restrictions affecting density.
A small positive rating is therefore given to each alternative. However, until sewered
areas are better defined, no rating will be shown.
IV-60
-------
Socio-Economic Systems
SES Project No. 18°
f") Category :
Sub-Category:
Socio-Cultural
Cultural and Aesthetic
Criterion:
Sub-Criterion:
Archaeological and Historical Sites
DEFINITION: The degree to which the proposed
project affects local archaeological and paleon-
tological sites.
RATING:
+100
~\ Preserves and enhances
archaeological and
paleontological remains.
BOUNDARY: Alternative 11
Project planning area
+76
METHOD OF ANALYSIS: Examination of the archaeological
reconnaisance report. +snl—
DISCUSSION: A literature survey (National Register of
Historic Places, Site Survey Records for Kitsap County +2
at the University of Washington) i-. dicated that there were
no known sites of archaeological or historical significance
within the project planning area. An archaeological survey
of the planning area in December, 1974, revealed only +1
one archaeological site, a shell midden near the Brownsville
Marina on Burke Bay. The midden has essentially been de-
stroyed by historic and modern activities (e.g., dredging 0
operations, road construction) and the investigating
archaeologist has judged that the cultural information
coming from further investigation of this site would be -10
of dubious value. The proposed project would therefore
have little or no impact upon the midden. No other
historical or archaeological sites have been identified
in the planning area.
-SO -
-7t -
SOURCE OF REFERENCE:
Analyst ; Reference 43
SIB Form #1016V
Copyright 1973
Suzanne Yuen, t Environmental
-100—*
<
No or negligible effect on
archaeological or paleonto-
logical remains.
Destroys paleontological or
archaeological remains.
IV-61
-------
Socio-Economic Systems
0 Criterion:
IJ Sub-Criterion:
SES Pr°Ject N°-
P**^
I | Category: Socio-Cultural
Sub-Category: Cultural and Aesthetic Impacts
Entertainment and Recreational Facilities
DEFINITION:
The degree to which the proposed project supplies
or demands entertainment and recreational facili-
ties.
RATING:
+ 5
+100
+75
+50
BOUNDARY: Kitsap County
Alternative 11
METHOD OF ANALYSIS:
Examination of the alternative plans for the
proposed project.
DISCUSSION:
+26
The proposed project will have a beneficial impact on the
recreational resources of the area. Outfall sites releasing
sewage after primary treatment will either be upgraded or
replaced, reducing the level of coastal pollution to +10
acceptable levels. The most significant improvements will
be noted in such areas as Liberty Bay and Dyes Inlet, which
receives the outfall from the Silverdale plant and which 0
suffers from inadequate flushing. The beneficial Impact
will result regardless of the alternative selected because -
no outfall will be permitted after oily primary treatment*-10
The pipeline rights-of-way offer potential recreational
resources. Once the pipeline is installBd, the corridor
may—at the county's discretion—be developed as nature -25
trails, bike trails and recreational access to shoreline.
However, these options have not as yet been included with
the facilities design.
-SO
-76 —
SOURCE OF REFERENCE:
EIR Form H1016/
Copyright 1973
William Ulwelling, Environmental
Scientist
Provides major new
facilities.
Significantly augments
existing facility inventory.
No or negligible effects.
Overloads existing facilities.
Destroys existing facilities
without replacement.
-------
Socio-Economic Systems
SES Project No. 180
fl Category: Socio-Cultural
Sub-Category: Cultural and Aesthetic Impacts
|""| Criterion- Visual and Aesthetic Environment
Sub-Criteri:*::
DEFINITION:
The degree to which the proposed project affects
the public's visual and aesthetic enjoyment of
an area.
RATING:
- 10
BOUNDARY: Alternative 11
Sewage treatment facility location
Pipeline routes
METHOD OF ANALYSIS:
Subjective opinions of project staff who have visitled
proposed sites.
+100f—| Substantially improves
aesthetic qualities and
provides for future.
+7,
+50
DISCUSSION:
The north Brownsville site is well screened from view """
from adjacent roadways and property. Its location on a
major route through the Study Area precludes any use of
the site as a "natural or serene" preserve. Its present
condition of overgrown farmland contains little aesthetic^ 0
value.
No aesthetic impact would be felt from pipeline placement
along existing roads.
-10
-2k
SOURCE OF REFERENCE: Project staff
SIR Form #1016/
Copyright 1973
-50-
-76-
-100—*
Promotes aesthetic
quality in localized areas.
No changes, in present
aesthetic quality.
Degrades aesthetic qualities
in some local areas
Substantially degrades
aesthetic qualities.
IV-63
-------
Socio-Economic -Systems SES Pr°Ject "°-l~
j_j Category;, Socio-Cultural
[x] Sub-Category: Traffic Effects
r~| Criterion:
|j Sub-Criterion:
DEFINITION: The degree to which the proposed pro-
ject impacts traffic flows and patterns.
ASSESSED BUT NOT RATED
BOUNDARY: Study Area
Alternative 11
METHOD OF ANALYSIS: Consultation with Traffic Engineer and the Engineering Consultant
DISCUSSION: Tne l°ading imposed by project-related traffic generated by the approximately
20-40 employees of a sewage treatment facility is negligible when compared with baseline
traffic loads. Additionally, these 20-40 employees will work in three shifts.
In the context of projected growth resulting from the Trident Support Site development,
traffic increases due to the proposed project are deemed too minor too rate.
Preliminary estimates of construction related traffic, provided by the engineering
consultant are intended to show an order of magnitude. For an initial 12 to 18 month
period, approximately 12 truck trips/day can be expected, for the final 2-3 month period,
an estimated 18 truck trips/day can be expected. The construction crew will add
approximately 22 trips/day. In the ev>_.it of an urgent request to reduce the construction.
period, related traffic can be expected to rise to 21/day (12 to 18 months), 20/day
(2-3 months), 44/day (work force).
SOURCE OF REFERENCE: William Ulwelling, Environmental Analyst.
EIR Form til 016/
Copyright 1973
IV-64
-------
V ADVERSE IMPACTS &
MITIGATIVE MEASURED
FOODLINER
WIT W»A$T K>»
MOW POUTOCS
•HI* O6«i. 6««
-------
CHAPTER V
ADVERSE IMPACTS AND MITIGATIVE MEASURES
This chapter presents adverse impacts and mitigative measures for
the proposed wastewater facilities plan.
Impacts which received ratings between -10 and +10 are considered
to be of negligible importance. In some instances these impacts would
have rated higher scores except that mitigative measures were automat-
ically built into the system. As an example, odors from a poorly oper-
ated sewage treatment facility could be very unpleasant and far ranging.
It must be assumed that the facility would be designed, constructed and
operated with reasonable care and diligence. Under such conditions,
odors are very rarely a problem.
This chapter specifically identifies substantially negative envi-
ronmental, social and cultural impacts and states special mitigative
measures that should be taken to lessen those impacts. The discussion
is separated into categories of physical, resource, economic and socio-
cultural impacts. Only impacts with ratings lower than -10 are con-
sidered sufficiently substantial to warrant a discussion.
PHYSICAL IMPACT MITIGATION
The following are physical impacts identified as being of sub-
stantially negative nature within the study area and/or as a result of
implementation of project alternatives.
V-l
-------
Socio-Economic Systems SES
f~| Category: Physical Impacts
r~j Sub-Category: Terrestrial Environment
[""[ Criterion: Vegetrr.ion Communities
Hi? Sub-Criterion: _ Overall Study Area less Clear Creek
NO.
DEFINITION:
The degree to which the proposed project affects
vegetation as a soil stabilizer. Site charac-
teristics (topography, riparian location) de-
termine degree to which vegetation prevents
erosion.
RATING:
- 20
BOUNDARY: Alternative 11
Study Area
METHOD OF ANALYSIS:
On-site inspection and evaluation of existing
conditions.
DISCUSSION:
+100
+75
+50
+25
The majority of the pipe alignments will be within local
roadway right-of-ways. Within Central Valley, approximately
2 miles of the alignment must pass through vegetated sections
Pipeline construction will cause minor land disruptions +10
during vegetation clearing, trenching, and burying of pipes
The open pasturelands and short segments of woodlots
should recover within 6-12 months. Marsh areas may re- 0
quire a longer time.
The last section of the pipe alignmen'- from South Keyport -10
Road to Port Orchard may suffer long-term effects. The
steep ravine leading down to the beach is a sensitive area
due to the poor soils and slope instability. Construction
without proper mitigation methods could affect the vege- _
tation community in that localized area.
-SO —
SOURCE OF REFERENCE:
Earnshaw and Richman, Consulting Botanists
EIR Form #1016 /
Copyright 1973
-lOCf
Project increases soil
stability by introduction
of vegetation (planting,
seeding, fertilizing).
Project will not induce
erosion, i.e., no or neg-
ligible effects on soil
stability.
Erosion hazard reduced by
less severe site character-
istics.
Vegetation removal will
cause serious erosion and
sedimentation because of
site characteristics (topo-
graphy, riparian location).
V-2
-------
Physical Impacts
Socio-Economic Systems
Q Category:_
\\ Sub-Category: __
Q Criterion: Wildlife and Wildlife Habitats
|_J Sub-Criterion:
SES Project No.
Terrestrial Environment
DEFINITION:
The degree to which the proposed project affects
wildlife numbers, complexity and habitat.
RATING:
- 15
. Significantly improves wild-
life habitats and wildlife
numb er.
BOUNDARY: Alternative 11
Study Area
METHOD OF ANALYSIS:
On-site inspection and evaluation.
DISCUSSION:
+50
+25
Construction of a new wastewater treatment facility will
remove 5-10 acres of wildlife habitat and displace wildlife
presently utilizing the area. The proposed site is generally
in areas previously disturbed by human actions. The
small size and proximity to major thoroughfares also limits
the disruption of wildlife and habitats.
0
All proposed pipeline routes except for small portions
north of Brownsville will be within road right-of-ways and .
should cause negligible impact to wi",llife and habitats _j(
in adjacent areas.
Construction within the Steel Creek (North Fork) drainage
will cause a temporary disruption of habitat. Sensitive _g/
areas are the freshwater marsh and swamp adjacent to the
treatment plant site. These areas provide a seasonal wild-
life habitat. Disruption or reduction of the marsh could
lead to a reduction in wildlife associated with this
ecosystem. _r,
The construction route of the final pipeline segment leading
to the marine outfall will diverge from the road easements
and traverse a wooded area to reach the shoreline. Wildlife
will be temporarily disrupted during this segment of pipe-
line construction. The ravine descending to the Port
Orchard outfall is unstable with sparse vegetation and thus
SOURCE OF REFERENCE:
E. Chan, Environmental Analyst
EIR Form #1016/ -100*-J
Copyright 1973
-7.
Increased wildlife numbers
provide more "niches".
Improves or expands wildlife
habitat in localities.
No changes reflected within
system.
Degrades or reduces wildlife
habitat in localities.
Decreases wildlife numbers
or leads to unstable popula-
tion.
Significantly degrades wild-
life habitats and reduces
wildlife number and complex-
ity.
V-3
-------
Socio-Economic Systems' SES Project No-
Q Catenary: Physical Impacts _
[j Sub-Category: , Terrestrial Env1ro™nPT.f
E3 Criterion: _ Wildlife and Wildlife Habitats
(""] Sub-Criterion: ^
represents the disturbance of only a marginal wildlife habitat.
Operation of facility or pipelines will not affect terrestrial wildlife. Relocation
of population near available sewer lines will disturb, if not eliminate, most wildlife.
Since it is assumed that population growth in the Study Area will occur with or without
the project and that presently built-up areas would not increase substantially in
density, this increase in population, wherever it occurs, would disturb wildlife for a
negligible impact difference between project and no-project.
V-4
-------
Mitigative Measures to Protect Vegetation and Wildlife Habitats
The destruction of vegetation along the pipeline route is un-
avoidable. The severity of the effects of this destruction and its
duration can be shortened. Appropriate measures would include re-
seeding and replanting disturbed areas with native vegetation and
short-term stabilization of the soil surface with organic mulches.
Straw has been successfully used as a mulch and soil stabilizer for
sloping embankments along new highway construction.
A chipper should be used to shred the brush and slash, with the
resulting mulch being used with the soil to fill in the trench. Be-
sides serving to check erosion, this activity would facilitate re-
seeding by native vegetation and reduce the availability of dry brush
feed for wild fires.
Seeding and fertilizing should be carried out, particularly in
pasture and meadow areas where natural reseeding would be expected to
be difficult. Additionally, reseeding would assure the growth of de-
sired plant species. Fertilization within forested areas would also
enhance revegetation of bare areas.
Separate storage during construction and replacement of the upper
natural soil layers over the backfill material would provide an im-
proved environment for the growth of new plants.
These mitigative measures should be applied at all locations
where the sewers would deviate from roadside cuts.
Secondary effects due to population growth can be minimized if
the County officials implement measures to protect the rural/agri-
cultural planning area designation north of Bucklin Hill Road.
The facilities planner is designing a tunnel for the placement
of this outfall through the shoreline ridge and steep bank. This
will greatly alleviate the problem of trenching through unstable
soil on a steep bank.
V-5
-------
Socio-Economic Systems
Q Category:_
|I Sub-Category:
[~j Criterion: Ground Vater
[xl Sub-Criterion: Quantity
SES Project No.
Physical Impacts
Water Quality
DEFINITION:
The degree to which the alternatives affect
the quantity (availability) of groundwater
in the Study Area.
RATING: - 25
BOUNDARY: Alternative 11
Proposed sewered area
METHOD OF ANALYSIS:
Evaluation of type of wells, depth, aquifer
penetrated and proximity to new sewer lines.
DISCUSSION:
+100r—i Substantially increases
groundwater availability.
+75
+50
+25
It is assumed that clay dams will be required at every
manhole along the sewer lines that traverse high ground-
water areas to prevent draining of the areas. Restricted
use of granular backfill should be required. Without +10
these precautions the rating would be -75 but with these
features the rating of -25 was made indicating that there
will be localized declines in the water table, particularly 0
where dug wells are utilized, such as Brownsville and
•leadowdale. This situation is a certainty because the
hydrologic balance of each stream basi:' will be adversely -10
affected by exporting water extracted from the basin for
discharge outside of the basin. Deep aquifers will
generally not be affected by the project.
-25
-50
SOURCE OF REFERENCE:
SIR Form 81016/
Copyright 1973
-75
W. 0. Maddaus, Water Resources Eng.;
Reference 5
-100
Water levels increase in
virtually all existing wells.
No or negligible effect.
«
Water levels decline in
some existing wells.
Water levels decline in
virtually all existing wells.
Substantially reduces ground-
water availability -
numerous wells go dry.
V-6
-------
Mitigative Measures to Protect Vegetation and Wildlife Habitats
The destruction of vegetation along the pipeline route is un-
avoidable. The severity of the effects of this destruction and its
duration can be shortened. Appropriate measures would include re-
seeding and replanting disturbed areas with native vegetation and
short-term stabilization of the soil surface with organic mulches.
Straw has been successfully used as a mulch and soil stabilizer for
sloping embankments along new highway construction.
A chipper should be used to shred the brush and slash, with the
resulting mulch being used with the soil to fill in the trench. Be-
sides serving to check erosion, this activity would facilitate re-
seeding by native vegetation and reduce the availability of dry brush
feed for wild fires.
Seeding and fertilizing should be carried out, particularly in
pasture and meadow areas where natural reseeding would be expected to
be difficult. Additionally, reseeding would assure the growth of de-
sired plant species. Fertilization within forested areas would also
enhance revegetation of bare areas.
Separate storage during construction and replacement of the upper
natural soil layers over the backfill material would provide an im-
proved environment for the growth of new plants.
These mitigative measures should be applied at all locations
where the sewers would deviate from roadside cuts.
Secondary effects due to population growth can be minimized if
the County officials implement measures to protect the rural/agri-
cultural planning area designation north of Bucklin Hill Road.
The facilities planner is designing a tunnel for the placement
of this outfall through the shoreline ridge and steep bank. This
will greatly alleviate the problem of trenching through unstable
soil on a steep bank.
V-5
-------
Socio-Economic Systems
Q] Category :f
f"l Sub-Category:
[~] Criterion: Ground 'fater
|~x] Sub-Criterion: Quantity
SES Project No.
Physical Impacts
Water Quality
DEFINITION:
The degree to which the alternatives affect
the quantity (availability) of groundwater
in the Study Area.
RATING:
- 25
BOUNDARY: Alternative 11
Proposed sewered area
METHOD OF ANALYSIS:
Evaluation of type of wells, depth, aquifer
penetrated and proximity to new sewer lines.
DISCUSSION:
+100
+75
+50
+25
It is assumed that clay dams will be required at every
manhole along the sewer lines that traverse high ground-
water areas to prevent draining of the areas. Restricted
use of granular backfill should be required. Without +10
these precautions the rating would be -75 but with these
features the rating of -25 was made indicating that there
will be localized declines in the water table, particularly 0
where dug wells are utilized, such as Brownsville and
•leadowdale. This situation is a certainty because the
hydrologic balance of each stream basi-.' will be adversely -10
affected by exporting water extracted from the basin for
discharge outside of the basin. Deep aquifers will
generally not be affected by the project.
-25
-50
-75 —
SOURCE OF REFERENCE:
SIR Form H1016/
Copyright 197 Z
W. 0. Maddaus, Water Resources Eng.;
Reference 5
-10$
Substantially increases
groundwater availability.
Water levels increase in
virtually all existing wells.
No or negligible effect.
Water levels decline in
some existing wells.
Water levels decline in
virtually all existing wells.
Substantially reduces ground-
water availability -
numerous wells go dry.
V-6
-------
Mitigative Measures to Protect Groundwater Quantity
The reduction of local availability of groundwater from the upper-
most water bearing strata will come about primarily due to the place-
ment of sewerage systems. Groundwater tables above the elevations of
gravity flow sewers will cause the infiltration of groundwater into the
sewers. This effect is somewhat minor and can be greatly minimized by
using neoprene or plastic gaskets or seals at sewer pipe joints. Of
greater impact would be the drainage of local groundwaters along the
bed of the sewer pipe. The beds upon which sewer pipe are placed and
the backfill material are usually more porous than surrounding undis-
turbed soils and will act as drains. All available groundwaters in
the vicinity of such drains and above the sewer pipe elevation would
be drained to the sewer pipe elevations. This impact can be very sub-
stantially mitigated by the careful placement of impermeable clay dams
at regular intervals along the sewers. These dams would act as a stop
to the drainage of groundwaters.
Water levels in shallow dug wells would still decline and may de-
cline in slightly deeper drilled wells in spite of these measures. The
current practice of using septic tank disposal fields in most of the
study area provides a natural, albeit impure, recharge to the local
groundwater. The proposed plans to extract waters from the ground, use
them and then transport them out of the local recharge areas will re-
duce the natural recharge but gain improved water quality.
Mitigative Measures to Protect Island Lake
The proposed plan has no impact upon lake waters in the study area
and receives an appropriate rating of zero. However, all other alter-
natives under consideration have a provision to sewer the residences,
existing and proposed, in the vicinity of Island Lake, with a connec-
tion to the Clear Creek interceptor. These alternatives would sub-
stantially reduce a documented bacteriological health hazard in Island
Lake.
Due to the relocation of the Trident Support Site interceptor
sewer onto State Highway 303, the interceptor sewer serving Island Lake
was dropped from consideration. It is recommended that an obvious,
existing bacterial pollution problem be addressed in the proposed plan
through the inclusion of an interceptor sewer from the existing resi-
dences at Island Lake to the proposed interceptor route along State
Highway 303.
V-7
-------
Mitigative Measures to Protect Marine Water Quality
It is expected that with typical municipal wastewaters and normal,
uneventful operation of the proposed wastewater treatment facility,
the impacts upon marine water quality from treated effluent discharge
to an appropriate site would be minimal. Proper facility design will
result in appropriate pollutant reductions and minimize the potential
for mishaps, and operation of the facility by properly trained person-
nel will further safeguard the environment. However, at this time the
facility planner recognizes that the wastewater to be discharged from
the Trident Support Site has poorly defined characteristics. Although
the U.S. Navy is obligated to provide appropriate wastewater pretreat-
ment before discharging to the regional system, the facility planner
felt that the following recommendations would help ensure a consistent-
ly high quality effluent:
1. Kitsap County should stipulate the maximum levels of pollu-
tants it will accept from the U.S. Navy as part of the con-
tracts for sewerage services. Table III-2 showed recommenda-
tions for pollutants that had been anticipated at this time.
The list would be modified when appropriate.
2. The Trident Support Site effluent should be monitored not
only for the listed pollutants but also for pH, temperature,
oil and grease, heavy metals and cyanide. A monitoring
program would help in identifying problems before they
become substantial and would serve as a record of the
presence or absence of pollutants in the event the effects
of treated effluent discharge upon the environment are
questioned.
As a further precaution for the protection of marine water quality
it is recommended that a 6-month study be undertaken at the proposed
North Port Orchard disposal site. During this study continuously
recording current meters would verify the direction, strength and
frequency of currents at the disposal site. Additional drogue or
drifter studies and measurement of seasonal changes in water column
density structure are recommended. It has already been concluded that
the North Port Orchard site is acceptable. These studies would serve
to further define the local marine condition so that an outfall and
diffuser could be designed to absolutely minimize any environmental
impact.
V-8
-------
RESOURCE IMPACT MITIGATION
Mitigative Measures to Protect Quantity of Potable Water Supplies
The preceding discussion on groundwater is applicable to this
topic.
ECONOMIC IMPACT MITIGATION
There are no substantial negative economic impacts associated
with the implementation of the proposed facilities plan.
SOCIO-CULTURAL IMPACT MITIGATION
There are no substantial negative social or cultural impacts
associated with the implementation of the proposed facilities plan.
IMPLEMENTATION OF MITIGATIVE MEASURES
Table V-l lists the special mitigative measures recommended in
this chapter and provides the responses from Kitsap County and the
EPA construction grants division on recommended implementation of
those measures. In general, the implementation of most of the
measures will become mandated by the acceptance by Kitsap County
of a construction grant from EPA.
The County currently expresses intent to maintain zoning desig-
nations within the study area. It cannot constrain future adminis-
trations from changing this zoning.
The contract between the U.S. Navy and Kitsap County for the
treatment of Trident Support Site wastes will stipulate maximum
allowable levels of pollutants.
V-9
-------
Socio-Economic Systems
SES Project No.
Criterion:
| x| Sub-Criter-lzr.:
l\ Category:
Sub-Category:
Groundwater
Resource Impacts
Natural Resources
Quantity of Potable supplies
DEFINITION:
The degree to which the alternatives affect
the quantity (availability) of potable ground-
water in the Study Area.
RATING:
- 25
+100
+75
+50
BOUNDARY: Alternative 11
Proposed sewered area
METHOD OF ANALYSIS:
Evaluation of type of wells, depth, aquifer
penetrated and proximity to new sewer lines.
DISCUSSION:
It is assumed that clay dams will be required at every
manhole along the sewer lines that traverse high ground-
water areas to prevent draining of the areas. Restricted
use of granular backfill should be required. Without +10
these precautions the rating would be -75 but with these
features the rating of -25 was made indicating that there
will be localized declines in the water table, particularly 0
where dug wells are utilized, such as Brownsville and
Headowdale. This situation is a certainty because the
hydrologic balance of each stream basin will be adversely -10
affected by exporting water extracted from the basin for
discharge outside of the basin. Deep aquifers will
generally not be affected by the project.
Oi
—&»
-50
SOURCE OF REFERENCE:
EIR Form H1016/
Copyright 1973
W. 0. Maddaus, Water Resources Eng.;
Reference 5
-J001—I
Substantially increases
groundwater availability.
flater levels increase in
virtually all existing wells.
Water levels increase in
some existing wells.
No or negligible effect.
1 Water levels decline in
some existing wells.
Water levels decline in
virtually all existing wells.
Substantially reduces ground-
water availability -
numerous wells go dry.
V-10
-------
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;VERSIBLE & IRRETRIEVABLE
SOURCE COMMITMENTS
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CHAPTER VI
IRREVERSIBLE AND IRRETRIEVABLE RESOURCE COMMITMENTS
The proposed facility plan will have negligible resource commit-
ments. The treatment facility site will occupy on the order of 15
acres of land within a 40-acre parcel, which will be removed from con-
sideration for other uses during the life of the treatment facility.
Small amounts of land will be committed to easements for the sewerage
system. Construction of the sewerage system will temporarily destroy
some flora, but this is not a permanent commitment, and regrowth of
vegetation will occur. With regard to other physical parameters, such
as water quality, fauna and marine resources, the effects of the pro-
posed alternative plans would be, if not negligible, at least rela-
tively minor and reversible.
The creation and construction of a regional sewerage system for
sub-basins 9 and 10, for the Trident Support Site and the Poulsbo ser-
vice area will impose on future generations the necessity for a strong
commitment to the maintenance, expansion and continuation of the waste-
water management systems now being developed. The selection of future
alternatives for wastewater collection, treatment and disposal will, to
a large extent, be limited by implementation of the selected plan.
A secondary—and desirable—effect is the population concentration
induced by the interceptor location. By providing service in appropri-
ately zoned areas designated in the General Plan (Reference 41), the
interceptor location could stimulate development according to County
planning goals. This will result in an irreversible environmental
change with respect to the applicable properties by committing them
to use for residential and commercial development purposes. By
permitting relatively high-density development in areas so designated,
the project will reduce the potential throughout the area for urban
sprawl and strip development in contravention of the General Plan.
The proposed plan will also protect the ecological resources of the
rural areas along Clear Creek by locating the Trident Support Site
interceptor sewer along highway rights-of-way and away from the
corridor.
The proposed project will require permanent commitments of
construction materials and a l-i year commitment of construction
workers for a combined value of $18 million. The materials would
consist of concrete, steel, fabricated machinery, electrical
VI-1
-------
components, wood forms and framing, and pipe. The supply of these
materials is not known to be critically short, and their purchase and
use would be beneficial to the regional and national economies.
The employment of construction workers for the regional facility
would draw on a large labor pool at a time of high national unem-
ployment. It cannot be predicted from where the workers might come,
but their employment would be of national and state benefit, and they
would reinvest some portion of their earnings in Kitsap County.
Any wastewater treatment system requires a commitment of energy
resources for its operation. Electricity is used to power equipment
and produce chlorine. This commitment is permanent for any energy
expended but can be terminated when public health protection is no
longer of prime importance.
VI-2
-------
VII SHORT TERM USES & LONG TERM
PRODUCTIVITY
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-------
CHAPTER VII
RELATIONSHIP BETWEEN SHORT-TERM USES OF THE HUMAN ENVIRONMENT AND
THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
IMPACTS OF THE PROPOSED ACTION
This section develops the relationships between basically nega-
tive, short-term impacts upon the environment and the ultimate bene-
fits to be accrued from the proposed facility plan.
Physical Impacts
The negative, short-term physical impacts of the proposed project
will be more than offset by the future benefits. Negative impacts can
be reduced to: temporary (one to ten year) disruption of present types
and quantities of vegetation along pipeline routes; temporary and lo-
calized disturbance of stream ecologies during construction; temporary
(one to three year) disruption of marine benthic communities due to
outfall construction; and a decrease in aesthetic appeal of the site
selected for the treatment facility. There will also be construction
impacts, which will include some traffic impacts due to construction
workers and material hauling, construction noises and—along the inter-
ceptor route—temporary impacting of traffic where the pipeline follows
highways and streets. For alternative plan No. 11, there would also be
some very small and reversible damage to clam beds in Liberty Bay
caused by the construction of the Poulsbo interceptor sewer.
Benefits to the physical environment would occur in varying de-
grees. Failure of septic tank drain fields will no longer occur in
sewered areas connected to the treatment facility. As a consequence,
existing pollution of streams and local groundwaters, which are used
extensively for potable water supply, will diminish. Pollution of Dyes
Inlet, Liberty Bay and Port Orchard channel will, in general, be dimin-
ished, and Health Department restrictions on shellfish harvesting in
presently highly polluted areas probably could be lifted. Health haz-
ards within the study area would be substantially reduced.
VII-1
-------
Adoption of the proposed facility plan would provide sewerage
service and wastewater treatment to wastes originating at the Trident
Support Site.
Resource Impacts
Construction of a treated effluent outfall will temporarily elim-
inate benthic organisms in a small area, and there would be some
small temporary damage to clam beds in Liberty Bay.
Balancing these negative impacts, a substantial reduction in bac-
terial pollution of clam beds is expected, beginning with the elimina-
tion of septic tank drainage and primary level treated sewage dis-
charges. Health Department restrictions upon certain clam harvesting
areas might be lifted, particularly if Poulsbo, Keyport and the Naval
Torpedo Station (Keyport) were to join the regional system.
Socio-Cultural Impacts
Development of a new major wastewater interceptor and treatment
system in an area largely lacking these services provides to Kitsap
County planners and officials a unique opportunity and mechanism by
which growth may be controlled in a well-planned and orderly manner.
The interceptor sewer routings and service areas generally correspond
to areas designated by the Comprehensive Plan (Reference 41) for
maximum urban development.
Placement of sewer interceptors in areas zoned for residential
use will tend to fulfill the goals of the Comprehensive Plan (Refer-
ence 41). Urban sprawl and strip development will tend to be
minimized, thereby maintaining agricultural and open space in areas
so designated in the Plan. The routing of the Trident Support Site
interceptor sewer away from the Clear Creek corridor will protect
the rural designation of that area.
Growth-Inducing Impacts
Growth-inducing impacts are secondary effects of a project which
either lead directly to growth (for example, by attracting large
numbers of workers to an area) or which remove an obstacle to growth
(for example, the construction of a highway which opens a new area
for development).
The growth-inducing impacts of a service facility are related
VII-2
-------
to a number of factors, including: other service facilities, labor
force, capital, transportation network and markets. In Kitsap
County there is another unique factor: the Trident Support Site.
Growth in Kitsap County between 1975 and 1995 will be induced
primarily by the development of the Trident Support Site. According
to the A.D. Little study, the county's population will rise from
its current 114,480 (1975) to 170,989 by 1995. An estimated 31,702
persons, or 54% of the total increase, will be drawn into the county
by the development of Trident. Since the proposed facility can
accommodate only 18,000 people in the service area (exclusive of the
populations of Poulsbo and Lemolo) in addition to the Trident Support
Site flow, no excess service capacity will become available to stimu-
late additional growth until after 1995 (Reference 72). Instead, the
facility will serve some of the additional population resulting
from the Trident development and will channel Trident-induced
growth along interceptor lines other than the interceptor serving
the Trident Support Site. Current planning restricts access to
the Trident interceptor as well as its size.
The rapid rise in local population will hit full stride in 1983,
when the Trident Support Site is scheduled to become operational. The
pressure on housing, schools and all other facilities and services
required by a residential population will be severe, and the area
will not be attractive to newcomers other than those employed at
Trident, their dependents and those associated with public and private
services that the area will need.
The existence of the proposed project will thus not have a sig-
nificant growth-inducing impact in the area; for the foreseeable
future, the entire growth capacity of the area will be strained to
the limit, and beyond, in coping with a growth stimulus already
under construction. When Trident is operating at its planned
level, and associated growth has already taken place, the service
capacity of the proposed facility will be utilized at or near its
limits, thereby effectively eliminating itself as a source of future
growth.
Rather than inducing growth, the proposed project will serve to
channel growth toward its service area, as it mitigates a serious
existing problem: the substandard treatment of sewage. Such an
outcome is clearly desirable because the service area conforms to
planning goals by providing service in urban and transitorial areas
designated for growth.
There will be small indirect impacts attributable to the proposed
project, stemming from the slight increase in jobs (20-40 is the
preliminary estimate) necessary to operate the treatment system,
VII-3
-------
sewer lines and pump stations and to manage the treatment system staff.
There will thus be a minor increase in population, with attendant
needs for housing and supplies, generating a small amount of business
activity. In the context of Trident, this small increase will not
measurably increase the growth pressure in Kitsap County and is
probably substantially less than the precision of estimating popula-
tion growth.
VII-4
-------
wu
•m
i0Mi£ J
-------
CHAPTER VIII
REFERENCES
1. The URS Company. Central Kitsap County Wastewater Facilities:
Draft Facilities Plan, Seattle, Washington, July 1975.
2. Horsely, John. Kitsap County Trident Coordinator, Personal Com-
munication, 13 August 1975.
3. U.S. Department of the Navy. Trident Support Site Final Environ-
mental Impact Statement, July 1974.
4. Pace Corporation. Water Pollution Control and Abatement Plan for
Drainage Basin 15, rough draft, Seattle, Washington,
July 1973.
5. State of Washington Department of Conservation, Division of Water
Resources. Water Resources and Geology of the Kitsap
Peninsula and Certain Adjacent Islands, Water Supply
Bulletin No. 18, 1965.
6. USDA Soil Conservation Service and Washington Agricultural Experi-
ment Station. Soil Survey, Kitsap County, Washington,
1934.
7. USDA Soil Conservation Service. Interpretations of Soils for Land
Use Planning, Supplement to Soil Survey of Kitsap
County, Washington, January 1972.
8. U.S. Army Corps of Engineers, Seattle District, Environmental Re-
sources Section. Washington Environmental Atlas, Jan-
uary 1972.
9. USDA Forest Service. Natural Vegetation of Oregon and Washington,
USDA Forest Service General Technical Report, PNW-8,
1973.
10. Kingsbury, John. State of Washington Department of Natural Re-
sources, South Puget Sound Area. Personal Communica-
tion, 9 July 1975.
11. State Lists of Endangered and Threatened Species of
VIII-1
-------
the Continental United States, Federal Register, Vol.
40, No. 237, 1 July 1975.
12. Ingles, Lloyd G. Mammals of the Pacific States, Stanford Univer-
sity Press, Stanford, California, 1965.
13. Larrison, E.J. and Sonnenberg, K.G. Washington Birds, Their Lo-
cation and Identification, Seattle Audubon Society,
1968.
14. Yocom, Charles and Dasmann, Ray. The Pacific Coastal Wildlife
Region, Naturegraph Company, Healdsburg, California,
1965.
15. Stebbins, Robert C. A Field Guide to Western Reptiles and Am-
phibians, Houghton Mifflin Company, Boston, Massachu-
setts, 1966.
16. Peterson, Roger Tory. A Field Guide to Western Birds, Houghton
Mifflin Company, Boston, Massachusetts, 1961.
17. Larrison, Earl J. Field Guide to Birds of Puget Sound, Seattle
Audubon Society, 1952.
18. Lyons, C.P. Trees, Shrubs and Flowers to Know in Washington,
J.M. Dent and Sons, Ltd., Toronto, Canada, 1956.
19. U.S. Department of Interior, Fish and Wildlife Service. United
States List of Endangered Fauna, May 1974.
20. State of Washington Department of Game. Rare Mammals of Washing-
ton, 1 June 1973.
21. Lincoln, John H. Model Studies of the Port Orchard System and
Adjacent Areas, Interim Report No. 2, University of
Washington, Seattle, June 1975.
22. Kitsap County Planning Department. Basic Data and Related Sources
to Shorelines, Port Orchard, Washington, February 1973.
23. Water Resources Engineers. Ecologic Modeling of Puget Sound and
Adjacent Waters, prepared for EPA, Contract No. 14-31-
001-3385, April 1975.
24. Census of Agriculture - Kitsap County, Washington. U.S. Depart-
ment of Commerce, Bureau of the Census, September 1971.
25. Kitsap County Comprehensive Park and Recreation System Plan, by
the ORB Company, October 1974.
VIII-2
-------
26. Munton, John, Vice President, Industrial Departments, Cascade
Natural Gas Company. Personal Communication, 15 July
1975.
27. Harstad Associates, Inc. Central Kitsap Study Area Comprehensive
Plan. Seattle, Washington, June 1969.
28. Linder, Paul G., Superintendent of Central Kitsap School District
No. 401. Letter of 22 July 1975.
29. Rutherford, F.C., County Assessor, Kitsap County. Assessed Valua-
tions with Levies and Taxes for 1975. Port Orchard,
Washington, 1975.
30. State of Washington Employment Security Department. Employment
and Payrolls in Washington State by County and by
Industry, No. 112, 3rd Quarter, 1974.
31. U.S. Department of Labor, Manpower Administration. Manpower Pro-
file, Kitsap County, Washington, September 1972.
32. Porterfield, Robert, Planner, Kitsap County Planning Department.
Personal Communications, 11 and 15 July 1975.
33. Puget Sound Council of Governments. Data Transmittal from Jan
Pilskog, PSCG, July 1975.
34. Arthur D. Little, Inc. Preliminary Allocations of Population and
Households to Subareas Under Alternative Policy Models,
to Central Puget Sound Economic Development District,
7 May 1975.
35. Sanderson, John, Superintendent of Public Works, Kitsap County
Public Works Department. Personal Communication, 11
July 1975.
36. Williams, Richard, Environmental Planner, URS Company. Personal
Communications, 8, 10 and 14 July 1975.
37. Brincken, Glen, Assistant Manager of Customer Service in Marketing,
Puget Sound Power and Light Company. Personal Communi-
cation, 16 July 1975.
38. Benham, Shirley, M.D., Department of Public Health, Kitsap County.
Personal Communication, 11 July 1975.
39. Loop, Enzo, Kitsap County Traffic Engineer. Personal Communica-
tions, July 1975.
VIII-3
-------
40. Kitsap County, Washington. Kitsap County Planning Policies: Out-
line for the Future Growth of Kitsap County, Washing-
ton: An Element of the Kitsap County Comprehensive
Plan. Approved 24 February 1970.
41. Kitsap County, Washington. Amendment to Kitsap County Planning
Policies: Outline for the Future Growth of Kitsap
County, Washington: An Element of the Kitsap County
Comprehensive Plan. Approved 24 June 1975.
42. Weigle, Joseph and Brown, Eleanor, Kitsap County Health Department.
Personal Communications, 11 July 1975.
43. Benson, Charlotte L. Archaeological Reconnaissance in the Clear
Creek Drainage, Eastern Kitsap Peninsula, University
of Washington, Office of Public Archaeology Reconnais-
sance Report No. 3, 3 February 1975.
44. Shobert, Cheryl, Office Administrator, Kitsap County Assessor's
Office. Personal Communication, 22 July 1975.
45. Savoie, Gordon, Manager of Bond Investments, Security National
Bank. Personal Communication, March 1974.
46. Hill, Ingman, Chase and Company. Comprehensive Water and Sewerage
Plans for Central Kitsap County, Seattle, Washington,
January 1970.
47. Engineering-Science, Inc. Pollutional Effects of Drydock Dis-
charges, a report to the Department of the Navy, Con-
tract No. N62474-73-C-5275, October 1973.
48. Li, Richard C.T. City of Poulsbo Facilities Plan for Proposed
Sewerage Facilities, Seattle, Washington, June 1974.
49. Kramer, Chin and Mayo, Inc. A Comprehensive Sewerage System Im-
provement Plan for the City of Bremerton, Washington,
March 1974.
50. The URS Company. Environmental Impact Statement for the Hansville
Road Solid Waste Disposal Site, Seattle, Washington,
March 1974.
51. Sopper, W.E. and Kardos, L.T. Recycling Treated Municipal Waste-
water and Sludge through Forest and Cropland, Pennsyl-
vania State University Press, University Park, 1973.
52. Stetson, John, State of Washington Department of Ecology. Personal
Communication, 16 July 1975.
VIII-4
-------
53. Lincoln, John H. and Collias, Eugene E. An Oceanographic Study of
the Port Orchard System, Final Report, University of
Washington, Seattle, 1975.
54. Yearsley, John R. Application of an Ecological Model to Port
Orchard, Sinclair Inlet, Dyes Inlet and Liberty Bay
Subsystem of Puget Sound, U.S. Environmental Protec-
tion Agency, Region X, Surveillance and Analysis,
December 1975.
55. Peck, Craig G., et al. Mathematical Model of Three Proposed Port
Orchard System Outfall Sites, Parametrix, Inc.,
Seattle, Washington, November 1975.
56. Arthur D. Little, Inc. Analysis of Selected Impacts of Trident
Related Population Growth in Kitsap County, San Fran-
cisco, September 1975.
57. Fusco, Steve. Letter to Herb Armstrong of Roots Engineering, 28
November 1975.
58. Kitsap County, Washington. Kitsap County Planning Policies: Out-
line for the Future Growth of Kitsap County, Washing-
ton. Approved by Board of Kitsap County Commissioners,
28 July 1975.
59. Lemolo Citizen's Club. Letter of 19 December 1975 to Steve Fusco
of URS Company.
60. Sanderson, John, Superintendent of Public Works, Kitsap County.
Personal Communication, 16 December 1975.
61. The URS Company. Central Kitsap County Wastewater Facilities:
Facilities Plan, Draft Supplement CDecember 1975);
Final Plan (March 1976), Seattle, Washington,
62. Northwest Environmental Consultants. Biological Baseline Studies
and Impact Assessment, Central Kitsap Facilities Plan,
Bainbridge Island, Washington, September 1975.
63. Armstrong, Herbert, Poulsbo City Engineer. Personal Communication,
17 December 1975.
64. Cox, Thomas, Keyport Public Works Department. Personal Communica-
tion, 18 December 1975.
65. Smith, John, Commissioner, Kitsap County Sewerage District No. 4.
Personal Communication, 18 December 1975.
VIII-5
-------
66. Fusco, Steve, URS Company. Personal Communication, 24 November
1975.
67. Voglantz, Lawrence, Kitsap County Department of Public Works.
Personal Communication, 16 December 1975.
68. Loop, Enzo, Kitsap County Engineering Department. Personal Com-
munication, 16 December 1975.
69. Bullard, L., Kitsap County Engineering Department. Personal Com-
munication, 23 December 1975.
70. Sullivan, Larry, Project Director, URS Company. Personal Communi-
cations, 29 December 1975.
71. Hollenbeck, Peggy, Associate Planner, Kitsap County Planning De-
partment. Personal Communication, 24 December 1975.
72. Fusco, Steve, URS Company. Personal Communication, 8 January 1976.
VIII-6
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.
J
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CHAPTER IX
COMMENTS TO THE DRAFT AND SUPPLEMENTAL DRAFT ENVIRONMENTAL
IMPACT STATEMENTS AND RESPONSES
The Environmental Protection Agency held a public hearing on
the Central Kitsap County Draft Environmental Impact Statement on
October 29, 1975 at Central Kitsap County High School in Silver-
dale, Washington. The hearing was attended by approximately 75
people of which four presented testimony for the record on the
statement. Because of the length of the official hearing record
and the costs involved, we have not reproduced the document here.
It is, however, available for public scrutiny at the Kitsap Re-
gional Library in Bremerton, Washington, and in branch libraries
at Silverdale and Wins low, Washington, and at EPA's Region X Office,
Seattle, Washington.
A brief summarization of major concerns voiced at the hearing
includes:
1. David Heiser of the Washington State Parks and Recreation
Commission stated that the Commission was not in favor of outfalls
at Manchester or near Fay Bainbridge State Park because of impact
on tidelands owned by the State and which are utilized by the public
for swimming, clam digging and other recreational activities.
2. Mr. Robert Gedney, a Bainbridge Island resident, stated
that the Draft EIS does not focus on environmental matters to the
degree needed. He expressed concern about the total capacity of
Puget Sound for receiving effluent discharges; necessary precautions
that should be taken to maintain water quality in Puget Sound; and
location of the selected outfall alternative. Mr. Gedney pointed
out that tracer studies would show that tides were often of diverse
nature in the water at proposed outfall sites on windy days and
suggested use of radioisotopes for study of dispersion characteristics
of alternative sites. He questioned whether Kitsap County has the
capability to handle many small sewerage treatment plants, and
stressed the advantages of regional treatment. In addition, the
nature of the Navy's industrial wastes and the pre-treatment that
is given to effluent discharged by the Navy were also presented as
concerns to be considered.
3. Mike Krieger, a Bainbridge Island resident, asked why the
Port Orchard site was shown as a better outfall site and received
higher rating relative to water quality than was the main Puget
Sound, east of Bainbridge Island, and requested further explanation
and re-evaluation of the alternative outfall sites.
4. Joel Haggard, attorney representing C. A. Ross, made re-
ference to comments he had formally presented to EPA by mail (see
Comments Section). He listed several matters to be considered,
such as: what further environmental analyses are required and who
will do them; definition of land use policies by the County and
IX-1
-------
evaluation by EPA in the Final EIS; regarding Trident: will con-
struction people reside on or off the base? What are final pop-
ulation projections? What would be the cost impact and who would
pay taxes if the Navy moved out of the area? What is the per capita
cost, using realistic bond rates? Since alternatives are totally
inadequate in his client's view, why is service to Trident assumed
and why can't the Navy treat wastes on the base and recycle? If a
regional system is selected as the best alternative, will Bremerton
cooperate?
Following these presentations, a question and answer period was
conducted to enable attendees to clarify issues of interest or con-
cern. Issues raised during the discussion period at the public hearing
have been covered in the Supplement to the Draft EIS and in this Final
EIS.
The Environmental Protection Agency, Region X wishes to express
its appreciation to all commenting agencies, groups and individuals
for the time and effort spent in reviewing the Draft EIS. All
comments were presented to the Regional Administrator and were con-
sidered by him in EPA's preparation of the Final EIS.
IX-2
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Room 360 U.S. Courthouse, Spokane, Washington 99201
September 16, 1975
Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
-Seattle, Washington 98101
Dear Sir:
Thank you for the opportunity to review your draft environmental impact
statement on the Central Kitsap County Wastewater Facilities, Washington,
EPA Project C-530494-01. It would appear the items of concern to the
Soil Conservation Service have been adequately covered.
Our only comment for your consideration would be in regard to Chapter V,
Adverse Impacts and Mitigative Measures. We would suggest that wording
of mitigative measures be strengthened to indicate positive action rather
than recommendations. Words such as "could", "should", and "can be" do
not indicate that the mitigative measures will be achieved. Wording that
includes "shall", "will", etc., would strengthen these portions of
Chapter V.
If we can be of further service to you on this or other projects, please
do not hesitate to let us know.
Sincerely,
TJaIen^>. Bridge
State Conservationist
RECEIVED
IX-6
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Room 360 U.S. Courthouse, Spokane, Washington 99201
October 16, 1975
Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
The environmental impact statement draft for Central Kitsap County Wastewater
facilities has been reviewed by this office. A notable effort has been made
to provide a clear understanding of the complex features of the proposal.
In the discussion of soils (P. II-4), reference is made in the second sentence
to the Alderwood and Edmonds series being underlain with hardpan or bedrock.
The reference to bedrock should be deleted from the sentence as the soils
mentioned are only associated with the cemented hardpan condition.
Drainage basin numbers 9 and 10 are frequently noted in the statement. It
is suggested that the delineation system to which these numbers apply be
footnoted. Several delineation systems are utilized in the state and clarity
would be served if the system was identified.
The opportunity to review the statement for this project has been appreciated.
Sincerely,
Galen S. Bridge
State Conservationist
RECEIVED
, i 20 1S75
IX-7
-------
Response to letters from U.S. Department of Agriculture
1. With regard to the mitigative measures recommended for the pre-
ferred alternative, most will be handled by Kitsap County through
construction specifications of the pipelines and facility or by
the NPDES permit issued by EPA. The County has expressed interest
in maintaining current zoning designations. Any mitigative mea-
sures not enforced locally will be included as conditions for
grant approval by EPA. See specific discussion in Chapter V.
2. The correction has been made.
3. The drainage basin numbers designated for the study area were ob-
tained from the "Water Pollution Control and Abatement Plan for
Drainage Basin 15," prepared by the Pace Corporation of Seattle,
Washington. This report was identified as Reference 4 in the
draft EIS.
IX-8
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Room 360 U.S. Courthouse, Spokane, Washington 99201
March 24, 1976
Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
We have reviewed your supplement to the draft environmental impact statement
for the Central Kitsap County Wastewater Facilities (EPA Project No. C-530494-01)
and find we have nothing further to add to our letter of September 16, 1975
relative to this project.
Thank you for the opportunity to review your supplement.
Sincerely,
Galen S. Bridge
State Conservationist
RECEIVED
f.;AR 2 9 liJ/6
IX-9
-------
ROBERT H. GEDNEY
ROUTE 7, BOX 7851
BAINBRIDGE ISLAND, WASHINGTON 981 1O
TEL. (206) 842-5353
September 22, 1975
Mr. Richard R. Thiel Reference: Your M/S 443
Chief, Environmental Impact Section Aug. 25
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Wash. 98101
Dear Mr. Thiel:
Thank you for your above referenced acknowl-
edgement and the Draft E.I.S. of the Central Zitsap County
Wastewater Facilities, which I subsequently received. In
accordance with your invitation, I am pleased to submit here-
with my attached comments on the E.I.S. and related matters.
The very recent public announcement of the
reported high level of mercury pollution in Liberty Bay is a
most tangible demonstration of the two major concerns about
the Kitsap County Wastewater Facilities which I expressed in
my letter of Aug. 8 to Director Biggs, namely:
i) studies are needed to fill the gap of information about the
effects of wastewater discharges into the main channels of the
Sound on the bays and inlets of the Sound shoreline£ and
ii) the nature and characteristics of the proposed waste eff-
luents need further evaluation with respect to toxicants,
particularly from the Trident facility.
Likewise the overall capability of the Sound to receive toxi-
cants at present and projected levels needs immediate evalua-
tion.
Although the forgoing matters are noted casually
in the E.I.S., the signifigance is submerged in the imposing
aggregation of verbiage and computerized presentation of the
text. In reading the Statement one has the feeling the authors
are ritually conforming to a prescribed format and do not wish
to delve deeply into basic environmental concerns.
I am aware that E.P.A. has, in preliminary
form,data on mercury and PCB levels in Puget Sound. The
question should be asked as to the capability of the Sound
to accept further loadings of existing waste systems, as well
as projected loads, with respect to marine life systems.
RECEIVED
P 2, 31975
IX'10
-------
Gedney
Sept. 22,1975
The matter of Tertiary treatment requirements
needs some further discussion. What might be its goals and
what might it consist of? In Puget Sound the Tertiary treat-
ment requirements might be significantly different from those
of freshwater environments.
Another matter of signifigance is the prolifer-
ation of treatment systems in Kitsap County. Is it reasonable
that each municipality such as Poulsbo, Bremerton and Silver-
dale should have its own system. The administration and opera-
tion of these separate systems may well become so costly and
complex that the separate municipalities simply will not be
able to support these costs* In the matter of laboratory con-
trol alone, the costs of complex routine tests which should be
made may well be beyond the budgeted funds available, let alone
the provision of skilled personnel for their undertaking and
evaluation. Shouldn't some thought be given to at least a
county organization and operation.
I appreciate the opportunity of submitting
these comments and I would like to be further informed about
these matters.
Encl,/Comments Sincerely yours,
^ J
*fje0Uu*^
Robert H. G-edney /I
cc Mr. John Biggs
IX-11
-------
September 22, 1975
COMMENTS BY ROBERT H. GEDNEY
ON THE DRAFT E.I.3.
CENTRAL KITSAP COUNTY
WASTEWATER FACILITIES
Dated Aug. 1975
1. Page xii, 5th par.
The statement is made that, "Development of a sewer interceptor
system will tend to promote growth along corridors of sewerage
availability."
This premise is open to serious question as such lands will
have higher costs and taxes and thus new housing may continue to
seek lowcost lands unless the County exercises zoning and positive
control measures to restrict or limit land development to sewered
areas.
2. Pg. 1-3, Fig. 1-1
Sub-basins 9 and 10 should be shown on the figure.
3. Pg. 1-4, under SUMMARY
The major issues noted include an item on "marine water quality".
However, there is no mention of marine ecology which should be a
major environmental concern.
4. Pg» 1-8, under Alternative Plan No. 9
It appears that the matter of the esthetics of the Manchester
Site visibility are overemphasized... perhaps a better statement
would merely emphasize the need for appropriate screening and land-
scaping.
5. Pg. 1-11, Table 1-1
The table would be enchanced by addition of a column on compara-
tive costs.
6. Pg. 11-32, under the Section, MARINE WATER QUALITY REGULATIONS
AND STANDARDS
The standards cited are only primary physical and biologic
standards. There is a real need to discuss toxicants, heavy metals,
chlorinated hydrocarbons and other hazards to the marine environ-
ment.
IX-12
-------
7. Pg. 11-33, under Physical Marine environment
No mention or concern is expressed about the possible buildup
of waste loadings in the many small bays and inlets which could
result from effluent discharges into the main channels of Puget
Sound.
8. Pg. 11-55, last par. under MARINE WATER QUALITY
No discusion is presented with respect to whether there is
an adequate data base to evaluate presence or absence of toxicants
in the Sound.
9. Pg. 11-36, 4th paragraph
The discussion of the effects of wasteload nutrients is very
lightly treated. Do competent authorities consider that nutrient
removal is a significant factor with respect to ecologic conditions
in the Sound? I-Jy preliminary and informal advice is that they do
not.
10. Pg. 11-37, Discussion of model limitations and their implications
Again there is no mention about possible effects of main channel
discharges on bays and inlets... nor is there any mention as to how
the shortcomings of the model should be remedied, i.e. through proto-
type measurements.
11. Pg. 11-39, last par.
There is no mention as to how a Pt. Monroe Outfall might affect
Port Madison, Eagle Harbor and Suquamish Bay locations.
12. Pg. 11-42, under BIOLOGICAL MRE3E MfiriBOflMBNT
This entire section is merely descriptive in terms of the
animal life and fauna in the Sound» There is nothing suggestive
of evaluations of present and projected waste loads on the environ-
ment... in other words a waste loading evaluation.
13.Pg III-4, 4th and 5th par's.
These paragraphs leave many important questions unasked, for
examp e - ^^ hydrocarbons
In the reported occurrence of various metals/from the existing
facility as wastes, were measurements made to determine whether
other toxicants were present such as mercury, PCBs, etc,.
Why hasn't the Navy taken steps to end these discharges? What is
their zone of influence?
Why isn't it vitally important that the Navy go on record as to the
kinds of toxicants expected from Trident, the estimated loadings,
the kind of treatment proposed and an evaluation furnished by the
Consultant as to the effectivety of such treatment and dependability
of special treatment measures.
Should a closed system of waste discharge and reuse be considered
for Trident to avoid hazards to the Sound?
In par. 4 it is stated that industrialization is virtually non-
IX-13
-------
existant in the tri/butary area and is expected, to remain so.
With a projected population increase of about 40,000 to year
1990, it can certainly be expected that at the least,fringe
commercial-industrial development will occur and that correspondingly
precautionary measures will be necessary to avoid toxicant waste
loadings«
14. Pg III-7, under Bremerton
Were analyses performed to determine presence of toxicants
in the domestic sewage, or were the analyses limited to routine
parameters?
15. Pg. 111-28, under Project Costs
There is no information as to how the Study Area's share of the
costs were determined. There is no presentation of costs to the
user, at least in some simplified form. The presentation of Annual
Costs in the E.I.S. is obscure with respect to the user who will
support the system. There is also lacking any discussion of cost
efficiency/of combining the various systems.
fand benefits)
l6« General
%ere is no discussion as to what might be involved in ultimate
tertiary treatment, although under E.P.A. guide lines this might be
an imminent requirement.
IX-14
-------
Response to letter from Mr. Robert H. Gedney
1. An evaluation of the effect of wastewater discharges upon Puget Sound
is a worthwhile project but totally beyond the scope of this EIS. Our
analysis indicates that land disposal is infeasible; therefore, some
form of discharge to the Sound is all that remains. The EIS studies
on the Sound waters adjacent to the study area do estimate effects,
and on the basis of these studies Dyes Inlet, Sinclair Inlet and
Port Orchard channel at Enetai were unfavorably rated.
2. Waste effluents from domestic or typical municipal sources have been
studied nationwide. Because of this we are able to say with confi-
dence that, with proper secondary level treatment, chlorination and
de-chlorination, any domestic wastewater would be acceptable under
the preferred alternative. Admittedly, we do not know specifically
what toxic matter may be discharged by the Trident facility. How-
ever, any toxic material that cannot be removed by the regional
facility will have to be removed by the U.S. Navy in a pretreatment
process, as required by 40 CFR Part 128.
3. Unfortunately this is far beyond the scope of this study. Our re-
sults indicate that, for the preferred alternative, local effects
will be insignificant, but this does in part depend upon flushing
of diluted effluent into the main body of Puget Sound.
4. It is agreed that tertiary treatment requirements may differ for
fresh and saline waters. There is no specific tertiary treatment
level or process that is defined by law or by the engineering pro-
fession. In effect, tertiary treatment means any major processes
that must be added to standard secondary treatment processes in
order to achieve or maintain receiving water quality standards.
The recommended alternative will not require a tertiary add-on-pro-
cess to meet water quality standards at this time, and we have no
information concerning the upgrading of receiving water quality
standards.
5. We agree and firmly believe that a regional treatment system, barring
large transport costs, is the most cost-effective solution. For
this reason, we are recommending regionalization with Poulsbo, Silver-
dale and all major wastewater sources in the study area. Inclusion
of Bremerton did not turn out to be as cost-effective, not is it
considered institutionally feasible (See earlier comments of CH2M
and City of Bremerton).
Response to comments:
1. It is understood from Mr. Gedney?s statement that the physical
presence of sewerage will raise the costs and taxes on land, making
development on that land more expensive. It is recognized that
sewerage systems, no matter how they are implemented, will result
in increased property values. However, Kitsap County does have the
IX-15
-------
option, through judicious zoning, of forcing new growth to concen-
trate in areas of sewerage availability. It is hoped that the
County will implement a planning policy that will designate, and
make coincident, areas for sewerage and growth. In terms of addi-
tional cost, most housing developments under construction in un-
sewered areas of the county are already installing dry sewer sys-
tems, temporarily leading to local septic fields, in anticipation
of a future sewerage system.
2. The relationship between the study area and drainage sub-basins 9
and 10 is appropriately described in Chapter II, Figure II-l.
3. Marine ecology as an issue is secondary to marine water quality in
that any substantial effects upon marine ecology would come about
as a result of changes in water quality due to effluent discharges.
Since marine water quality is the controlling factor, it was singled
out as a major issue. However, the environmental assessments were
made with careful attention to possible impacts upon marine organ-
isms, and these were identified in the appropriate statements. Most
effects upon marine ecology should be negligible.
4. Within the rigid limits of an evaluation of aesthetics for each al-
ternative, the Manchester site is appropriately treated. The rela-
tive concern or weight of aesthetics as an issue is resolved in the
EVAL system by multiplying each category score by a weight factor,
indicating its importance to local citizenry in the overall envi-
ronmental scheme.
5. Comparative costs are presented elsewhere in the Draft EIS and have
been integrated into the overall ratings of each alternative.
6. Additional water quality standards are presented in Appendix F. It
is unreasonable to expect every proposed discharger to marine waters
to question the adequacy of criteria set by law, in an environmental
impact statement. Existing criteria have been promulgated with the
intent of protecting the environment within the boundaries of proven
or probable damage and the technical feasibility of correction.
7. Our study results, and those of the facilities planner, indicate
that there is a net flow of water from bays and inlets into the
main body of Puget Sound. With this net flow, and the high dilu-
tion anticipated for any Puget Sound discharge, waste buildup
should be negligible and temporary in small bays and inlets.
8. This is beyond the scope of our study. We have only evaluated the
water quality criteria at our points of discharge.
9. Our estimates of the effects of waste nutrients are presented in
the final EIS. A much more detailed discussion of a computerized
modeling of nutrient loadings is presented in the final Facilities
IX-16
-------
Plan document which was one of the bases for our studies.
10. The shortcomings of the hydraulic simulation model, which was real-
istically evaluated in the draft EIS, could be overcome only by
reassessment of model parameters through field measurement of cur-
rents in Puget Sound. This was the purpose of the Phase II oceano-
graphic studies, the results of which are presented in Chapter II
of the draft supplemental and final EIS. In general, we felt that
our independently used continuity equations produced answers com-
parable to the modeling reported in the final Facilities Plan docu-
ment.
11. In view of the excellent dilution expected at the Point Monroe site,
it is estimated that effects of the discharge upon other areas would
be very minor if not undetectable.
12. A quantitative evaluation with any assurance of accuracy is virtu-
ally impossible at the present state-of-the-art. Please see the
responses to the letter from the Washington State Parks and Recre-
ation Commission.
13. Mr. Gedney has misread the paragraphs in question. Measurements of
shipyard wastes were not made at the Trident site but at other dry-
docks along the West Coast. Various metals and toxicants were mea-
sured, but EPA's consultant is not free to disclose the information.
Presumably the U.S. Navy will use this information internally to
develop estimated waste characteristics for the Trident site. The
referenced study also found that commonly available treatment pro-
cesses could remove the pollutants from these wastewaters.
The final EIS contains the facilities planning consultant's esti-
mate of Trident waste characteristics. The U.S. Navy has not re-
leased their estimates of waste characteristics, but Title 40 of
the U.S. Code, Chapter 1, Subchapter D, Part 128, ensures that in-
dustrial wastewaters will be pretreated for compatibility with mu-
nicipal treatment works. This means that the combined processes
must meet desired effluent and receiving water quality criteria.
With regard to fringe industrial development, future growth has not
yet been predicted. If it should occur within the context of a
publicly owned sewerage and treatment system, pretreatment require-
ments will ensure a safe and acceptable treated effluent. If fringe
industrial development should happen with no sewerage systems avail-
able, the industries would be forced to treat their own wastewaters
but would still discharge to the waters of Puget Sound. This would
be a less acceptable course of action.
14. The wastewater characteristics for Bremerton were assumed by the
facilities consultant to be typical of municipal wastewaters. No
analyses were conducted on Bremerton's wastes. Standard wastewater
IX-17
-------
treatment processes envisioned in the economic analysis of alter-
natives are adequate to remove typical municipal wastewater toxi-
cants to a harmless level. Any unusually resistant or persistent
toxicants would be dealt with accordingly, in order to maintain
receiving water standards.
15. The discussion of project costs has been expanded in Chapters I
and III of the final EIS.
16. EPA defines Best Practicable Waste Treatment in its publication
No. 430/9-75-013 of October, 1975 as secondary treatment, or
higher if required to meet water quality standards, for treat-
ment and discharge to surface waters. Again, we feel that water
quality criteria can be met with only secondary level treatment
for a discharge to north Port Orchard channel.
IX-18
-------
DANIEL. J. EVANS
GOVERNOR
RICHARD W. HEM8TAD
DIRECTOR
STATE OF WASHINGTON
Office of the Governor
OFFICE OF COMMUNITY DEVELOPMENT
OLYMPIA, WASHINGTON 088O4
108/791.1200
February 5, 1976
File No. 1236
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
This letter will acknoxjledge receipt of the Supplement to the Draft
Environmental Impact Statement on the Central Kitsap County Wastewater
Facilities EPA Project No. C-530494-01.
If you have not received a response from this Office by the end of the
review period, you can assume that we have no comments on this project.
Sincerely,
Lois E. Dufresne
A-95/EIS Coordination Section
Community Planning Division
LEDrl
RECEIVED
IX-19
-------
October 27, 1975 ^v^shin-T.,,,
i >t-i MruiK iii
Mr. Richard R. TMel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
RE: Draft Environmental Impact Statement,
Central Kitsap County Wastewater Facilities
Dear Mr. Thlel:
Thank you for the opportunity to review this document. It 1s apparent
that you have compiled a relatively complete document covering your project.
This draft reflects an example of a well prepared statement which contributes
to the better understanding of the areas of the proposal.
Review by our regional and headquarters staff members has produced these points:
1. Possibly some Information addressing how and to what extent the I ,
Industrial waste of Trident could have with regards to the proposal. |
2. Some mention of the cost of a non-regional plant could be added to I
assist 1n the comparison of regional vs. non-regional alternative. I '
We appreciate the opportunity to have reviewed your statement. If we can be
of futher service to you, please contact me at 753-6892.
Sincerely
D. R. Thompson, fc.T., P.E.
Environmental Review Section
RECEIVED
DRT;JW OCT281975
cc: Larry Lewis, N.W. Region v-p*_<-'~
IX-20
-------
Response to letter from State of Washington, Department of Ecology
1. A discussion of Trident Support Site wastes is presented on pages
2 and 3 of Chapter 3 of the final EIS. At this point, it is not
known exactly what the Trident wastes will contain, and the accept-
ability of these wastes for treatment in the County's facility lies
with the intent of the U.S. Navy to provide pretreatment and the
wording of the County's contract accepting these wastes.
2. The cost of a nonregional facility vs. the cost of the regional
facility is best explained in Chapter 1 of the final EIS where
Poulsbo's option to join the regional facility system is evaluated.
Readers are also directed to Kitsap County's Final Facilities Plan
for this cost information.
IX-21
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CXF1
600 North Capitol Way / Olympia, Washington 98504
Game Commission
Claude Bekins, Seattle, Chairman
Glenn Galbraith, Wellptnit
Frank L. Cassidy. Jr., Vancouver
Arthur S. Coffin, Yakima
Elizabeth W. Meadou-croft, Tacorna
Archie U. Mills, Wenatchee
Director / Carl N, Grouse
Assistant Directors / Ralph W. Larson
lack S. Wayland
September 19, 1975
Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Attention: Mike Mills, Office of Program Planning and
Fiscal Management, State of Washington
Dear Mr. Thiel:
The draft environmental impact statement Central Kitsap County
Wastewater Facilities, EPA project number C-530494-01, was reviewed by our
staff as requested. Our comments follow the format of your report.
Your statement seems quite extensive and well done. It is obviously
a sincere and objective effort to assess effects of the proposed action.
Our main concern is maintenance and enhancement of sport fish and wildlife
in the State of Washington.
Environmental Impacts:
The word "displace" is used to describe what the construction of a new
wastewater treatment facility will do to wildlife (page IV-9). We must object
to such usage of the word "displace", on principle. It suggests that the
wildlife will successfully relocate elsewhere. Loss of wildlife habitat,
however small, means a proportional reduction in wildlife numbers. Use of
space which is now wildlife habitat for a sewage plant will not simply cause
wildlife to relocate, but will act to significantly reduce wildlife numbers
at the site at least for the lifetime of the project.
We noted that alternatives three and four necessitate saltwater
crossings of the pipeline (page IV-18). In considering the full potential
impacts of this measure, should not the possible effects of pipeline rupture
be examined?
RECEIVED
IX-22
cp v
-------
Mr. Thiel -2- September 19, 1975
Adverse Impacts and Mitigative Measures:
The indication that you will seek recommendations from the Soil
Conservation Service and the Department of Fisheries concerning construction
of sewer lines through creeks (page V-6) is certainly commendable. A joint
hydraulics permit is required from our department and the Department of
Fisheries for work to be done within the wetted perimeter of streams.
The statement, "Assessment of the effects of wastewater discharge
upon the benthic community is expected to be minimal." (page V-1Q), is
somewhat confusing. Does this mean that examination of benthic communities
will be cursory? Or, does this mean that wastewater outfall will only effect
benthic communities in a limited manner. Clarification of this point in your
final statement seems desirable.
Appendix D:
This section seems to be rather academic, but well done, and appreciated.
We believe that herb Epilobium angustifolium is fireweed. We are quite surprised
that you did not find any Taxus brevifolia, or various species of the Genus
Mimulus (monkey flowers) (Scrophulariaceae family) in the study area.
References:
It was of interest to note that one of your references is the Washington
Environmental Atlas, by the U. S. Army Corps of Engineers. We recognize this
as a valuable tool for many types of natural resource work. There may be some
areas of your report where more extensive use of it could be advantageous.
You do not mention that the Atlas indicates the study area to be a critical
wildlife habitat (page 37 of the Atlas). In describing existing conditions
it may be helpful to mention the life zone in which the study area exists
(Humid Transitional Timbered, page 16 and "Life Zone Overlay" of the Atlas).
It may also be beneficial to indicate in Appendix D those birds on the National
Audubon Society's Blue List (page 40 of the Atlas).
Thank you for the opportunity to read and comment on your draft. We
trust our comments will be given consideration during preparation of your final
statement.
Sincerely,
THE-DEPARTMENT OF GAME
fEugene S. Dziedzic, Asst. Chief
Environmental Management Division
ESDrjb
cc: Fred Hosea IX-23
Agencies
-------
Response to letter from State of Washington, Department of Game
1. Current design plans for the Keyport crossing include a trench to
bury the pipeline and shield it from external damage. Pipeline
construction materials under consideration include high-pressure
PVC, a material that resists the corrosive effects of salt water
and sewage constituents.
2. This was a typographical error. It was intended to say that the
effects upon benthic communities from an ocean outfall would be
minimal, given the level of treatment and dispersion characteris-
tics estimated for the study area.
3. The plants have been added to the species list at your suggestion!
we simply did not notice any during our .survey.
IX-24
-------
OF
600 North Capitol Way / Olympia, Washington 98504
Game Commiritvn
Claude Be/tins, Seattle. Chairman
Glt'nn Galhratth. Wellpmit
Vrank L Catsidy. Jr. \'jnnnii\-r
Arthur S Coffin, Yaliwa
Klizaheth \f>. Miadou cro/i 'ljii,ii
Archie I' Millt. Vt'cnatihti
Director / Carl N. Crouse
4trt\taat Dimtnrt Ralph It" /..//>•//;
J.tit .S IT./)/,,;;,/
March 22, 1976
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA. 98101
Dear Mr. Thiel:
RECEIVED
2 4 1976
pp A_r--~
Your supplement to the draft environmental impact statement- -Central Kitsap
County, Washington, Wastewater Facilities, EPA Project C-530494-01— was
reviewed by our staff as requested. Comments follow.
Your efforts to fully evaluate alternatives, as reflected by this supplement,
are notable. As in our review of the original draft statement (correspondence
of 9/19/75 to Richard R. Thiel), we found this supplement thorough and objective.
Attention is given to the indirect and oftentimes elusive effects associated
with wastewater facility improvements as well as the more primary impacts of
construction and operation.
The discussion of growth-inducing impacts warrants comment. You seem to say
that this project would respond to service needs brought about by growth induced
by other causes (principally the Trident Project). This growth is expected
in any case. Adverse impacts on wildlife resources associated with that
growth will occur whether this proposal is implemented. While this may be
so, we hasten to point out that a need still exists for full evaluation of
wildlife impacts connected with population growth resulting from the Trident
Project. To our knowledge, such secondary impacts have never been fully
analyzed. For some time we have been participating in negotiations with the
Navy. These negotiations are aimed toward finding means to accomplish full
analysis of secondary wildlife impacts associated with the overall Trident
Project and appropriate mitigation. To date, no settlement has yet been
reached. We are concerned that wildlife needs not be forgotten as facilities
(such as the proposed project) come on-line to meet other needs partially or
wholly created by the Trident Project.
Thank you for the opportunity to review your supplement.
will be helpful.
Sincerely,
We hope our comments
THE DEPARTMENT OF GAME
/.f.
ESDrjt
cc: Hosea
Agencies
Eugene S. Dziedzic, Asst. Chief
Environmental Management Division
IX-25
-------
MMIEL J. EVANS
GOVERNOR
ROOM 115, GENERAL ADMINISTRATION BUILDING •
OLYMPIA, WASHINGTON 985O4
PHONE 753-66OO
DONALD W. MOOS
DIRECTOR
October 20, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
Your Draft Environmental Impact Statement for the Central Kitsap County Waste
sideration ***" rev1ewed' We have a few comments to offer for your con-
in thpnn, in. the. development of Kitsap County's wastewater facilities lie
*n Sron V P°tent1al lr"Pact on fisheries resources. Your statement has done
ClJr cllTS J2bt;n Presentln9 existing conditions and in anticipating impact on
Clear Creek and the marine receiving waters. Since we had the opportunity to con-
tribute data in areas of concern during the development of the Draft Facilities
Plan, there are only a few additional points we wish to cover.
u j J* n! stated that timing of the work that would disrupt the Clear Creek stream
tr^'hPd aV°TH Pe,T?S °f ? lm°n Cation. we would add" that damage to he
stream bed or the addition of sediment during the periods of egg and fry incubation
95 l flsh Potion. While the same statement regarding
Facilities Plan, it was overlooked in our response to
We also note that the recommended mitigative measures to protect Clear Creek
]ow foLp3 rS P^?11^ Crossings at locations where the creek is narrow and shal-
chaiin,,9 '' I uh! Str?am 9^dient of much of Clear Creek is moderately
shallow, an area of such description might provide some of the better spawning
bed material within the stream. A Hydraulic Projects Approval, jointly issued bv
the Departments of Game and Fisheries, should be obtained for this work and stream
crossing sites should be specifically identified and evaluated at that time.
We are encouraged to learn that the water quality of Dyes Inlet should be
improved with whichever alternate is selected. It should also be pointed out that
a much greater improvement in Dyes Inlet water quality would b* realized if thP
effluent is discharged into any of the other water bodies being considered. '
earl1est communications relative to development of this wastewater
plan, we favored effluent discharge in the more open areas! such as near
IX-26
RECEdVFO
f;CT 21
-------
-2-
Point Monroe or Manchester, and avoidance of the more confined inland bodies of
water. Since that time, however, we have discovered some of the best beds of sub-
tidal geoducks in Puget Sound located between Skiff Point and Point Monroe. These
beds will support a substantial regulated geoduck harvest and we anticipate leases
will be given in the near future. Therefore, we are very concerned about any impact
that a discharge within this area, such as proposed in Alternatives 3 and 4, would
have on this resource. Alternative 9, discharge at Manchester, appears to offer the
most favorable circumstances for preserving the quality of the marine receiving
waters.
In summarizing the discharge of treated effluent into Sinclair Inlet (Alter-
natives 6 and 7, pages 1-7 and -8), it is stated that dilution is good and dispersion
is fair. However, the model results cited on page 11-41 state that there will be
poor dispersal and mixing due to low current velocities. Some clarification would
be helpful.
Thank you for the opportunity to review your well prepared draft statement.
We hope these comments will be useful to you in preparation of the final EIS.
Sincerely,
^?C
Ray CJohnon, Acting
Fisheries Environmental Coordinator
cc: Mike Mills, OPP&FM
D. L. Lundblad - Dept. of Ecology
E. S. Dztedzic - Dept. of Game
IX-27
-------
Response to letter from State of Washington, Department of Fisheries
1. A Hydraulic Projects Approval will be sought from the Department
of Game and Fisheries along with additional recommended mitigative
measures for all water crossings. It should be noted that the rec-
commended plan does not involve placement of an interceptor sewer
along Clear Creek.
2. A greater improvement may not necesarily occur unless Bremerton
ceases discharge into Port Washington Narrows. The recommended
plan routes all study area sewage away from Dyes Inlet and would
discharge the treated effluent into North Port Orchard channel,
where flushing characteristics are far superior.
3. Preliminary unpublished results from the Bremerton Facilities Plan
study indicate that a Manchester outfall could result in a greater
return of diluted effluent to Port Orchard than had been expected.
However, the recommended alternative would not discharge at
Manchester or Point Monroe but in North Port Orchard channel. Pro-
tection of the commercial geoduck beds would have occurred by ex-
tending the outfall beyond the beds, but consideration of the beds
and the potential aquatic park preserve at Fay Bainbridge helped
lead to selection of the recommended plan.
4. Initial modeling results were subject to some variation in inter-
pretation subject to the context of the statement. The field
studies conducted by the University of Washington were designed to
dispell some of the initial uncertainties, and the results are pre-
sented in Chapter 2 of the final EIS.
IX-28
-------
GOVERNOR
DANIEL J. EVANS
COMMISSIONERS:
JEFF D. DOMASKIN
THOMAS C. 6ARRETT
KAY GREEN
BEN HAYES
RALPH E. MACKEY
EUSTACE VYNNE
WILFRED R. WOODS
DIRECTOR:
CHARLES H. OOEGAARD
WASHINGTON STATE
PARKS & RECREATION COMMISSION
LOCATION: THURSTON AIROUSTRIAL CENTER
P. O. BOX 1128
PHONE 753-5755
OLYMPIA, WASHINGTON 98504
October 21, 1975
IN REPLY REFER TO:
35-2650-1820
Draft EIS -
Central Kitsap
County Wastewater
Facilities
Mr. Richard R. Thiel
U. S. Environmental
Protection Agency
Region X
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
The Washington State Parks and Recreation Commission has reviewed the above-
noted document and has the following comments:
The Washington State Parks and Recreation Commission had previously reviewed
the Draft Facilities Plan. A letter was written to Mr. Steve Fusco of the URS
Company expressing our concerns with the Draft Facilities Plan. Our concerns
remain after reading the Draft Environmental Impact Statement.
The following is essentially what the letter to URS from the Washington State
Parks and Recreation Commission said:
"Plan No. 3P proposes an outfall somewhere in the vicinity of Fay Bainbridge
State Park. State Parks would oppose an outfall on the tidelands owned by the
Washington State Parks and Recreation Commission which front Fay Bainbridge
State Park. Further, State Parks would oppose an outfall that would impact
tidelands owned by the Commission. These tidelands are utilized by the public
for swimming, clam digging and scuba diving. There is a proposal to create
an artificial reef in front of Fay Bainbridge State Park to provide a fish
habitat and point of interest for scuba divers.
The Washington State Parks and Recreation Commission requests that the interests
of the recreating public be seriously considered when siting an outfall in
this vicinity."
RECEIVED
IX-29
-------
Mr. Thiel -2- October 21, 1975
Thank you for the opportunity to comment. If we can be of further assistance
please let us know.
Sincerely,
sg
David W. Heiser, Chief
Environmental Coordination
Arthur M. Skolnik
State Conservator
IX-30
-------
Response to letter from State of Washington, Parks and Recreation
Commission.
1. The outfall proposed in alternative 3P would be located several
hundred yards south of the State Park. The depth of the outfall,
at least 165 feet, and distance from the shoreline would make any
travel of effluent back to the shoreline minimal. Secondary level
treated effluent, after initial dilution within the mixing zone,
would have a very negligible impact upon water quality and thus
the Commission-owned tidelands.
With regard to the proposal to create an artificial reef for fish
habitat in that area, the diluted effluent would rise to the sur-
face and have no noticeable effect upon submerged reefs. As a
point of interest, fish have been frequently observed residing at
the ocean outfall for primary effluent from the Seattle West Point
facility. This situation does indicate that negative impacts
should not necessarily be associated with outfalls.
Finally, principally because of cost-effectiveness and, in some
measure, the opposition by your agency, this alternative is not
recommended.
Following is an excerpt from "West Point Environmental Planning
Study, Interim Report," by Metropolitan Engineers for Seattle
Metro, April 1973. The excerpt refers to the discharge of primary
level effluent and digested sewage sludge through an outfall into
Puget Sound from the West Point treatment plant.
"Studies were conducted by METRO from 1966 (prior to
startup of the West Point treatment plant) to 1968 to
determine the effects of the West Point discharge on
benthic organisms (bottom dwellers) and the extent of
possible buildup of sludge materials in the vicinity of
the outfall. Visual inspections of conditions in the
vicinity of the outfall were conducted in 1968 and 1971.
Further investigations of the benthic sediments and
organisms in this vicinity will be conducted in 1973.
"No measurable deposition of digested sludge was ob-
served in the vicinity of the outfall in the studies
conducted. Core samples of bottom sediments collected
in 1966 through 1968 indicated no layering of materials
and no definable buildup of organic material.
"Comparisons of the abudnance of certain benthic fauna
between 1966 and 1968 (preplant to postplant comparison)
after two years of plant operations indicated minor vari-
ations in numbers. The numbers and areas involved were
sporadic, however, and both positive and negative varia-
tions were observed, making interpretation difficult. In
IX-31
-------
any event no substantial change in benthic populations
was observed. The aquatic fauna visually observed in
the immediate vicinity of the outfall in both the 1968
and 1971 inspections appeared normal in both numbers
and reaction to effluent from the treatment plant. In
the 1971 inspection, sea anemone were observed attached
to the ballast rock and diffuser itself, and three spe-
cies of fish - ratfish, lingcod and copper rock fish -
appeared to have taken up residence in the ballast rock
surrounding the outfall."
IX-32
-------
GOVERNOR
DANIEL J. EVANS
COMMISSIONERS:
JEFF D. DOM ASK IN
THOMAS C. GARRETT
KAY GREEN
BEN HAYES
RALPH E. MACKEY
EUSTACE VYNNE
WILFRED R. WOODS
DIRECTOR:
CHARLES H. ODEGAARD
WASHINGTON STATE
PARKS & RECREATION COMMISSION
LOCATION: THURSTON AIRDUSTRIAL CENTER
P. O. BOX 1128
March 25, 1976
PHONE 7S3-S755
OLYMPIA, WASHINGTON 98504
IN REPLY REFER TO:
35-2650-1820
Supplement to
Dr. EIS -
Central Kitsap
County, Washington,
Wastewater Facilities,
EPA Project C-530494-01
(E-502)
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
The Washington State Parks and Recreation Commission has reviewed the
above-noted document and does not wish to make any comment.
Thank you for the opportunity to review and comment.
Sincerely
Environmental Coordination
\
U^Arfhur M. Skolnik
\ State Conservator
IX-33
RECEIVED
MAR 2
0 1376
-------
GOVERNOR
DANIEL J. EVANS
COMMISSIONERS:
IEFF D. DOMASKIN
THOMAS C. GARRETT
KAY GREEN
BEN HAYES
RALPH E. MACKEY
EUSTACE VYNNE
WILFRED R. WOODS
DIRECTOR:
CHAR1ES H. ODEGAARD
WASHINOTON STATE
PARKS & RECREATION COMMISSION
LOCATION: THURSTON AIRDUSTRIAL CENTER
P. O. BOX 1128
January 22, 1976
PHONE 753-5755
OLYMPIA, WASHINGTON 98504
IN REPLY REFER TO:
Mr. Richard R. Thiel, P.E.
Chief, Environmental Impact Section
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Thiel:
We have reviewed the proposed wastewater facilities project in your
Central Kitsap County EIS and find that it does not affect any properties
on the State or National Registers of Historic Places nor are there pro-
perties in the project area that have been inventoried for their cultural
value.
We have also reviewed the report of the Archaeological Reconnaissance
in the Clear Creek Drainage, Eastern Kitsap Peninsula and concur with
the conclusions reached by the investigating archaeologist that imple-
mentation of the proposed sewer line will have no negative effects on
cultural resources in the project area. We suggest that the recommen-
dation contained in the report, that if artifactual material is encountered
during the course of construction, personnel should contact the Office
of Public Archaeology and, in addition, the Office of Archaeology and
Historic Preservation, be included in your final EIS.
Sincerely,
Arthur M. Skolnik
State Conservator
kb
IX-34
-------
WASHINGTON STATE
HIGHWAY COMMISSION
DEPARTMENT OF HIGHWAYS
Highway Administration Building
Olympia. Washington 985O4 (2OB) 753-BOOS
Daniel }. Evans -Goverm
G.H. Andrews - Directoi
October 20, 1975
Mr. Richard R. Thiel, Chief
Environmental Impact Section, M/S443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Attention: 10A
Environmental Protection Agency
Central Kitsap County Waste-Water
Facilities
Draft Environmental Statement
Dear Mr. Thiel:
Reference is made to your letter of September 5 requesting our review of the
draft environmental statement for the above project.
We have completed our review and offer the following comments:
In conjunction with the Trident Support Site, the Department of Highways is
currently planning to make improvements to county roads that will be crossed
or paralleled by some of the alternate pipelines. We would encourage the
coordination of planning and design of the proposed facilities uith the
Department to facilitate the construction of compatible projects.
We would hope that the final facility plan take into consideration any
proposed highway work. We currently are preparing highway construction plans
for the effected area and will be prepared to make them available to Kitsap
County as soon as they are complete.
Coordination of planning efforts with the Department can be initiated by
contacting Mr. V. W. Korf, District Engineer, P. 0. Box 327, Olympia, Washington
98504.
Thank you for the opportunity to review this information.
Sincerely,
G. H. ANDREWS
Director of Highways
HRG:eh
RA/RBD
cc: V. W. Korf
Mike Mills (OPP&FM)
Baker Ferguson. Chairman A H. Parker
Walla Walla Bremerton
By;
IX-35
RECEIVED
COT 21 1975
CD V
'H. R. GOl'
Assistant Director for
Planning, Research and State Aid
Howard Sorensen
Ellensburg
Virginia K. Giinby
Seattle
Julia Duller Hanten
Cathlamet
Hal old I. lioulai
Secretary
-------
Response to letter from State of Washington, Highway Commission
The facilities planning consultant has assured that all pipeline con-
struction would be coordinated with the Kitsap County Engineering De-
partment and the Washington State Department of Highways.
IX-36
-------
410 West Harrison Street, Seattle, Washington 98119 (206) 344-7331
October 17, 1975
KING COUNTY
410 West Harrison St.
Seattle, 98119
(206) 344-7330
KITSAP COUNTY
Dial Operator for Toll
Free Number Zenith 8385
Bainbndge Island,
Dial 344-7330
PIERCE COUNTY
213 Hess Building
Tacoma, 98402
(206) 383-5851
SNOHOMISH COUNTY
506 Medical-Dental Bldg
Everett, 98201
(206) 259-0288
Mr. Richard R. Thiel, Chief
Environmental Impact Section
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Draft Environmental Impact Statement - Central
Kitsap County Wastewater Facilities
Dear Mr. Thiel:
We have reviewed the Kitsap County Wastewater Facilities
draft impact statement enclosed with your letter dated
September 5, 1975.
The introduction of primary sewage treatment facilities should
have no significant effects on ambient air quality, since
you conclude that'project-induced population growth will not
be significant." Dust generation during construction of pipe-
line and plant should be minimized by watering as needed to
comply with this Agency's Regulation I.
Thank you for the opportunity to comment.
Very truly yours,
A. R. Dammkoehler
Air Pollution Control Officer
, i Ji><-
By: J/R". Pearson
f / Senior Air Pollution Engineer
ARD:JRP:et
RECEIVED
BOARD OF DIRECTORS
CHAIRMAN; Everett Foster, Alternate for Patrick J Gallagher, Commissioner Pierce County, VICE CHAIRMAN: N Richard Forsgren, Commissioner Snohomish County,
Robert C. Anderson, Mayor Everett; Glenn K Jarstad, Mayor Bremerton; Gordon N. Johnston, Mayor Tacoma; Gene Lobe, Commissioner Kitsap County;
Harvey S. Poll, Member at Large, John D Spellman, King County Executive, Wes Uhlman, Mayor Seattle; A. R. Dammkoehler, Air Pollution Control Officer
-------
410 West Harrison Street, P.O. Box 9863 (206) 344-7330
Seattle, Washington 98109
March 22, 1976
Richard R. Thiel, Chief
Environmental Iirpact Section, M/S 443
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Subject: Central Kitsap County Waste Water Facilities
Supplement to Draft E.I.S.
Dear Mr. Thiel:
This Agency believes that the additional alternative and the revisions
in the statement shown in the supplement do not affect our earlier
conclusions about the air quality effects of the project. Therefore,
we will have no further comment to offer in addition to the previous
comments made in our letter of October 17, 1975.
Very truly yours,
A. R. Datnmkoehler
Air Pollution Control Officer
NG COUNTY
0 West Harrison St
O Box 9863
attle, 98109
06) 344-733O
tears on
Senior Air Pollution Engineer
JRP:wb
TSAP COUNTY
al Operator for Toll
ee Number Zenith 8385
inbndge Island,
lal 344-7330
ERCE COUNTY
3 Hess Building
coma, 98402
06) 383-5851
RECEIVED
MAR 2 3 1976
OHOMISH COUNTY
6 Medical-Dental Bldg
verett, 98201
06) 259-0288
ARD OF DIRECTORS
HAIRMAN Everett Foster, Alternate lor Patrick J Gallagher, Commissioner Pierce County,
bert C Anderson; Mayor Everett, Glenn K Jarstad, Mayor Bremerton,
jrvey S Poll, Member at Large, John D Spellman, King County Executive,
VICE CHAIRMAN N. Richard Forsgren, Commissioner Snohomish County;
Gordon N Johnston, Mayor Tacoma, Gene Lobe, Commissioner Kitsap County,
Wes Uhlman, Mayor Seattle, A R Dammkoehler, Air Pollution Control Officer
-------
Kfvt I.
COMMlSdlOTith u.
November 10, 1975
Mr. Clifford V. Smith, Jr., Regional Administrator
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Smith:
The draft environmental impact statement for the proposed Central Kitsap Waste
Water Disposal Facility has been reviewed by my Marineland Management Division.
We wish to submit the following comments regarding this proposal:
Alternative 7 appears to be the alternative with the least potential for adverse
impact on State managed shorelands, tidelands and beds of navigable waters.
Alternatives 1 and 2 provide poor locations for sewer outfalls due to incomplete
flushing action in Dyes Inlet and the presence of clam beds in this area.
While Alternatives 3 and A have better flushing action than 1 and 2, there are
commercial goeduck beds located in this vicinity that could be adversely im-
pacted.
Alternative 6 would likely have less impact than 1 and 2 but the outfall in
Dyes Inlet would have the potential for polluting the clam beds in the Inlet.
Alternatives 8 and 9 would have the potential for creating pollution problems
for recreation sites located near these outfalls.
The impact statement does not predict what toxic substances, if any, might
enter the system from the U. S. Naval Reservation. Until these possible im-
pacts are discussed, it is impossible to adequately assess the environmental
effects.
We appreciate having an opportunity to review this statement.
"s
/
Yours
/x-Y t
'(. U
V~^-< ft
BERT L. CO*E
Commissioner of Public Lands
BLC:wbe -. ;; j ..].
IX-39
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Response to letter from State of Washington, Commissioner of Public
Lands
Chapter 3 of the final EIS states which pollutants might be present
in industrial wastes from the Trident Support Site and what type
of domestic waste is expected. A more accurate assessment cannot
be presented in the absence of further information from the U.S.
Navy. It is our belief that this does not indicate secrecy on the
U.S. Navy's part but rather their own lack of knowledge at this
stage of their planning. However, we also feel that the U.S. Navy
is sincere in their intent to obey Federal regulations and pretreat
their industrial wastes to a level compatible with Kitsap County's
treatment facility. The National Pollutant Discharge Elimination
System (NPDES) permit to be issued by the State Department of
Ecology will include pretreatment requirements if industrial waste
constituents are included in the Navy's contribution. See also
the discussion of mitigative measures in Chapter V of the final
EIS.
IX-40
-------
Grand Central on the Park • 216 First Avenue So. • Seattle, Washington 98104 • 206/464-7090
Puget Sound Governmental Conference
as of July 1, 1975 - Puget Sound Council of Governments
October 7, 1975
Richard R. Thiel, Chief
Environmental Impact Section, MS-443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Subject: Draft Environmental Impact Statement for Proposed
Central Kitsap County Wastewater Facilities
PSCOG File # KT/9706/75
Dear Mr. Thiel:
Thank you for the opportunity to review the subject draft environmental im-
pact statement. We appreciate your effort to get input at an early stage prior
to selection of an alternative and our comments at this point are directed at
questions which should be answered before that recommendation is made.
It is our feeling, though, that once the selection of a. project has been made
based on an analysis of the alternatives, more detailed information should be
circulated for review and comment.
The following comments have been endorsed by the Kitsap County Subrcgional
Committee of this agency and are offered for your consideration in the prep-
aration of a final impact statement.
1. The EIS identifies urban sprawl as the major secondary impact to be
expected from the project, however, the supporting analysis of mitigating
measures in weak (page xii). Should the recommendation of "limiting
sewer size, access and location" be taken to mean that EPA's policy is
to consider the provision, limitation and access to sewers as the con-
trolling factor in urban development? If so, a statement to this effect
should be included in the EIS.
2. On page 1-5, the Dyes Inlet outfall is evaluated as "fair". The mixing/
assimilation capacity of this option should be quantified and compared
to anticipated future discharge volumes.
RECEIVED
GOT 1 0 1S75
IX-41
-------
Richard R. Thlel, Chief
October 7, 1975
Page two
3. The data on page A-6 should be more prominently presented. The
statement, "It was felt that the sub-category items received equal
weight", seems somewhat superficial. Are there no special cases?
4. Regarding the discussion on page 11-40, what is the waste concentra-
tion once "equilibrium is achieved", and is a possible error or "an
order or magnitude" accurate?
Again, it appears that samples are tested to determine how diluted
they become, when the question should begin with the loading to be
imposed vs. assimilation capacity. Will the assumed dilution be
achieved when one mgd are discharged? What about ten mgd? Also,
what evidence is there that dye-release accurately simulates disper-
sion of wastes at the point of outfall?
The 1995 estimated design flow is 3. 9 mgd (page III-4). After sec-
ondary treatment, the waste concentration of BOD should be 45 mg/e
(weekly average). For a dilution ratio of 100:1 to occur in Dyes
Inlet, an exchange of 3. 9 mgd x 100 is required daily, but the flow in
and out of the inlet is not given.
The figure on page III-4 of 15 gpcd for infiltration appears small. As-
suming 500 gal/acre/day, (highly optimistic for Kitsap County soils)
and a density of 3 du's/acre and 3.3 persons/du, a population of 24,000
would require 2,400 acres. This figure, multiplied by S(X) gal/acre/
day, results in 12,000 gallons or 50 gal. capita/day. This will sub-
stantially change the loading requirements placed on the treatment plant.
5. Mow does the project relate to the Sinclar Inlet Section 201 study curren-
tly underway? What are the plans for coordination with ihat study?
Thank you again for the opportunity to review the draft statement. I hope
our comments will be useful to you.
Mart Kask
Executive Director
IX-42
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Response to letter from Puget Sound Governmental Conference
1. The draft EIS points out that areas undergoing development can be
influenced by regulating access to sewer lines, and that mitigation
of a potential impact—uncontrolled development—-can be promoted by
such regulation. Such decisions are local, not Federal. It is not
the policy of EPA to consider sewer access to be the controlling
factor in urban development.
2. See response to comment 4.
3. The weights used in the public opinion survey were derived from a
study done by URS Co., the facilities planners. This study, which
identified concerns of the public, was used as the basis for deriving
the weights according to the table on page A-6. The survey was not
detailed enough to derive sub-category items, which were, therefore,
considered to be equal. It should be noted that the ranking of the
alternatives is the same for both sets of weighting factors.
4. Equilibrium dilutions for the various outfall sites under considera-
tion vary from a minimum of 5,800 in Sinclair Inlet to a maximum of
26,500 in Dyes Inlet. These dilution ratios are based upon a 1-mgd
discharge and assume complete mixing with the incoming tidal volume.
Corresponding dilutions for 10 mgd would be 580 and 2,650, respec-
tively. These estimates may well be inaccurate by two orders of
magnitude, particularly in the vicinity of the outfall. Waste con-
centrations in the receiving water can be found by dividing the ef-
fluent concentrations by the dilution. See Table 11-14.
Drogue studies conducted by the University of Washington in the
prototype appear to verify dye studies performed in the hydraulic
model at the Point Monroe, North Port Orchard and Dyes Inlet sites.
Agreement was best at the Point Monroe and North Port Orchard sites.
The tidal flow in and out of Dyes Inlet is, on the average, 1.391 x
10^ cubic feet per tidal cycle. This corresponds to an average flow
of 31,160 cubic feet/second.
5. The average sewage flow rate of 100 gpcd was a value measured at
Firglade, Parkwood East and Kariotis during an infiltration study
conducted by the URS Company in 1974. Somewhat higher rates were
measured in Silverdale; however, Silverdale is currently accepting
bids from contractors for a sewer rehabilitation program that will
greatly lower infiltration rates.
6. Kitsap County has been keenly aware of the status and activities on
the Sinclair Inlet 201 Facilities Plan. Their consultant has also
coordinated very closely with the Sinclair Inlet facilities planning
IX-43
-------
consultant and the City of Bremerton.
The following is an excerpt from a memorandum detailing the minutes
of a meeting between study area consultants and the Sinclair Inlet
Section 201 consultants held on 19 December 1975 in EPA's offices
in Seattle.
"The present status of the Sinclair Inlet Facilities Plan
is as follows: Initial data-gathering is essentially
complete; overall the Facilities Plan is approximately
30% completed. Alternatives have been conceptualized;
however, not studied in great detail. Their draft
Facilities Plan is due July 1, a hearing in early August,
and the final Facilities Plan due in mid-November. There
is presently little or no public controversy over the
Sinclair Inlet Facilities Plan; concerns are mainly local-
ized. A decision by Kitsap County as to which alternative
to select for their project and a decision that excludes
the Bremerton planning area would fit into their schedule
for completion of their facilities plan and would not
delay their planning study.
"In summary, it appears that there has been adequate coor-
dination between the two consultants and the County and the
City of Bremerton in the planning underway in these two
separate Facilities Plans. Costs have been interchanged
in the evaluation of common alternatives. Since the
regional alternative has been studied to Bremerton's sat-
isfaction in the Central Kitsap County Facilities Plan,
there is no reason to belabor further the consideration of
a large regional plant. The City of Bremerton will have
an opportunity to comment in detail on the final Facili-
ties Plan when it is released by URS Company for the
county."
IX-44
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ROLLA V. HOUGHTON (I97O)
JACK R. CLUCK
PAUL COUOHLIN
JOHM W RILEY
EMIL P SCHUBAT
DAVID SKELLENGER
BERT L. METZGER, JR.
JOEL HAGGARD
WILLIAM N. MATH IAS, HL
LAURITZ S HELLAND
LAW OFFICES OF
HOUGHTON CLUCK COUGHLIN & RILEY
9OO HOGE BUILDING
SEATTLE, WASHINGTON 9SIO-4
TELEPHONE
(2O6) 623-65OI
IN REPLY REFER TO
OUR FILE NO.
October 20, 1975
Mr. Richard R. Thiel
Chief Enivornmental Impact Section, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Dick:
We appreciate the opportunity EPA Region X has provided all
citizens of Kitsap County to systematically examine the
environmental factors related to the possible Central Kitsap
County Waste Disposal Facilities. In addition to the
previous oral comments and letters regarding the project,
detailed comments on the draft EIS (reference EPA Project
No. C-530494-01) are enclosed. These comments have endengered
certain general observations which follow. These and the
other comments have been prepared and are submitted on
behalf of our client Mr. C. A. Ross of Silverdale, Washington.
The content of the Draft EIS does reflect most unfortunately
certain constraints on the document preparation which appear
to be due to certain assumed but not stated timetable constraints,
For example, no data on benthic organisms is available (see
p. 11-49) but the conclusion is drawn elsewhere in the EIS
that there will be a negligible impact upon bentic organisms
(see p. IV-21). It well may be true that some of these
difficulties will be mitigated when the necessary EIS Supplements
are prepared to analyze the environmental impacts and the
alternatives for the specific project (if any) that is
selected. But there is little doubt that the timetable may
be constrained and inadequate analysis available now because
of a fundamental assumption in the Draft EIS — that being
that the Trident wastes of 2 mgd must and will be (?) handled
RECEIVED
:., T 21 19/5
IX-45
-------
Mr. Richard R. Thiel
October 20, 1975
Page Two
by the proposed project and on the Trident timetable. This
presumption has unfortunately rendered the Draft EIS inadequate
in the consideration of reasonable alternatives. Should the
Trident wastes be handled by an upgraded facility? Should
Trident industrial wastes be treated on the base and recycled
to protect a depletable natural resource, i.e. water?
Should Central Kitsap County facilities be constructed to
service Trident on the timetable and level of deployment
assumed in its own EIS? Should regionalization of waste
treatment facilities and coordination to the maximum extent
practicable with other existing or upgraded facilities be
goals more appropriate to this project than timetable adherence?
If so, the sites near Brownsville and by Enetai should be
deleted from further consideration. The draft EIS itself
appears to support a disposal site only on the east side of
Bainbridge Island or by Bremerton.
These issues relate to another significant area of concern
illustrated by the Draft EIS's assumption on costs. Municipal
bonds are assumed to be able to be sold at 5-7/8% which is
approximately 1-1/2% to 2% below existing market rates.
Besides this inaccuracy, no statement is made that the Navy
will guarantee paying 51% of the total costs regardless of
any actual flow of waste to the facility (see p. III-IV,
Navy Flow of 2 mgd out of 3.9 mgd average flow in 1995).
What is the impact upon the taxpayers of Kitsap County under
the proposed project and all reasonable alternatives thereto
including separate handling of the Trident wastes? Land
speculation itself resulting from the acknowledged growth
inducement of the proposed facility can and does cause tax
increases by increasing appraised values; but this impact
on the taxpayer is ignored. Even the mechanism by which the
facility is to be funded is ignored by presuming the use of
County bonds. What are the factors involved in analyzing the
socio-economic impacts upon the ratepayers or taxpayers when
selecting a different operating alternative such as a local
improvement district, a public utility district or the City
of Bremerton?
IX-46
-------
Mr. Richard R. Thiel
October 20, 1975
Page Three
'A
The planning exposecr the Draft EIS is important; and it is a
good start. But concurrent efforts to adopt land use plans
and criteria governing population expansion into certain
land areas is treated so preliminarily so as to mislead the
average citizen into thinking the problem has been addressed.
The Draft EIS's introduction notes that Kitsap County may
preserve rural areas and direct growth by limiting sewer
size access and location (see xii). Yet the criteria and
their reasonable alternatives for these factors are not
spelled out and analyzed. How can the project be specified
until such studies are done and policies are determined
unless we are only to lock the barn door after the horse is
stolen? Will not the choice for the Silverdale area of (1)
doing nothing, (2) planning for Trident growth, (3) creating
a new city of 11,000 people north of Island Lake, or (4)
urbanizing Silverdale to significantly change the environmental
analysis for the sewer project?
For such a significant investment of funds as the project
entails, premature decisions to adhere to a timetable in
lieu of developing adequate land use policies, in completing
the Bremerton study for treatment of its present wastes,
and in analyzing the proposed project with and without the
Trident facility is unreasonable for any reasonable decision-
maker.
We hope that the enclosed comments are of assistance to you
in your continued anlysis. We deeply appreciate the efforts
the Environmental Protection Agency has expended to assure
an adequate, open and comprehensive decision making process.
Yours truly,
HOUGHTON CLUCK COUGHLIN &/RILEY
( • .•'-,' / 7
•, -^cs ^.^ -s<.-?'^ r/
Joel' Ha'ggar'd ,
JH:mn
Enclosure
cc: Mr. C. A. Ross w/enc.
Comm. Frank Randall w/enc.
IX-47
-------
COMMENTS UPON DRAFT ENVIRONMENTAL IMPACT STATEMENT
CENTRAL KITSAP COUNTY WASTE WATER FACILITIES
EPA PROJECT NO. C-530494-01
1. Re page x, 1|4: As the proposed project's site has not
been selected and the site specific impacts have yet to be
analyzed, is it the county or EPA that will supplement this
EIS for the environmental analysis of the specific project
routing of all lines, project configurations and the dis-
charge?
2. Re page xi, !|4: EPA has indicated that one impact
would be that a mechanism for locating anticipated growth
within the study area will result. What criteria have been
adopted by the local governmental bodies for locating antic-
ipated growth? In what measure is the anticipated growth
associated with this project inconsistent with those criteria?
3. Re page xii: The EIS presumptively incorporates the
waste loads from the Trident facility without an examination
of the alternative of excluding the Trident generated wastes
from the proposed facility. In what manner would the en-
vironmental impacts differ if the Trident generated waste
loads were not incorporated into the proposed facilities and
instead were handled completely on the base with the nec-
essary upgraded sewage treatment systems?
4. Re page xii, 1IC: As significant increases in local
property taxes are likely to result from the construction
and operation of a waste water management system, what would
be the impact upon the local property taxes as a result of
any premature termination or project stretch-out for the
Trident project. In addition, in what manner will Value
Analysis be used in the design of the project to reduce the
cost impact upon the tax and rate payers?
5. Re page xii, second paragraph under paragraph d: Since
the potential for major adverse secondary impacts exist in
the area of population location but have not yet been con-
firmed, what further studies in detail are required as part
of the continuing effort to mitigate or eliminate these
IX-48
-------
adverse secondary impacts. As the project proceeds the
draft EIS also indicates that the county officials may, by
limiting sewer size access and location, have a method by
which natural rural areas can be preserved and growth di-
rected into urban and transitional zones. What rationale or
criteria will be utilized by the Kitsap County officials in
so limiting sewer size, access and location and have they
made a commitment to so do this in accordance with criteria
for direction of urban and transitional growth areas?
6. Re page 1-1, second paragraph: The environmental
impact statement alone does not fulfill EPA's total respon-
sibilities under the National Environmental Policy Act. The
EIS is directed solely to the requirements of Section 102(C)
of NEPA and does not relate to the continuing requirement to
study unresolved conflicts in Section 102(D), nor does it
necessarily fulfill EPA's responsibility under Section 101
which requires coordination to the maximum extent practicable
to fulfill the goal, among other things, that EPA is a
trustee of the environment for future generations. In what
manner does EPA intend to fulfill these other responsibilities
of the National Environmental Policy Act for this particular
project?
7. Re page 1-1, last sentence: What would be the en-
vironmental effects anticipated from an upgrading of the
sewage treatment facilities at the Trident support site so
as to engender their ability to handle the population in-
flux?
8. Re page 1-2, last paragraph: Kitsap County, as a
municipal corporation subject to the requirements of the
State Environmental Policy Act, RCW 43.21C, is required to
prepare an environmental impact statement for the proposed
action. The State Environmental Policy Act permits that to
the extent that there is an adequate environmental impact
statement prepared by a federal agency to utilize that in
lieu of one prepared by their own. The EPA environmental
impact statement is inadequate for all project aspects other
than selection of the alternatives discussed therein as
modified by the comments of this letter. While the county
may have prepared an environmental assessment in its facil-
ities plan for use by EPA in the preparation of this docu-
ment, that environmental assessment is not sufficient or
adequate for compliance with the State Environmental Policy
Act.
IX-49
-------
9. Re page 1-4, first paragraph: Have there been any
subsequent studies or new information developed which iden-
tify other or more severe adverse impacts associated with
the Trident project since the time that reference 2 was
published? To what extent has EPA independently considered
the environmental analysis and conclusions of the Trident
EIS?
10. Re page 1-4, second paragraph: It is noted that the
entire facilities plan would require reassessment if for
some reason Trident were not to proceed. Would a similar
reassessment be required as a result of a change in either
the time schedule for construction of Trident or due to
development of the Trident facility to handle more or less
than 20 boats?
11. Re page 1-4, last paragraph: With respect to the
issues identified as major issues of the project, what
further studies are required to provide a reasonable data
base for environmental analysis of the anticipated primary
and secondary impacts associated with these major issues?
12. Re page 1-5: Again the concern for presuming that the
Trident waste will be incorporated is unacceptable to an
environmental analysis considering all reasonable alter-
natives. What would be the environmental impacts upon the
alternatives identified if the Trident support site wastes
were collected and treated at an upgraded waste water treat-
ment facility located on the base? What would be the environ-
mental impacts associated with the alternative of Trident
wastes being handled totally on the base?
13. Re page 1-5, second paragraph: The draft EIS notes
that population growth within the study area and associated
demands upon utilities and municipal services are concluded
to be primarily due to the development of the Trident sup-
port site and the project induced growth will be negligible.
What is the basis for this conclusion? Similarly, what is
the basis for the statement that the sewerage systems of
each alternative will have a tendency to concentrate future
growth near sewer lines? Are any further studies necessary
to evaluate the environmental impacts associated with the
sewerage systems induced growth in the area?
14. Re page 1-5, third paragraph: What specific documents
identify the careful construction techniques that should be
IX-50
-------
utilized and will these documents serve as the basis for a
condition in any grant to so require the diligent applica-
tion of them?
15. Re page 1-5, fourth paragraph: It is noted that water
quality criteria should be met consistently. Is this re-
stricted to the numerical criteria in the WAC 173-201-030
water quality criteria or does it also include the criteria
that whenever the receiving waters of a classified area are
of a higher quality than the criteria assigned for said
area, the existing water quality shall constitute water
quality criteria. See WAC 173-201-040(6).
16. Re page 1-5, last paragraph: In concluding that al-
ternative plan number 1 has the lowest project cost, to what
extent has the cost analysis requirements of applicable EPA
regulations been used?
17. Re page 1-6, second paragraph: What is the meaning
(qualitative and quantitative) to be applied to the term
"fair" and to the term "good" in describing "mixing and
dilution of effluent" and to the term "subsequent dispersion
and flushing."
18. Re page 1-5 and following: What are the environmental
effects and alternatives associated with the alternative
identified by John Strasburger in his letter of October 2,
1975, addressed to Mr. Steve Fusco of URS? That alternative
involves the possibility of Poulsbo sewage being piped
across the Lemmolo-Keyport Narrows to be joined with the
Trident sewage near Keyport. In addition, what are the
environmental impacts associated with the alternative iden-
tified in the September 26, 1975 memo by Steve Fusco of URS
to the citizen advisory group relating to Poulsbo being
regionalized with the Central Kitsap County Facility (along
with the community of Keyport and the Keyport Naval instal-
lation) with subsequent discharge to be either on the east
side of Bainbridge Island or piped south to Bremerton.
19. Re page 1-5 and following: Since the submarine outfall
has not yet been designed, what criteria will govern the
design of the outfall and what site specific studies will be
necessary to adequately analyze the environmental impacts
associated with such an outfall?
IX-51
-------
20. Re page 1-5 and following: Is there some point where
the cost as a function of volume treated breaks down so that
the economy of scale cannot be realized?
21. Re page 1-5 and following: What is the anticipated
cost for increasing the dispersion and flushing to increase
the result from "fair" to "good"; and to increase the dis-
persion and flushing to maintain existing water quality
criteria?
22. Re page 1-9, fifth paragraph: Why was not the project
alternative of handling all Trident wastes separately cov-
ered? In addition, since project modification, specific
mains and collector lines, routings and discharge site
specific impacts have not been discussed, will EPA prepare a
supplemental EIS to discuss these factors of the proposed
action?
23. Re page 1-11: To what extent have the project ratings
been quantitatively or qualitatively adjusted to reflect
conformance with the NEPA and SEPA requirement that to the
maximum extent practicable, the plans, programs and func-
tions of governmental units should be coordinated to ac-
complish, among other things, the governmental responsi-
bility of trustee of the environment for future generations?
24. Re page 1-12: The graphical display presented is
unique and well done.
25. Re page II-l: The entire environmental setting de-
scribed in chapter 2 appears to be so general as to ignore
site specific characteristics. What additional studies will
be done to identify, analyze and mitigate site specific
variations and impacts from the general environmental setting
described in chapter 2?
26. Re page II-l, second paragraph: Why was the alterna-
tive of excluding portions of sub-basin 12 and 13 from this
document and including it with the entire Bangor annex to
the Keyport Naval torpedo station not been considered? What
are the environmental effects associated with this alterna-
tive and how does this variation affect the alternatives
described herein?
IX-52
-------
27. Re page II-2: To what extent is reference 3 inadequate
and what is EPA's judgment with respect to the environmental
consequences identified in reference 3, as applied to this
project?
28. Re page II-3: Since a possible disposal site is to be
located on the east side of Bainbridge Island, what is the
environmental setting for this area both on land and in the
water?
29. Re page II-8: What areas are contemplated to be sewered
and what criteria will govern the definition of areas to be
sewered? Will soils, growth and environmental impact all be
considered and if so by what specific criteria?
30. Re page 11-11: What additional studies of air pol-
lutant emissions and mitigating measures might be required
should be done particularly in the area of determining areas
to be sewered, since it is admitted that the proposed pro-
ject can have a major adverse secondary impact in deter-
mining population location areas.
31. Re page 11-14: Since Table 11-14 identifies in sites 6
and 11 the probability of significant adverse effect upon
people due to noise, what mitigating measurers might be
employed in sewering these areas so as to mitigate the
future growth?
32. Re page 11-15, second paragraph: What is the syn-
ergistic effect of the effluent characteristics from the
proposed facilities with other unexplained toxic discharges,
particularly those recently discussed in the newspaper with
respect to the Keyport-Lemmola area?
33. Re page 11-21: To what extent will the growth induced
by the proposed sewer project increase the demand upon
ground water as a result of population relocation or aug-
mentation?
34. Re page 11-33: What assumptions have been made as to
the physical dimensions of the mixing zone which is qual-
itatively described in the State of Washington's water
quality standards? How will the discharges interfere with
biological communities or populations of important species
to a degree which is damaging to the eco-system? What
biological communities or populations are important species
IX-53
-------
in each of the outfall areas? In addition, to what extent
will the effluent diminish other beneficial uses dispropor-
tionately?
35. Re page 11-33, first paragraph: Aesthetic values in
the water quality criteria apply within the mixing zone. To
what extent will these criteria be satisfied or effected as
a result of the discharges?
36. Re page 11-33, second paragraph: It is stated that
some of the alternatives may require further treatment in
order to meet water quality standards. By the term "water
quality standards" is the requirement that the existing
water quality shall constitute water quality criteria if
better than that criteria assigned for the area included in
this consideration? In addition, to what extent has the
cost for each of the alternatives been identified to meet
these objectives?
37. Re page 11-35, second paragraph: It is noted that Port
Orchard area has frequent violations of bacteriological and
turbidity standards in the Burke Bay/Brownsville area? The
sixth paragraph on this page notes that these local bacteri-
ological problems are in those areas which are subject to
only mild flushing. Since the facilities planning con-
sultant did not select the Burke Bay/Brownsville area of
Port Orchard as a major disposal site alternative, (See page
11-41 in the last paragraph) should not this alternative be
eliminated from further consideration?
38. Re page 11-36, second paragraph: To what extent is the
acute biological shock condition or water quality criteria
affected as a result of reconcentration of effluent due to
tidal action?
39. Re page 11-36, third paragraph: It is stated that
"presumably such simulations will be made in the future."
Who will make these simulations and will they be done or is
this just a faint hope? Further, with respect to the fourth
paragraph on page 11-36, what additional studies are needed
before the outfall site is selected?
40. Re page 11-37, top of page: What verification of the
model will be utilized at a specific site when examining the
alternative configurations and locations of the specific
discharge?
IX-54
-------
41. Re page 11-38, first paragraph: What is the basis for
the acceptability of the minimum effective depth selected,
the minimum reasonable rule of thumb regarding diffuser
length and the minimum current speed across the diffuser?
42. Re page 11-38, Table IV-13: In light of the high
average percent of time current speeds are less than 0.1
knotts for the Dyes Inlet, the Port Orchard Enetai and the
North Port Orchard sites, what additional cost will be
required to assure that discharges will not degrade existing
water quality or have an adverse impact upon the aquatic
biota?
43. Re page 11-39, Table IV-14: How large a mixing zone
has been assumed in identifying the location of the diluted
100 to 1 secondary effluent waste concentration?
44. Re page 11-39, first paragraph: It is noted that in
the interim reports the Point Jefferson site is probably the
best within the study area with respect to mixing and dis-
persal. What is the anticipated cost impact on the other
alternatives to increase their mixing and dispersal char-
acteristics to that which would yield similar effects off
Point Jefferson?
45. Re page 11-40, first paragraph: As noted in the third
paragraph on page 11-41, current velocities at Port Or-
chard/Enetai as in the rest of Port Orchard are very weak
and it could lead to erroneous conclusions in modeling. On
what basis then can one rely upon the analysis of the ef-
fluent mixing at the site north of Port Orchard? The second
paragraph on page 11-40 indicates that calculations were
made to confirm the good mixing but these calculations were
based upon assumptions. Further, the third paragraph on
page 11-40 recommends that if either of the two sites in
Port Orchard are given serious consideration a field dye
study of the area be made to determine actual feasibility.
Before any selection of these sites for further considera-
tion is made, the dye study should be a prerequisite.
Alternatively, it may be appropriate as a result of the
analysis contained in the draft EIS and other documents to
disregard in further work the discharge locations in Port
Orchard at the area north of Brownsville and at Enetai.
IX-55
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46. Re page 11-41, last paragraph: The rating of sites
from the point of view of waste dispersion includes the
north Port Orchard site. Yet the beginning of the para-
graph, in identifying the major disposal site alternatives
that should have further detailed investigation, ignored and
deleted this site. Why then has it been included for fur-
ther consideration.
47. Re page 11-49, Table 11-16: Since there is no data
available on benthic organisms at Site C or Site J, how
could anyone make a conclusion that there will a negligible
effect upon the benthic community as is concluded on page
IV-21?
48. Re page 11-54: What is the effect of the effluent from
the discharge alternative located north of Brownsville upon
salmonids utilizing Steel Creek? Have the migration pat-
terns of the juvenile and adult salmonids in the area north
of Steel Creek been identified?
49. Re page 11-60: To what extent has EPA coordinated
under the requirements of Section 101 of the National En-
vironmental Policy Act the planning for other water and
sewage systems in the area insofar as they might have an
impact upon or a relationship to the proposed Central Kitsap
County Disposal?
50. Re page 11-63: What are the anticipated volumes,
characteristics and disposal methods for the sludge re-
sulting from the proposed facility?
51. Re page 11-65, first paragraph: Since the existence of
Trident was assumed, how can an objective analysis of the
impact due to premature termination of Trident, project
stretch-out of Trident, or development of Trident at more or
less than the planned boat level be accurately considered
with respect to the growth inducement impacts associated
with the proposed action?
52. Re page 11-67: In what manner will the data given in
Table 11-22 be affected by the provision of sewers in the
area?
53. Re page 11-72: What is the impact of sewer rates upon
the 11.9% of the total county population classified as "near
poor" and the 6.1% of the county population classified as
"poor poor"?
IX-56
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54. Re page 11-76: To what extent have the impacts iden-
tified in these pages been reviewed to consider the alter-
native of having all construction housing for the Trident
facility located on the base?
55. Re page 11-77: What further continuing studies should
be made of population developments in the area prior to the
determination of the proposed project capacity?
56. Re page 11-77: It is stated that the study area will
contain 47% of the population increase of Kitsap County. In
what manner is this consistent with present plans or con-
templated plans of the county and in what manner should this
population be controlled by the areas to be sewered?
57. Re page 11-78: Will the final environmental impact
statement include in an analysis and revision to incorporate
definite results of the A. D. Little, Incorporated popula-
tion projection study?
58. Re page 11-79: In what manner will the criteria for
areas to be sewered reflect the land use plan identified in
Figure 11-14?
59. Re page 11-80: In what manner will the criteria for
determining areas to be sewered take into account the re-
striction of the 47% population increase into the transition
or urban areas identified in Figure 11-15?
60. Re page 11-82: Whether the individual collector lines
to be tied into the mains are to be funded by EPA or not,
the environmental effects associated with alternatives for
collector line areas should be identified and considered.
61. Re page III-l, second paragraph: It has been predicted
that only 18,000 persons would be connected to the ultimate
sewerage system. What areas will not be covered and what
impact upon urbanization and growth will result from such
restriction?
62. Re page III-4, top of page: Since it is indicated that
population estimates will be resolved prior to release of
the final EIS, we would appreciate an identification in the
final EIS as to where these revised population estimates
have affected the analysis.
IX-57
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63. The 20 year design flow for 1995 is estimated to in-
clude 85 gallons per persons per day of average dry weather
flow. This apparently means that approximately 1.61 mgd
would be the flow in 1995 for a population of about 18,000
persons or less. If this is correct, why does the estimated
average daily dry weather sewage flow for the Poulsbo area
identified on page III-6 indicate that they will have a
greater per capita dry weather sewage flow generated per
person than for the study area? In addition, since the
Trident support site will generate the majority of wastes to
be treated, will the payments to be made by the Navy for the
operation and construction of the facility be based upon a
fixed payment or will it vary with some actual flow? If it
is the latter, what is the impact upon the rate payers due
to such things as premature termination of the project
eliminating all flow and thus all payments, or of lower
flows as a result of project stretch-out or lower size
project development?
64. Re page III-4, third paragraph: It is noted that the
U.S. Navy projection of 2 mgd of average daily flow from the
Trident support site is based on the total absence of de-
tailed data. We would assume that the Navy will provide
this information on a detailed basis for purposes of anal-
ysis prior to the preparation of the final EIS.
65. Re page III-7, first paragraph: What coordination by
EPA (pursuant to the requirements of Section 101 of NEPA)
have taken place with respect to the planning activities
currently being undergone by the City of Bremerton? What is
proposed as to effecting a relationship between those plans
and the alternatives identified in this draft EIS?
66. Re page III-ll, second paragraph: It is noted that the
facilities planners and the EIS staff have assumed that the
Hansville Road solid waste disposal site or similar one
would be available for sewage sludge disposal. This is
totally inadequate for an environmental analysis of the
impacts upon disposal site life time, animal feeding ef-
fects, and ground water impact due to sludge disposal. What
are the environmental impacts identified with or associated
with the proposed central Kitsap County waste water facility
considering the reasonable variation in volumes of sludge to
be produced over the lifetime of the proposed facility?
What further studies should be made to determine the impact
IX-58
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of the site specific effects of leachate upon ground water,
of heavy metal concentration, etc.? Will the oxygen activated
sludge waste water treatment system dictated in EPA 625/4-
73-003a document be considered as a sludge treatment alter-
native?
67. Re page 111-16, last paragraph: It is noted that the
exact length and specific location of the outfall and dif-
fuser have not been determined for alternative number 5 and
that this is awaiting further studies on local water current
being conducted by the University of Washington. Has the
cost evaluation of this alternative reflected the probable
range of additional work or design features required to
produce an effluent which will not degrade water quality or
have an adverse impact upon the aquatic biota? Will these
studies be available and considered in the final EIS prior
to the selection of another alternative?
68. Re page 111-28, second and third paragraph: The alter-
native of no action should consider the impact of not treat-
ing any of the Trident base generated wastes and should also
consider the alternatives for the areas to be or not to be
sewered. As stands, this portion of the EIS draft is totally
inadequate for a reasonable examination of alternatives.
69. Re page 111-29: What is the impact of collector line
installation costs upon the total annual cost? At some
point in the document it was identified that the bonds could
be sold for 5 7/8%. In light of the current market this is
probably between 1 1/2% and 2% below current rates for
municipal bonds.
70. Re page IV-3: It is indicated that dust and partic-
ulates raised during construction activities can be reduced
by following EPA published guidelines for minimizing fugitive
dusts from construction sources. What are these published
guidelines and will they be adhered to in the construction
of the project?
71. Re page IV-21: It appears to be totally irresponsible
to conclude that there will be negligible effects on the
benthic community when there is no data available as iden-
tified on page 11-49. In addition, what is the effect of
the effluent at the Manchester outfall upon the dense pockets
IX-59
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of the small clam as well as upon the salmonids that may be
migrating to or from Steel Creek?
72. Re page IV-38: In this analysis it was assumed that
discharges meet water quality standards. What are the costs
associated with making this assumption a certainty due to
the site specific characteristics? Has the analysist con-
sidered that water quality standards also include the re-
quirement of nondegradation of existing water quality in
making this assumption and analysis of impact? Has the
nitrification of the effluent to reduce ammonia impact been
considered in the total cost? What treatment will be util-
ized to reduce chlorine concentration at the point of dis-
charge since minimum levels of chlorine can have a toxic
effect upon aquatic biota. Has consideration of waste
reconcentration as a result of tidal reversals or stagnation
been considered? If not/ what is the impact?
73. Re page IV-47; This page identifies and evaluates the
degree to which the proposed project affects commercial and
sports fisheries, including effects on mollusc abundance.
Where is the analysis for the specific sites for discharge
alternatives 3, 4 and 9?
74. Re page IV-59: Has the estimated operating and main-
tenance costs included the capital amortization of special
efforts required to avoid nondegradation of water quality at
each of the specific sites been considered. Has the estimated
operating and maintenance costs assumed 2 mgd of waste
originating with the Trident site will actually be delivered?
If less than 2 mgd actually flows from the Trident site, is
it anticipated that the taxpayers will have increased costs
levied against them due to a rate reduction payable by the
Navy?
75. Re page IV-61: The assumption of a $15,000,000 or so
bond issue for 20 year maturity at an interest rate of 5
7/8% is totally unrealistic in light of current tax free
municipal bond rates. What is the impact upon the cost of a
realistic interest rate being utilized?
76. Re page IV-70: What is the impact upon the taxpayer as
a result of the anticipated tax increase if the Trident
support site wastes are not included in the proposed facility?
77. Re page IV-73, top of page: What would be the impact
from the alternatives if the Navy were to house all con-
struction personnel on base?
IX-60
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Response to letter of October 20, 1975 from Mr. Joel Haggard
The general comments of this letter cover many subjects in a short
space. Since it would be extremely difficult to answer the general
content of the letter, and inasmuch as an attachment prepared by Mr.
Haggard reflects the contents of the letter in the form of specific,
numbered comments, response is made to the attachment. This response
will also answer the general comments of the letter.
1. The EPA has prepared a draft supplement EIS and a final EIS which
contain more site-specific information and show a recommended al-
ternative. The investigative level of effort is considered to be
more than adequate to provide a data base for the selection of an
alternative.
2. No specific criteria have been adopted by local governmental bodies
for locating anticipated growth. No decision to follow such a
course of action has yet been made. Only the Kitsap County land
use plan exists at this time. As the County amends its comprehen-
sive plan, it is anticipated that the A.D. Little study recommenda-
tions regarding urban concentration will be followed.
3. The presumption is incorrect; the alternative of excluding the
Trident-generated wastes from the proposed Central Kitsap County
facility was considered. With separate treatment by the Navy,
there would be no construction of an interceptor from the Bangor
base to the Central Kitsap County facility and, therefore, no im-
pact. For the County's alternative 4a, there would be little
change since the anticipated impact of the Navy interceptor along
Luoto Road and Highway 303 has been characterized as negligible.
The impact of the remainder of the construction, that is other
interceptors, treatment facilities and outfall line, would be un-
changed. With the discharge to receiving waters decreased by 2
mgd, the impact on water quality obviously would be less; however,
the decrease would not be significant since our modeling predicts
an insignificant increase in ambient conditions due to the pro-
posed discharge, including the Navy's 2 mgd, for all receiving
waters except Sinclair and Dyes Inlets.
Impacts associated with separate treatment of Navy wastes on the
Bangor base are discussed in the Trident EIS (Vol. 1, p. 285 ff.).
In our judgement the public would not accept the concept of dis-^
charge of waste to Hood Canal, which is considered to be a sensi-
tive and valuable water resource. Assuming for the moment that
this obstacle could be overcome, we have evaluated the feasibility
of separate waste treatment for the Navy. The assumptions are as
follows:
1. Pretreatment would be the same for a separate Navy discharge
or connection to a Central Kitsap facility.
IX-61
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2. Flow is equal to 2 mgd.
3. Use activated sludge process with nitrogen and phosphorus re-
moval and additional solids and BOD removal per Department of
Ecology policy on discharge to Hood Canal. This policy states
that, in order to meet water quality standards for Hood Canal
waters, removal levels required are 95 percent BOD, 95 percent
suspended solids, 95 percent phosphorus, and 90 percent nitro-
gen (DOE Hood Canal Policy dated January 24, 1972).
4. Phosphorus removal by two-clarifier lime clarification, and
nitrogen removal by ammonia stripping.
5. Basic reference for estimating is DOE publication entitled
"Cost Estimating-Sewerage and Sewage Treatment Facilities,"
July 1971.
Utilizing these basic assumptions, costs of separate treatment for
the Navy are estimated as follows:
Capital Cost, $ 0 & M Cost, $/yr
Primary treatment 675,000 28,500
Secondary treatment 620,000 51,800
Lime clarification 240,000 43,800
Lime recalcination 210,000 34,300
Ammonia stripping 195,000 31,400
Disinfection 31,000 7,300
Outfall 66,000
Subtotal 2,037,000 197,100
Cost escalation to June
1975 dollars, ENR index
= 1.72 3,501,100 354,800
Enginering, legal, admin. 1,400,400
4,901,500
Activated carbon process 1,517,000 230,000
Total project cost 6,418,500 584,800
(separate Navy project)
Navy participation in 5,756,200 231,200
regional project (alter-
native 4a)
IX-62
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From this comparison, it can be seen that, in addition to a lesser
total environmental impact, regional treatment is considerably more
cost-effective.
Concerning the concept of treatment and discharge for recharge pur-
poses, the demand is not apparent. A comprehensive study now being
completed by the U.S. Geological Survey, with a report to be publish-
ed in early spring 1976, shows that adequate groundwater resources
exist well beyond the projected needs of the Trident project. This
report will be entitled "Availability of Groundwater in the Trident
Impact Area—Kitsap County, Washington" and will be published by A.J.
Hansen, Jr. and Dee Molenaar, hydrologists with the U.S. Geological
Survey. Current fresh water being used is 13 mgd; this is supplied by
9 mgd brought in from outside reservoirs and 4 mgd being pumped from
groundwater. This is expected to eventually increase by 8 mgd due to
Trident. Current recharge in the Trident impact area is 46 mgd.
Approximately half of this reaches the deep permanent groundwaters, the
remainder going off as interflow. The larger withdrawals required by
growth associated with Trident will require careful evaluation of
drawdown and transmissivity factors in order to avoid salt water
encroachment problems. This is principally a problem of spatial
location of withdrawals, which can be properly managed. With adequate
groundwater available, then, for the foreseeable future, there is no
economic incentive for recharge and it is not cost-effective. Ad-
ditional water supply impact discussion can be found in the final
Trident EIS (Vol. 1, p. 389 ff).
Disposal within the confines of the Bangor base is not feasible. An
updating of the orignal soil surveys now nearing completion has shown
that the Everett soil series, a permeable gravely sandy loam, is not
nearly as prevalent as reported in the orginal 1939 survey. This was
one of the few soil series that appear to have potential for receiving
treated waste effluent. Navy Trident officials maintain that there is
not sufficient land available for land disposal of Bangor wastes and,
even if there were, Navy policy would not premit long-term commitment
of large amounts of Base property for land disposal purposes. Based on
the 1939 Soils Survey, there appeared to be sufficient Everett series
soils (550 acres) on the northern portion of the Bangor Annex and
adjacent private lands to accommodate the discharge of 3.8 mgd treat-
ed wastewater. Now that these soils have been reclassified as Alder-
wood series, 2,870 acres would be required. The entire Bangor Annex
itself is only 6,960 acres in area.
The Navy has investigated the feasibility of expanding and upgrad-
ing the existing trickling filter facility now located on the Bangor
base and has found this to be an infeasible alternative for reasons of
cost, location and space. Continued discharge of an expanding volume
of treated waste to Clear Creek would not only in all probability
violate water quality standards but would also be contrary to the De-
partment of Ecology's policy concerning minimum dilution requirements
IX-63
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for discharge to perennial streams. (DOE Advanced Waste Treatment
Policy dated May 12, 1972).
Finally, participation of Federal agencies in regional systems is
a national policy supported by EPA. Executive Order 11572 speci-
fies that Federal facilities shall incorporate common procedures
in compliance with water quality standards and effluent limita-
tions (Section 3 (d) (5). OPNAVINST 6240.30, the Navy's environ-
mental protection manual, states: "The use of approved municipal
or regional waste water collectional disposal systems shall be the
preferred method of disposal of wastes from shore activities."
(Paragraph 5102 a)
4. Please see the answer to comment No. 51.
5. All decisions regarding the use of sewer access to direct growth
toward selected areas are under the jurisdiction of County offi-
cials. Such decisions have not been formalized, except by the
recommendation of a plan which would not route the Trident Support
Site interceptor sewer down Clear Creek Valley. The EIS simply
points out the availability of this tool to County officials.
6. We do not agree that we are not fulfilling EPA's total responsi-
bilities under the National Environmental Policy Act. We are not
clear what unresolved conflicts you are referring to, but presum-
ably you mean those associated with the impacts of construction
of a waste treatment project. To our best knowledge, we are
addressing these in our EIS process. Also, to the best of our
ability, we are attempting to "study, develop, and describe
appropriate alternatives to recommended courses of action, "as
required by section 102 (2)(D). Your interpretation of section
101 is perhaps more specific than the writers of the Act may have
intended. The Act states, "it is the continuing responsibility of
the Federal government to use all practicable means, consistent
with other essential considerations of national policy, to improve
and coordinate Federal plans, functions, programs, and resources
to the end that the Nation may 1) fulfill the responsibilities of
each generation as trustee of the environment for succeeding gen-
erations." We construe this to be a broad charge to the Nation
as well as to EPA, which EPA is certainly attempting to fulfill.
All of EPA's programs, air, water, etc., are aimed at fulfilling
the public trust. If you could identify more specifically what
you mean by "these other responsibilities," we would be pleased
to evaluate our compliance.
7. It is not feasible to upgrade the existing sewage treatment faci-
lities at the Trident Support Site so as to engender their ability
to handle the Trident population influx. Please refer to comment
IX-64
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No. 3 for an expanded discussion. Furthermore, the population as-
sociated with Trident will not locate so as to permit the collec-
tion and treatment of its wastes on the Bangor base.
8. This statement is an opinion unsupported by the facts of the case.
9. The Trident Support Site development is subject to its own sepa-
rate environmental impact study. Questions regarding the Trident
Support Site, other than those concerning wastewater flow and
quality, should be directed toward the Department of Defense.
10. No.
11. The studies already conducted for the proposed project have been
substantially more exhaustive than typical environmental assess-
ments for a wastewater treatment facility. No further studies
are considered necessary.
12. This is a repetition of comments Nos. 3 and 7; please see those
responses.
13. The proposed project is being planned in an environment which in-
cludes the Trident base. Growth attributable to Trident is as-
sessed in the EIS for that project. Population growth attribu-
table to the wastewater facilities is limited to potential direct
employment (20 to 40 workers, depending on the alternative select-
ed) and the limited secondary employment, plus dependents.
Sewerage systems will tend to concentrate growth in their service
areas if alternative disposal is limited. Approximately 90 per-
cent of the service area has drainage limitations which inhibit,
if not eliminate, the use of septic tanks (Reference 1). Growth
is thus more likely in areas near sewer lines.
No further studies are considered necessary to evaluate the envi-
ronmental impacts associated with the proposed project at this
time.
14. Applicable controlling documents would include Washington State
building codes and permits from various agencies, including the
Washington Departments of Fisheries and Game and the U.S. Army
Corps of Engineers, all of which would demand compliance with
specifications designed to protect the public and the environment.
At the end of this response is an exerpt from the EPA construction
Grants Program Handbook, which covers EPA's review of plans and
specifications and related requirements placed on grantees.
IX-65
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15. The statement in the impact statement references water quality
criteria for the State of Washington. These criteria include the
statement that whenever the receiving waters of a classified area
are of higher quality than the criteria, then the existing water
quality constitutes water quality criteria.
16. Please note that the recommended plan, No.11, has the lowest an-
nual cost based on pre-reimbursement dollars. EPA must select
alternatives on the basis of project costs before reimbursement
to the local agency. The equivalent annual costs were calculated
in conformance with EPA guidelines for cost-effectiveness analysis.
17. The terms are subjective and relative. They are based upon cal-
culation of percentage dilution and include a subjective evalua-
tion of the physical modeling results demonstrated in the Univer-
sity of Washington film of their tests.
18. These questions have been answered in the analysis of alternative
plan No. 11, presented to the public in the Supplement to the
Draft Environmental Impact Statement and subsequently selected
as the recommended alternative.
19. Washington State Water Quality Standards will govern the design
of the outfall in that the facility must release treated effluent
in a manner which will meet the standards. Site-specific studies
at the outfall location were conducted during Phase II studies
and the results reported in the draft supplement to the Facilities
Plan.
20. This generally occurs where sewage transmission costs finally
exceed treatment cost savings.
21. The dilution, dispersion and flushing ratings for each alternative
were based upon a multi-port diffuser, e.g., the state-of-the-art
technology. These ratings are a function of the physical configu-
ration and hydraulics of the disposal area and cannot be changed.
Water quality standards can be met or improved upon by increasing
treatment, as was done for Dyes and Sinclair Inlets, or a new dis-
posal site with improved characteristics can be chosen, at a dif-
ferent project cost. Therefore, the differences between alterna-
tive costs presented in the EIS are also the incremental costs of
changing the rating of an outfall's site.
22. Please see the response to comment No. 3. The supplement to the
draft EIS and the final EIS contain all of the specific informa-
tion developed for EPA-funded portions of the proposed project.
Collector lines and local mains are not EPA funded. As these
later projects are developed, they will be subjected to addition-
al environmental reviews under SEPA, or, if Federal funds are
required, NEPA.
IX-66
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23. The ratings serve only as an aid to the governmental agencies so
that they may make a wise choice in their decisions affecting the
environment.
25. These studies have been reported in the draft supplement and final
EIS.
26. The wording in the paragraph of the draft EIS to which you refer
is a little misleading in that it leaves the reader with the im-
pression that consideration was given to including all of sub-
basins 12 and 13 within the Central Kitsap County planning area
and that finally a decision was made to include only those por-
tions lying within the Bangor base confines. This is not in fact
what happened. The planning basin boundaries were set long ago
by Washington State, at the beginning of the original studies for
a Central Kitsap sewage facility, to include sub-basins 9 and 10.
The Navy later requested service for wastes discharged from its
Bangor Annex and the expanding loads associated with the Trident
project. The planning area, then, should be considered as sub-
basins 9 and 10, with receipt of a point-source industrial/domes-
tic discharge from the Bangor Annex. From a practical standpoint,
there is no particular justification for including those portions
of sub-basins 12 and 13 outside of the Bangor Annex confines.
These areas have little or no need for sewerage facilities at
present and little or no growth projected into the future.
In answer to the second question, the environmental effects asso-
ciated with exclusion of the portions of sub-basins 12 and 13 out-
side the Bangor base confines are considered insignificant, with
no effect upon the alternatives considered under the Central
Kitsap project.
27. Reference 3, the Trident Support Site Environmental Impact State-
ment, was used only as a source of factual or design information.
All evaluations for the Central Kitsap project were conducted in-
dependently.
28. Additional information on the Point Monroe discharge site was pre-
sented in the draft supplement and final EISs. Also, please note
the letters from the Washington State Department of Fisheries and
from the Parks and Recreation Commission.
29. This question appears to relate to the provision of sewer facili-
ties below the interceptor level. Land use plans and policies
now in existence provide criteria for the definition of such
areas. It should be remembered that the facilities plan is de-
pendent upon land use policies and not the converse.
IX-67
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30. It is not admitted that the proposed project would have a major
adverse secondary impact upon air quality. The project will help
locate the population growth but will not cause it. No further
air quality studies are needed.
31. Let us first make it clear that the noise impact is predicted to
be the result of Trident-induced growth. Mitigating measures,
such as a limitation on housing density, are within the jurisdic-
tion of Kitsap County. Traffic-induced noise on major arterial
routes cannot be mitigated by the proposed project.
32. Pacific oyster embryo bioassays of wastes in the Liberty Bay area
were performed by EPA during the fall of 1975. The results of
this analysis indicate that effluent from a primary plant (Poulsbo
Sewage Treatment Plant) is about seven times more toxic than the
effluent from a secondary plant (Keyport Sewage Treatment Plant)
when diluted with seawater. Bioassays of the receiving waters
themselves showed little toxicity at depth, but a significant
amount at the surface. The causal relations for this have not yet
been firmly established, and the synergistic qualities of sec-
ondary effluent and Liberty Bay water are not precisely known.
Studies in California indicate that biological secondary treatment
is 80 to 100 percent efficient in removing toxicity compared to 33
to 56 percent for primary treatment.
33. The proposed sewer project will induce an insignificant population
growth; however, local groundwater supplies will be more than ade-
quate to service this growth. For additional data on water sup-
plies, please refer to the Facilities Plan and to Vol. 1 of the
Final Trident EIS (p. 389 ff).
34. Results of the ecological modeling indicate that certain con-
stituents, particularly phosphorus, accumulate significantly in
Dyes Inlet, Sinclair Inlet and Liberty Bay when waste is dis-
charged directly to these embayments. Even though the ac-
cumulation of phosphorus does not lead to an equivalent predicted
increase in productivity, it may well be an indicator for the
accumulation of toxicants such as heavy metals and chlorinated
hydrocarbons.
The predicted impact upon the Port Orchard system is less for dis-
charge to the Illahee and North Port Orchard locations. The dis-
charge sites to the east of Bainbridge Island (Manchester) appear
to have the least impact on the Port Orchard System.
It is entirely possible that the discharge of the Central Kitsap
facility waste anywhere in Puget Sound will have an effect on the
biological communities of Port Orchard. The magnitude of the di-
rect impact will be greatest for discharge to the shallow, iso-
lated bays such as Liberty Bay, Dyes Inlet and Sinclair Inlet;
IX-68
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less for discharge to the Illahee and North Port Orchard sites;
and least of all for discharge outside the Port Orchard system.
For site-specific species information, refer to Chapter II of the
draft supplement to the EIS and Appendix D.
The guidelines developed by the State of Washington's Department
of Ecology call for mixing zone where length in the direction
of the predominant tidal current is 150 feet plus the water depth
in either direction from the outfall centerline. The width of
the dilution zone is 100 feet plus the water depth over the dif-
fuser plus the length of the diffuser or 15 percent of the width
of the estuary, whichever is less. These guidelines are used at
the discretion of the permit writer, who may change the dimensions
on a case-by-case basis.
35. Possible aesthetic impacts from municipal discharges can come from
floatable material, oil and grease, and bio-stimulation. A biolog-
ical secondary treatment plant has a 75 to 85 percent efficiency
(almost 100 percent for visible large matter) and 80 to 90 percent
efficiency for the removal of oil and grease. Effects of bio-
stimulation can be as high as an increase of 8 percent for the dis-
charge from the Central Kitsap facility. It is debatable whether
this is a meaningful increase.
36. With regard to water quality standards, please see the response to
comment No. 15. The costs of the alternatives fully meeting these
objectives is correctly and fully presented in the final EIS.
37. It has been eliminated during the first screening stages.
38. The results of modeling studies indicate that reconcentration of
effluent is negligible with the exception of discharges to Liberty
Bay and Sinclair Inlet.
39. Such simulations will be made in the future when the state-of-the-
art improves sufficiently to assure accuracy of the results.
Phase II studies already completed are sufficient to select an
outfall site.
40. Verification of the hydraulic model studies was accomplished by
means of drogue studies. Drogues were released at the specific
locations, and their trajectories were observed by University of
Washington staff. Drogue trajectories in the prototype agreed in
general with dye releases in the hydraulic model.
41. Common engineering practice and experience together with theoreti-
cal equations were used to provide a simplistic yet reasonably
realistic answer to questions of dilution. Typical diffuser
IX-69
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widths vary from 4.8 feet/1 mgd (Metro-Seattle at West Point) to
21 feet/ 1 mgd (County Sanitation Districts of Orange County) .
Current speeds were estimated from the hydraulic model of Puget
Sound .
42. A secondary level treated effluent will assure against biological
damage to local biota. Please see the response to the letter from
the Washington State Parks and Recreation Commission. Although
current speeds would be less than 0.1 knot for an average of 29
percent of the time, this means only that dilutions would not
reach 100:1 or greater. However, 100:1 was selected as a con-
servative dilution, and numerical water quality standards could
easily be reached at dilutions of only 30:1. Of the 29 percent of
the time current speeds are less than 0.1 knot, they will mostly
be sufficient to achieve at least 30:1 dilution. The balance of
the time current speeds are higher promoting turbulent mixing of
previously released effluent.
43. This is a very complex problem. The size of the mixing zone and
its location will vary with effluent quantity, water depth, tem-
perature, diffuser configuration, current strength and direction.
The slope of the plume can be highly irregular, as shown in the
accompanying sketch:
V too.V-e.0 sorfcv.ce.
The distance, D, as estimated for the north Port Orchard channel
at 100:1 dilution and a current speed of 0.1 knot, would be on the
order of 10 feet, and the diffuser length would be approximately
270 feet. Please note that this is only a general estimate.
44. One cannot, practically, improve the mixing and dispersal char-
acteristics of a specific site once an optimally designed dif-
fuser has been selected. One can only relocate to a new site.
45. Phase II studies confirmed the currents in Port Orchard channel
usine drogues instead of dye. Drogues are plastic floats which
are pulled by the currents and give results comparable to dye
studies. They are often used because they are easier to follow
and do not disperse in the water.
46. The deletion of the site from the list was a typographical error.
IX-70
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47. Please see the response to the letter from the Washington State
Parks and Recreation Commission. General literature states that
with a properly treated effluent there is negligible, or no demon-
strable, damage to benthic organisms. If the organisms throughout
Puget Sound are similar, then inferences common to all may be
drawn.
48. We have not identified migration patterns of the salmonids. The
diluted effluent would not harm the salmonids or divert them from
their spawning travels. The mixing zone plume itself would be so
far offshore as to permit the salmon to swim around it on their
various travels.
49. Please see the response to the letter from the Puget Sound Govern-
mental Conference. Also, Chapter I of the final EIS contains a
discussion of coordination with the City of Poulsbo. Please note
also the comment letter from the City of Bremerton.
50. Specific discussion of sludge disposal is contained in the draft
supplement and final EISs.
51. Acceptance of a 2-mgd Trident point-source load does not preclude
an objective analysis of the possible impacts due to premature
termination of the Trident project. Volumes 1 and 2 of the Final
Trident EIS contain a discussion of premature termination, project
stretch-out and development at a different boat level for the Tri-
dent project.
The draft of the County's contract for sewerage service with the
Navy discusses termination under several cases. In each case, the
Navy is required to reimburse the County for all costs and ex-
penses incurred in the preparation and planning of the sewerage
facilities occasioned by the provision of service to the Navy and
resulting from such termination. In the event that the sewerage
facilities have become operational, the Navy is required to pay
all costs of maintenance and operation of facilities for capacity
provided by the Navy, until such time as the County is able to
secure other customers to utilize the facilities.
The Navy is paying the entire cost of constructing the interceptor
from the Bangor Annex to its connection with the North-South inter-
ceptor leading to the treatment plant. The Navy is paying its pro-
portionate share of cost of construction of the interceptor from
that point to the treatment plant, of the treatment plant itself,
and the outfall line discharging to receiving waters. There would
be therefore no loss of capital cost to the County should the Navy
terminate its participation. Since the treatment plant is being
designed with parallel modular processing units, termination of
the Navy's waste contribution would result in some of these units -
being taken out of service. Operation and maintenance costs would
therefore be reduced proportionately. The only economic impact on
IX-71
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the remaining users of the Central Kitsap County facility would be
those costs associated with the economies of scale which would be
lost due to termination of the Navy's participation. These should
be relatively minor and are not anticipated to have a severe eco-
nomic impact on the rest of the users of the system.
Concerning the level of user charges resulting from Navy contribu-
tions of less than 2 mgd, all users would pay their proportionate
share of their waste loadings contributed to the system, in accord-
ance with user charge guidelines, Appendix B to EPA's Construction
Grant Regulations (40 CFR Part 35). Under these guidelines, the
County will be required to review user charges at least annually
and revise them as necessary to reflect actual treatment works
operation and maintenance costs.
52. The data in Table 11-22 will not be significantly affected by the
provision of sewers in the area. Some additional traffic will be
generated by the small work force operating the plant and their
dependents (20 to 40 workers and families).
53. The county poor living in an area that will receive sewerage ser-
vice will have to pay approximately $5.00 per month for the
service. This may hurt their budgets, but they will benefit, along
with the rest of the population, from reduced health hazards.
54. Housing for Trident Support Site construction workers was assumed
to be off-base, as indicated by the U.S. Navy. In the long run,
this housing would be occupied by Trident employees and as such
is part of our basic assumptions.
55. The A.D. Little study is very exhaustive and definitive; no
further studies are considered necessary.
56. The County has taken the position that the Trident-related growth
will be accommodated as needed in Kitsap County. Non-Trident
growth has been projected and distributed on the basis of current
trends, and Trident-related growth has been distributed on the
basis of time distance from Bangor. These distributions were made
at the County Census Division level. At this point, the County
has not adopted a policy which would significantly disturb that
distribution. Some control on population distribution will un-
doubtedly result from the policies adopted in conjunction with the
Complex Facilities Plan.
57. Yes, it does.
58. Please see the response to comment 29.
59. First of all, it is not a restriction, it is an estimate. Please .
see the response to comment 56.
IX-72
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60. We disagree. The environmental effects are associated with land
use planning and should be approached whenever the County's land
use plans are opened for public discussion and approval. See also
the response to comment 22.
61. The sewered population of 18,000 is not a restriction. It is only
a prediction that sewer lines will go where the population is
densest.
62. This has been done in the draft supplement and final EISs.
63. With regard to Trident wastes, please see the response to comment
51. Flow rates for Central Kitsap County were based on measured
values. Flow rates for Poulsbo were not measured by the URS Com-
pany but were accepted from Poulsbo*s facilities planning consul-
tant. One reason for the difference lies in the expected high
number of multiple-family dwelling units in Central Kitsap County.
The units produce less per capita flow.
64. Please refer to the chart following our response to comment 3 in
your letter of March 26, 1976. We have absolutely no concern that
the Navy is in any way attempting to avoid disclosure of any de-
leterious constituents in the waste they will be contributing.
They have indicated that approximately 90 percent of their flows
will be domestic in nature, with the remainder being commercial/
industrial wastes from industrial type facilities. The largest
portion of the industrial wastes will probably be heating plant
boiler blowdown, along with some small amounts of wastes from
plating and photo shops. As a discharger into a municipally
owned and operated system, the Navy will be required to abide by
the pretreatment standards which are designed to protect the
operation of publicly owned treatment works and to prevent the
discharge of pollutants which would pass through such works
inadequately treated. Their present plans are to collect all
industrial type waste separately and pre-treat in an industrial
waste treatment facility on base. Those remaining wastes clas-
sified as "compatible" under pretreatment standards will then
be discharged into the County system. Discharges in industrial
categories are subject to effluent guidelines issued under Section
304B of the Federal Water Pollution Control Act Amendments of
1972 (Public Law 92-500). If they are discharging incompatible
pollutants to publicly owned treatment works, they are required
to adopt best practicable control technology currently avail-
able, as defined by the EPA Administrator, pursuant to Section
304B of the Act. The Navy will be specifically prohibited from
introducing any wastes which would interfere with the operation
or performance of the treatment works.
65. Please see the response to the letter from the Puget Sound Govern--
mental Conference.
IX-73
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66. The Hansville Road solid waste disposal site has been subjected to
the EIS process and found acceptable.
All reasonable and effective wastewater and sludge treatment sys-
tems were considered by the facilities planners, and in their judg-
ment the proposed treatment system was best. The publication you
cite is not a sludge treatment or process manual. The oxygen
activated sludge treatment system is a form of wastewater treat-
ment and is not applied to sewage sludge stabilization, generally
due to its high cost. EPA's technical publication on sludge
disposal is EPA 625/1-74-006, "Process Design Manual for Sludge
Treatment and Disposal".
67. Yes; yes.
68. We do not agree with your statement that the EIS draft is totally
inadequate for a reasonable examination of alternatives. Please
see our response to your comment No. 3 for a discussion of alter-
natives available to the Navy for separate treatment for Trident
wastes.
69. Collection line installation is strictly a local affair; there
are none proposed for this project and they have no effect on
the total annual cost of this project. The bond cost of 5-7/8
percent is not an unreasonable figure, depending on the type of
bond, issuer, etc. Recent bond prices, as published in the Wall
Street Journal, support the figure as a guideline. For example,
the Wall Street Journal for November 21, 1975, p. 28, reports
the sale of sewer bonds by the Heart of the Valley Sewerage Dis-
trict, Outagamie County, Wisconsin, at an average cost of 5.906
percent (ranging from 5.4 percent to 6.2 percent). For compari-
son, 5-7/8 percent is 5.875 percent. The average Wisconsin cost
and the cost used in the EIS differ by .013 percent.
70. The EPA-published guidelines on fugitive dust are the following:
INVESTIGATION OF FUGITIVE DUST
VOLUME I - SOURCES, EMISSIONS, AND CONTROL
EPA - 450/3-74-036-a
June 1974
INVESTIGATION OF FUGITIVE DUST
VOLUME II - CONTROL STRATEGY AND REGULATORY APPROACH
EPA - 450/3-74-036-b
June 1974
DEVELOPMENT OF EMISSION FACTORS FOR FUGITIVE DUST SOURCES
EPA - 450/3-74-037
June 1974
IX-74
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EMISSIONS INVENTORY OF AGRICULTURAL TILLING, UNPAVED ROADS, AND
AIRSTRIPS, AND CONSTRUCTION SITES
EPA - 450/3-74-085
November 1974
Volume I in particular contains a discussion of suggested construc-
tion techniques. Any construction specifications prepared by the
County would be subject to a technical review for adequacy by an
EPA project engineer prior to approval of grant award for construc-
tion. Consultants commonly require the utilization of specific
dust and erosion control techniques in their construction specifi-
cations.
71. Please see the response to the letter from the Washington State
Parks and Recreation Commission. It must be noted that treated
effluent is fresh water with more buoyancy than salt water. Ef-
fluent leaving a diffuser will rise and be very well mixed before
it works its way to the benthos. The very presence of thick pock-
ets of clams off Manchester implies that the Manchester outfall
produces negligible adverse effect upon them. The Manchester out-
fall also has no effect on salmonids migrating to Steel Creek.
Comparison of the toxicity data obtained from the Liberty Bay
study with calculated dilutions indicates the effluent will have a
negligible effect upon clams and salmonids in the Manchester area.
For a secondary treatment plant, the Liberty Bay study indicated a
required dilution of 1:70 to maintain a level of 0.1 times the EC5Q-,
concentration, as determined by an assay of Pacific oyster embryo.
The EC5Q concentration is that concentration resulting in a 50 per-
cent abnormality in the embryo after a 48-hour test.
72. Treatment costs that reflect site-specific characteristics have
been included in the analysis. As evidence of this, please note
the tertiary level treatment recommended for Dyes and Sinclair
Inlets. We have considered non-degradation and a negligible im-
pact - meaning one too small to estimate or notice - to be equiva-
lent. We do concede that nutrient enrichment could be a problem
in enclosed bays, but that is one reason discharges to such areas
were not recommended and that a discharge to North Port Orchard
channel was recommended. The cost of a nitrified effluent is in-
cluded in alternative costs. Dechlorination can readily be accom-
plished by aeration of the chlorinated effluent.
For consideration of waste reconcentration, please see the response
to comment No. 38.
73. The analyses available to us were presented in the draft supplement
EIS and are repeated in the final EIS. They are adequate to
assess the relative impact of the alternatives.
IX-75
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74. The answer to the first two questions is yes. Concerning Navy
flows of less than 2 mgd and their impact on costs to other system
users, the only impact would be a possible slight increase in user
charges due to the loss of economies of scale. See our response
to comment No. 51.
75. Please see the response to comment No. 69.
76. Again, see our response to your comment No. 51.
77. Please see the response to comment No. 54.
The impact from the alternatives would be negligible or
unchanged.
IX-76
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Handbook
of
Procedures
Construction Grants Program
for Municipal Wastewater
Treatment Works
February 1976
Municipal Construction Division
Water Program Operations
Office of Water and Hazardous Materials
U.S. Environmental Protection Agency
Washington, D.C. 20460
IX-77
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H. PREDESI6N CONFERENCE
Purpose and Discussion:
EPA, in conjunction with the State agency, should assume
responsibility for insuring that the plans and specifications are
prepared in accordance with sound engineering practice and regulatory
requirements. Because of the complexity of these requirements, a
predesign conference between the grantee, his consultant, the
State and EPA is strongly urged, whenever practicable.
The predesign conference, which may be held with one or
more grantees, promotes careful planning and coordination and insures
the timely completion of. the various phases of a project. In some
cases, the review of plans and specifications may be delegated to a
State. In such cases, the State is responsible for the predesign
conference arrangements. For the other cases, the regions are
encouraged to develop formats for the predesign conferences. The
formats may then be tailored to the individual staffing resources
of the States and the needs of the applicants.
Procedures:
Shortly after acceptance of a Step 2 grant, but prior to
the preparation of plans and specifications, the reviewer should
arrange a predesign conference with the grantee, grantee's
consultant and State agency. Suggested subjects to be discussed
include:
1. the legal requirement for inclusion of and
provisions for carrying out the bidding
procedures described in 40 CFR 35.936, .938,
.939 and Appendix C-2;
2. the technical requirements of the design to
insure that the project will meet effluent
limitations per NPDES permit and will be
designed in accordance with sound engineering
practice;
Re: 40 CFR 35.925-7
IX-79
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3. additional requirements, as applicable, for
detailed design reports beyond that submitted
with the facility plan. Possible examples are:
- loading rates and sizes of various
components of the plant;
- design computations for sewers, including
slopes and capacities;
- system head curves for pumping stations,
indicating number and capacity of pumps;
- other detailed design reports which the
particular project may require;
4. pretreatment design requirements and scheduling,
as applicable, for industrial dischargers;
Re: 40 CFR 35.925-15
5. design considerations or investigations
resulting from the environmental assessment
or environmental impact statement. Possible
examples are:
- a soil erosion plan;
- a traffic control plan;
- archaeological investigations;
Re: 40 CFR 35.925-8
6. design requirements arising from executed
agreements between jurisdictions;
Re: 40 CFR 35.917-6
7. force account requirements, as applicable;
Re: Program Guidance Memorandum, PG-34, 5/7/74
8. phasing of contracts;
Re_: Program Guidance Memorandum, PG-33, 5/10/74
IX-80
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9. flood protection insurance requirements, as
applicable;
Re_: 40 CFR 30.405-10
Program Guidance Memorandum, PG-54, 7/8/75
10. records to be maintained during design and
construction, separating eligible and ineligible
i terns;
Re: 40 CFR 30.805, 35.940
11. site certification requirements, if not
previously satisfied;
Rej 40 CFR 35.920-3 (b)(4)
12. future requirements for
- the user charge and industrial cost
recovery systems;
- a sewer use ordinance;
- an evaluation/rehabilitation program,
as applicable;
- an operation and maintenance program,
including O&M manual, staffing and
training;
Re_: 40 CFR 35.935-12, -13, -16
13. requirements for submission of project status
reports and requirements for periodic
inspections and audits, as necessary, for
large or complex projects;
Re: 40 CFR 30.635, .820
14. requirements for construction contracts to conform
with the standardized format, "Contract Documents
for Construction of Federally Assisted Water and
Sewer Projects";
Re_: Program Guidance Memorandum, PG-17A, 4/15/75
IX-81
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15. use of value engineering in the design phases
of the project;
Re: Program Guidance Memorandum, PG-45, 12/11/74
16. possible benefits from the use of construction
management.
The reviewer should provide the grantee with guidelines,
instructions, booklets, or other publications which describe specific
requirements in detail.
I. REVIEW OF PLANS AND SPECIFICATIONS
Purpose:
To insure that the project to be built will satisfy effluent
and statutory requirements.
Discussion:
Depending upon the complexity of the project, periodic reviews
and inspections will have been carried out during the preparation of
the plans and specifications and changes or modifications, if required,
will have been made. The set of plans and specifications submitted for
final review should reflect all changes and be suitable for bidding
purposes.
The review procedures are both administrative and technical.
The technical review procedures are broad in scope and each region is
encouraged to pattern its own review procedures to account for State
or local design practices and requirements. Although not specifically
required, the use of a checklist such as the "Program Checklist for
Engineering Drawings, Specifications, and Engineering Reports",
Appendix C, is recommended.
IX-82
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Review Procedures:
a. Administrative Review
The following six items must be included in the
bidding documents:
(1) a statement of work, including drawings
and specifications, and the required
completion schedule;
(2) the terms and conditions of the contract
(40 CFR 35.938-8);
(3) an explanation of the method of bidding;
the method of evaluating the bid prices,
and the basis for the award of the contract;
(4) the criteria for evaluating bidders;
(5) the standard statement concerning the
funding of the project by EPA;
(6) a copy of 40 CFR 35.936, 35.938 and 35.939.
In addition to the above six items, the reviewer is to
insure that the specifications include the following provisions:
(1) Supplemental General Provisions
Appendix C-2 of 40 CFR Part 35 which
includes requirements for:
- audit: access to records
- price reduction for defective
cost or pricing data
- contract work hours and safety
standards
- equal employment opportunity
- utilization of small and minority
business
- covenant against contingent fees
IX-83
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- anti-kickback
- gratuities
- patents
- copyrights and rights in data
- clean air and water clause
(2) Equal Employment Opportunity
The EEO provisions must be followed where contracts
are greater than $10,000. In areas having a home-town or an imposed
plan, the contract specifications must contain the specific provisions
of the plan as published by the Secretary of Labor in the Federal
Register. Home-town plans are agreements reached among the local
contractors, trade unions, minority groups and governmental agencies,
which are approved by the Secretary of Labor, and contain the goals for
the hiring and training of minority groups. Imposed plans likewise set
forth minority hiring and training goals; however, such goals are not
reached by agreement, but imposed by the Department of Labor.
In either instance, the reviewer should insure thau
the applicable plan is contained in the specifications.
In non-plan areas, contractors will be required to
comply with the provision of Executive Order 11246 and engage in
affirmative action directed at promoting and insuring EEO in the work
force used under the contracts.
When the cost of the construction is estimated to
exceed a ceiling amount specified by the Regional Administrator, the
contracts may require special provisions. The reviewer, in such cases,
should contact the Civil Rights and Urban Affairs Office within the
EPA regional office for specific instructions.
Re_: 40 CFR 35.935-6
40 CFR Part 8
IX-84
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(3) Davis-Bacon Act
The provisions of the Davis-Bacon Act must be
included in contracts exceeding $2,000. These provisions require the
payment of prevailing wages for the various trades as determined by
the Secretary of Labor.
Prevailing area-wide rates are published weekly
in the Federal Register. For individual projects not included in
areas with area-wide wage rate determinations, the Regional Office will
obtain a wage rate for inclusion in the specifications.
Modifications to area-wide wage rate determinations
are to be included in the bidding documents provided they have been
published 10 days prior to the bid opening date. Modifications to
individual project determinations are to be included provided they are
received in the Regional Office 10 days prior to bid opening.
The reviewer is to insure that the current wage
rate determination is included in the bidding documents or that
provisions for inclusion have been made.
Re_: 40 CFR 30.403, .415
(4) Flood Insurance
For projects requiring flood insurance (see
Chapter VI E.4.a. of this Handbook) make certain that the contractor is
required to obtain the necessary flood insurance during construction.
(5) Bonding
For contracts in excess of $100,000, the following
minimum bonding and insurance requirements must be met:
- 5% bid bond;
- 100% performance and payment bond;
- fire and extended coverage, workmen's
compensation, public liability and
property damage, and "all risk", as
required by local or State law;
- flood insurance, as applicable, during
construction.
IX-85
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For contracts less than $100,000, bonding and
insurance requirements shall be in accordance with local or State
practices.
b. Technical Review:
The technical review of the plans and specifications is
carried out to insure that the proposed facilities, if constructed in
accordance with the plans and specifications, will achieve the effluent
limitations or water quality standards required by the NPDES permit.
The review is also to insure that sound engineering design principles
are employed, primarily regarding process considerations. Structural,
electrical, and mechanical details of the design are not critically
reviewed because they are the responsibility of the engineer whose seal
appears on the drawings. However, obvious irregularities should be noted.
The technical review should evaluate the plans and
specifications according to the criteria in "Program Checklist for
Engineering Drawings, Specifications, and Engineering Reports" (see
Appendix C) to the extent appropriate for the particular project and
State requirements. The following are examples of items which should be
reviewed.
(1) Safety Precautions
The requirements of the Occupation Safety and Health
Act (OSHA) must be fulfilled;
(2) Mitigative Measures
Plans and specifications must be compared with
mitigative measures required by the environmental assessment or impact
statement. Examples might be soil erosion control, hours of operation,
backfilling and seeding, structural design for buildings in a flood
plain, etc.
(3) Bypassing
Construction is to be carried out so as to prevent
bypassing of flows during construction, where possible.
(4) Project Sign
Contractor is required to provide a project sign in
accordance with the drawing shown in Appendix B.
IX-86
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(5) Reliability and Flexibility
The proposed facilities must be reliable and
provide for flexibility in operation. This may be accomplished, for
example, by requiring standby power, by providing for bypass of
individual plant units, by providing pumping capacity sufficient to
operate the plant with the largest pump out of service, etc.
Rej_ No. EPA-430-99-74-001
(6) Operation and Maintenance
All equipment, piping, switches, instruments, etc.
are to be clearly marked for ease of identification and location for
operation and maintenance.
17) Public Water Supply
All public water supplies are to be protected by
adequate backflow preventers (for example, double check valves, air
gap).
(8) Chemical Storage
All chemicals are to be properly stored and curbed
to hold the entire volume in the event of an accidental spill. Also,
adequate safety protection gear is to be provided, with proper storage,
for plant personnel.
Re: Technical Bulletin No. D-71-1, 10/15/71
(9) Ventilation
Adequate ventilation is to be provided in all areas
where necessary (for example wet well, dry well, chlorine room, chemical
storage area, etc.).
(10) Laboratory Facilities
The laboratory facilities must be adequate to conduct
the type of sampling and testing required by the NPDES permit or by the
State agency.
or dangers.
(11) Emergency Alarms
Adequate alarms are to be provided to warn of failures
IX-87
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(12) Use of Mercury
Mercury is not to be used for trickling filter
seals. Other uses of mercury require special review and approval.
Re_: Technical Bulletin No. D-71-2, 10/15/71
(13) Sewers
Acceptable levels of infiltration and test therefor
are included; sewers should maintain minimum scouring velocities and
have adequate capacity, including peaking factors.
(14) Equipment
Except where based upon performance specifications
at least two trade names must be specified for all major items of
equipment.
Re: Program Guidance Memorandum, PG-19A
40 CFR 35.936-13(a)
(15) Shellfish Waters
Where discharges will come into contact with
shellfish waters, appropriate measures must be included to protect the
shellfish.
Re: Technical Bulletin, Protection of Shellfish
Waters, EPA 430/9-74-010, July 1974
(16) Pretreatment
Where applicable the design must be in accordance
with the requirements for pretreatment of incompatible industrial wastes.
Re: 40 CFR 35.925-15
IX-88
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c. Plan and Specification Approval
Upon approval by EPA of the plans and specifications,
the grantee and State agency are to be so notified. The notification
will generally be in the form of a letter and should contain any special
conditions resulting from the review which would be imposed on the
applicant upon application for a Step 3 grant. The approval notice
should specifically remind the applicant not to advertise for bids until
after applying for and receiving a Step 3 grant.He should also be
reminded that the EPA is not obligated to award a Step 3 grant for the
project.
IX-89
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Page 1 of
Date
PLAN AND SPECIFICATION APPROVAL
PROJECT NO: LOCATION: OWNER:
Design Engineer
Phone
Approval by State Engineer Date_
Conditions for Approval (attach copy of certification letter and plan
and specification approval letter)
Approval by EPA Engineer Date
Conditions for Approval (attach copy of plan and specification approval letter)
Description of project in terms of type of treatment, flow capacity, and
process units:
List of ineligible items (identify by bid item schedule, number and quantity),
IX-91
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Page of
Date
SUMMARY OF REVIEW
Summarize the apparent inadequacies revealed during the plan and specification
review process and describe the resolution of each. If necessary, summarize
pertinent conversations and cite specific correspondence with the consulting
engineer:
IX-92
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Page of
Date
GENERAL INFORMATION
PROJECT NO: PROJECT NAME:
YES NO
Has an Environmental Impact Statement (EIS) been prepared
on this project?
Have all recommendations of the EIS been followed?
Is the treatment process suitable for the character and volume
of the sewage to be treated?
Have the components of the sewerage system been properly sized,
based on realistic population projections?
Will a minimum of primary treatment be provided during
construction?
Has an organized, systematic, readily understood Basis of
Design been provided?
Has an I/I (infiltration/inflow) Analysis been completed?
If an I/I Analysis has not been completed, has the State certified
that the contributing sewer lines do not have excessive
i nfi1trati on/i nf1ow?
Is shellfish growing a consideration? If yes, what protective
provisions have been made?
Will any of the contemplated construction be located in the flood
plain and subject to flooding? If yes, what is the frequency?
What reasonable protection has been provided?
Is the project in a designated flood hazard area as defined under
PL 93-234 (Flood Disaster Protection Act)? If yes,what amount of
insurance has been obtained by the applicant under this Act? $
Are permits to construct required from other Federal Agencies?
If yes, are these permits in the process of being secured?
IX-93
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Page of
Date
ENGINEERING DRAWINGS AND
DETAIL SPECIFICATIONS
PROJECT NO: PROJECT NAME:
YES NO GENERAL
" Have at least two brand names been used with the or equal clause?
BUILDINGS
Is an adequately equipped and stocked laboratory provided?
If not, have provisions been made to contract for labwork?
Is the space provided in the various buildings adequate?
Are heating, lighting, and sanitary facilities adequate
in all buildings?
Are chemical storage and machine locations safe?
Have the restrictions on the use of mercury pursuant to
TB D-71-2 been complied with?
ENVIRONMENTAL CONSIDERATIONS
Have noise and odor control been given proper attention and
provided for where necessary?
Has attention been devoted to a generally aesthetic appearance
of the facility?
RELIABILITY
Is standby power provided? If standby power is not provided,,
describe on an attachment the means of assuring continuous
operation.
Have multiple units and equipment been provided to the maximum
extent possible?
Can individual plant units be bypassed?
Are there adequate provisions for flexibility of operation?
SAFETY FEATURES
Is the plant fenced or otherwise enclosed?
Is the public water supply protected by a backflow
preventer?
Is mechanical ventilation provided where required?
Are railings and machine guards provided?
IX-94
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Page
Date
of
PROJECT DESIGN DATA
PROJECT NO:
LOCATION:
PROJECT NAME:_
DISCHARGE TO:
Scope of Project:
Degree of treatment (present): SS removal %; BOD^ Removal
Degree of treatment (proposed): SS removal %; BODs Removal
Is this project related or tandem to previous project(s):
Description of new or modified plant:
Type of Sewer System:
Separate
Combined
PROJECT LOADING
1, Industrial Wastes - mgd
2. Industrial Wastes - ^OD5
3. Industrial Wastes BODs
Ib/day
4. Industrial Wastes - P.E.*
5. Domestic Population
Served
6. Domestic Average
Flow - mgd
7. Total Average Flow -
mgd (Items 1+6)
8. Raw P.E. (Before Treat-
ment (Items 4+5)
9. Effluent P.E. (After
Treatment)
(Item 8) x (1-%BOD5 Removal)
Present Load
Start-up
Load
Design Year
(19 ) Load
Principal types of industrial wastes:
Permit Number
Permit effluent limitations
*P.E. = Total Ibs. BOD5/day
0.17
IX-95
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Date
STREAM DATA
PROJECT NO: PROJECT NAME:.
1. Name of Receiving Stream
2. Estimated Minimum Daily Flow Duration Frequency_
3. Stream - Free Flowing ( ) Sluggish ( )
4. Distance Downstream to Nearest Community
5. Distance Downstream to Nearest Water Intake
6. Receiving Water Velocity
7. Salinity of Receiving Water_
8. D.O., BOD and S.S. of Receiving Water
9. Temperature range of Receiving Water °F
10. Temperature range of Effluent °F
11. Area of Mixing Zone
12. Trapping Level (Will Plume Reach Surface)
13. Dilution Ratio
14. Calculated Coliform/100 ml
15. Stream Classification
16. Water Quality Criteria
17. Make computations to assure that the project effluent will not have a
detremental effect on the quality of the receiving stream.
IX-96
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Page_
Date~
of
Bar Screen
Total Area
SCREENING, GRIT REMOVAL
AND FLOW MEASUREMENT
sq. ft. Effective Area
sq. ft.
Space Between Bars_
Slope of Screen
inches Velocity
fps
Mechanical Screen: Capacity_
Method of Cleaning: Manual
Disposal of Screenings
Comminuting Device
Type
Is Drainage Platform Provided?_
mgd Type
Mechanical
Can screen be bypassed?_
Location
Size
inches Capacity
mgd
Auxiliary Bar Screen_
Grit Chamber
Mo. Chambers
Type
Cross-Section Area Each
sq. ft. Total
Linear Velocity in fps: Average_
Method of Velocity Control
Min.
_sq. ft. Length_
Max.
ft
Detention Period: Present Flow:
Drain Provided
_Seconds Design Flow:
Seconds
Method of Cleaning: Manual
Disposal of Grit:
Flow Measurements
Type Metering Device_
Mechanical
_Location (Raw Sewage or Eff.
Indicating and Recording Mechanism_
Approval by State Engineer:
Comments:
IX-97
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Page of
Date
SEDIMENTATION TANKS
Type: Primary: Intermediate: Final:
Feed: End/center/peripheral
Number Tanks Shape of Tanks
Inside Dimensions: Length Width SWD Depth piarneter_
Effective Volume Each Tank cu. ft. Total Volume cu. ft.
Recirculation Rate Design Flow (including recirculation mgd
Detention (Average 24-hr, flow): Present hrs. Design _nrs-
Surface Loading: Present gpd/sq. ft. Design
Length of Overflow Weir ft.; Overflow Rate gpd/ft.
Is overflow Weir Adjustable? Type of Weir
Sludge Collection Equipment, Type
Scum Removal (Type):
Disposition of Scum
Sludge Removal by: Pump Gravity to
Approved by State Engineer:
Comments:
IX-98
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AERATION TANKS
Number Tanks
Inside Dimensions: Length
Net Volume Each Tank
Width
Page
Date
JShape of Tanks_
Depth
of
Diameter
cu. ft. Total Volume
cu. ft.
Percentage of Daily Flow of Return Sludge to Aeration Tank_
Design Flow (exclusive of return sludge)
BOD5 Loading ppm #/day
Required Air
mgd
_cu. ft./#BOD5/day
Furnished Air
cu. ft./#BODs/day (normally 150% of required air)
Detention Time (Average 24-hr. Flow): Design nrs.
Length of Overall Weir ft. Overflow Rate gpd/ft.
Equipment
Number Blowers Cap. Each cfm Total Cap cfm At Ibs.
Diffusers: Plates
Fixed Tubes
Impingement Aerator_
Mechanical Aeration
Number Units
Jet Aerator
Swing Diffuser_
Updraft Tube
Down Draft Tube
Operated Intermittently by Time Clock
Sludge Return Pumps
No. Pumps Type Cap. Each
_gpm Total Cap.
_gpm
Rated Heads
_ft. Computed Heads
ft.
Approval by State Engineer:
Comments:
IX-99
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Page
Date"
of
TRICKLING FILTERS
Type (Standard or High Rate):
Number of Filters Dimensions: Dia. ft. Depth ft.
Surface Area: Each_
Depth of Media
sq. ft. Total
sq. ft.
acres
ft. Volume of Media
cu. yds.
Average daily flow_
Recirculation
A. Quantity
B. Quantity
Total
_mgd
Hydraulic Loadings:_
BODs Applied Sewage_
BOD5 Loading
Filter Material: Size
Soundness test specified:_
Distributor: Type
Provisions for Flooding_
Recirculating Pumps
Pump No. Type
_mgd.
jngd. returned from
to
mgd. returned from
to
_mgd/acre
_ppm_
#/day
_#/cy/day
_#/acre-ft./day
inches; Kind
No. Arms
_Air Channels Adequate
Capacity Rated Head
gpm ft.
Computed Head
ft.
gpm
_gpm
_ft.
ft.
ft.
ft.
gpm
ft.
ft.
Approved by State Engineer:
IX-100
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Date
HASTE STABILIZATION PONDS
Location
Number of Ponds Operation: Series Parallel Either_
Surface Area: #1 #2 #3 Total: acres
Loading: Persons/Acre #BODs/Acre/day
Grit Removal Required Screens Required
Provisions to Divert Surface Water
Provisions for Measuring Flow:
Provisions for Sampling:
Depth: Optimum Operating ft. Maximum ft. Minimum ft.
Freeboard: ft.
Type of soil:
Are specifications adequate for compaction of embankments?
Top width of embankment ft. Erosion Protection •
Embankment Slopes: Inner Horz. ] Vert.
Outer Horz. ] Vert.
Depth of Submergence of Inlet ft. Distance from Bank_
Distance From Inlet to Outlet ft.
Is scour protection provided at inlet?
Drawoff levels: Top Middle Bottom_
Bottom Drain
Is controlled overflow provided?
Provision for effluent disinfection
Appropriate Warning Signs fence provided_
What provisions have been made to fill the ponds
Approval by State Engineer:
Comments:
IX-101
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page ot
Date
SLUDGE DIGESTION - SEPARATE
Single Stage or Primary Digestion Tanks
No. Tanks Dimensions Each: Diameter ft. Depth ft.
Volume Each cu. ft. Total Vol. 1st. Stage cu. ft.
Volume Per Capita (Design) cu. ft.
Second Stage Digestion Tanks
No. Tanks Dimensions Each: Diameter ft. Depth ft.
Volume Each cu. ft. Total Vol. 2nd. Stage cu. ft.
Volume Per Capita
First and Second Stage Digesters
Total Volume All Tanks cu. ft. Vol. Per Capita cu. ft.
Heated Unheated
Gas Disposal Aux Heat Heat Exchanger
Type of Cover Pressure and Vacuum Relief on Cover
Is unvalved overflow provided?
Flame Trap Drip Traps Waste Burner_
Sludge Withdrawal Line (Size) inches. Pumped Gravity
Circulation = Gas/Mechanical Supernatant Disposal
Recirculation Pumps or Sludge Pumps
Number Cap. Each gpm. Size Disch. Line inches
Rated Heads ft. Computed Heads ft.
Approval by State Engineer:
Comments:
Ix-102
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Page of
Date
SLUDGE DISPOSAL
Sludge Drying Beds
Number of Beds Area of Each Bed_
Total Area
Area per capita: Present sq. ft.
Design sq. ft.
Gravel: Layer Depths Sizes
Sand: Depth inches
Underdrains: Size Spaced C-C_
Freeboard Above Sand Suitable Splash Pad_
Beds Subject to Flooding Concrete Runners Provided
Is drainage from beds returned to plant for treatment?
Vacuum Filters
Type of Sludge to be Handled: Raw Digested
Number of Filters Size Capacity_
Total Area Chemical Treatment
Filtrate Disposal
Holding Tank
Lagoons
Will groundwater be protected from contamination?
Number of Lagoons Total Volume of Lagoons_
How will sludge be disposed of?
Approval by State Engineer:
Comments:
IX-103
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Page
Date
of
CHLORINATION
Points of Application
No. of Chlorinators
_Type_
Total Capacity lbs/24hrs.
Total Capacity Ibs/mg flow: Present
Chlon'nator Room
Outside Door Only
_Design_
Type of Ventilation_
Scales Provided
Adequate Storage for Containers
Gas Masks Provided
Chlorine Contact Tank
No. of Tanks
Inside Dimensions_
Capaci ty
Detention Time
Can Tanks be drained?
Disposal of Drainage:_
_min. @ present
_min. @ design
Sludge Removal
Approval by State Engineer:
Comments:
IX-104
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Page
Date
of
SEWAGE PUMPING STATION
Location
Type Pumps Specified_
Type Pump Control
Alternator
Simultanious
Are Duplicate Units Provided?_
Can max. flow be handled with largest unit out of service?
If not, explain alternate procedure
Maximum Flow
Average Flow
Minimum Flow
Volume of the wet well
Detention time & maximum flow
minimum flow
Does the fillet in the wet well have adequate slope?
Has a bar rack or sand trap been provided?
Is there a gate valve and a check valve on discharge?
Is there a gate valve on suction?
Is ventilation provided in the wet well? Dry well
Is standby power, automatic overflow or a detention pond provided?^
Is an adequate alarm system included?
PUMP
No.
SIZE
(in.)
FRICTION
Head (ft)
STATIC
Head (ft)
CAPACITY
gpm
RATED
TDH
COMPUTED
TDH
CONSTANT/ f
VARIABLE 1
SPEED !
;
I
Approval by State Engineer:
Comments:
IX-105
-------
SEWERS
Location
Type of Sewer: Sanitary_
Combined
Classification: Collector^
Type of Pipe
_Interceptor_
Length of Sewer_
Design Velocity_
_Type of Joint_
Diameter
Required Velocity
to Sta.
Minimum Velocity from Sta.
Design Capacity Required Capacity_
Is the cover adequate in all cases?
If the cover is not adequate, where? Sta.
What type joint test is required?
What are infiltration/exfiltration limits?_
MANHOLES
Maximum distance between manholes
Diameter of Barrel
page
Date
or
Storm
Outfall
Slope
to Sta.
Diameter of Cover
Are manholes provided at all changes in grade, size or allignment of sewers?_
Is outside plaster required? Paved invert?
Are corrosion resistant steps or ladders provided?
Are retainers and blocking provided where necessary?
Approval by State Engineer:
Comments:
IX-106
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Page
Date
of
Design Flow
Outfall Length_
Diffuser Length_
Number of Ports
Depth of Discharge_
OUTFALL
mgd
ft. Diameter
ft. Diameter
ft.
Jnches
inches
Approval by State Engineer:
Comments:
IX-107
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Page of
Date
FORCE MAIN
Location
Hazen-Williams "C" factor used for Design_
Type of Pipe Size Pressure Class
Type Joint Specified
Force Main Length Computed TDH Rated TDH_
Velocity Minimum Cover Provided
Are Blow-Offs Specified? Air Relief Valves?
Are Thrust Blocks and Retainers Provided Where Necessary?
Approval by State Engineer:
Comments:
-108
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ROLLA V. HOUGHTON (I97O)
JACK R CLUCK
PAUL COUGHLIN
JOHN W. RILEY
EMIL P SCHUBAT
DAVID SKELLENGER
BERT L METZGER, JR.
JOEL HAGGARD
WILLIAM N MATHIAS.m
LAURITZ S HELLAND
LAW OFFICES OF
HOUGHTON CLUCK COUGHLIN & RILEY
9OO HOGE BUILDING
SEATTLE, WASHINGTON 98IO4
TELEPHONE
(206) 633-6501
IN REPLY REFER TO
OUR FILE NO.
March 26, 1976
Mr. Richard Thiel
c/o EPA, Region X
1200 Sixth Avenue
Park Place
M-S 537
Seattle, Washington
Dear Mr. Thiel:
RECEIVED
MAR 2 9 1976
98101
On behalf of C. A. Ross, we are submitting the following
comments upon your draft EIS Supplement, EPA 910/9-75-012,
regarding the Central Kitsap County Wastr Water Facilities.
We understand that our comments of October 20, 1975 on the
draft EIS are to be included in your responses to the draft
EIS Supplement; so they are not repeated here.
ADEQUACY OF ENVIRONMENTAL ANALYSIS
The recently adopted State of Washington SEPA Guidelines
provide for use of your EIS in lieu of one separately pre-
pared under SEPA if certain conditions are satisfied. See
WAC 197-10-650, 652. Under these Guidelines and prevailing
NEPA case law, we must reluctantly disagree with the as-
sertion on Page 1-2 of the Draft EIS Supplement that a
"complete" (inferring adequate) description and environ-
mental analysis of the new alternative and indeed of others
has been made. With respect only to the SEPA Guidelines,
the environmental elements of WAC 197-10-444, when applied
locally, have not been adequately treated in the draft EIS.
Supplementation, modification or new EIS preparation will be
required. See WAC 197-10-652.
Without being inclusive and thus arrogating to ourselves the
County's duty to prepare adequate environmental documents,
we offer a few examples of the inadequacy. The total pro-
posal includes the collectors which are functionally related
to the treatment facility. See WAC 197-10-060. Yet the
IX-109
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Mr. Richard Thiel
Page 2
March 26, 1976
impacts and alternatives for that portion of the total
proposal are not discussed. Alternatives and mitigating
measures are absent for the treatment plant location, size
and configuration and for the outfall pipeline routing from
the treatment plant.
Continuous requests have been made for environmental anal-
ysis of the alternatives regarding the Trident waste load to
the treatment facility. (See our letters of 10/11/74, 6/3/75,
9/3/75 and 10/20/75 to EPA, and of 7/23/75 and 1/15/76 to
the County). What are the environmental factors and impacts
associated with the alternatives of 1) not treating any
Trident wastes, 2) accepting only Trident waste volumes that
cannot be further reused or recycled, and 3) deep well disposal
or high rate land disposal of Trident wastes. Without
examining these alternatives a course of action contrary to
the preliminary Kitsap County Comprehensive Growth Plan
goals and objectives of encouraging recycyling of waste
water and solid waste will result. An initial question is
what discernible reduction of impacts (like cold shock or
fresh water impact for marine water quality or biota)
are associated with a reduction in discharge volumes?
EPA's failure to examine a reduced Trident waste load re-
sulting from reuse enable the Navy and EPA to not act as
trustees of the environment for future generations. For
whether ground water is available or not, unnecessary short
term use of water resources is contrary to this trustee
duty. The County's Facility Plan consultant told the Citizens
Advisory Committee on April 2, 1975 that the Plan must look
at "3) reuse of waste water." It does not; and your action
to enable the construction of a treatment plant at a capacity
which takes no account of volume reductions by reuse is
contrary to NEPA and applicable grant regulations. See 40
CFR 35.905-3. We ask that you include in your final EIS
information from the USGS re ground water availability and
from the Navy re reduced waste load volumes resulting from
reuse. This coordination procedure is mandated by the
policy requirements of NEPA.
How can the alternative of high rate land disposal be analyzed
without soil type information for the Bangor site? See B-2
of the Draft EIS Supplement.
These reuse alternatives all relate directly and immediately
to the need for the proposed facilities capacity.
IX-110
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Mr. Richard Thiel
Page 3
March 26, 1976
RELATIVE ENVIRONMENTAL EVALUATION
Page 1-6 of the draft EIS Supplement notes that the relative
environmental weightings should be viewed with caution. Why
is this so? What limits should be recognized as limiting
the reliance upon these numbers? Whet confidence level and
uncertainty is to be associated wit i -he relative weightings?
The Paramatrix report "Mathematical Mo lei of Three Port
Orchard System Outfall Sites" states a^ page 6 "Although
values have occasionally been recorded, Port Orchard and
Dyes Inlet lack sufficient profile data for the remaining
seasons." How does this deficiency affect the relative
weighting for marine water quality and aquatic biota impact
at the North Port Orchard disposal location?
We request a complete review and verification of the weightings
set out in Figure II-l. We suggest particular attention to
the Socio-Cultural Impacts for Alternative 11. We must
question the relative ranking of Alternatives 9 and 11,
particularly since the Facilities Plan notes that the North /
Port Orchard disposal site is almost one-third worse than *
the Manchester site. Should the environmental facts not be
given adequate weight or recognition in the decision making
process and the North Port Orchard site be chosen, what
further studies, mitigating measures and costs are necessary
to preclude violation of the non-degradation water quality
requirements and all adverse impacts greater than the en-
vironmentally preferable alternative?
TREATMENT PLANT IMPACTS
A high ground water table problem is identified at page II-3
of the draft EIS Supplement for the proposed treatment plant
site. What alternative treatment plant locations and con-
figurations are available to eliminate adverse operational
consequences, on the ground water quality such though caused
by accidental spills or material storage? Because of this
ground water problem, we ask that you review the "+50"
rating given in Figure II-l to the ground water quality
parameter for Alternative 11.
Page IV-7 makes certain comments regarding adverse impacts «
and mitigative measures for the pipeline routing used with
Alternative 11. What mitigating measures and associated
IX-111
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Mr. Richard Thiel
Page 4
March 26, 1976
costs will be employed to eliminate these impacts? Do the
cost figures reflect this? What mitigating measures, as-
sociated costs or pipeline routing alternatives are there
to protect the ravine, preclude soil erosion and water
turbidity violations, and minimize pipeline integrity problems.
(See page II-7 re the ravine and pages II-8 re turbidity
problems).
A reasonable alternative would be to have the Navy construct
and own the pipeline from Bangor down Clear Creek connecting
at Bucklin Hill Road. This would preclude the possibility
of non-Navy hookups in the Clear Creek area and eliminate
growth inducement. The Navy would then pay a portion of
capital costs for the pipeline across Bucklin Hill Road and
reduce the capital costs to Central Kitsap County citizens
and the bond principal. Can not the Navy pipeline construction
be effected in a manner so as to preclude adverse environmental
consequences? Political opposition is not a determinative
factor in ruling out an environmentally preferable alternative.
WATER QUALITY IMPACTS
At page 11-10, the draft EIS Supplement asserts that it is
the transport of clean dilution water across the diffuser
which controls the degree of initial dilution obtainable.
Assuming a reasonable amount of receiving water, it is the
jet momentum of the diffusers not the volume of dilution
water which controls the near field dilution phenomenon and
hence initial dilution. Similarly, on page 11-13 certain
assumptions are stated regarding the calculation of dilution.
As to the assumption that jet momentum will cause mixing in
the bottom one-half of the total mixing depth, to what
extent have the studies for diffuser site location accounted
for inadequate momentum resulting in discharges colder than
the receiving water laying on the bottom?
At page 11-11, the draft EIS Supplement states that the Port
Orchard UW model is accurate, although subject to some
limitations for some outfall locations. What are the limi-
tations for the North Port Orchard outfall and what uncertainty
do they cause in the conclusion that ambient water quality
will not be degraded? (See page 12, "Application of an
Ecological Model to Port Orchard, Sinclair Inlet, Dyes Inlet
I
H
IX-112
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Mr. Richard Thiel
Page 5
March 26, 1976
and Liberty Bay Subsystem of Port Orchard" by John R. Yearsley.)
If there are uncertainties, what mitigating measures and
engineering safeguards and associated costs will be employed I1
to insure that the ambient water quality will be maintained *^
and enhanced. What added studies will be required to confirm
the acceptability of North Port Orchard should it be selected?
(See particularly pages 12 and 13 of Yearsley's report cited
above).
Table II-3 confirms the inadequacy of the North Port Orchard
site. On the average 29% of the time the assumed desirable
dilution factor of 100:1 will not be met. For neap tides,
it won't be met 40% of the time. Should Port Orchard be
selected, what conditions in an NPDES permit pursuant to
Section 302 of the Federal Water Pollution Control Act
Amendments of 1972 9PL 92-500) would be appropriate?
How is the data in Table 11-13 for North Port Orchard related
to the determination by Parametrix that under the worst case
the predicted dilution at the periphery of the defined
dilution zone would only be 29.5 (see page 23, Parametrix
report) or about one-third of the desirable initial dilution
which is well inside the dilution zone boundaries? This
also casts strong doubt about the rating of "+50" for marine 4 ^
water quality impacts identified at page IV-27. There the •*•
initial dilutions, serving as a basis for the +50 rating,
were said to be in the range of 50:1 to 200:1. When the
dilution won't reach 100:1 about 40% of the time for neap
tide conditions, the rating of +50 appears unrealistic and
arbitrary. Analysis of all this dilution information also
suggests strong doubt about the value of the statement on
page 11-15 that a dilution of 5000:1 is probable — par-
ticularly when it then says this is only considered accurate
to an order of magnitude.
We also question the unconditional statement regarding the
UW study. As evidenced by comments in that study, even the
UW does not conclude as to North Port Orchard that significant
doubts do not exist. They note at page 28 (Final Report, An
Oceanographic Study of the Port Orchard System) that dye
transport into undesirable areas was evidenced. This includes
the Brownsville area. (See also page 73, Final Report; page
3 of Interim Report #1, and pages 10 and 11 of Interim
Report #3). What is the possibility of localized water
IX-113
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14
Mr. Richard Thiel
Page 6
March 26, 1976
quality violations due to such transport from the North Port
Orchard site; and how will they be mitigated? At page 42,
the slow flow past the North Port Orchard site is discussed.
At page 40, the report notes that tidal waters can receive
two slugs of discharge a day. To what extent will waste
buildup or reconcentration occur from the North Port Orchard
disposal? Will this occasion localized water quality degrada-
tion; and if so, how will it be eliminated?
The conclusion on page 11-17 that the studies do not support
the conclusion that Point Monroe is a superior site to North
Port Orchard is error. The UW study at page 146 specifically
concluded "Model observations showed that discharge of waste
into the main basin of Puget Sound is more desirable than
discharge into the Port Orchard System." The Parametrix
study, even though it examined a Point Monroe discharge
closer to shore than is desirable (see top of page 11-15,
draft EIS Supplement), uniformly demonstrates the superiority
of the Point Monroe site over the North Port Orchard site.
Even Figure II-l of the draft EIS Supplement affirms the
superiority as to physical impacts of the Point Monroe site.
This rationalization to support North Port Orchard should be
corrected to reflect study results.
DEMOGRAPHICS
How much of the estimated population (see page 11-25) will i t-
be located on the Trident base and in the service area to be •»•
served? How will the Navy's determination regarding on-
base housing policy affect the waste load?
PLANT CAPACITY
Page III-l indicates a revised design flow of 3.8 mgd. Is
2.0 mgd of that flow still due to Trident? How would Trident
water reuse affect the design capacity? What are the cost
and environmental impacts of such reduced capacity? What
are the costs for the reserve capacity of the treatment
plant facility; and how does the capacity of the plant 7*7
compare with the capacity of the sewer system? (See December
5, 1975 report by the General Accounting Office to the
Natural Resources Subcommittee of the House Government
Operations Committee re EPA Region III and V approved grant
applications).
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Mr. Richard Thiel
Page 7
March 26, 1976
SLUDGE DISPOSAL
Sludge generated by the treatment facility will in part
originate at the Trident federal facility. Regardless of
its processing off the base, this fact subjects the treatment
facilities sludge disposal to EPA's guidelines for the land
disposal of solid wastes. See 40 CFR § 241, particuarly §
241.100(d). Will the sludge disposal be in accordance with
these guidelines? What are the costs associated with these
requirements? Have the environmental factors regarding
sludge disposal in EPA's report "Disposal of Sewage Sludge
into a Sanitary Landfill" (Final Report (SW-71d) for Grant
No. 5801582, 1974) been reviewed and considered here?
COSTS
The total O&M costs are less expensive for Alternative 9
than for Alternative 11 (See page III-ll). These total costs
are those costs dependent upon the annual quantity of waste
water collected and treated. Fixed annual costs are set out
in Table III-4 under the column titled "Annual Amortization."
It is the combination of these total annual costs which
represent the annual total cost of the facility. See Appendix
A, paragraph f(3), 40 CFR § 35. And this total annual cost
is cheaper for Alternative 9 than for Alternative 11.
Annual Cost Alternative 9 Alternative 11
Total O&M $412,800 $457,600
Annual Amortization 114,300 80,900
Total $527,100 $538,500
Port Orchard is simply more expensive.
The costs for Alternatives 9 and 11 should be lower since it
appears that an artificially high interest rate figure of
7.5% was used. Current tax free municipal bonds are going
at lower rates. The interest rate set out in the Water
Resources Council's "Proposed Principles and Standards for
Planning Water and Related Land Resources" should be used
and the cost figures corrected.
IX-115
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Mr. Richard Thiel
Page 8
March 26, 1976
What is the basis for the Navy paying 40% of the capital
cost? What would the percentage be if the Navy were to hook
on to the pipeline at Bucklin Hill Road south of Clear
Creek? How was the Navy's 48.08% shares of O&M costs calculated?
Does the percentage depend upon the Navy's percentage of
total design flow, does it depend upon actual delivered
flows, and does it depend upon the strength of wastes delivered?
At pages V-13 and VI-1, comfort is apparently given to
citizens about any uncertainties in the North Port Orchard
alternative since the plant could always be upgraded or the
outfall could be extended to Point Monroe. This is rather
like buying insurance after the plane crash. What criteria
and procedures will be used to give advance warning that
this might be necessary? What added costs might reasonably
be associated with such future significant changes?
Even assuming no uncertainty, no adverse impact, no con-
servation of water, and that the draft EIS Supplement costs
are correct, Table III-4 indicates that each citizen of
Central Kitsap County served by the facility would only have
to pay 4.6 cents per month more for Alternative 9 than for
Alternative 11. A decision for Alternative 9 when such
small costs (well within the uncertainty of the cost estimates
and to be less if a realistic interest rate were used) are
involved would constitute an arbitrary and capricious disregard
of the environment. This is because an added cost of 4.6
cents per month is a reasonable method to mitigate and
eliminate the adverse environmental consequences of Alternative
11 which are significantly greater than Alternative 9. The
Facilities Plan indicates that North Port Orchard is about
30% worse environmentally than Manchester.
Yet the 4.6 cents per month differential may be reversed if
the costs of all reasonably required mitigative measures
(see pages IV-12, 26, 27, 31, for example) and added studies
(see page IV-15, for example) and other costs identified in
Appendix A, 40 CFR §35 are fully accounted for.
Sincerely yours,
HOUGHTON CLtfGK COUGHLIN X RILEY
s> ^{-€- 'y'-/&?i.
Joel Haggard-' /
JH:mn
cc: Mr. C. A. Ross
Honorable Frank Randall
Honorable John Merkel
IX-116
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Response to letter of 26 March 1976 from Mr. Joel Haggard
1. Collectors are not normally funded by EPA grants and are not included
as part of the proposed project. As collection systems are proposed
later they will be subject to separate environmental reviews. The
health benefits of providing these collectors have been demonstrated
years ago. The proposed project would take wastewater from these
collectors to a central treatment facility and discharge treated
effluent.
No adverse impacts were found in association with the site proposed
for the recommended plan. Configuration of buildings within the site
is not considered relevant to environmental impact in this case. No
significant adverse impacts were found in association with the outfall
pipeline routing.
2. Please see the response to comment No. 3 of your earlier letter, which
addresses the separate treatment of Trident wastes. As for deep well
injection, groundwater is of higher quality than marine waters by any
standard and is used as the major source of water supply in the study
area.
3. Our discussions with the U.S. Navy resulted in their assessment that
90 percent of their wastewater would be domestic sewage. This implies
that 90 percent of their water use is for domestic purposes. At this
time, wastewater reuse for domestic purposes is not acceptable within
this country. No potential industrial users of reclaimed wastewater
were found in the study area.
The availability of sufficient groundwater supplies in the study area
has been referenced in the Facilities Plan as a personal communication
with Mr. Arnold Hansen, a hydrologist with the U.S. Geological Survey
in Tacoma, Washington on 28 October 1975.
The attached chart presents the Navy's estimate of wastewater source
distribution on the Trident Support Site. The reuse of wastewater
from each facility was considered in the preparation of these estimates,
but no major reuse opportunities are forseen at this time.
4. Appendix I of the draft supplement EIS states that three soil types
found in the study area are suitable for land disposal of effluent;
they are Indianola loamy sand, Kitsap silt loam and undifferentiated
alluvial soils. Based upon Figure 5-3 of the Facilities Plan's tech-
nical report, the relative quantity of the desired soils in the con-
fines of the Trident Support Site is very low and inadequate for land
disposal. See also the response to comment No. 3 of your earlier letter.
IX-117