EIS770942F
0942F REGION 5
UNITED STATES 230 S. DEARBORN ST.
ENVIRONMENTAL PROTECTION AGENCY CHICAGO. ILLINOIS 60604 MAY 1977
ENVIRONMENTAL FINAL
IMPACT STATEMENT
Organic Solids Reuse Plan
Madison Metropolitan Sewerage District,
Dane County, Wisconsin
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EIS770942F
FINAL ENVIPONfENTAL IMPACT STATEMENT
ORGANIC SOLIDS REUSE PLAN
PROPOSED BY
THE MADISON METROPOLITAN SEWERAGE DISTRICT
Prepared By The
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
CHICAGO, ILLINOIS
APPROVED BY:
7
GEORGE R. ALEXANDER, JR.
c REGIONAL ADMINISTRATOR
MAY 1977
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TABLE OF CONTENTS
Part I
Summary Sheet i
I. Background
A. Existing Water Quality Facilities and Agencies
B. Existing Problems
1. Background 1-1
2. History of the Sludge Disposal Program 1-1
C. Proposed Solution 1-2
II. Existing Environment
A. Natural Environment
1. Atmosphere
Temperature, Precipitation, Snowfall, Winds 2-1
Severe climatological events 2-1
2. Land
Topography 2-1
Geology 2-1
Soils 2-3
Wetlands and Water/Land Interfaces 2-3
3. Water
Water Quantity and Location 2-4
Water Quality 2-4
4. Natural Vegetation and Wildlife
Habitat 2-4
Wildlife 2-5
5. Sensitive Natural Areas 2-8
B. Man-made Environment
1. Air
Air Quality 2-8
Noise 2-8
Odor 2-15
2. Land Use
Existing Land Uses 2-15
Proposed Land Uses and Development Trends 2-20
3. Water Quality and Quantity
Problem 2-21
Uses 2-21
Management 2-21
4. Summary of Sensitive Man-made Resources
Historical and Archeological Sites 2-21
Recreation and Open Space Areas 2-27
Agricultural Land 2-27
Energy Resources 2-27
III. Alternatives to the Proposed Project
Summary of Alternatives 3-1
EPA Review of the Plan and Environmental Assessment 3-1
A. Lagoon Abandonment Program Alternatives 3-2
B. Future Sludge Handling and Disposal Alternatives 3-2
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(Con't.) TABLE OF CONTENTS
1. Greeley and Hansen Reports 3-2
2. Westen Report 3-3
Land Application of Sludge 3-3
Sanitary landfill of Sludge/Milled Refuse Mixture 3-3
Land Application of Compost 3-3
Sludge Treatment Alernatives Considered in the
Weston Report 3-4
3. MMSD Addendum 3-4
Alternative lA-Land Trenching of Dewatered Sludge 3-5
Alternative 2A-Land Application of Liquid Sludge 3-6
Alternative 3A-Landfilling of Sludge/Milled Refuse
Mixture 3-7
Alternative 3B-Land Application of Dewatered Sludge 3-8
4. CH2M Hill Study 3-9
5. Reuse Level Alternatives 3-9
6. Reuse Program Alternatives 3-9
7. Transportation Method Alternatives 3-9
8. Intermediate Storage Facility AlteTffiPSTT&i 3-9
9. Application Method Alternatives 3-10
10. No Action Alternative 3-10
11. Other Considerations in Developing the Proposed Plan 3-10
IV. Description of the Proposed Actions
Summary of the Proposed Actions 4-1
EPA Review of the Plan and Environmental Assessment 4-1
A. Sludge Treatment Facilities 4-1
1. Gravity Sludge Thickener Improvements 4-1
2. Dissolved Air Flotation Thickeners 4-1
3. Sludge Digester Improvements 4-1
B. Cost of the Organic Solids Reuse Program 4-2
C. Lagoon Dike Rehabilitation 4-2
D. Lagoon Abandonment 4-3
V. Environmental Effects of the Proposed Actions
Sumnary of Significant Environmental Impacts 5-1
EPA Review of Plan and Environmental Assessment 5-1
A. Sludge Lagoon Abandonment Program 5-2
B. Construction and Operation of Expanded Solids
Treatment Facilities 5-4
C. Construction of Solids Handling Facilities 5-5
D. Operation of the Organic Solids Reuse Program 5-5
1. Seasonal Sludge Storage in an Existing Lagoon 5-5
2. Sludge Transfer and Intermediate Storage 5-5
3. Sludge Application to Privately-owned
Agricultural Land 5-6
a. General Discussion 5-6
b. Issues Not Considered in the Facilities
Plan or Environmental Assessment or
Which Require Further Discussion 5-6
PO3 Monitoring 5-6
Nitrogen 5-7
Heavy Metal Considerations-Cadmium 5-7
Economic Effects 5-8
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(Con't.) TABLE OF CONTENTS
Effect on Endangered or Threatened Species 5-8
Effect on Soil Structure 5-8
Soil Conservation Practices 5-8
VI. Relationship Between Local Short-Term Uses of Man's
Environment and the Maintenance and Enhancement of
Long-Term Productivity
A. Water Quality 6-1
B. Open Space 6-1
C. Long Term Productivity of Application Site Soils 6-1
VII. Federal/State Agency and Public Participation
A. Facilities Planning Advisory Committee 7-1
B. Public Information Meetings 7-1
C. Final Public Hearing Held by Applicant 7-2
D. Hearing on Draft Environmental Impact Statement 7-3
E. Correspondence Received Related to the Draft EIS 7-4
Appendices
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LIST OF TABLES
Chapter 2
Table
2-1 Climatological Data, Madison, Wisconsin 2-2
2-2 Dane County, Natural Areas and Areas of
Scientific Interest 2-9-12
2-3 Rock County, Natural Arecir, ind Areas of
Scientific Interest 2-13-14
2-4 Industrial Point Source of Pollution,
Lower Rock River Basin 2-24-26
LIST OF FIGURES
Chapter 2
Figure Page
2-1 2-6
2-2 2-7
2-3 2-16
2-4 2-17
2-5 2-18
2-6 2-19
2-22
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SUMMARY SHEET
( ) Draft
(X) Final
U.S. Environmental Protection Agency Region V, Chicago
1. (X) Administrative Action
( ) Legislative Action
2. Description of the Action
The analysis of alternatives indicates that the sludge manacr-ment needs of
the Madison Metropolitan Sewerage District service area would most adequately be
met by abandoning the present system of lagoon disposal of liquid anaercbically
digested sludge and adopting a system of land disposal of liquid anaerobically
digested sludge on privately-owned agricultural land. The program would involve
marketing the sludge to farmers at their request.
3. Environmental Impact
a. Water
The abandonment of lagoon disposal of sludge at Nine Springs sewage treatment
plant will eliminate the threat of lagoon dike failure and resultant toxic spills
of the lagoon contents into Nine Springs Creek and the adjacent wetlands. As long
as the proposed land disposal program is strictly managed and operated as planned,
there will be no significant effect on water quality and quantity.
b. Air Quality
As long as the precautions related to sludge hauling and application which have
been outlined in the facilities plan and environmental assessment are taken, potential
odor problems will be minimized. Significant odor-producing sludge treatment processes
will be abandoned or modified by this plan so that odor problems will be minimized.
Dust generated from construction of solids treatment and handling facilities will
cause a temporary change in ambient conditions.
c. Land Use
The only significant effect on land use which is expected to result from the
proposed plan is the beneficial one which is the eventual return of the abandoned
sludge lagoons to a wetland condition.
d. Soils and Biota
The soil fertilizer value of the sludge will improve the fertility of the soils
on which sludge is applied while reducing the quantities of expensive commercial
fertilizers which must be used. Possible impacts on the soils and plant and animal
life of the study area could result from the build-up of materials contained in the
sludge to levels which may be toxic to normal life functions. This potential effect
will be minimized because MMSD's plan proposes to limit annual application rates and
total allowable loadings to levels which would provide for protection of the soils
and plant and animal life of the area while at the same time obtaining the maximum
soil amendment value to be gained from land application of the sludge.
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Cadmium levels and the ratio of cadmium to zinc in MMSD sludge are higher than
the United States Department of Agriculture would recomnend for sludge being applied
to privately-owned land. MMSD's conservative application rates and their proposed
cadmium source control pronrair should minimize the potential for build-up of
cadmium to toxic levels.
e< General Concern
Since the potential adverse impacts of MMSD's proposed organic solids reuse
plan can be minimized or avoided only if MMSD's proposed management and marketing
programs are strictly carried out, it is imperative that MMSD strictly adhere to
their plan.
4. Alternatives Considered
a) Lagoon Abandonment Alternatives
Treatment plant sludge
continue discharge to existing lagoons
or discontinue discharge and build new lagoons
Lagoon sludge
remove and apply to farmland
or leave in lagoons
Lagoon supernatant
remove and return to treatment plant
or leave in lagoons
Lagoons dikes
stabilize and maintain
leave as they are
b) Ultimate Disposal Alternatives
1) Land application of dewatered sludge;
2) Land application of liquid digested sludge;
3) Land application of compost;
4) Landfill of sludge/milled refuse mixture;
5) Landfill of digested sludge;
6) Subsurface placement of sludge;
7) Incinerate raw sludge;
8) Incinerate digested sludge;
9) Lagoon storage - NO ACTION ALTERNATIVE.
c) Transportation Method Alternatives
1) Rail transport;
2) Truck transport;
3) Pienline transport.
d) Application Method Alternatives
1) Sprinkler gun;
2) Subsurface injection;
3} Truck or tractor drawn spreader.
e) Sludge Reuse Program Alternatives
1) Sludge supplied by MMSD at fanner's request;
2) MMSD leases privately-owned land for sludge application;
3) Combination of 1) and 2).
ii
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5. Irreversible and Irretrievable Commitment of Resources
By the implementation of the proposed actions the only irreversible and irre-
trievable commitment of resources would be for the capital, labor and energy used
in the construction of the facilities and the operation and maintenance costs of
the entire program.
6. Federal, State, and Local Agencies and Individuals who Commented on the Draft
EIS for this Project
Federal
United States Department of Agriculture
Soil Conservation Service
United States Department of Interior
State
Wisconsin Department of Natural Resources
State Historical Spciety of Wisconsin
Local
Dane County Regional Planning Commission
Holtzman Company
7. Dates
Statement made available to: Draft Final
The Council on Environmental Quality October 1976 May 1977
The Public October 1976 May 1977
111
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CHAPTER 1
BACKGROUND
A. Existing Water_Quality Facilities and Agencies
The Madison Metropolitan Sewerage District (MMSD) which was organized under
Wisconsin Statutes in 1930 is a metropolitan sewerage district with the
responsibility for the transmission, treatment and discharge of wastewaters
from the City of Madison, Wisconsin and its surrounding areas. The MMSD
presently serves a total of three cities, five villages and twenty-six
municipal customers located within ten townships. The MMSD includes approxi-
mately 142 square miles and is located entirely within Dane County.
The 36.5 MGD of wastewaters currently generated within the District receives
secondary treatment at the Nine Springs Sewage Treatment Plant which is
located on the southern edge of the City of Madison.
B. Existing Problem
1. Background
On December 31, 1975, MMSD was awarded a Step 1 Grant (Grant No. C550826-01,-02)
from this agency to prepare a facilities plan which would meet the requirements
of Wisconsin Pollutant Discharge Permit No. WI-0025411. The facilities plan was
to include documentation to determine the cost-effective construction of advanced
waste treatment facilities and disposal of the effluent, and handling and disposal
of sludge from the treatment facilities.
In July 1975 the facilities planning effort was segmented into two portions,
1) advanced waste treatment and effluent discharge (Grant No. C550826-01) and solids
2) handling and disposal (Grant No. C550826-02). This segmentation was done because
of the need to expedite the solids handling portion of the study.
This EIS covers only the segment of MMSD's overall facilities planning effort
concerned with solids handling and disposal. Advanced waste treatment and effluent
discharge issues will be considered in a separate EIS.
When the draft EIS for this project was distributed for comment, it was accompanied
by a second volume which was comprised of MMSD's facilities plan and environmental
assessment for the project. This second volume has not been revised as part of the
Final EIS. Comments related to it have been addressed in Chapter 7 of the Final EIS.
If additional copies of the volume with MMSD's plan and assessment are required, they
can be obtained from Region V, Planning Branch, EIS Preparation Section.
2. History of the Sludge Disposal Program
Since the Nine Springs Wastewater Treatment Plant was put into operation in
the early 1930"s the problem of disposing of the sludge produced during wastewater
treatment has been present. From the 1930's until 1942, the sludge produced was
dried on sand beds and utilized as a fertilizer for lawns, gardens, and flower beds.
Small amounts were ground and bagged. With the outbreak of World War II the manpower
required to operate and maintain this system was no longer available.
1-1
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In 1942, Lagoon 1 was constructed and the sludge produced at the plant was
diverted to it for storage. This lagoon has been in continuous use since that
time. As the capacity of the original lagoon was reached, a second lagoon
(Lagoon 2) was constructed immediately to the east of Lagoon 1 in 1968. The
total lagoon area is approximately 145 acres.
In April 1970, portions of the dike of Lagoon 2 failed, allowing lagoon
supernatant to flow into Nine Springs Creek and then into the Yahara River
just upstream of Lake Waubesa. An additional dike failure occurred in November
1973, but spillage was negligible at that time. As a result of the first failure,
MMSD paid $20,000 in damages and entered into an agreement with VvDNR stipulating
that an alternative method of sludge disposal was to be implemented by MMSD as
soon as practicable.
A number of studies were then initiated which investigated the alternatives for
sludge disposal and the stability of the lagoon dikes. A major finding of these
reports (Warzyn Engineering and Service Co., Inc., 1970; CH2M-FH11 Engineers, Inc.,
1975) concluded that the dikes of Lagoon 2 were quite unstable and were subject
to probable failures in the future. Other reports (Greeley and Hansen Engineers,
1971; Roy F. Weston, Inc., 1974) evaluated and concluded that sludge reduction
and disposal methods such as incineration, heat treating, mechanical dewatering
and landfill ing were either economically or technically not feasible. The staff
of MMSD prepared an addendum to the Weston report evaluating other sludge handling
and disposal alternatives not considered in the Weston Report. For a number of
reasons, including the physical and chemical characteristics of the MMSD sludge
and high energy requirements, these methods were eliminated from further consider-
ation. The recommended method of sludge disposal was land application of the sludge
to utilize its nutrient value as a fertilizer substitute.
The sludge disposal portion of the facilities plan has evaluated the various
methods presently available to implement a land application program. Consideration
was given to the factors necessary to develop site location and management, environ-
mental factors and program costs. In addition, various methods of sludge treatment
have also been considered. Also, several lagoon abandonment options were evaluated.
The proposed plan will have the positive benefits of being an effective economical
sludge disposal method which realizes the natural resource value of sludge by
recycling the nutrients, water, and organic matter which it contains. Compared
to some other disposal methods such as landfilling and incineration the proposed
plan has added benefits such as minimizing air pollution. Also the range of
potential uses of the land application area after use for sludge disposal will
not be permanently affected as in some other methods. Other benefits of MMSD's
proposed plan include the elimination of lagoon-dike failure which resulted in
toxic spills into Nine Springs Creek and adjacent wetlands. The expansion and
modification of the sludge treatment facilities will eliminate odor problems
which some of the processes have previously contributed to.
3. Proposed Solution
MMSD proposes to abandon the present program of lagoon disposal of liquid
anaerobically digested sludge and to pursue a program of land application of liquid
anaerobically digested sludge to privately-owned agricultural land. The program
involves marketing the sludge to farmers for its fertilizer and soil amendment value
at their request. The total present-worth cost of the organic solids reuse proaram
is $14,949,000. The applicant is requesting $3,833,000 in Federal and $256,000*in
state grants to fund the project. MMSD's portion of the cost is expected to be
approximately $10,860,000 which represent the operation and maintenance costs and
their share of the construction costs. The Federal and state grant amounts cited
above are tentative in that it remains to be determined by Region V, USEPA and
the State of Wisconsin which costs are actually grant eligible.
1-2
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CHAPTER 2
EXISTING ENVIRONMENT
A. Natural Environment
1. Atmosphere (Climate)
Chapter 6 of the facilities plan and Section 2 of the environmental
assessment present an adequate summary of climatological conditions in the study
area. Some additional information is provided to supplement these sections.
The main source of this supplemental information is the environmental inventory
for the project prepared by the applicant and its consultants.
Temperature, Precipitationy Snowfall, Winds
Table 2-1 is presented to provide a summary of temperature, precipitation,
snowfall and winds data for Madison, Wisconsin.
Severe Climatological Events
No additional information is necessary.
2. Land
Topography
Section 2.03 of the assessment is an adequate summary of topography. The
following information has been extracted from the environmental inventory for the
plan to supplement the discussion of drainage basins.
"There are numerous lakes and wetland areas found in central
and eastern Dane and Rock Counties (WENR, 1970, 1976). The
Yahara River flows generally southwestward to the Rock River,
closely following its pre-glacial course. Partial damming
of the river valley with moraine left by the receding glaciers
has resulted in the formation of the Madison Lakes (Mendota,
Monona, Wingra, Waubesa, and Kegonsa). There are numerous
wetland areas adjacent to the Yahara River.
"The Rock River also closely follows its pre-glacial course,
flowing generally southward from its headwaters in Dodge County
through Jefferson and Rock Counties. The two major impoundments
on the Rock River, Lakes Koshkonong and Sinissippi were formerly
marsh areas which have been turned into shallow lakes by the
placement of dams across the river channel.
Geology
Section 6.1 of the facilities plan and Section 2.04 of the environmental
assessment provide an adequate discussion of the geology of the project area
and how the geology influences surface and ground water resources.
2-1
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Soils
Sections 6.3 and 6.5 and Figure 6-4 (general soil map) of the facilities plan
and Section 2.05 and Table 2-2 of the environmental assessment present sufficient
information related to soils. Section 6.3 discusses soils from the standpoint of
suitability for sludge application. Figure 6-4, Section 6.5, Section 2.05 and
Table 2-2 provide a display and discussion of the location and characteristics of
various soil types. The information presented is of necessity of a general nature.
More detailed soils series data would be required for detailed agricultural manage-
ment or construction design work when specific project sites are under consideration.
Wetlands and Water/Land Interfaces
Section 2.10 B of the environmental assessment presents a summary of wetlands
in the study area. The environmental inventory for the study lists 16 priority,
No. 1, 19 priority No. 2, and 12 priority No. 3 wetland areas in Dane County and
their location and importance. However, the acreage of each area is not listed.
Figure 6-4 in the facilities plan shows the general location of wetlands within
the study area. The various wetland priority types are not distinguished on the
figure. The wetlands shown on the figure fall primarily within the areas designated
as "few of the soils suitable for application" or secondarily within the areas
designated as "some soils suitable for sludge application".
Of the Priority No. 2 wetlands listed in the inventory there is one area which
would potentially be impacted on by this project since it is within the vicinity
of the Nine Springs Sewage treatment plant site. Priority No. 2 wetlands were
those which were considered to have a biologically good rating with other values.
The Priority No. 2 wetlands listed is Upper Tiud Lake in Blooming Grove Township,
Sections 28, 29, 30, 32. This wetland is considered to have value for diverse
vegetation, animal life, bird life, recreation, and watershed protection. There
is also a Priority No. 3 wetlands area which could potentially be affected by the
project. Priority No. 3 wetlands were those which were considered to have a
biologically fair rating or poor biological rating with other values. The Priority
No. 3 wetlands listed is Nine Springs wetlands in Blooming Grove Township, Sections
31 and 32 and Fitchburg Township, Sections 12, 3, and 10. This wetland is considered
to have value for diverse vegetation and watershed protection.
A further discussion of these wetlands is included in subsequent sections of
Chapter 2.
Related to flood hazards, the environmental setting description, Section 2.03
and Table 2-3 include flow value data/ however, no discussion is presented on flood
hazard areas. Section 2.06 of the environmental inventory for the facilities plan
does indicate that in respect to flooding in the lower Rock River basin (includes
Yahara River basin):
"Flood flows are relatively low due to the small relief of the basin, as well
as the storage capacity provided by the many lakes, reservoirs and wetlands.
Flooding in headwater areas is generally limited to low-lying agricultural or
undeveloped land adjoining waterways, although some springtime flooding of low-lying
residences near the Madison Lake and Lake Koshkonong does occur. Substantive flood
potential does exist in the cities of Janesville and Beloit where commercial and
residential construction has taken place on the floodplain."
2-3
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3. Water
Water Quantity and Location
Section 6 of the facilities plan and Section 2.06 of the environmental assessment
provide an adequate discussion of ground water resources.
The discussion of surface water quantity in Section 2.06 of the environmental
assessment is sufficient.
Water Quality
Section 6 of the facilities plan and Section 2.06 of the environmental assess-
ment present sufficient information on groundwater quality. Section 2.6 and Table
2-4 of the environmental assessment adequately summarize surface water quality
conditions. Additional monitoring information is included in backup appendices to
the facilities plan. They have not been included because of their voluminous nature.
As a point of clarification, Table 2-4 presents two sets of monitoring data. The
1955-1958 data was for a period prior to MMSD's diversion of their effluent into
Badfish Creek. The 1972-1975 data is post-diversion.
4. Natural Vegetation and Wildlife
Habitat
Section 2.07 I of the environmental assessment is a summary of existing vegeta-
tion in the study area. Some clarification and supplementation of this section is
necessary. Additional species information is included in backup appendices to the
facilities plan.
One plant species which possibly occurs within the study area has been included
as a proposed endangered species on the proposed list of "Endangered and Threatened
Plant Species of the United States" published in the Federal Register on June 16,
1976. Lespedeza leptostachya (bushclover) is expected to occur on dry prairies in
the study area.
Related to the discussions of aquatic vegetation some clarification is required.
The discussion refers to an Appendix D which was described as including the results
of an algal survey of Badfish Creek. This appendix was not, however, attached to
the environmental assessment. The survey referred to was a survey of fish and algae
of the Badfish Creek (main stem and and Rutland Branch) and Yahara River conducted
in 1975 by John Magnuson and Gary Herbst from the University of Wisconsin. From
their survey of fish and algae they concluded that:
1) in relation to Badfish Creek a) Badfish Creek is most severely polluted
upstream of Cooksville, b) limited recovery occurs in the lower regions of the
stream, c) water quality of Badfish Creek is inferior to both the Rutland Branch
and the Yahara River;
2) the fish found in the Yahara River appear unaffected by Badfish Creek;
3) diatom species abundance and diversity in the Yahara River is reduced down-
stream of the mouth of Badfish Creek (indicating therefore, that the algal flora of
the Yahara River is influenced by the Badfish Creek);
4) the Rutland Branch (of the Badf ish Creek) is a pristine stream;
5) further detailed investigations of the fish fauna are warranted.
2-4
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One area of special concern which could potentially be affected by this
project either positively or negatively is Nine Springs Creek and adjacent
wetlands which are in proximity to the Nine Springs Sewage Treatment Plant
with its sludge lagoons. In 1970 and 1973 sludge lagoon dike failures occurred
which resulted in toxic spills of lagoon contents into Nine Springs Creek and
then into the Yahara River. As can be seen on Figure 2-1 the creek has been
channelized in the vicinity of the lagoons. It flows around the south and
east perimeters of the sludge lagoons and then through the wetlands out to the
Yahara River, the plant cover mapping shown on Figure 2-2 was done in 1973 by
the Wisconsin Department of Natural Resources as part of a study of the Upper
Mud Lake wetlands. The wetlands cover about 800-900 acres and can be described
as a sedge meadow. The area has been ditched. It is shrubby at one end with
cattails at the other. The vegetation consists of diverse sedges, cattails,
and other species. See Figure 2-2 for more detailed species information.
Wildlife is prevalent and consists of a variety of shore birds, nesting birds,
and small mammals. The area beyond the perimeter of the sedge meadow consists
of Lake Waubesa and farmland while more intense development lies to the west.
Wildlife is still prevalent in the surrounding agricultural land, more so
than in the developing areas bordering the plant site to the west.
Wildlife
Section 2.07 of the environmental assessment summarizes wildlife in the study
area. Additional backup information is included in the environmental inventory
to the facilities plan. However that information is voluminous in nature and has
therefore not been reproduced in this report. Section 2.07 is adequate with some
clarification and supplementation. Section 2.07 F refers to Appendix E and Section
2.07 G refers to Appendix D. Those appendices were not attached to the environmental
assessment. However, they are included as backup information to the comprehensive
facilities plan.
The investigation of the macroinvertebrate found of Badfish Creek referred to
in Section 2.07 F of the environmental assessment was completed by William L.
Hilsenhoff and Thomas S. Karl of the Department of Entomology, University of
Wisconsin, Madison in 1975. Their conclusions were that:
1. Effluent from the Madison Metropolitan Sewerage District's
treatment plant has severely altered the macroinvertebrate
fauna of Badfish Creek. This fauna in 1975 was characteristic
of that which is normally found in moderately large streams
severely polluted by organic wastes.
2. Faunal alteration was caused by a greatly increased volume
of water flowing through the stream and by increased nutrient
and BOD loads. The BOD creates a depression of dissolved
oxygen levels, especially in the summer, which severely
restricts the macroinvertebrate fauna that can exist in
Badfish Creek. The increased nutrient loads that promote
abnormal amounts of plant growth and abnormally high
concentrations of certain ions may also be contributing
factors in limiting the fauna.
3. Faunal alteration is most severe in the upstream areas of Badfish
Creek, with some indications of recovery in downstream sections.
4. The macroinvertebrate fauna of the Yahara River was distinctly
altered by waters from Badfish Creek during spring and early
summer of 1975, but in late summer and fall alteration of
the fauna was insignificant.
2-5
-------
FIGURE 2-1
*BASE MAP OF THE NINE SPRINGS
SEWAGE TREATMENT PLANT AREA
racted from Volume II of Madison Metropolitan
erage District's Facilities Plan and Adapted
Use in this Report.
-------
Mud Lake Marsh
South Madison Belt Line
WISCONSIN DEPARTMENT OF NATURAL RESOURCES
COVER MAPPED
BY
ARLYN F. LINOE
GROUND CHECKS COMPLETED IN FEBRUARY AND MARCH, 1971
LEGEND
ALDER IALNUS RUCOSAI
ASTER (ASTER SPP)
BLACK CHERRY 1PRUNUS SEROTINAI
SLUEJOINT GRASS (CALAMAGROSTIS CANAPE
3UR REED I5PAR6ANIUM EURYCARPUM)
BOX ELDER (ACER NECUNOOI
CANARY GRASS IPHALARIS ARUNOINACEAI
ELDERBERRY ISAUBUCUS CAHADiHSIS)
GOLOENROD ISOLIDACO SPP)
GRASSES. MIXED IC.RAMINEAE)
HICKORY, SHAGBARK (CARYA OVATAI
HONEYSUCKLE (LONICERA SPP)
NETTLE, STINGING IURTICA QIOlM
OAK (QUERCUS bPPI
REED GRASS IPHRACMITES COMMUNISI
RED OSIER DOGWOOD ICORNUS STOLONIFERAI
ROUND STEM BULLRUSH ISCIRPUS SPP)
SEDGE ICAREX SPP)
SUMAC. STAGHORN 1KHUS TYPHIMAl
SWEET CLOVER IMELILOTUS SPP)
TAMARACK (SCATTERED) ILARIX LARICINAI
CATTAIL tTVPHA SPP)
WILLOW ISALIX SPP)
WHITE SNAKEROOT (EUPATORIUM RUGOSUM)
ASPEN AND COTTONWOOO IPOPULUS SPP)
ALD
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su
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I
USE OF LETTER SYMBOLS TO DESIGNATE VEGETATION PATTERNS
l\ THIS (,ASL CANARV (,RASS ^N) IS OOMINENT AND NO OTHER SPEUES IS
PRLSLNT Vi'MCH \'.OLLD PROVIDL MORE THAN 10 PERCENT L.ROUMJ LOVLH IN
Tl L h'AI TLKN
b'lMiJOL AbOVL AND ONt t.ELO\\ A HORIZONTAL EAR AS
S>MROL AL;OVL THE BAR OLSIC.NATES THE OOMINENT SPECIES PRESENT I
AND SYMBOL BELOrt iBJ) OESILNATt& A SPECIES V\H1CH PROVIDES MORE
THAN j Q PERUNT GROUND (.OVER IN THE PATTERN
iin Department of Natuisl Resources
-------
Table 2-6 in the environmental assessment is taken after "Surface Water Resources
of Dane County", 1961, WDNR, "Surface Water Resources of Rock County", 1970, WENR
and "Wisconsin Mapped Lakes", Clarkson Map Company. More recent sampling was com-
pleted for Badf ish Creek and the Yahara River in 1975 by John Magnuson and Gary
Herbst from the University of Wisconsin. That survey showed additional species
existing in the Yahara River such as bluegill, crappie, and white bass. Their
Badfish Creek survey data show some trout and bluegills living there in addition
to those shown on the table. Refer back to the section on habitat for a discussion
of the general conclusions of their study.
Nine Springs Creek in the vicinity of the Nine Springs Sewage Treatment sludge
lagoons is channnelized. Fish sampling data for Nine Springs Creek close to Nine
Springs Sewage Treatment Plant is not available. However, the Department of
Natural Resources conducted a fish sampling program upstream of Nine Springs
Sewage Treatment Plant in the suirmer and fall of 1972 and 1973 using shocker gear
pulled up the creek. The 29 species of fish sampled there should represent some
of the fishes from the Yahara River and up through the wetland areas around the
treatment plant since the fish move freely up the creek from the river. A list
of the fish species sampled at the upstream location can be found in Appendix D.
5. Sensitive Natural Areas
Section 2.10 of the environmental assessment summarizes sensitive natural areas.
As indicated in this section there are many sensitive natural areas and areas of
scientific interest within the project area which should be given special considera-
tion when planning any specific project action. Tables 2-2 and 2-3 have been
extracted from the environmental inventory for the study and are included here
to provide additional information on sensitive areas which should be protected.
Of these areas listed on Tables 2-2 and 2-3 there is only one site which
could potentially be impacted by this project. It is listed as Upper Mud Lake
wetlands. The lagoons of Nine Springs Sewage Treatment Plant are located on the
easterly edge of an extensive grass-sedge marsh area known as Nine Springs Marsh
and portions of which are referred to as Upper Mud Lake wetlands. These wetlands
occupy 800-900 acres and lie within Blooming Grove Township, Sections 28, 29, 30,
31 and 32.
B. Man-made Environment
!• Air
Air Quality
Section 2.08 of the environmental assessment is an adequate discussion of
air quality.
Noise
There has been no discussion of noise levels in the project area in the
environmental assessment. In 1970, the Madison Standard Metropolitan Statistical
Area (SMSA) had registrations of 494 motor vehicles per 1000 population and 16
motor cycles per 1000 population.A recent USEPA publication used this index
of vehicle registration as an index of noise population with the Madison SMSA
ranking 19th and 37th lowest, respectively, for these two categories among 83
SMSA's with population between 200,000 and 500,000. In both cases Madison ranked
in the quieter half of those towns of its size surveyed. This kind of an analysis
could be somewhat misleading considering the study area includes both urban and
rural areas which would by their nature have different noise sources and levels.
However, no better information is available.
2-8
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Odor
The environmental assessment does not present an adequate picture
of potential odor problems created by the proposed project and how they should
be mitigated. Since the majority of the project area is agricultural land, it
would be expected that the types of odor sources in these areas would be typical
of agricultural areas. In addition, Nine Springs Sewage Treatment Plant has been
reported as an odor source to the Wisconsin Department of Natural Resources; however,
no action orders have been issued to MMSD. Processes such as the trickling filters
and grit dump in the lagoon were significant odor producers in the past. The
potential for odor problems would be minimized or eliminated by implementation
of the facilities plan proposed by MMSD since these processes will be abandoned
or modified as part of the plan.
2. Land Use
Existing Land Uses
Section 6.1 and 6.5 and Figure 6.5 of the facilities plan and Section 2.09 and
Table 2-10 of the environmental assessment present a general summary of existing
land uses. Figure 6.5 shows the types of areas which have uses incompatible with
an agricultural reuse plan and should therefore be avoided. Some correction and
supplementation of these sections is needed.
Two corrections of the text of Section 2.09 of the assessment should be noted.
The figure 345,715 given for the population in the MMSD planning area in the year
2000 should be 299,643. The figure 2,040 acres given for the amount of additional
acres of land for development (commercial, residential, and manufacturing) demanded
by the year 2000 should be changed to 4,049 acres of additional land. (Personal
communication with O'Brien and Gere Engineers staff).
Land use around the existing plant and sludge lagoon site was one item not
discussed in the environmental assessment. It should have been at least briefly
considered in this portion of the plan since this plan proposes a modification
of the existing sludge lagoon use and expansion of sludge treatment facilities.
The following information was taken from a portion of the advanced waste treat-
ment and discharge segment of the facilities plan related to plant siting.
"The plant site is bound on the northeast, east, and southeast by
undeveloped property. (Refer to Figures 2-1, and 2-3). On the east
side is a wetland, in public ownership, of 800-900 acres. (Refer to
Figures 2-4 and 2-5). Industrially-zoned property to the northeast
can be expected to develop in the future, while land to the east and
southeast has limited development potential. Property immediately
south of the plant is a mobile home subdivision. The area farther
south and to the southeast is under cultivation. An undeveloped parcel
of land lies immediately west of the plant, with an apartment complex
and residential subdivisions beyond to the west. Land to the northwest
is undeveloped, and an industrial complex lies to the north."
"Zoning ordinances are administered by the respective jurisdic-
tions within the vicinity of the plant and sludge lagoons; the
City of Madison, the City of Monona, and Dane County. Land
adjoining the treatment plant on the north is zoned industrial;
the lands to the west are zoned manufacturing, agricultural,
conservancy, and residential. The areas to the east and south
of the plant are zoned manufacturing, agricultural and planned
residential development." Refer to Figure 2-6.
2-15
-------
Lake Mon
-------
Lake Monona
-------
'"'•A?*! ^> '•*»
:«Hte«>
-------
"Existing zoning is compatible with the present operation of the
Nine Springs plant, but a mix of uses, including residential,
has developed near the plant. Any nearby residential development
can be considered a potential source of opposition to the further
expansion of the plant."
Proposed Land Uses and Development Trends
The facilities plan and environmental assessment include only a minimal amount
of discussion of proposed land uses and development trends for either the plan
area in general or for the vicinity of the treatment plant and sludge lagoons
specifically. To provide a better picture of future land use and development
trends for the general study area the following information was extracted from
the environmental inventory for the study.
"Definite statements cannot be made regarding future land
use trends. The lack of strong, uniform land use planning
implementation programs (personal communication, Mary Louise
Symon, Dane County Board Chairman), and uncertain factors such
as future birth rates and economic development, prohibit a
clear estimation of future land use requirements. There is
also no assurance that the trends noted in the past decade are
indicative of long range land use patterns. However, based on
the data available for the 1964 to 1973 period, some general
land use trends seem apparent.
"Agricultural land use will probably continue to decline for
a number of reasons. Increased production per acre of farm
land will probably require that less land will be needed to
produce the crops needed to feed increased future populations.
Also, present economic conditions have led to a decreasing
number of farms in operation.
"Dane County farms have decreased only slightly from 3,950 in
1972 to 3,940 in 1973, while the total land area has remained
constant at 660,600 acres (Wisconsin Legislative Bureau, 1975).
"These figures all indicate a steady decline in both the total
number of farms in operation and in the total number of acres
devoted to agricultural practices on a state wide basis. Dane
and Rock Counties do not seem to be affected as greatly.
"Population increases will require that additional lands be
developed for housing, commercial establishments, services,
utilities, etc. It is also anticipated that increased demand
for recreation facilities will result in an increase of acreage
devoted to this purpose."
One of the assumptions made by Dane County Regional Planning Commission in pre-
paring their forecasts for area socioeconomic development is that an increasing
proportion of future population increases will be located outside the Central
Madison) Urban Services Area.
Related to land use plans and zoning for the area in proximity to the Nine
Springs treatment plant (including sludge lagoons) some potential for conflicts
appear to exist. As stated in a portion of the comprehensive facilities plan
related to plant siting:
2-20
-------
".... At the present time, existing zoning does not represent any
serious conflicts with maintenance, operation and possible expansion
of the treatment plant. Zones considered incompatible are fully
developed, i.e., R-l (the apartment complex) and PHD (the mobile
home subdivision).
"There is reason for concern, however, when the comprehensive land
use plan (Refer to Figures 2-7 and 2-8) is compared to existing
zoning. Existing zoning does not totally reflect proposed land use
patterns in the area, and the land use plan is the guiding reference
in approving zone changes. Under the proposed plan, areas to the
southwest, south, and southeast currently zoned agricultural could
conceivably be altered to permit low-density or medium-density
residential development. This would result in further encroachment
of residential devlopment around the plant."
3. Water quality and quantity
Problem
Section 2.06 discusses surface and groundwater quality and quantity considera-
tions. General reference is made to the types of pollution sources (point and
nonpoint) affecting the area. Specific reference is made to the municipal point
source discharges. However, no reference is made to industrial discharges. In
the general area considered for sludge application the environmental inventory
for the study shows eleven industrial point sources of pollution. These industries,
the receiving waters into which they discharge, and the quantity and quality of
their discharges are listed on Table 2-4 extracted from the environmental inventory
for the study.
The most critical water quality problem most directly applicable to this organic
solids reuse study is related to the storage lagoon problems which MMSD has experi-
enced at Nine Springs sewage treatment plant. Those problems are summarized in
Section 1.2 of the facilities plan and Section 1.04 E of the environmental assessment.
Uses
The discussion of water uses in Section 2.06 of the environmental assessment
is sufficient for the level of detail of this report. Additional information is
available in backup appendices to the comprehensive facilities plan.
Management
Sections 2.06 and 2.12 of the environmental assessmental adequately summarize
water management programs in force in the study area.
4. Summary of Sensitive Man-made Resources
Historical and Archeological Sites
Section 2.16 of the environmental assessment is an adequate discussion of
historical and archeological sites.
In a letter of comment on the draft EIS (letter included in Appendix A) the
State Historic Preservation Officer indicated that there are no sites listed on
the National Register of Historic Places that would be affected by this project.
Also, there are no known sites of archeological, architectural, or historical
significance in the project area that would be eligible for inclusion on the
National Register of Historic Places.
2-21
-------
Lake Monona
-------
Lake Monona
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Recreation and Open Space Areas
The discussion of recreatipnal areas and activities in, Section 2.13 of the
environmental assessment is an adequate summary of these subjects for the general
project area. However, some additional discussion of recreation and open space
areas in the vicinity of the Nine Springs Sewage Treatment Plant site and its
sludge lagoons is necessary.
The Nine Springs Sewage Treatment Plant and surrounding areas falls within
the Nine Springs Creek Corridor of the "E-way" system proposed by Dane County
Regional Planning Commission. The basic framework for the "E-way" system
consists of public roads, streets, walkways, and open space systems. These
connected corridors enclose the city in an environmental loop which highlights
its prominent educational, ecological, and environmental characteristics. The
corridor widens in the area around Nine Springs Sewage Treatment Plant to include
the undeveloped land and the adjacent wetlands a unique feature in the area. As
can be seen on Figure 2-5, a large portion of land immediately to the south and
east of the treatment plant and sludge lagoons is in public ownership. This land
is being held for recreation and open space use. The public agencies owning land
include the State of Wisconsin, Dane County, and MMSD. A portion of the area to
the north of jihe sludge lagoons is designated as open space (see Figure 2-7) in
the land use plan. The area is currently undeveloped. However, it is in private
ownership. As shown on Figures 2-*5 and 2-8 it is included as part of the E-way
corridor system.
Agricultural Land
Chapter 6 (Section 6.1 and 6.4) of the facilities plan and the previous discus-
sion of land use in this chapter together provide sufficient information on the
agricultural economy and trends in agriculture in the study area.
Energy Resources
Energy uses by MMSD are adequately discussed in Section 2.14 of the environ-
mental assessment. Other present or projected electrical power, natural gas and
heating oil needs in the study area were not identified, "The Upper Mississippi
River Comprehensive Basin Study" published in 1970 predicts a substantial increase
in energy requirements in the basin between 1970 and the year 2000. The figures
cited for Power Supply Area 13 which includes Dane County show that energy require-
ments will increase from 9,690 million kwh in 1970 to 50,560 million kwh in the
year 2000, While these predictions may have changed somewhat since 1970, it can
be expected that there will be an increasing demand for energy as the population
increases.
2-27
-------
CHAPTER 3
ALTERNATIVES TO THE PROPOSED PROJECT
Summary of Alternatives
Major alternatives evaluated:
Lagoon Abandonment Alternatives
Treatment plant sludge
continue discharge to existing lagoons
or discontinue discharge and build new lagoons
Lagoon sludge
remove and apply to farmland
or leave in lagoons
Lagoon supernatant
remove and return to treatment plant
or leave in lagoons
Lagoons dikes
stabilize and maintain
leave as they are
Ultimate Disposal Alternatives
Land application of dewatered sludge
Land application of liquid digested sludge
Land application of compost
Landfill of sludge/milled refuse mixture
Landfill of digested sludge
Subsurface placement of sludge
Incinerate raw sludge
Incinerate digested sludge
Lagoon storage - NO ACTION ALTERNATIVE
Transportation Method Alternatives
Rail transport
Truck transport
Pipeline transport
Application Method Alternatives
Sprinkler gun
Subsurface injection
Truck or tractor drawn spreader
Sludge Reuse Program Alternatives
Sludge supplied by MMSD at farmer's request
MMSD leases privately-owned land for sludge application
Combination of above alternatives
EPA Review of the Plan and Environmental Assessment
The organic solids reuse plan and the environmental assessment are accurate
as far as they go in their presentation of how Madison Metropolitan Sewerage
District systematically evaluated the various alternatives and arrived at their
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proposed plan. However, some supplementation and clarification of what is pre-
sented in these two reports is required to allow the public to fully understand
how various alternatives were eliminated from consideration. In some cases these
reports compare the alternatives on the basis of economics when in reality MMSD
and its consultants took other factors into account in addition to monetary costs.
There is some additional information related to various alternatives which has
not been considered in eliminating certain alternatives. Sludge treatment
alternatives were discussed only briefly in the facilities plan, and environmental
assessment. Instead of repeating what has been presented in the facilities plan
and environmental assessment, this section will reference the sections of the
facilities plan and environmental assessment which provide the information necessary
to understanding how alternatives were evaluated and eliminated and supplement,
clarify, or summarize this information where necessary.
The proposed plan includes a proposed lagoon abandonment program as well as a
proposed plan for future sludge handling and disposal. Therefore, the alternatives
discussion is broken up into those two categories.
A. Lagoon Abandonment Program Alternatives
Sections 1.2 and 1.3 of the facilities plan and Sections 1.04 and 1.05 of the
environmental assessment give an adequate history of sludge lagoon problems at
Ni,ne Springs Sewage Treatment Plant. They show why MMSD was forced to cease their
previous program of lagoon disposal of sludge and adopt a course of action to stop
t;he threat of lagoon dike failure.
Chapter 5 of the facilities plan adequately discusses how the various alternative
lagoon abandonment options were evaluated in selecting the proposed plan. Appendix
B, Tables B-l - B-4 of the facilities plan compare costs for the various alternatives.
It appears that MMSD has systematically and adequately considered all reasonable
and feasible alternatives to lagoon abandonment and lagoon sludge disposal.
B. Future Sludge Handling and Disposaj. Alternatives
This category includes the alternative methods of treating, transporting and
disposing of sludge produced by MMSD in the future.
As indicated in Sections 2.1 - 2.4 of the facilities plan and Section 3.01 of
the environmental assessment, MMSD has had several studies done related to sludge
treating, transport, and disposal. The results of the reports are summarized in the
above-referenced sections. From the information presented in these sections it would
appear that feasible alternatives were screened solely on the basis of monetary costs.
Although monetary cost was certainly the overriding concern in the screening of
alternatives, the various reports did include consideration of other factors in the
screening process. The following discussion of the various reports is meant to
supplement and evaluate what has been presented in the referenced sections of the
facilities plan and environmental assessment.
1. Greeley and Hansen Reports
The discussion presented in Section 2.1 of the facilities plan and Section
3.01 of the environmental assessment is accurate. The alternatives include
consideration of handling and disposal of sludge. It should be realized that
alternatives A-D assume 25-mile truck transport of sludge and alternative E
(liquid sludge application) assumes 25-mile pipeline or rail transport. The
current proposed plan includes immediate truck and potential future pipeline
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transport of liquid sludge. It would appear that on the basis of monetary
costs no comparisons could be made of the proposed immediate plan of truck
transport of liquid sludge with the alternatives in the Greeley and Hansen
report since the assumed modes and distance of transport presented vary.
However, Appendix B to the facilities plan compares the costs for various
modes of transport so that comparisons can be drawn.
2. Weston Report
This report was discussed in Section 2.2 of the facilities plan and
Section 3.01 of the environmental assessment. These sections present an
adequate discussion of how lagoon disposal, land application of dried sludge,
incineration of sludge and subsurface placement or trenching were eliminated
from consideration on the basis of monetary costs. However, the discussion
of how the three remaining alternatives (land application of liquid sludge,
sanitary landfill of a sludge-milled refuse mixture and land application of
compost) were compared only includes information on monetary costs. The
Weston report had also compared these three alternatives on a non-monetary
basis. Some additional factors considered related to these alternatives
were:
Land application of sludge - In addition to the cheaper dollar cost of
this alternative the report gave a shorter implementation time and retrieval
of the fertilizer value of sludge as advantages. This alternative requires
lagooning over the winter months. The report also indicated that virus
survival, odor, heavy metals and runoff could be problems. However, with
adequate control they are surmountable difficulties.
Sanitary landfill of sludge-milled refuse mixture - With this alternative
the report indicated that sludge dewatering would be required and would probably
provide a centrifuge effluent return of unacceptable quality. Cover material
would probably be required in this alternative. The availability of a reliable
source of milled refuse was considered questionable.
Land application of compost - According to the Weston report, some of the
advantages of composting are: 1) Composting would return a valuable resource
to the soil; and 2) Composting the Nine Springs sludge with wood chips or
milled refuse would present additional dewatering benefits considering the poor
dewatering characteristics of the sludge. After consideration of mechanical
composting as an alternative, the Weston report concluded that it would be
difficult or impossible to achieve the optimum moisture content which would
promote effective growth of the aerobic organisms necessary to achieve composting.
In addition, it was felt that the effluent from the centrifuge dewatering system
could potentially impact on the balance of the treatment system. Open windrow
composting such as has been tested at BeJtcville, Maryland was also considered
in the Weston report. It was felt that this type of composting could only be
accomplished during summer months because of the low nighttime temperatures
common to winter in Madison. It would be difficult to achieve an acceptable
dewatered state as with mechanical composting. The problems with centrate quality
affecting treatment balance would also be the same. A negative concern related
to?aKmposting in general was the doubt of finding reliable sources of wood chips
or milled refuse.
The Weston report was prepared based on initial test results at Beltsville,
Maryland. More recent experiences by the United States Department of Agriculture
at Beltsville and subsequent experiences at Bangor, Maine vary from the discussion
of windrow composting presented in the V7eston report. The experience at Bangor,
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Maine (personal communication, USDA Laboratory, Bangor, Maine) has been that
adequate windrow composting can be achieved year-round with proper controls. Also,
the costs associated with composting would be lower than those cited in the Weston
report. The cost of composting is less than the $140/dry ton cited in the Weston
report. Estimated cost figures cited in a paper by Epstein and Wilson related to
the sludge composting project at Beltsville, Maryland are $30/dry ton at a 40/dry
ton/day plant receiving dewatered sludge. Personal communication with Dan Kowaseco,
USDA Beltsville, Maryland indicated that the estimated cost would be in the range
of $30-$60/ dry ton. This estimated cost does not include haul costs or any revenue
resulting from sale of the product. This would still be higher than Madison's
proposed plan. The Weston report also indicated that the highest practical and
economical level of solids which could be attained at Nine Springs STP was around
12% and that this was below the level necessary to achieve composting. In recent
tests at Beltsville, Maryland composting has been achieved using sludges with as
low as 5% solids. The results of the tests have not yet, however, been published.
(Personal communication, Dan Kowaseco, USDA, Beltsville, Maryland).
The Weston report did not consider additional benefits of composting which have
been experienced at Beltsville, Maryland. These include better kill-off of pathogens
and fewer potential odor problems. The recent experiences at Beltsville have shown
that composting can produce a soil amendment product which could either be sold to
offset the processing cost or used with the municipality for a variety of purposes,
decreasing the amount of inorganic fertilizers which would otherwise be purchased.
Related to the composting alternative for MMSD it would appear that certain
problems discussed in the Weston report such as finding a reliable source of wood
chips and' finding a market for the product would still offset the benefits to be
gained from using composting. If the proposed farm market for liquid sludge does
not develop as anticipated, it may be possible to reconsider composting as an alter-
native backup program.
Sludge treatment alternatives considered in the Weston report - The selection
of sludge treatment alternatives was based on the need to produce sludges of a
quality which would be suitable for the alternative methods of suitable ultimate
disposal. Various combinations of processes were considered for each of the major
sludge handling systems (Sanitary Landfill System, Land Application of Compost System
and Land Application of Liquid Sludge System). The proposed system of land appli-
cation of liquid sludge incorporated the process of blending of primary and secondary
sludges, gravity thickening, and anaerobic digestion.
3. MMSD Addendum
Section 2.3 of the facilities plan and Section 3.01 of the environmental
assessment discuss this report. The report analyzed several sludge treatment
and disposal alternatives on the basis of costs and environmental impacts. The
system proposed in the report as most cost-effective includes thickening and
anaerobic digestion followed by pipeline transport and land application of liquid
sludge. The evaluation of liow three of the alternative systems were eliminated
in a preliminary screening was adequately discussed. However, the evaluation
of the four remaining alternatives was not sufficiently detailed. The following
evaluation of these alternatives was excerpted from the MMSD Addendum to supplement
the information in the facilities plan and environmental assessment. The final
selected land application system varies somewhat from the Alternative 2A presented
here in that the final system is more conservative and eliminates most of the
disadvantages discussed for Alternative 2A. The costs of the four alternatives
considered in the final screening in MMSD's Addendum is presented in Appendix B.
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Alternative 1A - Land Trenching of Dewatered Sludge
Advantages
This option does not require digestion of the sludge.
Elimination of a unit operation eliminates operational
and control problems associated with that unit operation.
The operation would be continuous, without the need for
lengthy sludge storage which has the potential for odor
problems. There would be very little visible evidence of
sludge disposal at the final disposal site. A relatively
small land area would be required to handle the sludge in
this manner. If a farm were purchased by MMSD for the
purpose of trench disposal, the farmer could continue
to work the undisturbed property with minimal interference
due to the sludge disposal. Odor problems at the disposal
site would be minimal.
Implementation time for this system would be short and
primarily dependent on the delivery time for the dewatering
equipment. The final disposal site could be switched easily
because of the small area required per year and the fact that
the dewatered sludge would be transported by truck.
Disadvantages
The main disadvantage of the trenching option is the
inability to predict whether the land used for disposal
would be stable enough to be brought back into useful
crop production. The dewatered sludge at 16% solids content
is still pliable and may not readily lose enough of its
remaining moisture to the surrounding earth or the atmosphere
to stabilize. If the dewatered sludge would not stabilize,
productive land may be lost.
A site with suitable geological characteristics would
have to be found to prevent uncontrolled discharge of pollu-
tants to the surrounding groundwater. The trenches might
have to be lined with an impermeable membrane prior to
sludge placement or drain tiles might be required to catch
any downward movement of leachate. This leachate may have
to be treated, probably by spraying it back on productive
land.
The sludge dewatering step would produce a recycle stream
which must enter the secondary treatment system. The recycle
stream would use some plant capacity and may also have a
harmful effect on the effluent discharged from the secondary
plant. The 1990 loading from this recycle stream would equal
3.5 per cent of the anticipated 1990 BOD load, 3.9 per cent
of the anticipated 1990 suspended solids load and 3.3 per
cent of the anticipated 1990 ammonia nitrogen load in the
secondary treatment plant. The suspended solids in the
recycle stream would be very fine in nature and may accumu-
late in the secondary treatment system. Chemicals which may
become increasingly expensive and hard to get must be used
for conditioning prior to dewatering.
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Elimination of the digestion step would eliminate
production of methane gas now used to heat buildings and run
specific equipment at the treatment plant.
Another disadvantage of this option would be the loss
of the fertilizer value in the sludge because of the manner
of disposition. The nutrients in the sludge may be discharged
to the groundwater as a pollutant rather than recovered as a
resource. Frozen ground may make winter trenching difficult.
Alternative 2A - Land Application of Liquid Sludge
Advantages
This disposal option utilizes the high fertilizer value in
the sludge. Crop uptake of the nutrients would turn a problem
into a benefit. Very little land would be permanently taken
out of useful crop production. The same site could be contin-
ually used with no loss in aesthetic or economic value during
or beyond the design period.
The implementation time of this system could be short relative
to the other alternatives. With this system, it would also be
easy to slowly reduce the sludge volume in the existing lagoon
•if this action were necessary. There would be limited expansion
necessary at the existing Nine Springs Treatment Works. No
recycle stream, with the associated problem of BOD , SS and
NH-N removal, would be returned to the secondary treatment
plant. There would be no dependence on chemicals for sludge
conditioning or no worry about fines buildup in the secondary
treatment system.
Disadvantages
The major disadvantage associated with this option is the
expected difficulty in locating and purchasing or leasing the
large land areas required for controlled successful land irriga-
tion of sludge. If the land were not purchased or leased, there
would be difficulty in coordination with local farmers for land
use.
The necessity for a temporary sludge storage lagoon could
lead to an odor problem if proper controls were not maintained.
The land application of sludge may result in a musty odor which
could be offensive to some individuals. A buffer area would have
to be provided around the land used for storage and application.
Possible virus survival is also of concern. With increased
digestion capacity, more complete digestion should minimize
the potential odor and virus problems.
Aeration of the lagoons would help prevent odors. The
sludge lagoon would be storing sludge primarily during the
winter months when odors are not normally a problem. In
summer the lagoons would be used as a transfer point and
would not hold large volumes of sludge, therefore minimizing
potential odor problems. New efforts directed at reducing
odor problems would have to be implemented.
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For this option it may also be necessary to line the
final disposal site with drain tiles, collect the leached
water and return it to the surface for crop irrigation.
Careful control of runoff would be necessary along with
adjacent stream monitoring.
Laying a pipeline to a specific point severely limits
the location of the final disposal site. The permanence
of a pipeline, along with the tine and money associated
with construction of a such a line, tend to make this option
inflexible. It would be difficult to justify abandoning
or severely altering this system once it was operational.
The entire application and cropping procedures would
require agricultural management expertise which would have
to be acquired by MMSD.
Alternative 3A - Landfilling of Sludge/Milled Refuse Mixture
Advantages
This alternative would take advantage of the expertise
available in the operation of traditional sanitary landfill
operations. It would utilize the absorptive capacity of
existing refuse to act as a dewatering agent for the sludge.
It would be necessary to dewater the sludge but not to a
high degree.
Site control could be insured from experience gained in
the solid waste handling field. There should be no odor
problem associated with this operation if proper cover
techniques were used.
The land requirements would not be excessive. There
would also be minimal sludge storage requirements which
could result in potential odor problems. Also, with this
option, it would be easy to reduce the volume of sludge
in the existing lagoons by gradual inclusion in the mixing
process if more milled solid waste were to become available.
Disadvantages
Land utilized as the final disposal site could be
recovered as cropland or for some other use but, may have
some limitations. Once the landfill has been placed and
the original site filled, a new site must be located.
The necessity of dewatering produces a recycle stream
which must be treated and may have a harmful effect on the
effluent from the secondary treatment plant. The 1990
loading from this recycle stream would equal 1.0 per cent
of the anticipated 1990 BOD load, 1.5 per cent of the
anticipated 1990 suspended solids load and 13.5 per cent
of the anticipated 1990 ammonia nitrogen load in the
secondary treatment plant. The suspended solids in the
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recycle stream would be very fine in nature and may
accumulate in the secondary treatment system. Chemicals
which may become increasingly expensive and hard to get
must be used for conditioning prior to dewatering.
This option involves rehandling the sludge several
times, once before mixing and once after mixing. Again,
the fertilizer value associated with the sludge is lost
in the landfill.
This option is dependent on obtaining a certain quantity
of milled refuse from the City. If that refuse were not
available or very high in moisture content, sludge disposal
would be impaired.
This option limits the potential resource recovery from
the milled refuse unless it were used in a compost operation.
Sludge/milled refuse in a landfill would generate leachate
which would have to be collected and treated. The nutrients
associated with the sludge would be a potential groundwater
pollutant.
Alternative 3B__- Land Application of Dewatered Sludge
Advantages
*•
The major advantage of this option is the use of the
fertilizer value associated with the sludge. Nutrient
uptake would be accomplished by crop production. No land
would be taken out of farm use. The same site could be
used in future years with no physical or economic loss.
No storage lagoons are necessary. The sludge could be
stockpiled on the land on which it would be eventually spread.
Odor problems associated with the dewatered completely di-
gested sludge should be minimal. Spreading of the sludge
could probably be accomplished with normal farm equipment.
The necessary nutrient loading could be provided with one
pass over the land.
Disadvantages
Hauling the dewatered sludge to rural farmland may result
in some objection from the local residents. The same large
amounts of purchased or leased land is required as in the
liquid sludge application alternative. If the land were not
purchased or leased, coordination with the local farmers
might be difficult. Virus survival may again be a question
not to be overlooked.
The sticky character of the dewatered sludge due to the
polymer addition may make it very difficult to spread or plow
under evenly. These problems would result in poor acceptance
by farmers. This problem might possibly be reduced by lowering
the polymer dose to the centrifuge such that the centrate stream
character degrades but the sludge cake solids content does not
appreciably change. The centrate stream might then be air
floated or recentrifuged to clean up the centrate.
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This option involves treatment of a recycle stream. This
stream would use part of the planned secondary expansion and
could degrade the treatment plant effluent. The percentages
of anticipated 1990 BOD , SS and NH-N loading attributable to
the recycle stream are the same as for Alternative 3A. Again
there would be a dependence on chemicals for conditioning.
4. CH2M Hill Study
The aforementioned studies all came to the same basic conclusion, that the most
cost-effective method of sludge management for MMSD is land disposal of liquid
digested sludge. Therefore, MMSD resolved to pursue that method of disposal.
The firm of CH2M Hill was hired by MMSD subsequent to the aforementioned studies
to further evaluate the sludge treatment processes which would be employed prior
to land application. They compared aerobic vs. anaerobic digestion and determined
that anaerobic digestion should be utilized for primary and secondary sludges due
to the higher power consumption requirements and requirements for separate land
application required for aerabic digestion. They also compared various type thick-
eners (gravity, air flotation, centrifuge, and centrifugal screen concentrators)
and determined that a two-stage thickening process first employing gravity thickening
and then air flotation thickening would be least costly. The system of land appli-
cation of liquid sludge which they propose includes gravity and air flotation
thickening and anaerobic digestion prior to disposal.
5. Reuse level alternatives
Section 3.1 and Table 3-1 of the facilities plan give a complete summary of
the three reuse categories, (fertilization, high rate fertilization and disposal)
including loading rates, objectives, suitable soils and impact on soil and water.
Section 7.1 is somewhat misleading because it implies that high rate fertilization
and disposal would definitely affect surface and groundwater. Those impacts can
be avoided, however, only with a very strict management program. The selected
reuse program is a fertilization type program.
6. Reuse Program Alternatives
Section 7.2 and 7.6 of the facilities plan adequately discusses how the reuse
program of supplying sludge to farmers at their request was selected as the
proposed reuse plan.
7. Transportation Method Alternatives
Section 3.02 of the environmental assessment adequately discusses the advantages
and disadvantages of the three most feasible methods of sludge transport which are
rail, truck, and pipeline transport. Section 7.5 and Appendix B compare truck and
pipeline transport. As was discussed, although pipeline transport is less expensive
and has other advantages, a pipeline route could not be determined until a reliable
and sufficiently large sludge market develops. Therefore, Madison proposes to use
truck transport in the immediate future until a market develops.
8. Intermediate Storage Facility Alternatives
Section 7.5 of the facilities plan and Section 3.02 of the environmental
assessment adequately discuss the two types of intermediate storage facilities
considered for on-site sludge storage to increase the efficiency of the sludge
transportation and application systems. The additional alternative exists of not
providing for intermediate sludge storage. Not utilizing such facilities would
result in a less efficient system, especially during peak application periods.
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9. Application Method Alternatives
Section 7.5 of the facilities plan and Section 3.02 of the environmental
assessment are adequate in their discussion of application methods with one excep-
tion. Since air borne pathogens at sludge irrigation sites has been considered by
some as a potential public health problem, the subject should be discussed.
According to Burge (1974), ."The threat of infection to sprinkler irrigation
site workers and to the surrounding communities through exposure to aerosols
containing pathogens has not been completely defined, but experience and
what literature is available seem to indicate that the threat is minimal."
A USEPA - sponsored research project currently being conducted at the Fulton
County, Illinois sludge disposal area of the Metropolitan Sanitary District
of Greater Chicago is expected to provide some additional information related
to airborne transmission and survival of pathogens in aerosols from big gun
sprinkler irrigation systems. It would appear unlikely that truck spreader
and soil injection systems would present any kind of potential airborne pathogen
problem since the formation of aerosols is not a problem, with those methods.
10. No Action Alternative
The "No Action" alternative is adequately discussed in Section 3.03 of the
environmental assessment.
11. Other Considerations in Developing the Proposed Plan
Existing State and Federal guidelines were followed in formulating the
proposed plan. The Federal guidelines mentioned on page 3-6 of the environmental
assessment will be superceded by a technical bulletin (published in draft form in
the Federal Register on June 3, 1976) when it becomes final. This bulletin is
meant as guidance and does not have the force of a regulation. Where state
guidelines exist, the stricter of the two guidelines, Federal or state, would be
followed in developing a sludge management plan.
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CHAPTER 4
DESCRIPTION OF THE PROPOSED ACTIONS
Summary of the Proposed Actions
The studies which were conducted regarding the treatment and final disposal
of sludge produced at Nine Springs Wastewater Treatment Plant determined land
application of liquid anaerobically digested sludge to be the most cost-effective
method of disposal. The plan involves marketing of sludge to farmers at their
requests. Initially truck hauling and spreading will be employed until an
adequate market for sludge develops. Various sludge lagoon abandonment options
were also evaluated to eliminate the potential for lagoon dike failure. Past
failures have resulted in toxic spills to Nine Springs Creek and adjacent
wetlands. It was determined that a lagoon dike rehabilitation and maintenance
program is necessary. One lagoon will gradually be dredged out and eventually
abandoned. The other lagoon will also be cleaned out and one-half of this
lagoon will also be abandoned. The other half will be used for seasonal sludge
storage. The lagoon sludge resulting from lagoon cleanout will be applied to
land just as the new treatment plant sludge will be.
EPA Review of the Plan and Environmental Assessment
Chapter 8 of the facilities plan and Section 4 of the environmental assessment
present an adequate description of the proposed actions with a fev.7 exceptions.
Construction of additional sludge treatment facilities is now considered part of
the organic solids reuse plan. Therefore, some information on the proposed
treatment facilities is provided. Related to the cost of the proposed system;
some supplementation and correction is required. Additional information on the
lagoon dike rehabilitation and abandonment is also provided.
A. Sludge Treatment Facilities
Additional facilities are necessary for thickening and digestion of the
additional organic sludges produced by the expanded and upgraded treatment
plant. The Basis of Design for the solids handling facilities and construction
staging is presented in Appendix C.
1. Gravity Sludge Thickener Improvements
The mechanisms on the two original gravity thickeners will be refurbished
and worn parts will be replaced as needed. An additional 55' diameter gravity
thickener may be needed to supplement the two original units. Facilities will
be constructed to facilitate the addition of secondary effluent to the thickeners
in order to reduce odors caused by septic conditions.
2. Dissolved Air Flotation Thickeners
Dissolved air flotation thickeners will be constructed in order to pre-
thicken waste activated sludge prior to digestion.
3. Sludge Digester Improvements
A total of five new digesters (two primary and three secondary digesters)
will be constructed to serve the plant through the year 2000. The units
will be two-stage digesters operating in the mesophilic temperature range.
A new digester control building will also be constructed.
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Modifications will be made to the existing digesters including resealing,
replacement of heat exchangers, the addition of gas mixing equipment and the
renovation of the waste gas burners. In addition, MMSD will consider instal-
lation of a supernatant draw-off system and a supernatant treatment system in
order to return supernatant from the secondary digester back to the head end of
the treatment plant. The supernatant draw off systems would be used only on the
secondary digesters (non-mixed tanks).
B. Cost of the Organic Solids Reuse Program
Table 8-1 of the organic solids reuse program is incorrect as shown. Table C-3
in Appendix C is a revised version of Table 8-1. Information on total present
worth of the proposed system was not included in the organic solids reuse plan or
environmental assessment. Table C-4 in Appendix C summarizes the calculation of
the total present worth of the proposed system.
C. Lagoon Dike Rehabilitation
The sludge storage lagoons at the Madison Metropolitan Sewerage District's
(MMSD) Nine Springs Sewage Treatment Works are located just east of the treatment
works on Raywood Road (Plate I). There are two lagoons—one approximately 45 acres
in size, and one approximately 85 acres in size. The smaller lagoon (Lagoon 1)
was constructed in about 1942. The larger lagoon (Lagoon 2) was constructed in
1967. Digested sludge produced at the Nine Springs Sewage Treatment Works is
currently being discharged and held in these two lagoons.
This project involves rehabilitation of certain portions of the existing
Lagoon 2 dikes. Approximately 3,000 lineal feet of dike will be modified to
provide increased freeboard through the use of a lightweight fill embankment
improvement. Approximately 700 lineal feet of dike will be completely recon-
structed. The objective of the work is to minimize the risk of an uncontrolled
release of sludge and supernatant because of the continued subsidence and
spreading of the existing containment dikes.
The area of the proposed dike rehabilitation consists of the eastern 1600
feet of the existing north dike of Lagoon 2 and the entire south dike of Lagoon 2,
The proposed rehabilitation consists of two parts: modification and reconstruction.
Plan reviews and typical sections of the proposed rehabilitation are shown on
Plates II, III, and IV.
Modification will consist of constructing a lightweight fill of wood chips on
and adjacent to the existing dikes. The lightweight fill will be constructed
with a 16-foot-wide crest that will be approximately 7 feet above the existing
marsh. Nonwoven synthetic fabric will be used as lateral reinforcement (corduroy)
and as a filtering and separation medium at the base of and on the inboard sloping
face of the lightweight fill. Both the inboard and outboard sloping faces of the
lightweight fill will be covered by a 1-foot-thick layer of well graded granular
soil (15 to 25 percent by weight of this soil will pass the No. 200 sieve). The
crest of the modified dike will be surfaced with 6 inches of granular base course
to provide all-weather access.
Reconstruction will consist of backfilling the area where the existing dike
has subsided below the marsh level (1973 failure zone), and constructing a new
lightweight dike. Backfilling will be done with channel fill, a mixture of
approximately one part granular soil to one part wood chips (volume basis).
Nonwoven fabric will be used at the base of the channel fill to provide lateral
reinforcement. The surface of the completed channel fill will be approximately
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at the level of the surrounding marsh. The lightweight dike will be constructed
of wood chips and nonwoven fabric will be placed at the base of the wood chips
to provide lateral reinforcement. The geometry and details will be essentially
identical to those for dike modification.
D. Lagoon Abandonment
On 15 July 1971 the Wisconsin Department of Natural Resources (WCNR) issued
Pollution Abatement Order No. 4B-71-1L-22 to MMSD. The order required that MMSD
provide for satisfactory disposal of liquid sludge from the Nine Springs Sewage
Treatment Works and that the operation include provision for abandonment of the
present method of disposal of liquid sludge in Nine Springs Marsh.
The disposition of liquid sludge was studied as a part of the Facilities
Plan. This study recommends that the program to implement the abandonment
directive consist of the following:
1. Continue using the western half of Lagoon 1 for annual or temporary
storage of sludge.
2. Begin cleaning out Lagoon 2 and the eastern half of Lagoon 1 and
apply the sludge to agricultural lands. An estimated 9-14 years
will be required to completely unload the lagoons.
3. Continue to return and treatment supernatant until the lagoons are
fully unloaded.
4. After the lagoons are fully unloaded, allow Lagoon 2* and the eastern
half of Lagoon 1 to revert to marsh.
Implementation of this program requires that the dikes perform satisfactorily
until the lagoons are unloaded. The review of existing conditions and evaluation
of past performance led to the following conclusions (among others) in the special
report entitled, "Geotechnical Evaluation of Sludge Lagoon Embankments."
1. Certain reaches of the embankments of Lagoon 2 are unstable.
2. Failures and possible damaging spills are imminent, and for portions
of the dikes of Laggon 2, incipient.
3. Regardless of the disposition of the sludge in the lagoons, the unstable
reaches must be repaired as soon as possible.
The special report recommended:
1. Stabilize portions of the dikes of Lagoon 2 as soon as possible.
2. Stabilize those portions of the Lagoon 2 embankment by replacing the
existing dikes with embankments constructed using berm and corduroy
techniques.
The method which has been selected for cleaning the sludge out of the lagoons
prior to abandonment is the use of a Mudcat dredge. This is a small portable
floating dredge which is self-propelled and can move into the sludge to be pumped.
It can slurry the sludge prior to pumping.
The various lagoon abandonment options were discussed in detail in Section 5.5
of the facilities plan.
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CHAPTER 5
ENVIRONMENTAL EFFECTS OF THE PROPOSED ACTIONS
Summary of Significant Environmental Inpacts
Water
The abandonment of lagoon disposal of sludge at Nine Springs sewage treatment
plant will eliminate the threat of lagoon dike failure and resultant toxic spills
of the lagoon contents into Nine Springs Creek and the adjacent wetlands. As long
as the proposed land disposal program is strictly managed and operated as planned,
there will be no significant effect on water quality and quantity.
Air Quality
As long as the precautions related to sludge hauling and application which have
been outlined in the facilities plan and environmental assessment are taken, potential
odor problems will be minimized. Dust generated from construction of solids treat-
ment and handling facilities will cause a temporary change in ambient conditions.
Significant odor-producing sludge treatment processes will be abandoned or modified
by this plan so that odor problems will be minimized.
Land Use
The only significant effect on land use which is expected to result from the
proposed plan is the beneficial one which is the eventual return of the abandoned
sludge lagoons to a wetland condition.
Soils and Biota
The soil fertilizer value of the sludge will improve the fertility of the soils
on which sludge is applied while reducing the quantities of expensive commercial
fertilizers which must be used. Possible impacts on the soils and plant and animal
life of the study area could result form the build-up of materials contained in
the sludge to levels which may be toxic to normal life functions. This potential
effect will be minimized because MMSD's plan proposes to limit annual application
rates and total allowable loadings to levels which would provide for protection
of the soils and plant and animal life of the area while at the same time obtaining
the maximum soil amendment value to be gained from land application of the sludge.
Cadmium levels and the ratio of cadmium to zinc to MMSD sludge are higher than
the United States Department of Agriculture would recommend for sludge being applied
to privately-owned land. MMSD's conservative application rates and their proposed
cadmium source control program should minimize the potential for build-up of
cadmium to toxic levels.
EPA Review of Plan and Environmental Assessment
In many cases the environmental effects section of an EIS would compare the
environmental impacts of the proposed action and its alternatives. For this
plan the information available on the effects of various alternatives was
discussed in Chapter 3 of this EIS and in sections of the facilities plan and
environmental assessment referenced therein. Although the information available
on the environmental affects of system and subsystem alternatives considered
by MMSD is not presented in a great level of detail, we feel that it is adequate
to assess how the most cost-effective sludge management plan was selected. It
remains, then, to ensure that the plan proposed by MMSD is environmentally sound
and should indeed be pursued. The discussion of impacts will therefore relate
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strictly to the effects of MMSD's proposed plan and not to the effects of
alternatives.
MMSD's organic solids reuse plan has been developed to be in accordance with
Wisconsin CNR Technical Bulletin No. 88 entitled "Guidelines for the Application
of Wastewater Sludge to Agricultural Land" and with recommendations of the proposed
USEPA Technical Bulletin on "Municipal Sludge Management: Environmental Factors"
published June 3, 1976, in the Federal Register.
Since, overall, MMSD's plan has been carefully formulated to minimize adverse
environmental effects 'and the facilities plan and environmental assessment system-
atically discuss the potential effects of the proposed plan in a generally adequate
fashion, we will identify here only those critical impact issues which require
further discussion or have not been mentioned. The discussion of impacts of the
proposed plan is divided into sections which correspond to various segments of the
organic solids reuse plan.
A. Sludge Lagoon Abandonment Program
The impacts resulting from these actions are discussed in the environmental
assessment Sections 5.02 D, 5.02 F, 5.02 K, 5.02 L and 5.02 M. The effects
of transporting of lagoon sludge and applying it to agricultural land will
be considered under "Operation of the Organic Solids Reuse Plan."
The potential impacts of dike repair and sludge removal on the fishery of
Nine Springs Creek and adjacent wetlands were not specifically addressed in the
facilities plan or environmental assessment. They were only addressed in terms
of the net beneficial effect expected to result from the lagoon abandonment
program, i.e., removing the threat of lagoon dike failure and toxic spills into
Nine Springs Creek and adjacent wetlands. Obtaining this net positive impact
requires that the dikes perform satisfactorily until the sludge has been
removed from the lagoons.
The proposed rehabilitation construction carries inherent risks with the
consequence of loss of lagoon contents by spilling. However, if nothing is
done, failure or overtopping of the dikes of Lagoon 2 is a virtual certainty.
If sludge is released, oxygen-depleting organics, taste and odor-producing
constituents, toxic substances, and heavy metal ions will be introduced to the
receiving waters. A spill will also release tremendous amounts of nutrients,
increase color and turbidity, increase suspended and dissolved solids, and
introduce potentially pathogenic wastes to the adjacent surface waters. The
environmental consequences would be deposition of. sludge in Nine Springs Creek,
stimulation of excessive growths of weeds and algae, deterioration of water
quality, killing and prohibiting the existence of certain species of fish and
aquatic life, and devaluation of aesthetic and recreational values of the
affected waters.
To minimize the risks of failure caused by construction activities, the
following techniques will be used:
1. Lightweight aggregates will be used to substantially reduce loads
imposed on the low strength foundation soils.
2. Corduroy techniques will be used to increase the stability of the
modification and reconstruction by providing lateral reinforcement.
3. Surface instrumentation including survey hubs and settlement platforms
will be used to monitor movements during construction. This information
will be used to measure actual performance versus predicted performance
and to forewarn of impending failure.
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4. All construction activities will be closely observed by a qualified
geotechnical engineer.
The potential adverse environmental impact of the proposed construction
is less than the probable environmental impact of the introduction of sludge
and supernatant into the adjacent surface waters that would occur during a
failure or overtopping of the existing unstable dikes.
Should a failure occur during construction, a contingency plan to prevent
spilling of lagoon contents will be immediately implemented. Wood chips will
be placed on the existing dike to maintain freeboard/ and a covering of corduroy
fabric will be used to prevent the woodchips from floating away. Pins will be
driven through the fabric to secure it. The contractor will be using very light
equipment for construction, and loadings from equipment working at a failure
zone should not cause progressive failure. The wood chips will only be a
temporary measure against breaching, and after the new dike is in place, they
will no longer be needed for freeboard. MMSD also has a supply of sandbags
which can be filled with mixed soil and wood chips to construct lighweight
temporary repairs.
Response to potential failure conditions will be immediate since the contractor
will have the necessary equipment at the site and can go straight to work without
time-consuming mobilization of men and materials. Past failures have been pro-
gressive in nature because the soil that was added to maintain freeboard as the
dike settled merely added more weight which, in turn, led to more settlement.
The contingency plan will prevent recurrence of this situation.
No natural marsh habitat will be lost as a result of this construction.
A limited area of man-made wildlife habitat will be temporarily lost where
dike modifications are placed at the outboard toe of the existing dike. As
vegetation develops on the soil cover, this habitat will return. No adverse
effect on wildlife (other than the temporary loss of habitat) is expected.
The new dikes require a useful life of 9-14 years, during which time the
sludge will be fully unloaded. The lagoon area will then be allowed to revert
to natural marsh and provide about 120 additional acres of wildlife habitat
and green area for the City of Madison.
The only structure adjacent to the proposed construction is the Chicago,
Milwaukee, St. Paul and Pacific Railway line which is parallel to and approxi-
mately 160 feet north of the centerline of the existing north dike. This
railway line crosses the marsh on a fill constructed in 1854. No records of
fill construction exist. However, it is undoubtedly a displacement fill,
constructed by dumping material until settlement ceased. Consequently, the
base of the fill probably rests on the glacial till underlying the soft marsh
soils. The loads imposed by the proposed north dike modifications will be
very low and the distance between the railway fill and the existing dikes is
relatively large. As a result, no interaction with or effect on the railway
line is expected.
Studies made at MMSD Station 14 in the Cherokee Marsh indicate that the
scars of construction heal very rapidly in the marsh environment. No
controlled revegetation measures were instituted at Station 14, and the
disturbed area was quickly covered with natural grasses that moved in readily
on the exeation spoils. Rapid revegetation of disturbed marsh areas has also
been observed at the Phase I demonstration project.
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Natural vegetation is expected to establish itself on the side slopes of the
rehabilitated dikes shortly after construction. The marsh environment provides
sufficient moisture as well as abundant, fast-growing plant life to readily establish
ground cover on disturbed areas. Straw cover will be placed on the side slopes
of the rehabilitated dikes to help speed revegetation and prevent surface erosion.
Natural vegetation outside the limits of work will be protected.
While sludge is being removed from the lagoons, some spillage of sludge
could potentially occur. This would negate some of the net positive benefit
to be gained by remvoing the source of toxic spills to Nine Springs Creek and
permitting the lagoons to return to a wetland condition. MMSD will take pre-
cautions to insure that such spillage is avoided.
B. Construction and Operation of Expanded Solids Treatment Facilities
The construction of the expanded solids treatment facilities is expected to
have a substantial net beneficial impact because the facilities will alleviate
the problems created by overloading the existing facilities. There will be no
significant adverse impact on the site where the facilities will be constructed
because the facilities will be built on a portion of the existing treatment plant
site which has been graded several times. (Personal communication with staff of
M^ISD). There will be temporary adverse impacts caused by truck traffic carrying
construction supplies and the operation of construction equipment. The major
impact of truck traffic will be in the immediate area of the construction site
where there will be an increase in traffic volume and therefore an increase in the
required road maintenance, an increase in noise levels and consumption of fuel by
the vehicles. The temporary effects of operation of construction machinery will
be an increase in noise levels, temporary deterioration of air quality and consump-
tion of fuel. Since the construction site is not in a heavily populated area, the
number of persons temporarily affected will be minimized.
The operation of sludge treatment facilities could have an adverse impact because
of odors affecting nearby residents unless proper control measures are employed.
Odor control could include abandoning the odor-causing process, imposing equipment
or chemical controls, and buying the property in the region of impact. Odor control
at an expanded plant would be best accomplished by controlling the source. Acquisition
of a buffer zone surrounding the plant as a means of controlling or eliminating odor
complaints is a weak solution. Residential encroachment has already occurred to
the point that effective control by this method would require purchasing expensive
developed properties. The plant expansion and upgrading will involve the abandonment
or modification of all significant odor-producing processes, including the trickling
filters and grit dump in the sludge lagoon. Abandonment of these odor sources will
reduce the total odor problem, and the remaining odor can be managed effectively.
These include odors from the headworks, gravity thickeners, and aeration basins.
Related to potential noise impacts of construction and operation, the following
noise criteria were used by MMSD in their planning process to minimize any noise
impacts.
Although temporary, construction noise could potentially have a significant
impact upon the surrounding area. Most construction equipment used would exceed
an operating noise level of 80 dBA at the source. The most sensitive receptors
of noise in the area are understandably residential dwellings. The nearest dwellings
are curently 500 to 600 feet from the plant property boundary. To prevent inter-
ference with normal speech communications, noise levels in the vicinity of these
receptors should not exceed 55 dBA. The levels observed during construction of the
Fifth Addition appear to be within these limits, and no problem is anticipated.
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If construction noise becomes a problem in the future, however, then a
combination of the following measures might be used.
- Use electric rather than diesel or gas-powered machines.
- Use hydraulic or electric impact tools, rather than pneumatic.
- Use mufflers on all equipment powered by internal combustion engines.
- Mix concrete offsite.
- Keep noisy equipment as far as possible from noise-sensitive areas.
- Avoid construction acitivity during noise-sensitive hours (nighttime).
Typically, the overall treatment facility, even in an expanded mode, would
be a reasonably tranquil operation. Some processes and equipment used in the
final design, however, are potentially noisy, including aeration blowers, exhaust
fans, and worn pump bearings. To avoid any serious conflicts with adjacent
uses, the following noise criteria have been employed in the planning process.
1. Noise levels contributed from the treatment facilities at the affected
property shall not exceed the ambient noise level by more than 3 dBA
for properties zoned residential.
2. If the affected property is commercially zoned, the levels may exceed
ambient by 5 dBA.
3. If the affected property is open space, agricultural or industrial zone
land, the noise levels may exceed ambient by 10 dBA.
The guidelines are accomplished by either localizing noisy operations away
from noise-sensitive areas or abating noise through acoustical treatment.
C. Construction of Solids Handling Facilities
The impacts of this action (i.e. constructing loading docks, etc.) are briefly
but adequately discussed in the environmental assessment Section 5.03 C.
D. Operation of the Organic Solids Reuse Program
This segment of the plan includes use of one of the existing lagoons for
seasonal sludge storage, sludge transfer and intermediate storage, and marketing
of the liquid anaerobically digested sludge to farmers for application to their
agricultural land as a fertilizer.
1. Seasonal Sludge Storage in an Existing Lagoon
The impacts of use of the western half of Lagoon 1 for seasonal storage
of sludge is accurately discussed in Section 5.02 I of the environmental assessment.
2. Sludge Transfer and Intermediate Storage
The impacts of sludge transfer by trucks and potential storage in on-farm
lagoons is adequately considered in the environmental assessment Sections 5.02 H,
5.02 I, 5.02 L, 5.02 M and 5.03 A.
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3. Sludge Application to Privately-owned Agricultural Land
a. General Discussion
Of all segments of the organic solids reuse program this segment has the
potential for the most adverse short-term and long-term effects if the manage-
ment and monitoring programs are not carried out strictly as planned. At the same
time the plan represents substantial benefits to be gained by return of the organic
solids and nutrients contained in the sludge back to the land.
With only minor exception the potential adverse environmental effects which
could result from operation of this sludge marketing and application program
have been considered and the plan has been developed to minimize or eliminate the
potential for those effects. The facilities plan and environmental assessment
present very clearly the environmental considerations which went into development
of the plan.
The critical issues which must be addressed in a sludge management plan with
sludge applied as a fertilizer to privately-owned land include the following:
1) effects on soils, especially potential for accumulation of heavy metals and
nutrients; 2) effects on groundwater and surface water quality; 3) effects on water
quantity; 4) effects on air quality; 5) effects on land use; 6) effects on vegeta-
tion, primarily crops; and 7) effects on public health. These critical issues as
well as some less significant concerns have been addressed in the facilities plan
and environmental assessment. In each case the measures which will be taken to
minimize or eliminate the potential for these effects have also been addressed.
The key to minimizing or eliminating the most significant effects is to insure that
the management program (which includes limiting maximum annual application rates
and total allowable loading rates and controlling time and method of application)
and monitoring program are 'carried out as planned.
There is no mechanism by which the Federal government can insure that the
management and monitoring programs will be carried out as planned. The Wisconsin
Department of Natural Resources, however, is setting up a program to regulate
sludge disposal activities in Wisconsin which includes requirements for self-
monitoring of sludge disposal activities and reporting to the State. It is
felt that the Madison Metropolitan Sewerage District will have the resources
and capabilities necessary to carry out their proposed management and monitoring
programs.
b. Issues Not Considered in the Facilities Plan or Environmental
Assessment or Which Require Further Discussion"
PCBMonitoring
The facilities plan and environmental assessment did not consider the
potential problem of PCB's in the sludge. Region V is recommending that MMSD
analyze their sludge for PCB's and include monitoring for PCB's as part of their
monitoring program. Since MMSD has not previously analyzed its sludge for PCB's,
it is not known whether their sludges are contaminated by PCB's and to what level.
PCB's are of concern because of their known toxic effects. Background information
on PCB's in particular is discussed in a July 1975, paper by the USEPA titled
"Statement of Concerns of the Lake Michigan Toxic Substances Committee Related to
Polychlorinated Biphenyls". The proposed USEPA Technical Bulletin titled "Municipal
Sludge Management: Environmental Factors published in the Federal Register on June 3,
1976, recommends that sludge management programs include monitoring for persistent
organics such as PCB's because of their potential toxic effects.
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Nitrogen
Sections 5.02 C, 5.02 D and 5.02 J of the environmental assessment discuss
some problems resulting from excess nitrogen leaching into groundwater and to
surface water if application rates are not based on crop uptake of nitrogen. One
issue related to nitrogen leaching which has not been discussed here is the fact
that through groundwater contamination excessive nitrates in drinking water can
cause human and animal health problems. Excessive accumulation of nitrate will not
be a problem if proper annual application rates based on crop uptake of nutrients
are followed.
Heavy Metal Considerations - Cadmium
Cadmium is a heavy metal which demands special consideration in developing
a sludge land application program because it can be relatively mobile in the soil
and is not excluded by plants (see page 6-29 of the facilities plan). It is of
particular concern in this plan because the level of cadmium in sludge from Nine
Springs Sewage Treatment Plant is relatively high compared to the levels recommended
by the USDA. USDA recommendations related to sludge which is to be applied to
privately owned land are:
If sludge Cd is.greater than 25 mg/kg the ratio of Cd/Zn must be less
than 0.015. Soil ph should initially be greater than 6.5 and greater
than 6.2 thereafter. Do not apply on land normally cropped to leafy
vegetables.
The level of cadmium in MMSD's treatment plant sludge is currently 73 mg/kg
dry sludge. The Cd/Zn ratio of the sludge is .031. Both of these values are
above USDA's recommendations. Region V, USEPA is recommending that this sludge
management program be implemented even though MMSD sludge has higher cadmium
levels than USDA recommendations. Several factors which should minimize the
effects of applying MMSD sludge on land support our recommendation. These
factors include: 1) application rates which are very conservative, 2) a
source control program which will identify cadmium sources and decrease these
levels significantly, and 3) a monitoring program designed to detect cadmium
uptake in plant tissues. It is essential that MMSD carry out their strict
management and monitoring program as proposed so that effects of cadmium uptake
will be minimized.
The MMSD currently has 94 points established throughout the district at
which samples are taken and flow measurements are made quarterly. The main
purpose of the sampling is to obtain the information necessary to operate the
User Charge System. However, since the establishment of the program in 1976,
samples from a majority of these stations have been analyzed quarterly for
cadmium. MMSD is attempting to locate the areas within its boundaries where
the cadmium concentration is highest. They will then follow up the highest
concentrations in an attempt to isolate potential sources. This is a time
consuming effort which may or may not lead them to major sources of cadmium.
Related to cadmium uptake by leafy vegetables, there are certain precau-
tionary measures which MMSD should take. On page 6-20 of the organic solids
reuse plan it is stated that "The total loading should be reduced for land
which will be used for leafy vegetables, by one-half because cadmium tends to
accumulate in the leaves." Because of the relatively high level of cadmium
in MMSD sludge, it is strongly advised that MMSD follow USDA's recommendation
as a precautionary measure and not apply their sludge to land on which leafy
vegetables will be grown until the source control program has significantly
lowered the sludge cadmium levels.
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Economic Effects
Since the sludge will be applied to cropland as fertilizer, it would appear
that this program could potentially impact on the commercial fertilizer market.
In reality, this program will have little impact on the commercial fertilizer
market for the reasons stated in Section 6.4 of the facilities plan.
Effect on Endangered or Threatened Species
The proposed project is not expected to have an impact on endangered or
threatened species of plants or animals.
Effect on Soil Structure
MMSD intends to include as part of their sludge application site management
program provisions to insure sludge application will minimize soil compaction,
destruction of aggregate structure, puddling and increased susceptibility to
erosion.
Soil Conservation Practices
Since the sludge will be applied to privately-owned land at the farmer's
request, it is out of EPA's authority to control conservation practices on the
land used. However, we are recommending that MMSD suggest to the farmers that
they contact their local soil conservation service and extension offices if they
require assistance in determining the best conservation practices to use.
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CHAPTER 6
RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE
MAINTENANCE AND ENHANCEMENT OF LONG TERM PRODUCTIVITY
A. Water Quality
The water quality of the surface waters of Nine Springs Creek, the Yahara River
below the confluence with Nine Springs Creek, and in Mud Lake have been adversely
affected in the past by the release of approximately 85,000,000 gallons of lagoon
supernatant. This resulted from the failure of a portion of the Lagoon 2 dike in
1970. The spill was cited as the cause of a fish kill which occurred downstream
of the spill..,;.An additional dike failure occurred in 1973 but little supernatant
was spilled, prior to the sealing of the failure zone, by a mud wave which developed
in the lagoon. The proposed actions would alleviate the threat of future spillage
to nearby surface waters by remqvif» the material now stored in the lagoons.
Groundwater quality has not been affected by the storage of sludge in the
lagoons.
Development of annual application rates, proper site management, and close
monitoring of environmental factors at the application sites would minimize
possible adverse impacts on the surface and groundwater quality from developing
over a period of time.
B. Open Space
Accidental spillage of supernatant from the storage lagoons in the past has
contributed to the temporary degradation of the water quality areas downstream
from the lagoons. The fish kill may have decreased the fish populations in these
areas and hence the recreational opportunity afforded to fisherman by their
presence. Aesthetic enjoyment of these areas may have been temporarily decreased
by the presence of dead fish in the water. Increased weed and algae growth may
also have been accelerated by the discharge of nutrients with the spills.
The unstable condition of the dikes of Lagoon 2 appear to be susceptible to
structural failures in the future if corrective measures are not taken. The proposed
actions would remove the threat of future spills. In addition to the removal of
the threat to the water quality, the proposed actions would allow the land area
currently devoted to Lagoon 2 (approximately 85 acres) to eventually return to
its natural sedge-meadow condition. This would be a distinct departure from
the general practice of draining wetland areas to provide additional acreage
farming or other development.
C. Long Term Productivity of Application Site Soils
If the buildup of metal concentrations is not carefully managed and limited
as the plan proposes, there is the potential for adverse effects on long-term
productivity of the land on which sludge is applied. Proper program management
will insure that total allowable loadings are not exceeded and the private
agricultural land on which the sludge will be applied will be useable and
productive for future generations.
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CHAPTER 7
FEDERAL/STATE AGENCY AND PUBLIC PARTICIPATION
A. Facilities Planning Advisory Committee
The Facilities Planning Advisory Committee (FPfC) was established in the fall
of 1974 by the MMSD to act as an advisory group for the engineering firms engaged
to complete the Facilities Plan. Members of the FPPC included representatives from
the MMSD, Dane County Regional Planning Commission, Rock County Board, Rock Valley
Metropolitan Council and an independent private citizen. Representatives of this
Agency and the Wisconsin Department of Natural Resources also attended these
committee meetings.
The committee met regularly during the course of the study to monitor the
progress of the study work and to offer advice to the engineers regarding areas
of concern. The FPfC meetings served as a time for presentation of work progress;
to interchange views on areas of concern; and to identify additional study tasks.
All committee meetings were open to the public and news media.
B. Public Information Meetings
A public information meeting was held November 6, 1973, in Madison by MMSD
to present to the public an account of the progress of the sludge disposal
study being conducted at that time by the engineering firm of Roy F. Weston, Inc.
On May 15, 1974, a second public meeting was held in Madison by MMSD to
present the recommendations of the Weston report and of the addendum which had
been prepared by the staff of the MMSD. It was the recommendation of this report
that the alternative of the land application of liquid anaerobically digested
sludge be developed. Public comments on this recommendation were favorable.
The Capitol Community Citizens (CCC), a concerned group of area citizens,
submitted a position statement to MMSD on May 30, 1974, stating that they
approved of the land application of sludge only on a temporary basis. They
suggested that a long-term sludge disposal program should include the composting
of the sewage sludge along with the solid wastes generated in the area.
The commissioners of MMSD, after consideration of the Weston report recom-
mendations, and public input, resolved on June 7, 1974, that the disposal of
sludge should be handled through a land application program. On July 15, 1974,
the MMSD commissioners resolved that the land application program should be
implemented immediately.
A letter describing the land application alternative and a questionnaire
requesting their comments was sent by MMSD to area farmers in August of 1974.
The comments received from the farmers were quite favorable and a high degree
of interest in the alternative was shown.
During September of 1974, Wisconsin Pollutant Discharge Elimination System
(WPDES) Permit No. WI-0024597 was received. It was stated in the permit that
funding for the construction of any additional wastewater treatment and disposal
facilities, including sludge treatment and disposal facilities, would not be
forthcoming until a Facilities Plan was completed.
Contracts were awarded for the preparation of a Facilities Plan late in 1974.
Public input to the study was continued through the FPflC and through a series
of public meetings held during the course of the study. Public meetings
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conducted by MMSD were held on June 26, 1975, at the Town of Dunn Town Hall, and
again on October 2, 1975, at the Town of Fitchburg Town Hall. At each of these
meetings progress of the sludge study was reported. Various methods of field
application were discussed as were the potential advantages and disadvantages
of land application program. Interest expressed in the program by members of
the farm community in attendance was high at each meeting.
A demonstration of liquid and dry sludge spreader trucks manufactured by
Big Wheels, Inc. was conducted for members of the FPAC and other interested
persons on May 30, 1975, at.the Nine Springs Wastewater Treatment Plant. On
September 4, 1975, a demonstration of a dredge manufactured by Mud Cat was
conducted at the existing sludge lagoons.
C. Final Public Hearing Held by Applicant
On April 28, 1976, the final public hearing conducted by MMSD was held
at the Town of Fitchburg Town Hall. The purpose of this hearing was to present
to the public the recommended organic solids reuse plan and the assessment
of that plan on the environment. Public comments and questions on the program
were also accepted for the record. Notice of the hearing was published in
area newspapers thirty days prior to the hearing. Copies of the Environmental
Assessment Statement were available for public review for a period of thirty
days prior to the hearing.
Approximately 80 to 100 people attended the hearing including members of the
local farm community; City of Madison, Dane County, State of Wisconsin and Madison
Metropolitan Sewerage District personnel; and other interested member of the public.
A member of the engineering firm of CH2M-Hill presented a summary of the work which
was done in the evaluation of the various alternatives available for the reuse
program and a review of MMSD's sludge handling and storage programs. Members of
the engineering firm of O'Brien and Gere presented a summary of the work which
was done in evaluating the potential impacts which the proposed reuse program may
have on the environment.
Comments and questions from the members of the public present were taken. None
of the comments expressed or questions raised at the hearing were negative to the
proposed reuse of sludge on agricultural lands. Several members of the farm com-
munity spoke in endorsement of the proposed program. Another endorsement was
given by Professor Arthur Peterson, Soil Science professor at the University
of Wisconsin. A representative of the City of Madison, Engineering Department
read into the record a resolution, dated April 28, 1976, which had been passed
by the City of Madison Common Council and signed by Mayor Paul Soglin, also
endorsing the proposed program.
Some concerns were expressed regarding certain aspects of the proposed program,
such as the suitability of lands receiving sludge application for development in
the future. A review of material presented in both the Organic Solids Reuse Pro-
gram and the Environmental Assessment Statement indicated that such concerns had
been considered and accounted for in the development of the program.
Written comments were accepted at the MMSD offices for a period of 15-days
following the public hearing. Any written comments which have been received as
well as an official transcript of the public hearing are contained in Volume VIII
of the Facilities Plan. The official transcript also contains a copy of the
notice, a list of th newspapers which published the notice as well as other
materials.
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D. Hearing on Draft Environmental Inpact Statement
A draft EIS was filed with the Council on Environmental Quality on October 29,
1976, and was distributed for public comment.
This hearing was held on Tuesday, November 30, 1976, at 8:00 pm at the Fitchburg
Town Hall, Dane County, Wisconsin.
Complete hearing transcripts may be viewed at USEPA, Region V, Chicago, Illinois;
Wisconsin Department of Natural Resources, Bureau of Environmental Impact, Madison,
Wisconsin; and at the Janesville Public Library, Janesville, Wisconsin.
Approximately thirty people were in attendance.
The following is a summary of comments received at the hearing along with EPA
responses to comments where appropriate. The actual correspondence received can
be found in Appendix A. (C=Comment, R=Response).
Wisconsin Department of Natural Resources Southern District Office
C - We have reviewed the EIS and we feel it was rather well done.
It did address many of the problems that we felt might be encountered in
that situation.
The Southern District does agree with the concept of incorporating the material
into the soil. We think it is a wise use to recycle those nutrients.
We do, however, see a few potential problems associated with the program. Most
of these were adequately addressed in the statement.
We feel the potential problems will be involved in the actual implementation of
the program such as has been pointed out with potential problems with heavy
metals, potential surface water pollution due to runoff or perhaps even public
acceptance of the program. I think it's been discussed tonight that that
apparently will be no problem.
We felt that most of these problems can be overcome just by good program
supervision and management and that is to say when this program is initiated.
R - In summary, these comments indicate that the Department of Natural Resources
feels that there are some potential problems which could occur because of this
project. However, they feel that a good program of supervision and management
will overcome these potential problems. We have expressed this same concern
several places in the EIS. We feel that if MMSD carries out their program as
proposed, any potential adverse effects will be minimized and the maximum
positive benefits will be gained.
Dane County Regional Planning Commission
C - In our opinion, all of the major areas of environmental concern are adequately
addressed in the plan and the environmental impact statement. The proposed
program, if implemented in accordance with these documents, appears to be
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environmentally sound as well as cost-effective. In addition, the use of
organic residuals from the wastewater treatment plant as a substitute for
commercial fertilizers represents a direct form of recycling, and should
reduce the demand for commercial fertilizers.
If the proposed program is to be successful, the stringent management and
operation controls and environmental monitoring called for in the plan are
absolutely essential. Because the program relies on the voluntary coopera-
tion of individual landowners and units of government, it is critical that
the Madison Metropolitan Sewerage District conduct the operation so as to
prevent any occurrences of environmental degradation or other possible causes
of public complaints. This will entail a high level of MMSD control of
transporting and applying the organic solids, including locations, methods
and timing, as well as extensive environmental monitoring.
R - As we stated in the previous response as well as in the EIS, we feel that if
MMSD carries out their program as proposed, any potential adverse effects
will be minimized and the maximum positive benefits will be gained.
E. Correspondence Received Related to the Draft EIS
Federal
United States Department of Agriculture, Soil Conservation Service -
November 23, 1976
United States Department of the Interior - December 23, 1976
State
State Historical Society of Wisconsin - December 10, 1976
Wisconsin Department of Natural Resources - December 23, 1976
Local
Dane County Regional Planning Commission - November 23, 1976
(Their comnent letter was entered as part of the record at the EIS hearing).
Holtzman Company - November 12, 1976
The following are comments received related to the draft EIS subsequent to the
EIS hearing along with EPA responses to the comments as appropriate.
(C=Comment, R=Response). In some cases comments were made related to portions
of the applicant's facilities plan which was provided as Part II of the draft
EIS as supporting information. Since the text of the applicant's plan will
not be revised as part of the final EIS, we have included the appropriate
information in the responses or in the final EIS. The actual correspondence
received related to the EIS can be found in Appendix A.
United States Department of Agriculture - Soil Conservation Service
C - More consideration needs to be given to the protection of lands where the
sewage sludge will be disposed. Careful conservation treatment and management
of disposal areas will be needed to minimize pollution.
R - The site investigations, monitoring programs and careful development of
annual and total application rates proposed by MMSD if carried out as
planned will insure that pollution is minimized.
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C - Existing conservation practices on disposal areas should be maintained.
R - Since the sludge will be applied to privately-owned land at the farmer's
request, it is out of EPA's authority to control conservation practices
on the land used. However, we are recommending that MMSD suggest to the
farmers that they contact their local soil conservation service and extension
offices if they require assistance in determining the best conservation
practices to use.
C - No SCS projects will be affected by the proposed project.
R - The comment is of an informational nature and has been noted.
United States Department of Interior
C - The environment and impacts of the proposed action are described inadequately
with reference to Nine Springs Creek. Water quality and fishery information
for Nine Springs Creek are not presented, nor are impact of dike repair and
sludge removal on the fishery of Nine Springs Creek or on the existing wildlife
and habitat addressed. This information should be made part of the final EIS.
R - The text of Chapters 2 and 5 of the final EIS includes fishery and habitat
information for Nine Springs Creek and adjacent wetlands and potential impacts
of dike repair and sludge removal on them. We were not able to obtain water
quality information for Nine Springs Creek in the area of potential impact.
However, the effects of dike repair and sludge removal can still be determined.
The intent of dike repair and sludge removal is to protect the water quality
and biota of the creek by preventing toxic spills into Nine Springs Creek.
It is MMSD's intention to carry out these actions in a manner that will protect
this resource. Therefore, we feel there can only be a net positive impact
on water quality and biota in the area.
C - Since much of the area surrounding the lagoons is high-quality wetland habitat,
we ask that you contact the Green Bay Field Office of the U. S. Fish and Wild-
life Service with more detailed information on the dike repair, to ensure that
all measures will be taken to minimize harm. A Department of the Army Section
404 permit may be required for placement of fill in these wetlands. The District
Engineer, U. S. Army Engineer District-Rock Island, should be contacted for
additional information.
R - ^MSD has contacted both the Corps of Engineers and the U. S. Fish and Wildlife
Service Green Bay Field Office with more detailed information on the dike
repair. The Corps of Engineers has indicated that a Section 404 permit will
not be necessary for the dike maintenance. The U. S. Fish and Wildlife Service
has no objection to MKSD proceeding with their proposed dike rehabilitation
as planned. Correspondence from these agencies can be found in Appendix A.
C - The discussion of recreational areas and activities in Section 2.13 of the
environmental assessment is not an "adequate summary of these subjects,"
as stated in Part I. Not only should a list of parks (and other recreation
facilities) be included in the discussion, but a site location map is necessary
to get a clear picture of the relationship of open-space land to the project
area. A land-use map indicating the actual spectrum of uses should supple-
ment figure 6-5 (Part II) to aid in the review process.
R - The paragraph on recreation and open-space on page 2-19 of the draft EIS
referred to the environmental assessment for a general discussion of recreation
and open-space. The paragraph also indicated that a list of parks in the
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area was included in the environmental inventory for MMSD's facilities plan
but was excluded from the draft EIS. We felt that the general summary in
the assessment was adequate and that it was not necessary to list all the
parks in the entire study area in the draft EIS because we did not feel
that any additional information would aid in identifying the impacts of the
project. The major part of the project involves application of sludge to
suitable private cropland at farmer's requests. Since these application
sites have not yet been identified, we still feel that listing recreational
areas and parks in the entire potential application area would not aid in
identifying impacts from sludge application.
We do agree, however, that some additional information on recreation and
open-space and other land uses in the vicinity of the Nine Springs Sewage
Treatment Plant site is warranted since this project also proposes lagoon
dike rehabilitation, lagoon abandonment, and some sludge treatment facility
expansion which have the potential to impact on the area adjacent to the
plant site. Land use in the vicinity of the plant site is described in
Chapter 2 of the Final EIS. The section of Chapter 2 related to recreation
and open space has been expanded to include discussion of recreation and
open space areas in the vicinity of the plant site.
C - The proposed Nine Springs Corridor/Dane County E-way (environmental way) has
been overlooked. In the eastern portion of the Nine Springs Corridor of the
Dane County E-way, 139.5 acres, adjacent to the public land controlled by the
Madison Metropolitan Sewerage District, have been acquired with monies from
the Land and Water Conservation Fund. Section 6(f) of the Land and Water
Conservation Fund Act of 1965, as amended, states that no property acquired
or developed with these funds can be converted to other than public outdoor
recreation use without the approval of the Secretary of the Interior.
R - As indicated in this comment, Dane County Regional Planning Commission has
proposed E-way corridors. The E-way corridor system consists of public roads,
streets, walkways and open-space systems. These connected corridors enclose
Madison in an environmental loop which highlights its prominent educational,
ecological and environmental characteristics. The Nine Springs Creek corridor
in the vicinity of Nine Springs Sewage Treatment Plant includes the parcel of
land mentioned in this comment. It is parcel 13, one of the parcels which is
shown as being in public ownership on Figure 2-5 in Chapter 2 of the Final EIS.
It is held by Dane County and has been set aside for future park use. For
a further description of land use and ownership in the Nine Springs E-way
corridor refer to Chapter 2 of the Final EIS.
C - The Madison Metropolitan Sewerage District has orally indicated plans for
coordination with Dane County and the Wisconsin Department of Natural Resources
regarding one-time sludge deposition on E-way land before seeding and public
use. A thorough discussion of these plans should be included in the statement
along with site maps indicating the relationship of the E-way to the proposed
project area.
R - WSD was asked by the Director of the Dane County Parks to apply sludge on
approximately 60 acres of County acquired farmland within the proposed E-way.
The land in question had previously been planted in corn and is not in the
best of condition. The Parks Department felt that the land was in need of
organics and fertilization to insure that a good grass cover crop could be
grown prior to public use. The sludge was applied as requested. The text
of Chapter 2 has been revised to discuss the E-way and its relation to the
project area.
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C - The groundwater monitoring program seems too arbitrary in its specifications,
in view of the many natural variables and the importance of groundwater to
public health. Plans now call for baseline monitoring followed by a check
on nitrate nitrogens and total dissolved solids at three-year intervals for
wells within 500 feet of any area of sludge application. Shallow water table
conditions apparently prevail over most of the area (p. 6-10 and 6-11); thus,
the probability for downward migration to groundwater and accelerated movement
of pollutants in groundwater flow is fairly high. Most of the reported rates
of groundwater movement are in the range from tenth of a foot to over three
feet per day (figure 6-1). Since it is anticipated that domestic supply wells
will commonly be perhaps 200 feet away (p. 6-8), the three year sampling interval
may give protection only in the areas of slowest movement—particularly if some
mounding of the water table occurs in the areas of application. Therefore,
we believe that although a maximum precautionary sampling interval may be
appropriate, the results of the groundwater study for each site (p. 3-7)
should be used to determine the need for more frequent sampling of groundwater.
For example, in some parts of the project area it is evident that groundwater
may travel 200, 500, or even 1,000 feet in a year or less (p. 6-4 and figure 6-1).
On the other hand, the slow movement of groundwater in some parts of the area
suggest that the travel of pollutants to affected wells may exceed the arbi-
trary 5-year post-application limit set on page E-9. Because of the shallow
depths to groundwater, testing to determine the rate of movement of groundwater
toward given wells should not be an excessive burden. This seems to be especially
true inasmuch as the allowable distance to wells is to be lowered to 200 feet
(p. 6-8). Monitoring should be much more frequent in the vicinity of storage
lagoons, in order to assure integrity of the clay linings. We agree also in
general (p. 4-4 of the environmental assessment) that the baseline inventory
should include all existing wells and groundwater sources within one-half mile
of each application site, and periodic monitoring of nitrate nitrogen and total
dissolved solids as indicators of pollution should be on an annual basis as a
minimum.
R - The groundwater study for each site will consist of the preapplication back-
ground monitoring and post-application monitoring outlined in the facilities
plan (Section E.4). We are recommending to MMSD that their well and groundwater
source monitoring program be expanded to include a higher frequency of well
monitoring. We would recommend that the well monitoring be done annually
instead of every three years as they propose, that it be done for all wells
and groundwater sources within one-quarter mile of each application site and
that the sampling be conducted during the summer months or in the periods
subsequent to application of sludge to nearby sites. If farm storage lagoons
are constructed, groundwater monitoring programs specific for each site should
be set up to insure protection of groundwater. It has been the experience of
this Agency that the existing technology does not entirely eliminate the
potential for groundwater contamination from these sources. Related to testing
to determine the rate of movement of groundwater, we feel that the cost of
testing every site would be an excessive burden for the applicant especially
since it is possible that sites could change every year and since the applicant
proposes a conservative sludge application rate. If the features of a partic-
ular site indicate the need, the applicant will be responsible for performing
additional tests.
C - The statement should also include at least representative values for permeability
and/or transmissivity, and storage coefficient or specific yield of the soils
and groundwater bearing materials in order that the evaluations of potential
for groundwater impacts can be appraised.
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Wisconsin Department of Natural Resources
C - Page 2-4 (4.) , second paragraph - Threatened plant species should be avoided.
Section 2.07 of the Environmental Assessment does not elaborate on the effect
of the proposed project on threatened species.
R - Page 5-4 of the final EIS has been revised to indicate that it is not expected
that the proposed project will have an impact on any endangered or threatened
species of plants or animals.
C - Page 2-6 (2.) - Present land use in the project area should be described.
R - We feel that the information on land use discussed in this section of the draft
EIS was adequate to be able to determine the impact of the proposed action.
Since land application sites have not yet been determined, we felt that only
general discussion of land use in the potential application area was warranted.
The referenced section of the draft EIS presented a more specific discussion of
land use in the vicinity of Nine Springs Sewage Treatment Plant. To supplement
this discussion we have included several figures in Chapter 2 of the final EIS
which depict present and proposed land use, zoning, committed development, and
ownership in the area of Nine Springs Sewage Treatment Plant. In addition, the
section of Chapter 2 on recreation and open space has been expanded to discuss
the area around the plant site and its inclusion in the "E-way" corridor system
proposed by Dane County Regional Planning Commission.
C - Page 2-6 (5.) - Legal descriptions of the locations of unique scientific or
natural areas should be included.
R - Of those areas listed on Table 2-2 there is only one site which could potentially
be impacted on by this project. It is listed as Upper Mud Lake wetlands. The
referenced section has been expanded to discuss these wetlands.
C - Page 2-6, Odor - This section states the information contained in the Environ-
mental Assessment is incomplete. Additional summary information should be added
to describe the potential odor problems.
R - The only additional information on odors which can be incorporated into the
above-referenced paragraph is the fact that some of the significant odor
producing processes on the Nine Springs Plant site in the past will be abandoned
or modified because of this plant expansion and upgrading. The trickling filters
and grit dump in the sludge lagoon were two significant odor producing processes
in the past.
Chapter 5, Section B has been modified to discuss the potential odor impacts
which could result from the construction and operation of the proposed expanded
solids treatment facilities. Since the significant odor producing processes
will be abandoned or modified as part of this plan, there will be a net beneficial
impact on odors resulting from the implementation of this project.
C - Page 2-19, Recreation and Open Space - Why were recreational areas and parks
excluded from the report?
Page 2-19 - Facilities Report information should be summarized and included.
The paragraph on recreation and open space on page 2-19 of the draft EIS referred
to the environmental assessment for a general discussion of recreation and open
space. The paragraph also indicated that a list of parks inventory for MMSD's
facilities plan but was excluded from the draft EIS. We felt that the general
summary in the assessment was adequate and that it was not necessary to list
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all parks in the entire study area in the draft EIS because we did not feel
that any additional information would aid in identifying the impacts of the
project. The major part of the project involves application of sludge to
suitable private cropland at farmer's requests. Since these application
sites have not yet been identified, we still feel that listing recreational
areas and parks in the entire potential application area would not aid in
identifying impacts from sludge application.
We do agree, however, that some additional information on recreation and open
space in areas in the vicinity of the Nine Springs Sewage Treatment Plant site
is warranted since this project also proposes lagoon dike rehabilitation, lagoon
abandonment, and some sludge treatment facility expansion which have the potential
to impact on the area adjacent to the plant site. Land use in the vicinity of
the plant site is described in Chapter 2 of the final EIS. The section of
Chapter 2 related to recreation and open space has been expanded to include
discussion of recreation and open space areas in the vicinity of the plant site.
C - Page 5-1 - The subjects of increased road maintenance, increased noise generation
and the numbers of persons in the affected area should be addressed.
R - More detailed information is not available on the probability of increased road
maintenance other than to acknowledge that it is likely to result from increased
traffic in the vicinity of the construction site during the two-year construction
period.
Related to potential noise impacts the following noise criteria were used by MMSD
in their planning process to minimize any noise impacts. This additional infor-
mation has been incorporated into the section of Chapter 5 (Section B) to which
DNR's comment relates.
C - The Department's staff feels that this section of the document failed to offer
the reader adequate summary information.
R - The summary sheet and introductions to the sections of the EIS have been revised
to provide additional summary information.
C - The many references to the facilities plan and the Environmental Assessment make
Part I very difficult to read.
R - In attempting to not duplicate the information presented in the facilities plan
and environmental assessment it was necessary to sacrifice some readibility.
C - Part 2 - Specific Comments
Page 6-7 - A 200-foot horizontal separation of the sludge site from an existing
well may be satisfactory in some cases. However, additional evaluations may be
necessary on a site specific basis depending on the topographic, hydrologic and
geological features of the area.
R - This comment will be given as a recommendation to MMSD to incorporate into their
site management program.
C - Page 6-9 - The evaluation of soil structure may be a useful eighth criterion for
soil suitability tests. Aeration, tilth improvement and ultimately fertility
will be directly affected. Management of the program would have to insure that
sludge application would minimize soil compaction, destruction of aggregate
struction (puddling) and increased susceptibility to erosion.
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R - Soil structure is just one of many other factors which could have been used
to evaluate the soils. While soils structure was not specifically identified
as a factor, its consideration is included in such factors as permeability
and soil texture. All of the soils, regardless of soil structure, will be
managed to minimize soil compaction, puddling, and erosion.
C - Page 6-12 - The discussion of Cation Exchange Capacity (CBC) should also
relate to fertility.
R - This particular discussion of CEC on page 6-12 of the facilities plan did not
discuss soil fertility as it relates to the CEC because it was directed toward
determining soil suitability for sludge disposal primarily for calculating the
heavy metal loading rates for each soil. As the DNR points out in this
comment, the CEC of a soil does affect the soils fertility. Exchangeable
cations are the primary source of calcium, magnesium and potassium in plant
nutrition. The exchangeable cations represent nature's mechanism for insuring
a continuous storehouse of cations that are readily available for plant growth.
C - Page 6-14 - Crop Suitability - This section should include a discussion of
soluble salts and potential imbalances of macro and micro element requirements.
If additional amendments or supplements would be required, they should be
explained.
R - We do not feel it is reasonable or necessary to require that MMSD's facilities
plan include a discussion of specific amendments or supplements which would be
required since they would vary with factors such as existing soil condition
and crop to be grown. However, we can offer some general statements in this
regard. Some fertilizer supplementation of the sludge could be required
depending on the soil type and condition and crop grown. Since sewage sludge
typically is low in potassium (K) relative to its nitrogen (N) and phosphorus
(P) contents, K fertilizer may need to be supplemented. MMSD's monitoring
program includes soil analyses which should identify any potential nutrient
imbalance to prevent crop deficiencies and maximize crop yields. We feel
that there was an adequate discussion of dissolved salts in the sludge pre-
sented on page 6-19 of the facilities plan. The discussion indicates that
dissolved salts in the sludge should not cause salinity problems to crops
grown on sludge-amended land.
C - Page 6-18, Heavy Metals - "Other" heavy metals should be named and discussed
in Table 6-4, page 6-19. Heavy metal concentrations should be stated. What
are the heavy metal sources? To what extent will heavy metals be attenuated
in the soil atmosphere? Potential threats to groundwater resources should
be clearly explained.
R - We feel that MMSD's facilities plan (pages 6-18-6-19) presents an adequate
discussion of heavy metals and their bases for determining heavy metals
loadings. They first discussed the heavy metals for which more specific
information on safe loading rates is available (Zn, Cu, Ni, and Cd). They
then discussed the metals for which no standards have been developed specifi-
cally related to sludge application. They then set a limit for metals other
than Zn, Cu, Ni, and Cd by applying heavy metal criteria for irrigation water.
They then separately discussed mercury. The environmental assessment (paqes
5-2, 5-3, 5-6, 5-7, 5-10) and the EIS (Chapters 5 and 6) also discuss heavy
metals and how any potential impacts will be mitigated.
C - Page 6-20 - The methods employed to determine sludge application rates for
crops intended for human consumption are not fully explained.
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R - These total sludge application rates for crops intended for human consumption
were developed for MMSD by its consultants. These total sludge application
rates were arbitrarily determined in recognition of the fact that heavy metals,
particularly cadmium, can accumulate in soils and can be taken up by plants in
differing ways. The leafy and vegetative portions generally accumulate cadmium
in higher concentrations than the reproductive tissue (pea and corn seeds). In
order to increase the safety factor for human consumers MMSD's consultant elected
to arbitrarily reduce the total sludge application rate for crops grown for
direct human consumption. Since leafy vegetables generally are greater accumu-
laters of cadmium they elected to reduce the total sludge application by 1/2
for these crops. For crops such as processing peas and sweet corn which
accumulate less cadmium in the edible portions of the plant they elected to
reduce the total sludge loading rate by 1/4 as an additional safeguard.
Related to this subject Wisconsin Department of Natural Resources sludge
management guidelines, USEPA sludge management guidelines and USDA sludge
management recommendations recommend avoiding growing leafy vegetables on
sludge-amended land, particularly when the sludge contains a relatively
high level of heavy metals such as cadmium.
C - Page 6-21, Tables 6-5 and 6-6 - The source of the information presented in
these tables should be given. If this information was researched by the
consultant, does EPA agree with the analysis presented?
R - How this information (total application rates and annual application rates)
was developed by MMSD's consultant is adequately discussed in the facilities
plan Section 6.3. Soil suitability for sludge application was developed
taking several factors into consideration. Crop suitability for sludge
application was then discussed. The development of annual sludge application
rates based on nitrogen uptake of crops was then presented. In addition,
total sludge application rates based on constituents which accumulate in
the soil, particularly heavy metals, was discussed. Tables 6-5 and 6-6
represent estimates of annual and total sludge application rates which were
developed by MMSD's consultants in the manner discussed in previous sections
of the chapter. The analyses done by MMSD's consultants is in keeping with
available EPA guidelines with one exception. Current guidelines recommend
as an additional safeguard that growing leafy vegetables be avoided on sludge-
amended land when the sludge has a relatively high content of heavy metals
such as cadmium.
C - Page 6-22 - The summary section should include plans for long-term monitoring.
R - We feel that MMSD's comprehensive monitoring,program was adequately discussed
in other portions of the facilities plan such as Appendix E so as not to
require duplication in this particular section.
C - Page 6-22, Section 6.4 - The Department feels that it is in the best interest of
the proposed project that a factual statement outlining the expected benefits
of sludge application be included in the final statement. This would prove very
useful in the public's understanding of the document.
R - The summary sheet and Chapter 1 - Background of the final EIS have been revised
to include additional discussion of the benefits of the proposed action.
C - Page 6-23 - How many acres of the potential 5,000 acres have been evaluated as
sludge sites?
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R - The 5,000 acres mentioned as belonging to farmers apparently willing to use
sludge represents a potential market. Detailed site investigations, evaluating
land as sludge application sites will not be conducted until the organic solids
reuse program is actually underway and the fanners have formally requested that
their land be used as sludge application sites.
C - Page 6-26 - How will grazing near restricted sludge application areas be
controlled? In the event of cattle intruding on a restricted site, what are
the potential hazards? This may be particularly sensitive in the area of
high producing dairy herds.
R - Since MMSD's program involves marketing of sludge to farmers at their request
for application to their land, the grazing restrictions discussed on page 6-26
can only be carried out through voluntary action on the part of farmers after
having been informed by MMSD of the need for these controls.
On page 8-3 of the plan MMSD stated their intent to inform farmers accepting
sludge of the necessary buffer areas and other areas of special concern. We
will recommend to MMSD that each farmer be given a brochure explaining the
various precautions which should be taken to insure that the potential for
environmental degradation is minimized while benefits are maximized. We will
also recommend that MMSD make spot checks to insure that farmers are taking
the necessary precautions.
Since MMSD is proposing a conservative application rates, we expect that hazards
which could occur if cattle inadvertently strayed onto the application site on a
one-time or infrequent basis should be minimal. If rain or some other method
has not removed the sludge from the plants and/or sufficient time has not
elapsed since sludge application to allow for pathogen die-off, there are
potential hazards which could occur. The cattle could directly ingest the
sludge with its nutrients, contaminants (such as heavy metals), and perhaps
pathogens. We do not feel that the risk to cattle or human consumers would
be very high if si"-h an event should occur. However, in the absence of
specific data on the level of risk, we feel it is important for the farmers
to recognize the potential risks and take the necessary precautions to
prevent such occurrences.
C - Page 6-26 - The effects of soil wetting, water balance, and leaching potential
require a more thorough explanation.
R - The maximum annual sludge application will be approximately one-half inch of
liquid, while the total annual precipitation in the Madison area is approxi-
mately 36-inches. It would appear, therefore, that the soil wetting, water
balance and leaching potential due to the sludge are minimal and minor compared
to normal precipitation. Although soil wetting by liquid sludge would be a
minor problem, it can be alleviated by the management suggested on page 6-26
of the plan. The conservative application rate MMSD proposes would not have
the same problems as programs where several feet of water is applied to the land.
C - Page 6-28 - The need for 10 to 20 percent additional herbicide usage should be
explained. Will this alter acceptance of the program in the farm community?
What price considerations have been taken into account to insure the sludge plus
the additional herbicide will be competitive with commercial amendments. The
benefits of increased organic material should be strongly emphasized.
R - The cost of herbicide use is normally in the range of $3-$20 per acre per year.
Increasing the amount of herbicide applied by 10-20 percent will increase the
farmer's cost by $0.30-$4.00 per acre. This will be more than offset by the
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fertilizer value of $45.00 per acre. Several farmers who noted this problem
were quick to add that they would continue to use the sludge.
The benefits of increased organic material are noted, but it should not be
strongly emphasized because, unless sludge applications of many tens of tons
per acres are applied, the beneficial effect will be minor.
C - Page 6-28 - The statement appears to lack information concerning types of
pathogenic organisms, any potential problems and how good management will
minimize potential adverse effects.
R - We agree that the Public Health Aspects statement lacks information concerning
specific pathogenic organisms, however, we believe it is adequate to address the
pathogen question in the terms stated. Most of the public would not understand
nor could they relate to specific organisms. For the informed public, the
references cited in the statement provide the detailed information referred to.
The pathogen question is always a primary concern. In anticipating this
question, the statement on page 6-28 was prepared by MMSD as a handout for
those attending the public meetings held by MMSD. The handout was picked up
by many of the attendees and, as far as we know, adequately addressed the
potential problems and how these potential problems would be minimized by
good management.
C - Page 6-31 - Soil classifications other than Class 1 or 2 should be included.
Is 72 tons per acre correct?
R - This discussion was used to indicate a general concept and does not require a
discussion of a Class 3 soil. A Class 3 soil could accept 48 tons (2 tons
per year for 24 years). Seventy-two tons equal 3 tons per year for 24 years.
Class 4 soil could not accept application.
C - Page 7-3 - Facilities Requirements - Farm storage lagoons are discussed as
sites for seasonal storage of sludge. The location of such lagoons is
extremely important, particularly if seepage or leakage should occur. If
such lagoons are with 500 feet of navigable water, Section 30.19, Wisconsin
Statutes, would be applicable.
A pipeline distribution system presents the additional potential problem of
leakage should a break occur. Therefore, the location of such a pipeline
with respect to lakes or streams is very important. Section 30.20 permits
would be required for all stream crossings.
R - As indicated in page 7-3 of the plan only the farm storage lagoons or pipeline
would be utilized if the District would obtain a commitment from a farmer to
accept sludge for several years. It is therefore not known at this time
where any of these structures would be located. We will reconmend to MMSD
that DNR's siting concerns be taken into account when constructing any such
structures.
C - Page 7-6 - The discussion of existing methods of sludge incorporation points
out that large pieces of frozen sludge were left on top of the frozen ground
in February of 1975. During the spring thaw, the sludge was washed into
Lake Waubesa which resulted in adverse public reaction. Such mismanagement
in the future could jeopardize the entire project.
R - As we indicated in the summary sheet and several other places in the EIS,
we feel that the potential impacts of MMSD's proposed organic solids reuse
7-13
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plan can be minimized or avoided only if MMSD's proposed management programs
are strictly adhered to.
C - Page 8-19 - Additional data should be presented on the reasonableness of the
fee schedule.
R - Table 8-3 gives a complete breakdown of the sludge use fees in relation to
the benefit gained. MMSD feels it is reasonable that a farmer with 40 acres
would pay a first year fee of $220 and subsequent yearly payment of $20 to
obtain" $1,800 worth of sludge yearly. These fees were presented to the
farm community during the public meetings held by MMSD and there was no
opposition. The major part of the fee is record keeping and soil and crop
analyses; costs the farmer would normally incur with commercial fertilizer use.
C - Page 3-1 - Additional comments concerning the lagoon abandonment are in
Specific Comments, Part 2, page 9-3, Section 9-5 of this letter.
Page 9-3, Section 9.5 - In its docket SD-306, acting as the trustee for
navigable waters, the ENR issued a permit for Lagoons 1 and 2. In that
permit, are the following:
"1) The project site shall be restored to the Department of Natural
Resources specifications upon abandonment of the sludge lagoons.
2) The authority herein granted can be amended or rescinded if the
structure becomes a material obstruction to navigation or becomes
detrimental to the public interest."
No standards for restoration were discussed or enumerated. The intent was
that current standards (and laws) would be applied at the time of abandonment.
R - MMSD has previously coordinated their lagoon rehabilitation and abandonment
program with portions of the Department of Natural Resources. We will recommend
to them that they should also coordinate any further development and implementation
of this plan with the portion of DNR having the permit authority so that the
above concerns can be satisfied.
General Comments, Part 2
1. Organization and readability are very good.
2. Important information could be summarized more concisely, i.e., sludge
advantages and disadvantages.
3. Technical data in the statement should be referenced. It should be
readily apparent to the reader which information was accumulated by the
consultant, and what your agency's comments and analyses were concerning
that material.
R - These three comments are related to Part 2 which was attached to the draft
EIS so that the EIS would not duplicate information already compiled and
reported by the applicant. Part 1 is Region V's evaluation of the adequacy
of the plan and environmental assessment (Part II) submitted to us by MMSD.
Where Region V felt there were inadequacies in MMSD plan and assessment we
included supplemental information in Part I. In many cases the supplemental
information was acquired from portions of MMSD's overall facilities plan
aside from the volumes in Part II. All references used were cited at the
end of the draft EIS (Part I).
7-14
-------
In preparing the final ELS the text of the applicant's documents (Part II)
have not been changed. Rather the information requested by the comments
will be included in either the text or comment-response section of the
final EIS.
State Historical Society of Wisconsin
C - There are not sites listed on the National Register of Historic Places
that would be affected by this project. Furthermore, there are no sites
known to us of archeological, architectural, or historical significance
in the project area that would be eligible for inclusion on the National
Register of Historic Places.
R - This comment is of an informational nature and has been noted,
Holtzman Company
C - As a producer of albino rats use (sic) for medical research, we have customers
who require non-estrogen-stimulated rat uteri. We produce our own corn for rat
feed and have grown corn (Pfizer's Trojan DMS102) on land spread with sewerage
sludge from Madison Metro Sewerage District to a depth of 3"-5". We made an
assay comparing the uterine weights of rats fed corn grown on pludged and non-
sludged land. There was no significant difference in uterine weights. We
conclude that birth control pill residues do not enter corn,
R - This coimnent is of an informational nature and has been noted.
7-15
-------
Appendix A
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The Department of Nat
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Sincerely,
Bureau of Environnent
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James R. Huntoon
Director
CC! A. S. Ehly
Robert Krill
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-------
Appendix B
-------
TABLE B-l **
CAPITAL COST ESTIMATE*
ALTERNATIVE 1A - LAND TRENCHING OF DEWATERED SLUDGE
Thickening Tanks $ O.(l)
Sludge Storage Tanks 0.(2)
Centrifuges 8 @ 46 GPM 1,155,000.
Centrifuge Building 124,000.
Centrate Storage Tank 86,000.
Sludge Cake Storage Tank 0.(3)
Trucks and Associated Equipment 374,000.
Secondary Treatment Plant Requirements 328,000.
Land
Sub-total 2,091,000.
Process Contingencies (8%) 167,000.
Sub-total 2,258,000.
Engineering (7%) 158,000.
TOTAL CAPITAL COST $2,416,000.
The ENR Index used throughout is 2000.
(1) Thickener costs are included in the cost of the proposed Greeley
and Hansen plant expansion.
(2) The existing sludge storage tanks can be used.
(3) All trucks and associated equipment are amortized to $0. over
5 years and included in annual operating cost only.
**Source: "Addendum to Nine Springs Sewage Treatment Works
Sludge Disposal Study for Madison Metropolitan
Sewerage District," prepared by Staff of the Madison
Metropolitan Sewerage District, Madison, Wisconsin,
April 1974
B-l
-------
TABLE B-2**
CAPITAL COST ESTIMATE*
ALTERNATIVE 2A - LAND APPLICATION OF LIQUID SLUDGE
Thickening Tanks $ O.(l)
Digestion Tanks 2 @ 160,000 cu. ft. each 948,000.
Sludge Transfer Pipeline
Pipe - Purchase and Installation 528,000.
Manholes 13,000.
Pumping Stations w/o Pumps 60,000.
Pumps 56,000.
Sludge Storage Lagoon 620,000.
Sludge Irrigation Equipment 51,000.
Land 2,377,000.
Sub-total 4,653.000.
Process Contingencies (8%) 372,000.
Sub-total 5,025,000.
Engineering (7%) 352,000.
$ 5,377,000.
TOTAL CAPITAL COST
;i) Thickener costs are included in the cost of the proposed Greely
and Hansen plant expansion.
**Source: "Addendum to Nine Springs Sewage Treatment Works
Sludge Disposal Study for Madison Metropolitan
Sewerage District," prepared by Staff of the Madison
Metropolitan Sewerage District, Madison, Wisconsin,
April 1974
B-2
-------
TABLE B-3**
CAPITAL COST ESTIMATE*
ALTERNATIVE 3A - LANDFILLING OF SLUDGE/MILLED REFUSE MIXTURE
Thickening Tanks $ 0.(1)
Digestion Tanks 2 @ 160,000 cu. ft. each 948,000.
Storage Tanks 0.(2)
Centrifuges 7 @ 46 GPM 1,012,000.
Centrifuge Building 112,000.
Centrate Storage Tank 86,000.
Sludge Cake Storage Tank 13,000.
Trucks and Associated Equipment 0.(3)
Secondary Treatment Plant Requirements 154,000.
Sludge Receiving and Unloading Area 27,000.
Drum Mixes 1,431,000.(4)
Land M5)
Sub-total 3,783,000.
Process Contingencies (8%) 303,000.
Sub-total 4,086,000.
Engineering (7%) 286,000.
Total Capital Cost $ 4,362,000.
(1) Thickener costs are included in the cost of the proposed Greeley
and Hansen plant expansion.
(2) The existing sludge storage tanks can be used.
(3) All trucks and associated equipment are amortized to $0. over 5 years
and included in annual operating costs only.
(4) A more economical mixer could possibly be designed.
(5) All costs associated with the landfilling operation are considered
operating costs.
**Source: "Addendum to Nine Springs Sewage Treatment Works
Sludge Disposal Study for Madison Metropolitan
Sewerage District," prepared by Staff of the Madison
Metropolitan Sewerage District, Madison, Wisconsin,
April 1974
B-3
-------
TABLE B-4**
CAPITAL COST ESTIMATE*
ALTERNATIVE 3B - LAND APPLICATION OF DEWATERED SLUDGE
Thickening Tanks $ O.(l)
Digestion Tanks 2 @ 160,000 cu. ft. each 948,000.
Sludge Storage Tanks U.(2)
Centrifuges 7 @ 46 GPM 1,012,000.
Centrifuge Building 112,000.
Centrate Storage Tank 86,000.
Sludge Cake Storage Tank 18,000.
Trucks and Associated Equipment 0.(3)
Secondary Treatment Plant Requirements 154,000.
Land 2,377,000.
Sub-total 4,707,000.
Process Contingencies (8%) 377,000.
Sub-total 5,084,000.
Engineering (7%) 356,000.
TOTAL CAPITAL COST $ 5,440,000.
(1) Thickener costs are included in the cost of the proposed Greeley
and Hansen plant expansion.
(2) The existing sludge storage tanks can be used.
(3) All trucks and associated equipment are amortized to $0. over
5 years and included in annual operating costs only.
**Source: "Addendum to Nine Springs Sewage Treatment Works Sludge
Disposal Study for Madison Metropolitan Sewerage District,"
prepared by Staff of the Madison Metropolitan Sewerage
District Madison, Wisconsin, April 1974
B-4
-------
TABLE B-5**
CAPITAL COST DATA SOURCES
MAJOR UNIT
Digesters
Centrifuges
Pipeline
Pumping Stations
Pumps
Manholes and Valving
Buildings
Storage Tanks
Trucks
Sludge Transportation Trailers
End Loaders, Farm Machinery
Sludge Storage Lagoon
Drum Mixers
Irrigation Equipment
Secondary Treatment Plant
Requirements
DATA SOURCES
Weston Cost Estimate
Weston Cost Estimate
MMSD Staff Estimates
MMSD Staff Estimates
L.W. Allen and ITT Marlow
MMSD Staff Estimates
MMSD Staff Estimates
MMSD Staff Estimates
Verona International Trucks
Fruehauf Trailer Div.,
Fruehauf Corporation
Brooks Industrial Sales
Weston Cost Estimate
Buhler Co. Cost Estimate
and E.P.A. Report (1)
Roberts Irrigation Company
MMSD Staff Estimate and
Greeley and Hansen Projected
Cost Estimate for Plant
Addition
(1) Recovery and Utilization of Municipal Solid Waste, by M.L. Drobny, M. E. Hull,
and R. L. Testim, Battelle Memorial Institute, Columbus, Laboratories E.P.A.
Contact No. PH 86-67-265.
**Source: "Addendum to Nine Springs Sewage Treatment Works Sludge Disposal
Study for Madison Metropolitan Sewerage District," prepared by
Staff of the Madison Metropolitan Sewerage District, Madison,
Wisconsin, April 1974
B-5
-------
TABLE B-6**
1975 ANNUAL OPERATING COST ESTIMATE
ALTERNATIVE 1A - LAND TRENCHING OF DEWATERED SLUDGE
ASSOCIATED OPERATING COSTS
Cost of Thickening and Sludge Storage Absorbed in Present Operation
Polymers $ 150,000.
Labor 30,000.
Power 5,600.
Maintenance 21,400.
Air Blowers 4,900.
Labor, fuel, maintenance, 52,000.
tires, license, taxes, etc.
Amortization of three 20-ton
tri-axle trucks over 5 yrs. 20,500.
Labor 12,000.
Power 3,100.
Ma intenance 1,300.
Amortization of field equip. 7,500.
Payment in lieu of taxes 1,300.
1975 ANNUAL OPERATING COST $ 309,600.
**Source: "Addendum to Nine Springs Sewage Treatment Works Sludge
Disposal Study for Madison Metropolitan Sewerage District,"
prepared by Staff of the Madison Metropolitan Sewerage
District, Madison, Wisconsin, April 1974
B-6
-------
TABLE B-7**
1975 ANNUAL OPERATING COST ESTIMATE
ALTERNATIVE 2A - LAND APPLICATION OF LIQUID SLUDGE
ASSOCIATED OPERATING COSTS
Cost for Thickening Absorbed in Present Operation
Labor $ 52,000.
Power 2,400.
Maintenance 9,500.
Power 3,200.
Maintenance 2,000.
Ma intenance 1,000.
Labor 33,000.
Power 3,800.
Amortization of field equip. 2,300.
Maintenance 6,500.
Payment in lieu of taxes 9,700.
Sub-total 125,400.
Return from leasing land ,. , -33,600.
1975 ANNUAL OPERATING COST , $ 91,800.
**Source: "Addendum to Nine Springs Sewage Treatment Works Sludge Disposal
Study for Madison Metropolitan Sewerage District," prepared by
Staff of the Madison Metropolitan Sewerage District, Madison,
Wisconsin, April 1974
B-7
-------
TABLE B-8**
1975 ANNUAL OPERATING COST ESTIMATE
ALTERNATIVE 3A - LANDFILLING OF SLUDGE/MILLED REFUSE MIXTURE
ASSOCIATED OPERATING COSTS
Cost for Thickening Absorbed in Present Operation
Labor $ 52,000.
Power 2,400.
Maintenance 9,500.
Use Available Tank 0.
Polymers 77,500.
Labor 24,000.
Power 4,500.
Maintanence 30,000.
Air Blowers 12,600.
Labor, fuel, maintenance,
tires, license, taxes, etc.
to haul sludge portion 54,600.*
Amortization of two 2Q~ton
capacity trucks over 5 years 13,700.
Labor 12,000.
Power 1,100.
Maintenance 3,000.
Purchase, preparation and
operation 134,400.*
Payment in lieu of taxes 1,700.
1975 ANNUAL OPERATING COST $ 438,000.
*0nly includes handling & disposal
-------
TABLE B-9*
1975 ANNUAL OPERATING COST ESTIMATE
ALTERNATIVE 3B - LAND APPLICATION OF DEWATERED SLUDGE
Cost for Thickening Absorbed in Present Operation
Labor $ 52,000.
Power 2,400.
Maintenance 9,500.
Polymers 77,500.
Labor 24,000.
Power 4,500.
Maintenance 30,000.
Air Blowers 12,600.
Labor, fuel, maintenance,
tires, license, taxes, etc. 54,600.
Amortization of two 20-ton
capacity trucks over 5 years 13,700.
Labor 24,000.
Power 1,300.
Ma intenance 1,000.
Amortization of field equip. 4,500.
Payment in lieu of taxes 9,700.
Sub-total 321,300.
Return from leasing land -33,600.
1975 ANNUAL OPERATING COST $ 287,400.
**Source: "Addendum to Nine Springs Sewage Treatment Works Sludge
Disposal Study for Madison Metropolitan Sewerage District,"
prepared by Staff of the Madison Metropolitan Sewerage
District, Madison, Wisconsin, April 1974
B-9
-------
TABLE B-10**
BASIC COST FACTORS FOR CALCULATION OF OPERATING COSTS
Labor:
Power:
Chemicals:
Maintenance:
Recycle Stream Treatment
Air Requirements:
$12,000/operator/year
$8/hr./truck driver
1.2 cent/kw-hr
Altasep 105C - $1.25/lb.
Hercafloc 814.3 - $1.60/lb.
A given percentage of the unit capital
cost or experience.
1200 cu. ft./lb. BOD applied
7500 cu. ft./lb. NH3-N applied
Fuel:
Capital Investment: The portion of the unused
capacity of the planned
expansion which would be
used by the recycle stream.
$0.5U/gallon
**Source: "Addendum to Nine Springs Sewage Treatment Vvorks Sludge
Disposal Study for Madison Metropolitan Sewerage District,"
prepared by Staff of the Madison Metropolitan Sewerage
District, Madison, Wisconsin, April 1974
B-10
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-------
TABLE C-3
REVISED TABLE 8-1 OF THE ORGANIC SOLIDS REUSE ELAN*
ESTIMATED INITIAL CONSTRUCTION COST
SLUDGE REUSE PROGRAM
Madison Metropolitan Sewerage District
ITEM COST
REUSE PROGRAM
Lagoon Sludge Removal Equipment $ 100,000
Sludge Distribution Equipment
(6 tanker trucks, 1 sludge loading dock,
2 nurse tanks, 1 slurry pump). 351,000
Sludge Application Equipment
(4 truck spreaders, 1 soil injector, 1 tractor spreader) 240,000
Subtotal Reuse Program $ 691,000
SOLIDS TREATMENT FACILITIES
Gravity Thickeners
Refurbishment 5,000
Sweetening Equipment 15,000
Gravity Thickener No. 5 110,000
Flotation Control Building 100,000
Flotation Thickeners No. 1 and 2 550,000
Anaerobic Digesters
Refurbishment and Upgrading 430,000
Digester Control Building No. 2 350,000
Digester Utility Tunnel 220,000
New Digesters and Equipment** 1,390,000
Supernatant Drawoff Equipment 70,000
Subtotal Solids Treatment Facilities $ 3,240,000
Subtotal Initial Construction Costs $ 3,931,000
Engineering (12%) 472,000
Legal and Fiscal Costs (2.5%) 98,000
Administration (0.5%) 20,000
Contingency (15%) 590,000
Total Initial Construction Costs $ 5,111,000
Less Federal Grant (75%) 3,833,000
Less State Grant (5%) 256,000
NET COST TO MMSD $ 1,022,000
C-3
-------
TABLE C-3 Cent.
*The solids treatment facilities costs were revised to correspond to those
on Table 13-8 of Volume II, Wastewater Treatment Systems. All costs are
in January 1976, dollars.
**Primary Digesters No. 4 and 5 and Secondary Digester No. 3
C-4
-------
TABLE C-4
PRESENT WORTH COST OF ORGANIC SOLIDS REUSE PLAN
Madison Metropolitan Sewerage District
BASIS:
Reuse plan construction and O&M costs were computed by converting the
year-by-y?ar costs in Table 8-14 of the organic solids reuse plan to
January 1176, present worths.
Solids treatment construction present worth costs were computed for
the facilities listed in Table 13-8 of Volume II of the comprehensive
facilities plan assuming construction will begin in 1978.
Solids treatment power and other O&M present worth costs were computed
from a fraction of the upgraded secondary treatment and advanced
wastewater treatment costs listed in Table 13-9 of Volume II of the
comprehensive facilities plan.
Engineering, legal and fiscal administrative and contingency costs are
included in the present worth cost estimate.
CONSTRUCTION COSTS:
Solids Treatment
Gravity Thickeners $ 148,000
Flotation Thickeners 738,000
Anaerobic Digesters 2,793,000
Reuse Program
Lagoon Program 250,000
Sludge Distribution 1,100,000
Sludge Application 418,000
Subtotal P.W. of Construction Costs $ 5,447,000
OPERATING AND MAINTENANCE COSTS:
Solids Treatment
Power $ 3,115,000
Other D&M 4,361,000
Reuso Program
Lagoon Program 130,000
Sludge Distribution 875,000
Sludge Application 385,000
Program Management 336,000
Monitoring Program 360,000
Income " - 60,000
C-5
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TABLE C-4 Cant.
Subtotal P.W. of O&M Costs $ 9,502,000
PRESENT WORTH:
Total Present Worth $14,949,000
C-6
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Appendix D
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Fishes - Nine Springs Creek, 1972-73*
AMIIDAE - BOWFIN
Bowfin, Amia calva Linnaeus
SALMONIDAE - TROUT
Rainbow trout, Salmo gairdneri Richardson
Brown trout, Salmo trutta Linnaeus
UMBRIDAE - MUDMINNOW
Central mudminnow, Umbra limi (Kirtland)
CYPRINIDAE - MINNOWS AND CARP
Carp, Cyprinus carpio Linnaeus
Brassy minnow, Hybognathus hankinsoni Hubbs
Golden shiner, Notemigonus crysoleucas (Mitchill)
Emerald shiner, Notropis athennoides Rafinesque
Common shiner, Notropis cornutus (Mitchill)
Sand shiner, Notropis stramineus (Cope)
Spotfin shiner, Notropis spilopterus (Cope)
Bluntnose minnow, Punephales notatus (Rafinesque)
Fathead minnow, Pimephales promelas Rafinesque
Creek chub, Semotxlus atromaculatus (Mitchill)
CATOSTOMIDAE - SUCKER
White sucker, Catostomus commersoni (Lacepede)
ICTALURIDAE - FRESHWATER CATFISH
Black bullhead, Ictalurus melas (Rafinesque)
Yellow bullhead, Ictalurus natal is (Lesueur)
Brown bullhead, Ictalurus nebulosus (Lesueur)
ATHERINIDAE - SILVERSIDE
Brook silverside, Labidesthes sicculus (Cope)
GASTEROSTEIDAE - STICKLEBACK
Brook stickleback, Culaea inconstans (Kirtland)
PERCICHTHYIDAE - TEMPERATE BASS
White bass, Morone chrysops (Rafinesque)
Yellow bass, Morone mississippiensis Jordan and Eignmann
CENTRARCHIDAE - SUNFISH
Green sunfish, Lepomis cyanellus Rafinesque
Pumpkinseed, Lepomis gibbosus (Linnaeus)
Bluegill, Lepomis macrochirus Rafinesque
Smallmouth bass, Micropterus dolomieui Lacepede
Largemouth bass, Micropterus salmoides (Lacepede)
D-l
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(con't,)
PERCIDAE - PERCH
Yellow perch, Perca flavescens (Mitchill)
SCIAENIDAE - DRUM
Freshwater Drum, Aplodlnotus grunniens Rafinesque
*Source: Wisconsin Department of Natural Resources
D-2
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Appendix E
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BIBLIOGRAPHY
This list includes only those references specifically cited in the text.
Surge, W.D., "Health Aspects of Applying Sewage Wastes to Land", ARS, USDA, 1974.
CH2M Hill, "Organic Solids Reuse Plan" prepared for the Madison Metropolitan
Sewerage District, 1976.
CH2M Hill, "Environmental Assessment Statement - Sludge Lagoon Dike Rehabilitation,
Phase II" prepared for the Madison Metropolitan Sewerage District, 1976.
Epstein, E. and Wilson, G.B., "Composting Sewage Sludge", Proc. Natl. Conf. on
Muncipal Sludge Management, Information Transfer, Inc., Wash. D.C., 1974.
Hilsenhoff, W. and Karl, T., "Investigation of the Macroinvertebrate Fauna of
Badfish Creek, its Rutland Branch and the Yahara River", prepared for the
Madison Metropolitan Sewerage District, 1976 (included in Volume IV of MMSD's
Comprehensive Facilities Plan).
Madison Metropolitan Sewerage District, "Addendum to Nine Springs Treatment
Works Sludge Disposal Study", 1974.
Madison Metropolitan Sewerage District, "Comprehensive Facilities Plan",
Volumes I, II, III and IV.
Madison Metropolitan Sewerage District - Personal communication with staff.
Magnuson, J. and Herbst G., "Stream Survey of Badfish Creek and the Yahara
River: Fish and Algae", prepared for the Madison Metropolitan Sewerage
District, 1976 (included in Volume IV of MMSD's Comprehensive Facilities Plan).
O'Brien and Gere, Engineers, Inc., "Environmental Assessment of the Organic
Solids Reuse Plan", prepared for the Madison Metropolitan Sewerage District.
United States Department of Agriculture, Agricultural Experiment Station, Bangor,
Maine - Personal communication.
United States Department of Agriculture, Agricultural Experiment Station, Beltsville,
Maryland - Personal communication.
United States Department of Agriculture, proposed additions to the USEPA "Proposed
Technical Sludge Management Environmental Factors", proposed for public comment
June 3, 1976.
United States Dapartment of Interior, "Proposed List of Endangered and Threatened
Plant Species of the United States", published in the Federal Register for public
comment June 16, 1976.
United States Environmental Protection Agency, "Technical Bulletin - Evaluation
of Land Application Systems", 1975.
United States Environmental Protection Agency, "Proposed Technical Bulletin
Municpal Sludge Management, Environmental Factors", proposed for public
comment June 3, 1976.
E-l
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BIBLIOGRAPHY Cont.
United States Environmental Protection Agency, "Quality of Life Indicators
in U.S. Metropolitan Areas - 1970 A Comprehensive Assessment", Washington, D.C.,
1975
United States Environmental Protection Agency, "Statement of Concerns
of the Lake Michigan Toxic Substances Coimiittee Related, to Polychlorinated
Biphenyls", 1975.
"Upper Mississippi River Comprehensive Basin Study", Volume VI, Appendix M:
Power, 1970.
Weston, Roy F., Inc., "Nine Springs Sewage Treatment Works Sludge Disposal
Study", prepared for the Madison Metropolitan Sewerage District", 1974.
Wisconsin Department of Natural Resources, "Technical Bulletin No. 88 -
Guidelines for the Application of Wastewater Sludge to Agricultural Land in
Wisconsin", 1975.
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