United States       Region 7         EPA 907/9-86-003
            Environmental Protection   726 Minnesota Ave.     May, 1986
            Agency         Kansas City, KS 66101

            Environmental Review      	      	
vxEPA      Environmental            Final
            Impact Statement
            Proposed Wastewater
            Treatment Facilities for
            Eastern St. Charles
            County, MO
              including:
               Duckett Creek Sewer District
               St. Peters Sewer District
               St. Charles Sewer District
               Portage des Sioux Sewer District

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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                             REGION VII
                        726 MINNESOTA AVENUE
                       KANSAS CITY, KANSAS 661Q1
                                                       OFFICE OF
                                                 THE REGIONAL ADMINISTRATOR
TO:  ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS

     Attached for your information is a copy of the Final
Environmental Impact Statement (EIS) for Proposed Wastewater
Treatment Facilities for Eastern St. Charles County, Missouri.
This EIS includes the proposed facilities for the Duckett
Creek, St. Peters, St. Charles, and Portage des Sioux Sewer
Districts.  The document is submitted pursuant to Section
102(2)(c) of the National Environmental Policy Act of 1969
(Public Law 91-190).  All comments received, both oral and
written, on the draft EIS are responded to in the final EIS.
All changes and additions to the draft EIS have been included
in the final. EIS.

     The Environmental Protection Agency will not take actions
toward these proposed projects for 30 days following the pub-
lication of the Notice of Availability of this document in the
FederalRegister*  At the termination of that no action period,
thisAgencywill issue a Record of Decision (ROD) affirming the
recommended alternatives and allowing the projects to proceed
toward completion.  The date of issuance of the ROD is antici-
pated to be July 28, 1986.  Additional copies of this document
are available for public review at the following locations;

              Kathryn M. Linnemann Branch Library
              2323 Elm Street
              St. Charles, Missouri

              Spencer Road Branch Library
              425 Spencer Road
              St. Peters, Missouri

     Additional information on the document or the review
period may be obtained from Thomas Lorenz at the above address,
or by phoning (913) 236-2823 or (FTS) 757-2823.

                             Sincerely yours,
                             Morris Kay
                             Regional Administrator
Attachment

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                     FINAL

        ENVIRONMENTAL IMPACT STATEMENT
   PROPOSED WASTEWATER TREATMENT FACILITIES
     EASTERN ST. CHARLES COUNTY, MISSOURI
     U.S. ENVIRONMENTAL PROTECTION AGENCY
        REGION VII, KANSAS CITY, KANSAS
                    June 1986
APPROVED BY:
            ^Morris Kay, Regional Administrator
                 Consultants

                 WAPORA, Inc.
              Rosslyn, Virginia

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                               EXECUTIVE SUMMARY

BACKGROUND

     The  eastern portion  of St.  Charles  County is  experiencing significant
population growth and  urbanization.   As a result of past and projected growth
in  this  area,  improvements in wastewater  collection  and treatment facilities
are  necessary.   In addition,  some existing wastewater  treatment plants have
not  been  able  to meet effluent limitations specified in their National Pollu-
tant Discharge  Elimination System (NPDES) permits due to hydraulic overloads,
system  deterioration,  and related factors.   Some  areas currently  served by
onsite wastewater  treatment systems  also  need improved  wastewater management
systems  since  many existing  systems are  not  providing an  adequate level of
treatment to safeguard public health.

     In  order  to develop a plan  for  increasing wastewater  treatment capacity
and  capabilities,  as  well as provide adequate  collection facilities, a waste-
water  facilities planning study was  initiated  in  1981.   The facilities plan-
ning area includes the  cities  of St. Charles  and  St. Peters,  the Village of
Portage  des  Sioux,  and unincorporated portions of  eastern  St.  Charles County
 (See Figure 1-1, page  1-2).  The  facilities  planning consultant, Sverdrup &
Parcel and  Associates,  Inc., developed  and evaluated  alternatives which would
 correct  existing pollution problems  and provide necessary improvements in the
wastewater management systems  in  the  planning  area.

     The National  Environmental Policy Act of 1969 (NEPA)  requires a Federal
 agency to prepare an EIS on "...major Federal  actions  (e.g.,  funding of waste-
 water  treatment and collection  facilities) significantly affecting the quality
 of the human environment..."   The U.S.  Environmental  Protection Agency  (USEPA)
 has developed  its  own regulations (40  CFR Part 6) for the  implementation of
 the EIS  process.  Pursuant to  these  regulations,  USEPA Region VII  determined
 that an  EIS  was required for this facilities planning effort.

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ALTERNATIVE DEVELOPMENT AND SCREENING

     Eight preliminary alternatives for collection and treatment of wastewater
in the planning  area were identified by the facilities planner.  These alter-
natives  involved eight  interceptor  sewer  system  configurations that  would
transport wastewater  from the  six sewer service subareas within the planning
area to various  sewage treatment plants (STPs).   For each municipal STP to be
utilized  under  these  eight preliminary  alternatives, various  treatment  and
disposal  options were evaluated.   These  eight preliminary  alternatives were
then screened  by the facilities planner,  with input from the Citizen Advisory
Committee,  to  select  four  alternatives  for detailed  evaluation.   Screening
factors  included costs,  environmental  constraints,  reliability, flexibility,
and implementability.

DESCRIPTION OF THE EIS/FACILITY PLAN RECOMMENDED ALTERNATIVE

     As  stated,  four "action"  alternatives (Alternatives 3, 6,  7, and 8) were
evaluated with respect to  costs and non-monetary considerations  as well as the
No Action Alternative.  A cost-effectiveness analysis was performed  and Alter-
native 6  had the lowest  total present worth cost of $46.0 million.  The three
other  alternatives  were  approximately  3  to  12  percent more  costly based on
their total present  worth cost.

     Non-monetary factors used  in comparing the detailed alternatives  included
reliability,   environmental  effects,   floodplain  infringement,  energy  use,
public   approval,  implementation  capability,  contributions   to  goals,  and
expandability.   Environmental  consequences  from the  construction and operation
of  the four  final  "action" alternatives  and the  No Action Alternative were
presented in Section 4.0  of the Draft EIS.

      In  both the EIS  and 201  Facility Plan, Alternative 6  was recommended as
 the most cost-effective  system  that  would  satisfy both the  needs and require-
ments  of the Duckett Creek Planning Area  and  fulfill environmental  and regula-
 tory requirements.   Alternative  6  consists  of expanding the Mississippi River
 and Spencer Creek STPs,  constructing new facilities at the  Missouri River and
 Duckett   Creek  STPs,  and  upgrading the  existing  wastewater   collection  and

                                       ii

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transmission system.   Further,  construction would  begin in the  riear future,
and various stages of the overall plan would be implemented at  different times
during the 20-year planning period.

Recommended Vastewater Collection and Conveyance Facilities

     Under  the  recommended  alternative,  four major  interceptor routes  are
proposed:   (1)  South  Plant to the Harvester-Dardenne site;  (2)  Spencer Creek
STP  to  the Mississippi  River;  (3) Boschertown  lagoon to  the  Missouri River
STP; and (4) St. Charles Trails STP to 1-70.

     Wastewater flows pumped from the South Plant service area  would be inter-
cepted by  a gravity  sewer.   The  sewer line would follow Dardenne Creek to a
pumping  station north  of the  Harvester-Dardenne  STP,  where  the  wastewater
would  be pumped  to the  Harvester-Dardenne pumping station.   The  Harvester-
Dardenne pumping station  would  pump  both  the South Plant  and  the  Harvester-
Dardenne service  area flows  to a new 5 mgd Duckett Creek STP.   Once the down-
stream treatment  facilities  are constructed, the interim South Plant would be
eliminated.  Treated  effluent from the Spencer Creek STP would be pumped into
the  Mississippi River.   The  force main  would follow Spencer  Creek and then
extend northward, across  the  floodplain, to the Mississippi River.

     The Boschertown interceptor would extend from  the  Boschertown  lagoon to
the  Missouri  River  STP.   Gravity sewers  would  be used  with  an intermediate
lift station.  This interceptor would eliminate the Boschertown lagoon and the
Hutchins, Riverview,  Princess Jodi, and Bedford pumping stations.

     The Missouri River  interceptor stops  at 1-70.  An extension of this sewer
line would  eliminate the  St. Charles Trails STP, Timbercrest and Heatherbrook
lagoons, Riverview Hills  septic tank and  sand  filter, and Heatherbrook pumping
stations numbers  1  and 2.  The  alignment of the sewer line would extend from
the  St.  Charles Trails  STP along  Taylor Branch,  and  then follow  the MK&T
Railroad to the existing  Missouri  River  interceptor.
                                       111

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Recommended Wastewater Treatment Facilities


     • Mississippi River STP —  The Mississippi River  STP would be  expanded
from a  5.5 mgd to a  7.0 mgd  facility.   The existing unit processes  would  be
maintained;  however,   expansion or  replacement  of  certain  items  would  be
required.  A  new  effluent  pumping  station would be required.  Currently, when
the Mississippi  River is  at  high  stage,  wastewater effluent must be pumped
through  an empty  activated carbon  filter  to  provide  enough head  to  allow
gravity  flow  to  the  river.  The new pumping  station would contain three cen-
trifugal  sewage  pumps and would pump  effluent through a  force main  to the
river.

     • Missouri River STP  — The Missouri River STP would be expanded from a 3
mgd primary facility to a 5 mgd secondary system.  The plant was built in 1966
and most of  the  mechanical equipment would require replacement.   An oxidation
ditch system  is  proposed to provide secondary treatment.  The existing sludge
handling  system  at  the Missouri River STP currently is not used; however, the
building  could be  modified to house  the new  sludge  dewatering  equipment.
Dewatered  sludge  cake would  be  trucked  to  the  Mississippi  River   STP for
incineration.

     • Duckett Creek STP — The 1  mgd  Duckett  Creek package plant  would  be
replaced  by  a 5  mgd treatment  facility.  None of the existing equipment would
be  used at  the  new plant.  Oxidation ditches  would provide secondary treat-
ment.   Waste  activated sludge  would be thickened in a gravity thickener prior
to  stabilization  in  two aerobic digesters.  The digested sludge would then be
dewatered  by  two belt  filter presses.

     Final disposal  of  dewatered  sludge would  be  by land  application, when
possible.   Sufficient (30-day)  cake  storage facilities and alternate sludge
disposal methods,  including  landfilling,  would be  necessary.   The  proposed
plan  includes onsite storage,  land  application  of  sludge to  the  greatest
extent  possible, or   landfilling  of  sludge  cakes.   Final  application  sites
currently are not  known,   but would  be  selected  during the project design
stage,  and would be subject to  site-specific review  and  approval at that  time.

     Sludge  disposal  facilities and equipment  would include a sludge storage
shed  for  the  dewatered  cake,  and  a land application  truck  and  a feeder tank
truck would  be required for farmland subsurface injection.   Sludge cake  would
be  produced when  land application  is not feasible and stored until it  could be
applied to land  or  until   storage  capacity is  reached, whereupon the  sludge
would be hauled  to a  landfill  for  final  disposal.

     •  Spencer Creek  Plant —   The  Spencer Creek STP  would   require  upgrading
from  a  3.0  mgd extended  aeration plant  to  a 4.0  mgd  contact stabilization
plant.   Much  of  the   existing  equipment was  installed  in  1980  and  could be
utilized in this upgrading plan.   Effluent would be pumped  to the Mississippi
River  rather  than  discharged   to  Spencer  Creek,  as currently practiced.  The
Spencer Creek plant could, as  an  option,  be upgraded to meet advanced  treat-
ment  standards and discharge   to Spencer  Creek.   To handle  sludge, a  gravity
thickener would  be added  prior to  aerobic  digestion.  Two new digesters  would
replace the  original  digester.   Digested sludge would be dewatered by two belt
filter  presses housed in a new sludge handling  building.
                                       IV

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     The City of  St.  Peters has been investigating land application of sludge
because the existing  sludge handling method (lagoon) is  not acceptable.   The
City of St. Peters  has acquired a  sludge  application vehicle and is now land
applying  sludge from  both  their water  and wastewater plant.   The use  of a
landfill  also  was  considered  as  an  alternate  sludge  disposal method.   A
flexible system, including storage facilities for dewatered sludge cake, would
also be required.

     • Portage des Sioux Plant — The  Portage  des Sioux STP would be upgraded
to a secondary facility.  However, it is recommended that an extended aeration
package  plant be  constructed  in  lieu  of the 1978  selection  of  a rotating
biological contact plant.

     • Onsite Systems  — In the planning area, there are three general classi-
fications  of  existing  onsite  system  areas:   (1)  developments   along  the
Mississippi  River  and  in  the  floodplain  that  are  serviced  by   individual
shallow wells and onsite systems; (2) the upland portion of the planning area;
and  (3)  residences in areas  with  karst topographic features,  mainly around
Taylor  Branch.   The  final  facilities  plan  concludes that  the  use of onsite
systems in densely populated areas in the upland portions of the planning area
(area  2),  and further development in the karst areas (area 3),  should be dis-
continued as  interceptors are constructed.

     Although the  residences  currently  served  by  onsite  systems   in  the
Mississippi  River  floodplain  (area  1)  were  originally recommended  (in the
draft  facilities plan)  to  be served by centralized  collection and treatment
facilities where  the  density of residences was sufficient, it  subsequently has
been  determined that  these floodplain  communities cannot  afford the cost of
collection and  transmission systems  for  treatment of wastewater  at the nearest
centralized facility.   As  such, a  centralized collection system  for the major
floodplain  communities  was  not considered  implementable.   Instead,  it is
recommended   that  St.  Charles   County   develop  a  plan  that  could mitigate
problems  without being  capital-intensive.   The proposed plan recommends the
following measures:

      (1)  establishment  of a  centralized  management agency  responsible  for
          planning  and  supervising the  upgrading and maintenance  of onsite
          systems;

      (2)  a  public  education program  on  proper  septic tank and  absorption
          field operation;

      (3)  emphasis  on the  need for  community  wells  to  replace  individual
          shallow wells;

      (4)  consideration  of  cluster  systems;

      (5)   consideration  of  holding  tanks for riverfront properties;  and

      (6)   flow  conservation practices and  devices  to  reduce  the load on exist-
           ing onsite  systems.

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     The continued use of  onsite systems in the  upland areas  also  would still
be necessary  for numerous  residences  because interceptor sewers are not  and
will not  be located  sufficiently  close to provide service.  Sufficient data
currently  are  not  available to  ascertain whether  or not  continued use  of
onsite  systems  in these areas  would be  technically  feasible if  centralized
management  and  systematic  upgrading of  failing systems  onsite  were  to  be
implemented.  Regardless  of the final wastewater management  options  selected
for  the respective  "problem areas," implementation  of an onsite  management
district  is recommended  for those  residences  that  would not  be served  by
centralized alternatives.

     • Private Systems —  Two  wastewater treatment  facilities,  the Tee  Kay
lagoon  and  the  Martell  lagoon,  serve isolated communities in the  South Plant
service area.   Interceptors are  not yet available because of high costs  re-
lated  to  low population density.   As the population increases,  interceptors
would  be  extended to these  outlying areas,  and it is  recommended that these
lagoons should  be  eliminated.   Meanwhile, strict enforcement of KPDES permits
should  reduce the  impact  that these lagoons  may have on water  quality in the
planning area.

     • Small Systems Outside the Planning Area   --  It   is   recommended  that
pollution  to upper  Dardenne Creek  by  small treatment  plants  located  just
outside  the planning  area  could  be reduced  by strict enforcement  of NPDES
permits conditions.  The Weldon Spring Elementary School and Safari Campground
each  have  treatment  plants  that  may  affect Dardenne  Creek water  quality.
Eventually,  these  areas  should  be eliminated as interceptors are constructed.


ENVIRONMENTAL CONSEQUENCES


     Environmental  impacts of  the  recommended  alternative generally are ex-
pected  to  be beneficial,  particularly with  regard  to surface and  groundwater

quality.   The  recommended  alternative   would  replace  or upgrade currently

inadequate  centralized  wastewater treatment  plants and provide  more suitable
collection  and  treatment systems for small communities with problems resulting

from  failing septic tanks  and other  small  treatment  facilities.  For  the
floodplain  areas  currently using onsite  systems, the  recommended plan provides

for  better technical guidance  (via a  central  management agency)  in  siting,

operating,  and  maintaining  onsite systems which  will help mitigate problems
without being capital intensive.


      Some  adverse impacts  also are associated  with  the recommended alterna-

tive;  however,  they generally  are localized  in  nature  and of relatively short

duration.   Such  impacts  include  temporary  loss  of  vegetation  (woody  and

herbaceous),  erosion,  sedimentation,   disruption  to  riparian and  roadside
                                       VI

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vegetation and  associated  fish and wildlife habitats, and temporary displace-
ment  of  certain species  of wildlife during sewer line  construction in rural
areas.  Local  traffic disruptions,  safety hazards,   noise,  and fugitive dust
caused by construction activities in the more developed areas also will occur.
Temporary  interruptions  of  farming  operations  and other  local services also
may  occur  although these  and other adverse impacts  can be  minimized through
use of effective mitigative measures.

     There is  also  potential for longer-term impacts  that include impacts on
archaeological  resources,   user  charges,  land  use changes,  and operational-
related odors and noises.   Cost impacts of collection and treatment systems to
residents  of  the planning area always exist, despite efforts to reduce costs
and  the opportunity for Federal grant assistance.  Officials and citizens of
these  affected  communities  have  actively  participated in  the  planning of
wastewater  management facilities  for  their areas and  their  views  are con-
sidered and  reflected in  the recommended  alternative.   For a more detailed
discussion of  impacts of the  recommended alternative, refer  to Section 2.4 of
this Final EIS.

AGENCY DECISION AND REQUIRED MITIGATION MEASURES

     The  EIS and facilities planning process were performed concurrently and
in  close  coordination to ensure that the most cost effective,  environmentally
acceptable  alternative was  selected.   This EIS  analysis  has  determined that
the  environmental  benefits  of  the  recommended  alternative  (Alternative 6)
outweigh the adverse  environmental effects.  Therefore, EPA intends  to provide
further  federal  funding for  this project, subject  to  all  other review and
approval  requirements of  EPA's  Construction Grants  Program,  as  well  as the
requirements of the Missouri  Department  of Natural Resources  (MDNR).

      As  previously  identified,  various  adverse  impacts  would be  associated
with all  proposed  action alternatives.  Many of  these adverse  impacts must be
reduced  significantly by the  application  of mitigative measures.   These miti-
gative measures consist  of  a variety of  legal requirements, planning measures,
and  design practices.   The extent  to  which these measures  are  applied  will
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determine  the  ultimate  impact  of the  particular  action.   During  subsequent
design and  construction phases  of  the proposed project, EPA,  in  cooperation
with MDNR, will  be  responsible  for seeing that recommended measures are taken
to  mitigate potential  adverse  impacts.   The  principal required  mitigative
measures are summarized below:

     Mitigation of Construction Impacts

     Anticipated  construction-related  impacts are  primarily  short-term  and
result from land-disturbing activities at the STP sites or along the routes of
proposed  wastewater  collection  and   conveyance  lines.  Specific  mitigation
measures  recommended for  reducing  dust generation,  subsidence,  erosion,  and
sedimentation include:

     • frequent  street  sweeping;
     • prompt road repaving;
     • prompt reseeding, landscaping,  and restoration of vegetation;
     • regrading and compacting of trenches to prevent  subsidence;
     * minimizing areal requirements of grading and excavation;
     » removing  topsoil and  stockpiling  it whenever  possible before  grading
       begins;
     • applying  appropriate  structural  or  agronomic  practices   to   control
       runoff and sedimentaton during  and after construction;
     • developing stabilized  drainage  systems; and
     • establishing   a  firm  construction  schedule  that is  coordinated with
       clearing  and  grading activities.

     Any interceptors proposed in or  near  wetlands  or floodplain areas could
have significant  impacts on bottomland vegetation which  provides valuable
wildlife habitat.   Any  such  facilities should be aligned  to  avoid  these areas
or disturb as little area as possible.   Minimizing the width  of construction
corridors  through   these  areas  is  recommended.   These corridors  should be
regraded  to  natural  contour   and  replanted with  native  vegetation.   The
Missouri Conservation  Commission should  be  consulted  in this regard  and can
help to  provide  for natural  replanting.
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     Construction-related  disruption in planning  area communities  should be
minimized  through considerate  contractor scheduling  and  appropriate public
announcements.   State and  County highway  department  regulations  concerning
roadway  disruptions  should be  rigorously adhered to.   Special care  must be
taken  to minimize disruption of access  to  frequently  visited establishments.
Announcements  should be  published  in  local  newspapeers  and  broadcast  from
local  radio  stations  to  alert drivers  to  temporary traffic  disruptions on
primary  routes.   Street  closing  and  blasting  schedules  also  should  be
announced by  flyers delivered to each affected household, or by another appro-
priate technique.   Construction schedules also should be coordinated with the
farm  planting/harvesting  cycles  in  order  to  reduce  disruptions  to farming
operations.

     To  avoid or minimize damage to  roadways,  planning  routes  for heavy con-
struction  equipment and materials must  ensure  that  surface load restrictions
are  considered.   Trucks  hauling  excavation spoil to  disposal sites  or  fill
material to the  STP sites  should be  routed along primary arterials to minimize
the  threat  to  public   safety  and  to   reduce  disturbance  along  residential
streets.   Also,   to  minimize  exhaust emissions  and  noise  from construction
equipment,  proper  equipment  operation   and  maintenance  procedures  must be
followed.

     Known  archaeological sites  located within or  near proposed interceptor
rights-of-way have  been inventoried by pedestrian survey.  Two sites, located
partially within the construction corridors, should be avoided.  If it is not
possible to avoid these  sites,  subsurface testing would be necessary to deter-
mine  their eligiblity  for  nomination   to  the National Register  of Historic
Places.   If  a  site is  found  eligible,  the extent  of adverse  effect must be
assessed,  and activities, such as data  recovery, must be carried out to miti-
gate  adverse impacts  in  accordance with  36 CFR  Part 800.   Also,  if any
additional  cultural  resources are  found  during  construction,  the  State
Historic Preservation Officer  (SHPO)  must be notified  immediately.

     Mitigative  measures  also  may  be  required near  the  Findett Corporation
hazardous  waste  site which could affect, or  be  affected  by, construction of
proposed  interceptor  lines  in  this   general  vicinity.   Any  environmental

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analyses, mitigative  measures,  and  remedial  actions that may be required  in
this area will be determined by the EPA Superfund Program for hazardous  wastes
clean-up.  The  implementation of  remedial  actions at the site will  not occur
until after  EPA completes a Remedial  Investigation/Feasibility  Study (RI/FS)
of the Findett  site.   The grantee should monitor this study and  determine its
status or results prior to any construction in this general  area.

Mitigation of Operation Impacts

     Adverse  impacts  related  to  the  operation of  the proposed  wastewater
collection systems  and  treatment  facilities should be minimal if  the facili-
ties  are  designed,  operated,  and  maintained  properly.    Aerosols,  gaseous
emissions, and  odors  from the various  treatment  processes  must  be controlled
through  responsible operation  and maintenance procedures.  Above-ground pumps
should be enclosed  and installed to minimize sound impacts.

     Special care must  be taken to  control chlorination and effluent concen-
trations of chlorine  residuals at the Spencer Creek and Mississippi River STPs
to minimize  adverse impacts to the  aquatic biota in receiving streams, since
chlorination of wastewater can result  in the formation of halogenated organic
compounds  that  are potentially carcinogenic.   Plans for chlorination systems
should provide  for  continuous  monitoring of  chlorine  residuals (with visual
and  audible  alarms)  to   ensure  that  chlorine  concentrations  remain  within
design limits.

     Once  specific  sites  are  selected  for  sludge application,  potential
adverse  impacts to  soil  and groundwater  resources  will be mitigated through
grant conditions required  by the state  including:  (1) analysis of sludge on a
quarterly  basis, (2)  groundwater  monitoring for  wastewater treatment facil-
ities in excess of  5  mgd,  and/or  (3) groundwater monitoring  if sludge applica-
tion  rates  exceed  2  dry  tons per acre  per year.  Where  groundwater monitoring
is  required,  the primary pollutant  of  interest  is nitrates; however, monitor-
ing  for  other  constituents (e.g.,  heavy  metals,  priority  pollutants)  may be
required if  there  is  an  industrial  wastewater  contributor  to  the system.
These  ongoing  measures  will  serve  to  minimize adverse   impacts  of  sludge
application  operations.

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     Operation  impacts  resulting  from  power  failures  could include  sewer
backups  and localized  flooding in the  collection system;  biological  system
upsets at the STP; stagnation of waters;  and mechanical problems in the treat-
ment facility.  To  mitigate the potential for such problems,  secondary power
sources are required to enhance system reliability.

Mitigation of Secondary Impacts

     Some secondary  impacts are expected to occur from  implementation  of any
of the  action  alternatives, including the recommended alternative.  Effective
zoning,  health,  and water  quality regulations and enforcement will minimize
these impacts.  Local growth management planning also would assist in regulat-
ing the general location, density, and type of growth that occurs, which would
serve to  minimize the potential for adverse impacts due to changes in popula-
tion and  land use.

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                            DUCKETT CREEK FINAL EIS

                               TABLE OF CONTENTS

Section
EXECUTIVE SUMMARY	      i
TABLE OF CONTENTS	    xii
LIST OF TABLES	   xiii
LIST OF FIGURES	   xiii

1.0  INTRODUCTION	   1-1

     1.1  Background of Facilities Planning	   1-1
     1.2  Background and Issues of the EIS	   1-5
     1.3  Organization of Final EIS	   1-7

2.0  EIS STUDY SUMMARY	   2-1

     2.1  Environmental Setting...	   2-1
     2.2  Wastewater Treatment Problems/Need for Action	   2-9
     2.3  Description of Alternatives Including the Recommended
            Alternative	   2-11
          2.3.1  No Action	   2-13
          2.3.2  Alternatives	   2-15
          2.3.3  Alternative 6 (Facility Plan and EIS Recommended
                 Alternative)	   2-16
          2.3.4  Alternative 7	   2-17
          2.3.5  Alternatives	   2-18
          2.3.6  Comparison of Final System Alternatives	   2-18
          2.3.7  Description of Recommended System Alternative	   2-21

     2.4  Environmental Consequences of Recommended Alternative....   2-37
     2.5  Issues and Comments  in Response to the Draft EIS	   2-44
     2.6  Additional Considerations Since the Draft EIS	   2-45

3.0  CORRECTIONS AND ADDITIONS TO DRAFT EIS	   3-1

4.0  COMMENTS ON THE DRAFT EIS AND EPA RESPONSES	   4-1

     4,1  Written  Comments and Responses	   4-1
     4.2  Responses to Public Hearing Comments	   4-24
 APPENDICES
           Key Correspondence (Missouri River Levee  System (L-15)  Project
           Status Report
           Mailing List for Final EIS
                                       xii

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                                LIST OF TABLES


Table                                                                 Page

2-1  Evaluation of costs for the four final alternatives	      2-20

2-2  Facility plan recommended alternative construction
     cost estimates	      2-31

2-3  Facility plan recommended alternative annual operation
     and maintenance cost estimates	      2-32

2-4  Preliminary calculation of user charges	      2-34

4-1  Index of written public comments on the Draft EIS	      4-2

4-2  Index of verbal public comments received at the public
     hearing on the Draft EIS, May 9, 1985	      4-3
                                LIST OF FIGURES


Figure

1-1  Location of planning area	     1-2

2-1  Alternative 6	     2-22

3-9a Findett site map	     3-3

3-9b Findett study area	     3-4
                                      Kill

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1.0  INTRODUCTION

1.1. Background of Facilities Planning

     The planning  area  addressed  in this Environmental Impact Statement (BIS)
is  located  in  eastern St. Charles County in eastern Missouri approximately 25
miles west  of  St.  Louis  (Figure 1-1).  The planning area is generally bounded
by  the  Mississippi  River  on  the north,  State  Highway 94  on the  east,  the
Missouri River on the  south,  and US Highway 40 and County Highway C on the
west.   It  includes the  upper Mississippi River — Salt River Basin watersheds
of  Dardenne,  Spencer,   Sandfort,  Cole  and  Boschert creeks,  and  the  Lower
Missouri River Basin watersheds of Duckett Creek and Taylor Branch.  The plan-
ning  area  includes the  cities  of  St. Charles and St. Peters,  the Village of
Portage  des Sioux as well as unincorporated portions of  St.  Charles County.

     The planning  area  is located in the Dissected Till Plains section of the
Central  Lowland  Physiographic  Province.   The northern portion of the planning
area,  i.e., north of the Norfolk and Western Railroad,  constitutes a broad,
generally  level  floodplain area of the  Mississippi  and  Missouri rivers.  The
southern  portion  of  the planning area  contains gently rolling  upland areas
with  dissected river valleys and  includes almost all of the population of the
planning area.

      This  portion  of St.  Charles  County is  currently experiencing  significant
population growth  and   urbanization  due  to a  number  of  factors  including:

      •   Improved transportation access between the planning area  and St. Louis
      •   Existence  of large amounts of vacant buildable land suitable for  resi-
         dential  and  commercial  development
      •   Pro-growth planning policies  to  facilitate population  growth
      •   Siting of  major new employment centers in nearby areas.
      The history  of wastewater facilities  planning in  St.  Charles  County  in
 the last 12 years  is as follows:

      1972   -  St.  Charles County voters  created a countywide  Regional
               Sewer  District (RSD).   The  formation  of a RSD  was  opposed
               by the cities of  O'Fallon  and  St.  Peters.
                                     1-1

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1976    -      St.  Charles  County  Voters  defeated  a county  bond
               issue to financially support the RSD.

1978    -      The Duckett Creek  Sewer  District came into existence
               as an operating  entity  following the purchase of two
               private treatment facilities.

1978    -      The East-West Gateway Coordinating Council  (EWGCC),
               the regional  208 planning agency,  adopted a 208 plan
               which  recommended  a regional   treatment  system  to
               serve  0'Fallen,  St.  Peters,  St.  Charles,  and  the
               unincorporated   areas   between   these  communities.

1979    -      The  Missouri  Clean  Water Commission  (CWC)  reviewed
               and certified the  EWGCC  208 plan.  Strong opposition
               to  this plan was  expressed by  O1 Fallen, Lake  St.
               Louis,  and St.  Peters   as  well  as  the  St.  Charles
               County Municipal League.


1979/
1980    -      Federal regulations  require  the Governor of Missouri
               to designate  management agencies for implementing 208
               plans.  The EWGCC  208 plan did not, however, make any
               recommendations  on  management   agencies.   For  this
               reason, the CWC  ordered the local governments in St.
               Charles  County  to  reach  a  consensus  concerning man-
               agement  agencies by 1 January  1980.   In response to
               this mandate,  the   local  governments  in  St.  Charles
               County banded together to form the St.  Charles County
               Waste  water  Management  Board  (WMB).   The WMB recom-
               mended to  the CWC  on 28  December 1979 the following
               management agencies  for implementing wastewater faci-
               lities  plans: (1) Wentzville;  (2) O'Fallon/Lake St.
               Louis;  and (3)  Duckett Creek/St. Peters/St. Charles.
               The  CWC endorsed  this  management strategy  for St.
               Charles  County,  and  transmitted this  recommendation
               to the Governor.

April    -      The  Governor  certified the St. Charles  County manage-
1980           ment   agencies  to  the  US  Environmental Protection
               Agency  (USEPA).

May     -      USEPA accepted  the  state's 208  certification,  in-
1980           eluding  management  agencies to  St.  Charles County.

January -      St.  Peters,  St.  Charles, and the  Duckett  Creek Sewer
1981           District agreed  upon a  local consultant for preparing
               a facilities  plan on the  "eastern" subregional area.

July     -      A Step 1  planning grant  was awarded by USEPA  for the
1981           facilities plan  with the Duckett Creek Sewer District
               serving as the lead  agency.
                                1-3

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     December -     USEPA  determined that  an EIS  was required  on  the
     1982           plan  and  issued  a  Notice  of Intent  to prepare  an
                    EIS.
     At present,  public wastewater  treatment  facilities  are operated by  St.
Peters, St. Charles,  Portage  des  Sioux,  and the Duckett Creek Sewer District.
In  addition,  there  are several private  and industrial wastewater  treatment
facilities in the planning area.   A detailed discussion of  the  existing  cen-
tralized collection and treatment systems in the planning  area is contained in
Section 2.1 of the Draft EIS.

     The primary  impetus  for  facilities  planning in the planning  area is the
high population growth  which  the area is experiencing.  As  additional growth
occurs,  improvements in  wastewater  collection  and treatment capability  and
capacity will be  necessary.   In addition, some of the facilities in the plan-
ning  area currently  have difficulties  in  meeting  the effluent  limitations
specified by  their National  Pollutant  Discharge Elimination  Systems (KPDES)
permits because of hydraulic overloads,  system deterioration, and related  fac-
tors.   Further,  some portions  of the planning  area are  currently served by
onsite  wastewater treatment systems, some of which  are not  providing an ade-
quate level of treatment to safeguard public health.  Therefore,  consideration
must be given to  upgrading inadequate onsite systems or providing centralized
collection systems in these currently unsewered areas.

     Facilities planning  in the planning area was initiated in December 1981.
The  facilities planning  consultant, Sverdrup  & Parcel and  Associates,  Inc.
developed  eight (8)  preliminary  alternatives for the  planning  area for  cor-
recting existing  pollution problems  and  for providing necessary improvements
in  wastewater collection and  treatment capability and capacity.   An Infiltra-
tion/Inflow  (I/I)  analysis  also  was performed.   Following analysis  of the
eight   preliminary   alternatives,  four  (4)  alternatives  were  selected  for
detailed  engineering  analysis  on  the  basis of cost-effectiveness, probable
environmental  impact,  implementability,  and related factors.  A more detailed
discussion  of the  alternatives and  the  screening  process  used  to eliminate
preliminary  alternatives  from further analysis  is contained in Section 2.4 of
the Draft EIS.
                                     1-4

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     This EIS is  being  prepared concurrently with the facilities plan.  Prior
to  the  development  of  the  Draft EIS,  an  Environmental Setting  Report  was
prepared which summarized  the  existing natural and manmade environment of the
planning area.  This  report  was used by the facilities planning consultant in
the development of  the  preliminary alternatives and  in  the  screening process
used  to identify alternatives suitable for  in-depth evaluation.  The  draft
facilities plan was  completed  in November 1983 and has been reviewed by USEPA
and  the Missouri Department  of  Natural  Resources  (MDNR).   Following  this
review,  a  final  facilities  plan  was prepared  and  submitted during October
1984.  The final  facilities  plan addresses the comments provided by USEPA and
MDNR  on the  draft  facilities  plan;  the  final  plan is  currently  undergoing
agency review.  The Draft and Final EISs are based on information in the final
facilities plan and  will  be  submitted for public and agency comment.   Follow-
ing the  close of  a  45-day comment period on the Draft EIS, this Final EIS was.
prepared and  identifies the  action(s) which USEPA  regards  as  most suitable,
from an environmental, economic and legal standpoint.

1.2  Background and Issues of the EIS

     The National Environmental Policy Act of  1969  (NEPA)  requires a Federal
agency  to  prepare an EIS on "...major Federal actions significantly affecting
the quality of the human environment..."  In addition, the Council on Environ-
mental  Quality  (CEQ)  has  established  regulations  (40 CFR Parts  1500-1508) to
guide  Federal agencies in  determinations  of whether or not  Federal  funds or
Federal  approvals would result in a  project  that would significantly affect
the  environment.  USEPA has  developed its own regulations (40 CFR Part 6) for
the  implementation  of the EIS  process.  In accordance with these regulations,
USEPA  Region VII determined  that an EIS was  required  for  this  facilities
planning effort.  EPA therefore issued a  Notice  of Intent to prepare the EIS
on  the  subject  facilities  plan and  retained  WAPORA,   Inc, as  a consultant.

     The purpose  of this EIS  is to provide federal,  state, and  local  decision
makers  and the concerned  pubic with  sufficient information on the  environ-
mental,  economic, and  technical impacts  of  the  various alternatives to make
sound  wastewater  management decisions.  Participants in the wastewater plan-
ning  process  during the past  2 years  have included:  the cities of St. Peters
                                     1-5

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and St. Charles, the village of Portage des Sioux,  the Duckett Sewer  District,

the State of  Missouri,  USEPA,  Sverdrup & Parcel and Associates,  Inc.  (facili-

ties planning consultant),  WAPORA,  Inc. (EIS consultant), and other Federal,

state,  local, and  private  agencies and  organizations.   A citizens  advisory

committee (CAC) composed  of local officials, local residents, and representa-

tives  of  a  number of local  interest  groups was formed to provide input  into
the planning  process and has  met at  key decision points during  the project.

In particular,  the  CAC  provided valuable input into the selection of alterna-

tives  considered  most  suitable by detailed  engineering analysis.   A  public

hearing on the  draft facilities plan also  was  held  on February 15,  1984.  An

additional public  hearing on  the Draft EIS  was held  on May 9,  1985  in St.

Charles to discuss  its  conclusions and recommendations, and to solicit public

comments.  This  Final EIS  revises  the Draft  EIS  as  a result of public and
agency  comments, and responds  to all written and  verbal  comments received on

the Draft EIS.


     During the course  of preparing the EIS, the following issues were deter-

mined  to be  of significant concern  and  thus  received  emphasis in  the  EIS:


     •  Induced population growth and associated indirect impacts on:

          floodplains
          wetlands
        -  potable water supplies
          hazardous  areas
          recreational lands
          prime and  unique agricultural areas
          fish and wildlife habitat areas
          threatened and endangered species
          historic and archaeological sites

     •  The effects of effluent  discharges on the water quality of the Missouri
        and Mississippi  rivers  and  their  tributaries from hydraulically over-
        loaded centralized  wastewater  treatment facilities as well as malfunc-
        tioning on-site systems.

     •  The development of a user  charge system  acceptable to a population that
        is  currently being  served  by  numerous  systems with   varying  user
        charges.

     •  The  development  of  alternatives which  satisfy the needs of numerous
        public and  private  entities with  facilties  that have  widely ranging
        treatment capabilities,  capacities,  and  design periods.
                                     1-6

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     • The development of an equitable plan for compensating private  utilities
       and public entities  that  have  facilities which could be transferred to
       regional or subregional systems; however, compensation to the  owners of
       private utilities is not grant  eligible.
     • Construction  impacts,  including  disruption  of  traffic  flows   with
       attendant impacts  on existing  land  uses, local businesses,  and  resi-
       dents'  commuting patterns.

1.3  Organization of Final EIS
     This Final  EIS focuses  on  responding to comments received on  the  Draft
EIS  and  summarizes   and   updates  information  previously  presented.    The
Executive Summary  presents a  brief  synopsis of the proposed  facilities plan
alternatives,  environmental  consequences,  EPA's  decisions,  and  recommended
mitigation measures.  Section 1.0 provides a historical overview of facilities
planning and the EIS  process and presents the organization for the Final EIS.
Section 2.0  summarizes  the major EIS sections,  and includes a synopsis of the
issues and comments on the Draft EIS, but does not repeat the full  text of the
Draft EIS.   Section 3.0 presents  revisions  to  the Draft EIS in  the  form of
errata.  Section 4.0  includes the  written and verbal  public  hearing comments
on  the Draft  EIS   and EPA's  responses.   The  Draft  EIS  document  should be
consulted for additional details and references as required.
                                     1-7

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2.0  EIS STUDY SUMMARY

2.1  Environmental Setting

     Location and Topography

     The planning  area  is located in eastern St. Charles County, Missouri and
encompasses  the  lower Dardenne,  Spencer,  and Duckett  Creek watersheds.   The
planning  area includes the  City  of  St.  Charles, the City  of  St.  Peters, and
the  Duckett  Creek Sewer District.  The planning  area  is situated between the
Missouri  and Mississippi  rivers immediately west of the confluence of the two
rivers.   Topographically,  the  planning  area  is  divided  into  two different
areas,  an upland  area and a  floodplain area.

     The  majority  of  the population  in  the planning  area is  in  the upland
portion which contains hilly uplands with rolling to steep  slopes  and rounded
divides.   Areas  of karst topography exist between  Spencer Creek and Sandfort
Creek  near  1-70  and between Duckett  Creek and Taylor Branch.  Karst topography
is  characterized  by a  rugged  landscape  with dissolution  of  the underlying
limestone.

     A broad  floodplain  area  exists  in  the northern  portion of the planning
area  and  contains  agricultural uses,  scattered residential  and industrial
developments, and  extensive waterfowl habitat  in low-lying wetlands,  sloughs,
and oxbows.

      The  land surface  is   nearly  level  to  flat.   Wastewater  collection  and
 treatment primarily is provided by the three participating authorities  and,  in
 some areas, by private utility districts  that serve  a  single subdivision.  The
 floodplain  area  currently  is not served by centralized wastewater collection
 and treatment systems.

      Air Quality

      St.  Charles County is  located within the  metropolitan St.  Louis  Inter-
 state  Air  Quality Control  Region.   Carbon monoxide (CO) is the most pervasive
                                     2-1

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air pollutant.  More  than  75% of the CO emitted in the St.  Louis  metropolitan
area   comes  from   motor  vehicles.    The  area bordered   by  1-270  and  the
Mississippi River  is  not  in  attainment of  the National Ambient Air  Quality
Standard (NAAQS) for  CO.   Data collected at the nearest monitoring  station in
St. Ann indicates a trend toward lower CO concentrations.

     All of the St.  Louis metropolitan area  is designated  as  nonattainment
area for ozone.  Ozone  in the lower atmosphere is a major component of photo-
chemical smog.   In addition,  the St. Louis metropolitan area has not met the
secondary  NAAQS  standard  for  total  suspended  particulates,  and  the  downtown
area of  the city has not attained the primary standard.  Particulates include
dust,  soot,  and  fly ash.  The major  sources  of particulates in the St. Louis
area are coal combustion, construction  activities,  automobile exhaust, agri-
cultural  activities,   industrial  processes,  and  traffic  on  unpaved  roads.

     Geology and Soils

     St. Charles County is characterized by several types of geologic history
including   Paleozoic  deposition   and  erosion,  the  advance  and  retreat  of
Pleistocene glaciers,  and deposition of  alluvium from major  river  systems.

     The  bedrock  of  the  area  consists of Mississippi  and Pennsylvania-aged
sedimentary rocks   under the  uplands.   Pleistocene and recent-aged  deposits
overlie  the bedrock  except  at  some  outcrops.   In  the  upland areas, glacial
till,  loess, and occasional alluvium  are present.   In  the floodplain, alluvium
overlies  the bedrock.  Bedrock  formations  consist of  limestone,  chert, dolo-
mite,  shale, and sandstone.

     The  soils  in  the planning  area  are mostly silts and clays  although some
sands  are  present  in  the floodplain areas.  The soils  generally exhibit low to
moderate  permeability,   depending  on the  clay  content,  except in portions of
the floodplain  areas where sandy  soils  with high permeabilities are present.
The depth  to  the seasonally high water  table  generally is between 2 and 6 feet
in the upland  areas, except in the  low-lying  areas along the stream bottoms
where  the  water  table is less  than 2  feet  from  the surface.   In the floodplain
areas, the depth  to  the seasonally high water  table generally ranges  from 0.5
                                     2-2

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to 3 feet.  The  primary constraints to the use of onsite wastewater treatment
systems in the planning area are wetness, periodic flooding, and slow percola-
tion.

     The St.  Charles  County soil survey estimates that  about  5% of the plan-
ning area soils have slight limitations, 8% have moderate limitations, and the
remaining 87% are rated  as  having servere limitations  for  the  use of onsite
wastewater  treatment  systems.  The  facilities  planner's preliminary estimate
is that there are approximately 11,000 residences in the planning area utiliz-
ing onsite systems.

     Water Resources

     The  planning area is  located immediately west of  the confluence of the
Mississippi  and  Missouri rivers.   Of the  150  estimated square  miles in the
planning  area,  12.8%  is in the  Lower  Missiouri River Subbasin (a  subbasin of
the  Missouri  River Basin),  and 87.2%  is in the Upper Mississippi River Basin.
As  a result of the planning  area's  location near the confluence of two of the
nations largest  rivers, the small  streams within the planning area  are antici-
pated  to  have negligible influence  on downstream receiving water quantity and
quality.  Six named creeks of  low or  intermittent  flow provide surface water
drainage  in  the planning  area.   Tributaries  to the  Mississippi  River are
Spencer Creek,  Cole Creek,  Sandfort Creek, and Dardenne Creek.  Duckett Creek
and  Taylor  Branch drain into  the Missouri River to the south.

     Urbanization has proceeded at  a  high  rate in the planning area  over the
last decade  and  may  have a  significant influence  on flow characteristics of
these  small streams,  especially Spencer and  Duckett creeks, because  of  their
small  drainage areas.

     Dardenne Creek is classified as  a  "water quality  limited stream" by the
Missouri  Department of Natural  Resources (MDNR).  Presently, the Duckett  Creek
Sewer  District's Harvester-Dardenne STP discharges  to  a tributary  of Dardenne
Creek.  A  recent study  conducted by  the  MDNR, concludes that the Harvester-
Dardenne  discharge be eliminated and that the St.  Peters  STP be  upgraded  to
 include  nitrification facilities.
                                     2-3

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     The Mississippi and Missouri  rivers  are designated for use  as  a  drinking
water  supply,  industrial  uses,  commercial  fishing, boating,  aquatic  life,
irrigation, and  livestock  water supply.   The Mississippi  River is also  de-
signated for body-contact recreational activities.

     According to the  208  planning study, Dardenne Creek and  its  tributaries
are subject to pollution from point sources, nonpoint sources, and undersized
or  failing onsite  systems.   Duckett  Creek  is  subject  to non-point  source
runoff from both rural and  urban sources.

     Nine  of  the  16 wastewater treatment  plants in  the planning area  with
effluent discharges had BOD and/or TSS concentrations in excess of their KPDES
permit  limits  for  one or  more of the  reporting periods  from October  1981
through September 1982.  Furthermore,  a comparison of effluent discharge flow
rates, with both  average and 7-day Q2s for  the  small streams, shows  that the
facility  discharges may greatly  exceed  the  estimated stream flows.   During
periods of  low  stream flow in Dardenne, Spencer, and Duckett creeks,  effluent
discharges would  account for a majority  of  the  flow volume in those streams.

     Groundwater  in the planning  area occurs in the  underlying alluvium and
bedrock  aquifers.   The  alluival  aquifers  underlying  the  Mississippi  and
Missouri  rivers  are  the  primary  sources  of groundwater.   The  quality of
groundwater  in the  alluvium  is  variable,  but  generally  has high  iron and
manganese  concentrations  and high  total  dissolved  solids.   Water in bedrock
wells  is  used minimally for public water  supplies.   Private water supplies,
including several subdivisions and mobile home parks, use bedrock and alluvial
wells.  The quality of the water  in  the  bedrock aquifers is highly variable,
with the quality being poorer near  the Mississippi River.  High iron, chloride
or  fluoride concentrations are the most  frequently  encountered  problems.  In
addition,  radionuclides in  some bedrock wells  exceed the  state  recommended
maximum standard.

     Sensitive Environmental Resources

     The sensitive  environmental resources that occur in  the planning area are
prime  agricultural  lands,  floodplains,  and wetlands.
                                    2-4

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     Approximately 45% of  the St.  Charles County meets  the  soil requirements
for prime  farmlands.  Most of the farmland is  located  in the Missouri River,
Mississippi River, and Dardenne Creek floodplain areas.

     Flooding occurs  on  nearly all of the bottomlands  of the Mississippi and
Missouri  rivers  and  on many of  the smaller  streams  in the planning area,
particularly during the  spring season.   No flood control  reservoirs  exist in
the planning area; however, several creeks have undergone channel modification
to  reduce the  flood potential  and the  Missouri  River is  almost completely
controlled by an extensive reservoir system in its headwaters area.  In addi-
tion, St. Charles County has  adopted a floodplain ordinance that complies with
the requirements  of the National Flood Insurance Program.

     Wetlands occur predominantly in the  northern half of the planning area in
the  Mississippi River and Missouri River floodplains.   Most of the wetlands
are  emergent palustrine type and are  extremely valuable for  a diversity of
wildlife  in  the planning area.

     Aquatic and  Terrestrial  Ecology

     Important  aquatic habitats in the  planning area include the  Mississippi
and Missouri rivers,  the numerous  small  streams  which disect  the planning  area
from  north to  south, and  several  small  lakes  and ponds.  The Mississipi River
is  a productive  fishery with carp, buffalo and sunfish being the  most  import-
ant  species.   Phytoplankton, zooplankton,  and macroinvertebarates  are  also
found  in the rivers  and lakes.   Diatoms are an important constituent  of  slow
flowing  streams  and the  Mississippi River.   However, overall phytoplankton
abundance is limited  by  high  levels of  turbidity in area streams.

      Four major  terrestrial  land  cover  types  that occur in  the planning  area
 are  forest,  agricultural,  wetlands,  and urban/residential.   Bottomland  forests
 and unforested  bottomlands exist along  the floodplains  of the Missouri  and the
Mississippi  rivers and along  sections of major streams.

      The southern half of  the planning  area  contains oak-hickory forests.   The
 forest areas support a  variety  of birds, turtles,  snakes, squirrels, opossum,
                                     2-5

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mice,  and  white-tailed  deer.   The bald  eagle is  the  only Federally  listed
endangered species that frequents habitats in the  planning area.

     Land Use

     The existing  land use  in  the planning  area is influenced  primarily by
natural features,  i.e.,  floodplains,  steep slopes and stream  courses,  and by
transportation  routes.   The cities of  St. Charles  and  St. Peters  developed
adjacent to  the railroads  which extended across the county and linked the St.
Louis area with the western plains.

     The major  natural  feature  that affects land use in the planning area is
the broad  floodplain  area  of the Mississippi and Missouri rivers.  The flood-
plain  is  demarcated by  the steep  bluff  line that  differentiates  the upland
portions of  the planning area from the nearly level,  lowland  portions of the
planning  area.   The  bluff  line also represents  the boundary between urban
development  and the  open space, agricultural  uses  of the floodplain.  Within
the  upland areas, development  also is  limited in  some  areas  by  steep slopes
that are present in the watersheds of the smaller tributary streams.  Eighty-
five percent of the planning area  is non-urbanized with the next largest land
use being  residential which occupies about 10% of the total area.

     Land  use within the planning area is  regulated by St. Charles County, and
the  cities  of  St. Charles,  St.  Peters,   and  Portage  des Sioux.   Zoning and
subdivision  ordinances  are  the means   of  land  use regulation used.   The
majority of  the upland portion  of  the planning area is zoned for residential
use while  the floodplain portion primarily is  in  floodplain zoning as required
by the National Flood  Insurance  Program.

     The  Golden Triangle area which includes  land  that  is within the  service
areas  of  the cities  of St. Charles,  St.  Peters, and the Duckett Creek Sewer
District  is  projected to experience moderate  increases  of about  2-4% per year
in residential, commercial,  and  industrial land use.

     The City of St.  Peters anticipates annexation  of about  4,000 acres by the
year 2000.  Most  of the residential growth  will occur  in undeveloped areas.
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Within  Spencer Creek  and Dardenne Creek  watersheds,  most  commercial  growth
will occur along  1-70  and the Missouri highway corridors.  The most extensive
area  of industrial  growth will  be  in the northwest  portion of  St.  Peters
called the Arrowhead Industrial Park.

     The City  of  St.  Charles expects that  the  majority of future development
will  be in  the area  south of 1-70.   This area  is  planned for  low density
residential development  with  neighborhood commercial centers along Highway 94
and at the intersection of the major collector roadways.

     Population

     St.  Charles  County has both the highest  growth  rate and  the greatest
absolute population  increase  between 1970  and 1980 of the eight counties that
comprise  the St.  Louis  metropolitan area.   The population increases experi-
enced  in  St.  Charles County  and  the two planning  area cities between 1970 and
1980  primarily are the result of in-migration;  70.9% (36,289 persons) of St.
Charles County's population increase was due to  net in-migration while natural
increase  (births  over deaths) accounted for  the remaining 29.1% (14,864 per-
sons.   The increasing attraction  of this  area  for residential development is
further borne out by  information from  the  1980  Census on housing age.  Nearly
half  (49.0%) of the year-round housing units  in St. Charles  County were con-
structed  from  1970  to March  1980.   In St.  Peters,  the  amount  of new resi-
dential construction  in  the last decade  is even more  significant; 93.5% of
that  City's  5,286 housing units  were built from  1970  to March 1980.  In the
City  of St. Charles,  31.6%  (14,344)  of the housing units were built over the
same  period.

      Based on population projections  which are  discussed more  fully in  Section
3.2.2.3 of  the Draft EIS,  St.   Charles Service Area is expected  to  increase
 from  55,100  in 1985  to  89,800   in the year  2005.  St.   Peters is  expected  to
 increase  from  21,200  to  43,000,  and  the Duckett Creek  Service Area  expected
growth is approximately 42,500 to 60,850.
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     Cultural Resources

     St. Charles  is one of  the  oldest  communities in Missouri.  Most  of  the
historic resources included on the National Register in St.  Charles  County  are
within  the  community of St.  Charles.   There  are no prehistoric sites  in  St.
Charles County currently listed  on the  Register.  However,  a number of Paleo-
Indian  sites  have been found  in Missouri on terraces and bluffs adjacent to
stream channels and floodplains and it is possible that interceptor  sewers  may
traverse such areas.   Avoidance  of adverse impacts on cultural resources will
require the development of a well organized management plan.

     Economics and Financing

     The total  employment in  St.  Charles  County  increased  at  a higher rate
than  the  County's  population between  1970  and 1980.  Total  employment  in-
creased by 83.8% during the 1970s while the population increased by  55% during
the  same  period.    In  the  St. Louis  SMSA  (Standard  Metropolitan  Statistical
Area)  employment  levels decreased  by 21%  during  the 1970s  while  population
levels decreased by only 2.3%.

     In  1980,  retail   trade,  services  and  manufacturing  sectors were  the
greatest  for both  St.  Louis SMSA  and  St. Charles  County.   In recent years,
layoffs in  the auto  industry and  other  large  manufacturers have contributed
significantly  to   the  number  of unemployed  in the  St. Louis  area.   Bonded
indebtedness  ranges  from  approximately  $6.5   million  for  the  City  of  St.
Charles to over $12 million  for  St. Peters.  Correspondingly, St. Peters has  a
substantially higher debt  per capita, $766 versus  $52 and $31 for the County
and  St. Charles,  respectively.    The  residents of  St.  Peters also  pay more
property taxes  per capita ($59) than the  County ($27) and St. Charles ($43).

     The Duckett  Creek Sewer District is  a quasi-governmental agency that is
responsible  for  its  own financial  accounting.   During  1981,  the  District
received  revenues  of  $772,820   composed   largely  of  sewer  service   charges
($567,743)  and -connection fees  ($111,718).   After budgeted  transfers of  some
of the revenues to  other funds,  the total  revenues  received by  the District in
1981   were  $511,937.   Expenditures during 1981  totalled  $455,864  of which
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$315,894  was  spent  for operation,  $88,561  for  administration,  $43,114  for
general expenditures, and $8,295 for emergency expenditures.

     Community Services

     Community services  (police  and fire protection, energy, and health care)
are adequate  to  meet the needs of  the  planning  area.   With the rapid popula-
tion growth occurring in St. Charles County, additional educational facilities
will be required in the short-term.

     Solid waste disposal  is  a growing concern for  the  planning area.  Capa-
city  studies  of the  two major landfills serving St.  Charles  County indicate
that  the  West Lake  Landfill  achieved design capacity in  1983  while the Fred
Weber  Landfill   should  remain  active until  1988.   The St. Charles Planning
Department  has   identified four new  potential  solid  waste disposal  sites.

     Federal,  state  and  county highways,  the  St.  Louis  Airport,  the  St.
Charles County Airport,  and the private St. Charles Airport provide the major
transportation routes  for  residents of the planning area.   No  passenger rail
service  is  available.   The availability of  adequate  transportation will con-
tinue  to be  an  important factor  in  the  development of  the  planning area.

2.2  Wastewater  Treatment  Problems/Need for Action

     Centralized as well as onsite wastewater collection systems are presently
being  utilized  in the Duckett Creek  Facility Planning Area; however, most of
the sewage is collected  and treated by  centralized systems.  A majority of the
communities  in   the  planning  area  have  a  centralized  collection system(s) or
jointly  share a  system with  a  neighboring community(ies).  Other private col-
lection systems  are  used primarily  in rural areas where the population density
is too low to warrant  construction  of sewers.

     The  Duckett  Creek  Facility  Planning  Area  is  located  in  eastern St.
Charles  County  (Figure  1-1).  The population of the  planning area was esti-
mated  at 103,400  in 1983  and  is projected to be  193,700 by  year 2005.  The
planning  area includes  the Upper  Mississippi  River—Salt River Basin water-
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sheds of Dardenne, Spencer,  Sandfort,  Cole,  and Boschert creeks  and  the  Lower
Missouri River Basin watersheds of Duckett Creek and  Taylor  Branch, along with
the City of St. Charles'  Missouri River Service Area.

     Approximately 56% of the 96,000-acre planning area is under  the  jurisdic-
tion of three sewer authorities: the Duckett  Creek Sewer District,  the City of
St. Charles, and the City of St. Peters.  Portage des Sioux maintains a separ-
ate  sewer  system.   Most of  the heavily populated areas of the  planning area
are  sewered,  with the exception of a  few subdivisions.  Rural  residents  and
isolated  communities  predominantly  use septic tanks.   Much  of the planning
area is undevelopable floodplain.

     Wastewater  generated  in  the  planning area  is  primarily  domestic sewage
although  there  are  some  industrial and  commercial  discharges.   Currently,
there  are  16  domestic  wastewater  treatment   facilities  and  six  industrial
facilities.  The  industrial  discharges include filter backwash water and lime
sludge  lagoon  decant  from  three water  treatment  plants;  cooling water,  floor
and  sink drains  washwater,   steam condensate,  and  boiler blowdown  from an
organic  chemical manufacturer; cooling water  from a  metal  casting operation;
and truck washdown water from  a concrete plant.

     The  eastern portion  of  St.  Charles  County is  experiencing  significant
population  growth  and urbanization.  As a result of past and projected growth
in  this area, improvements  in wastewater  collection and treatment  facilities
are  necessary.  In addition,  some existing wastewater treatment  plants have
not  been able to meet effluent  limitations specified  in their National Pollu-
tant Discharge Elimination System  (NPDES) permits due to hydraulic  overloads,
system  deterioration, and related  factors.   Some  areas currently  served by
onsite  wastewater  treatment  systems  also need  improved  wastewater systems
since many  existing systems are not providing an adequate level of treatment
to safeguard public health.

     In order to develop  a  plan  for increasing wastewater treatment  capacity
and  capabilities,  as well  as  provide  adequate  collection facilities,  a waste-
                                                                             *
water   facilities  planning   study  was initiated  in  1981.   The   facilities
planning area includes the  cities  of  St.  Charles and St. Peters, the Village
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of  Portage  des  Sioux,  and  unincorporated portions  of  eastern St.  Charles
County,  The facilities planning consultant, Sverdrup & Parcel and Associates,
Inc., developed  and  evaluated  several alternatives which would correct exist-
ing  pollution  problems  and provide necessary improvements  in wastewater col-
lection and treatment capability and capacity.

2.3  Description of Alternatives Including the Recommended Alternative

     Eight preliminary alternatives for collection and treatment of wastewater
in  the planning area  initially were  developed.   These alternatives involved
eight interceptor sewer system configurations to transport wastewater from the
six  sewer  service  subareas within the planning  area  to various sewage treat-
ment plants (STPs).  Elements common to each alternative included the eventual
abandonment of five STPs and six pump stations.  The five STPs to be abandoned
include:   Highway  94-South STP, St.  Charles Trails  STP,  Heatherbrook Lagoon,
Boschertown Lagoon,  and Riverview Hills Septic Tank.  Sewage pumping stations
to be abandoned  included:  Riverview Drive, Bedford Mobile Park, Princess Jodi
Mobile  Park,   Hutchins  Metals,  Heatherbrook  No.  1,  and Heatherbrook  No.  2.
Depending  on  the  alternative  selected,  the  following STPs would  be either
abandoned,  expanded,  or upgraded:  Mississippi  River  STP,  Spencer Creek STP,
Harvester-Dardenne STP,  and  Missouri River STP.  For each municipal STP to be
utilized  under  the  eight  preliminary  alternatives,  various  treatment  and
disposal  options  were  considered by  the facilities  planner.   These eight
preliminary alternatives  were  further screened  in order to select four alter-
natives  for detailed evaluation.   Screening  factors  considered were:  costs,
environmental  constraints,  reliability,   flexibility,  and   implementability.
The  respective rankings of each  of the eight preliminary alternatives based on
these  evaluation criteria were presented in Table 2-10, page  2-83 in the Draft
EIS.

     The  four  wastewater management alternatives selected for detailed analy-
sis  in the facilities plan  involve  the  continued use of either three or four
                                                                         v
municipal  STPs  throughout  the  20-year  planning period,  while  the Highway
94-South  STP would  become an  interim  treatment facility under each alterna-
tive.  Specific  descriptions of  these  final four "action" alternatives  and the
"no  action"  alternative  are  presented  in  the following  sections.   Public
views,  non-monetary factors, and  economic  factors  for each  final alternative
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were compared to  arrive  at the recommended alternative.   In the draft facili-
ties plan, an analysis  of the four final action alternatives (Alternatives 3,
6, 7,  and  8)  was  performed using EPA's CAPDET program.   Special attention was
given  to  types  of  activated  sludge systems and sludge handling  methods.   In
some cases, the costs derived by computer assistance were refined.

     Engineering  considerations  and site-specific  conditions  weighed heavily
in the  selection  of sludge handling options for the four action alternatives.
Two filter presses  and  an incinerator are  currently  in  operation at the Mis-
sissippi River Plant.  The sludge handling equipment at the plant has adequate
capacity  to  accommodate  additional loads resulting from  population growth in
the planning  area  during  the 20-year design period.  The  incinerator at the
Mississippi River Plant  can also handle sludge from the Missouri River Plant.
In  the facilities  plan,  a  determination  was  made  that  it  was  more cost-
effective  to  transport  dewatered sludge from the Missouri  River Plant to the
Mississippi River Plant,  than to construct a sludge  handling  facility at the
Missouri  River  Plant.  Filter  presses were  selected  as the  best dewatering
method  at the Missouri River Plant.

     Although disposal  of sludge incinerator ash could continue onsite at the
Mississippi  River  Plant,  disposal of the ash  in  a sanitary landfill would
eventually be necessary.  All costs in the analysis assumed disposal of ash in
a landfill.

     Belt  filter presses were recommended for sludge dewatering at  the Spencer
and Duckett  Creek plants.  Belt  filter  presses  are cost-effective for plants
of  this size and are simple to operate and  maintain.   Final  disposal of the
sludge, derived primarily  from residential versus  industrial sources, would
preferably be by land application  as  a  soil  conditioner; however,  landfilling
costs  are essentially  the same as land application.   In the facilities plan
analysis,  all cost estimates assumed were  for land application of  digested
sludge, although  no comprehensive  final sludge disposal plan  was presented in
the facilities plan.

     The  selected wastewater  management  option  for  the floodplain areas should
be the most  cost-effective and  implementable  of the available  options. The  one
option investigated  in  the facilities  plan  was conventional  gravity  sewers.
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Because this  option is  high in  cost  and involves a  long-term commitment to
maintaining these communities, other options such as onsite treatment systems,
that have  lower costs  and a  lower  level of  service  were investigated.   The
Federal Emergency Management  Agency  (FEMA) policies  discourage construction
and maintenance of  residences  in areas  subject  to  frequent flooding.   Flood
insurance  rates are based on flooding frequency and  are  established to  dis-
courage  residential  development in  floodplains.  The  insurance program is
intended to replace  the need for  "disaster" funding (through which individuals
previously  repaired  their residences  following floods) by discouraging devel-
opment  in  flood-prone  areas.   Because  other  Federal programs  likewise are
attempting  to  discourage residential  development in areas subject to frequent
flooding,  no  significant  investments  in infrastructural  improvements  can be
recommended.

     To  improve the effectiveness of  wastewater  management  planning in  these
floodplain  areas,  establishment  or expansion  of  an  onsite wastewater manage-
ment  district  to  direct  and oversee  onsite  system  improvements  should be
strongly   considered.    This   management  district  or  agency  should provide
evaluations  and supervision  specifically for  onsite  system construction and
maintenance  so that the public  health of the  residents  of the  area  is not
jeopardized.   The upgrading  of   existing onsite  systems  would  not  provide  a
level  of  protection equivalent  to  centralized  sewers, but centralized  man-
agement and upgrading of failing onsite systems in particular,  would  result in
improved  operations  and reduced  potential health  risks.  Flooding  events  would
remain as major problem  periods  with  onsite  systems,  although  the centralized
alternatives  also  could be rendered inoperable during  major  floods.

      Brief descriptions  of  each of  the alternatives  selected for detailed
evaluation,  including the "No Action"  alternative are  presented below.

2.3.1 No Action

      The   "No  Action"  Alternative  implies  that no Federal,  state, or  local
 funds would be provided to build and/or upgrade wastewater management systems.
Problems  identified in  Section  2.2 would be expected to  remain unsolved, and
as a  result,  new problems  likely would  develop during  the 20-year planning
period.
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     Within the  City of  St.  Charles, the  Missouri  River STP is not  meeting
secondary effluent  limitations  specified in the NPDES permit  established  for
the facility.   The plant is currently overloaded,  therefore,  the  likelihood of
bypassing  raw sewage to  area streams,  as  a result  of  increased 1/1  during
storm events,  would increase.  Both  the St.  Charles Trails STP and  the  Hea-
therbrook Lagoon  have not  consistently  met their established NPDES  effluent
limitations.  It  is  unlikely  that effluent limitations could  be  attained for
both facilities unless  some corrective action is taken.   The  consequences of
no  action  would be  to  further degrade  area stream water quality due to the
discharge of inadequately treated wastewater.

     Within  the City  of  St.  Peters, the  Spencer  Creek STP does  not  con-
sistently meet  its  NPDES effluent limitations for TSS.   Based on the results
of  a  wasteload allocation  analysis  for  lower Dardenne Creek, it  is  expected
that  the  STP will  be required to  remove  ammonia  in order to  continue  dis-
charging effluent to Dardenne Creek.   Due to existing facility design, the STP
is  not  capable of  providing ammonia  removal  and an effluent pump  would be
required  to  convey  effluent to  the  receiving  stream during heavy  rainfall
events.

     Within  the  Duckett Creek  Sewer District,  the Harvester-Dardenne  STP,
Highway  94-South STP,  and Boschertown  Lagoon  have little,  if any,  excess
capacity for  increased wastewater flows  resulting from projected future devel-
opment.  Based  on the wasteload allocation analysis  for lower Dardenne Creek,
both  the Harvester-Dardenne STP and Highway 94-South STP would be required to
remove ammonia  if they continue to discharge effluent to Dardenne Creek.   Due
to  existing design,  neither  STP is  capable of  removing  ammonia from waste-
water.   Without any modifications, these three  treatment plants are expected
to  be  hydraulically  overloaded,  resulting in  further  degradation  of the
effluent and  water quality  of the receiving  stream.

     Areas  served by onsite  sewage  treatment  systems  which have experienced
problems,  would be  expected to continue to have problems under the no action
alternative.   These  problems would  result in  the  continued degradation of
local area  streams,  as well as present a potential health  hazard.
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2.3.2  Alternative 3

     Alternative 3 would  involve  the continued use of  the  Spencer Creek STP,
Duckett Creek  STP,  Missouri  River  STP,  and Mississippi River  STP.   Each STP
would treat wastewater conveyed from their respective service areas (see Table
2-8c and Figure 2-6 in the Draft EIS).

     The Highway  94-South STP  would initially be expanded and  upgraded  to a
0.5  million  gallons  per day  (mgd)  treatment  plant.   The  plant would  be
operated  until the  interceptor  system  is  constructed  in 1989,  which would
transport wastewater from the South subarea to the Spencer Creek STPs.

     The Spencer  Creek  STP would be expanded to a 7.5 mgd secondary treatment
plant.  The  existing  treatment plant would be converted to a contact stabili-
zation  activated  sludge  plant.  An effluent  chlorination  system,  effluent
pump,  and  outfall to  the Mississippi River would be  constructed.   Selected
sludge  treatment  and disposal  options  would  require  construction of gravity
thickeners  and an aerobic  digestion system  and  installation of  belt filter
presses to  dewater  the sludge.  Dewatered sludge would be disposed of by land
application.

     The existing Duckett Creek STP would be replaced by a new 1.0 mgd second-
ary  treatment  plant  constructed on the existing plant site.  The new facility
would  be  an oxidation ditch  activated sludge  system with effluent discharged
to  Duckett  Creek.    New  sludge  treatment  units  would  consist   of  gravity
thickeners,  anaerobic  digesters,  and belt  filter presses.  Sludge  would be
disposed of  by land application.

     The  Missouri River  STP would  be  expanded and  upgraded from a  3.0 mgd
primary facility  to a 5.0 mgd  secondary treatment plant.  The selected liquid
treatment  and  disposal  options would include  the expansion  of the existing
primary treatment  system  and  construction  of  an  oxidation  ditch system.
Treated effluent would  continue  to be discharged by  gravity to the Missouri
River.   The selected sludge  treatment and  disposal  options include construc-
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tion of gravity  thickeners  and the addition of belt filter presses for sludge
dewatering.  The dewatered sludge would be hauled to the Mississippi River STP
for incineration.

     The Mississippi River  STP would be expanded from  a  5.5 mgd to a 7.0 mgd
secondary  treatment plant.   The plant would continue to  consist of a primary
sedimentation,   step   aeration  activated  sludge  system,  with  chlorinated
effluent flowing by  gravity to the Mississippi River.  Existing sludge treat-
ment facilities  would  continue to be  utilized.   Sludge facilities would con-
sist of gravity  filters, filter presses, and an incineration system.  Disposal
of  incinerator  ash would  continue onsite  but would eventually be sent to a
sanitary landfill.

2.3.3  Alternative 6 (Facility Plan and EIS Recommended Alternative)

     Alternative 6  is the  facilities plan and  EIS  recommended  alternative.
Alternative  6   would  involve  the  continued  use  of the Spencer  Creek STP,
Duckett Creek  STP, Missouri River STP, and  Mississippi  River STP.   The Highway
94-South  STP would be operated  until  the  interceptor system that  would  trans-
port  wastewater from  the  South  Subarea  to  the Duckett  Creek  STP  is con-
structed.   The  Spencer Creek  STP would be  upgraded,  as described  for  Alterna-
tive  3.   However, under  Alternative 6, the plant  would  be expanded to a  4.0
mgd facility and the effluent would  be pumped  to  the  Mississippi River.

     The  existing Duckett Creek STP  would be replaced by  a new 5.0 mgd second-
ary treatment  plant  constructed on  the existing plant site.   The  selected
 liquid treatment/disposal  options are the  same as  those  described for Altern-
 ative  3.  The  only  difference between the  selected  sludge  treatment/disposal
 options under  Alternatives 3  and 6  is that sludge  stabilization  would be by
 anaerobic digestion  in  Alternative   3  rather than  by  aerobic digestion  in
 Alternative 6.   The  Missouri River  STP  would  be  expanded  and  upgraded as
 described under Alternative 3.
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     The Mississippi  River STP  would  be expanded  and  upgraded to a  7.0  mgd
secondary treatment  plant.  The  expansion  and upgrade  scheme  is similar  to
that described under  Alternative 3.   The only major difference  between Alter-
native  3  and 6  is  that under  Alternative  3, effluent would flow by  gravity
rather than be pumped to the Mississippi River.

2.3.4  Alternative 7

     Alternative 7 would  involve the continued use of the  Duckett  Creek STP,
Missouri River STP,  and Mississippi River STP.

     The Highway 94-South  STP  would be abandoned when the  interceptor system
is constructed to convey  wastewater to the Mississippi River STP.   One major
difference between  the previously described  "action" alternatives and Alter-
native  7,  is  that  the  Spencer Creek  STP  would be  abandoned  in 1995  under
Alternative  7  rather  than remain operational  throughout  the  20-year  planning
period as under the former alternatives.  The Spencer Creek STP  would become a
pump station and wastewater would be pumped  to  the  Mississippi River STP for
treatment.

     The Duckett Creek STP would be replaced by a new 3.5 mgd secondary treat-
ment plant constructed on the existing plant site.  The  treatment plant scheme
would consist of the same treatment/disposal options for  wastewater  and sludge
that was developed in Alternative 6.  The Missouri River  STP would be expanded
and upgraded as described under Alternative 3.

     The Mississippi  River STP  would  be  expanded and upgraded to a  12.0  mgd
secondary treatment  plant.  The  upgrade  scheme is similar to  that  described
under  Alternative  6.   The only major difference  between Alternative  6  and
Alternative  7  is that  under  Alternative 7,  sludge is aerobically  digested,
while under the Alternative 6,  sludge is not digested.

2.3.5  Alternative 8

     Alternative 8 would  involve the continued use of the  Spencer  Creek STP,
Duckett Creek STP,  Missouri River STP,  and Mississippi River STP.
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     The Highway 94-South STP  would  be abandoned when the  interceptor  system
is constructed  to  convey wastewater  to the Spencer  Creek STP.  The  Spencer
Creek STP would be  upgraded,  as described for Alternative  3.   Under Alterna-
tive 8, the plant would be expanded  to a 5.0 mgd facility.  The Duckett Creek
STP would be  replaced  by a new 3.5 mgd facility, as described for Alternative
7.  There  is  no difference  between  the  Duckett Creek STP replacement plant
developed  under Alternatives   7  and  8.  The   Missouri  River  STP would  be
expanded and  upgraded  to 5.0 mgd as  described  under the other "action" alter-
natives .

     The Mississippi  River STP  would  be expanded  to a 7.0  mgd facility,  as
described under Alternative 6.  There is no difference between the Mississippi
River STP expansion developed under Alternative 6 and Alternative 8.

2.3.6  Comparison of Final System Alternatives

     This section presents preliminary construction, operation and maintenance
costs  for  the four  final sewage conveyance and treatment alternatives identi-
fied in previous  sections.   Economic analyses  were based  on  a 20-year design
period.  Projected  wasteloads  and flows for the year 2005 were used  to size
sewer  lines,  pumping  stations, and treatment facilities.   A  discount  rate of
8%  over a  20-year period  was used  during  facilities planning to determine
present worth and uniform annual equivalent costs  for the economic analysis.

     Cost  estimates were only one of the factors used in the detailed evalua-
tion  of alternatives.   Non-monetary factors such as environmental, reliabil-
ity,  flexibility,   and  implementability  were  also considered.   This   section
briefly addresses each of these factors.

     • Cost-Effectiveness Analysis--A  summary  of CAPDET  costs for  comparison
purposes  is  shown  in  Table 2-1. Project operation and maintenance costs are
shown  for  each of  the  four final action alternatives.   Present worth values
are  also  presented.   The values shown in the table  do  not include costs for
facilities  that are common to  all alternatives.
     • Non-Monetary Factors—Non-monetary  factors used  in comparing alterna-
tives  included reliability,   environmental  effects,  floodplain  infringement,
energy use, public  approval, implementation  capability, contribution to goals,
and  expandability.    Environmental  consequences  from  the  construction and
operation  of  the four  final  action alternatives  and the no  action alternative,
were discussed  in detail in  Section  4.0  of the Draft  EIS.
                                     2-18

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     Floodplain infringement would  result  from the construction of any of the
four final  alternatives.   Alternatives  3,  6,  and 8 would  require  force main
easements  from the  St.  Peters  STP site to  the Mississippi River  discharge
point.   Alternative  7  would  require force main  easements from  the  St. Peters
STP  site  to  the St.  Charles  Mississippi River STP.   Each alternative also
would require limited land acquisition at existing treatment plant sites, some
of  which  are  in the  floodplain.   Impacts of  the various  alternatives upon
wetlands and  floodplains  were  discussed in Section 4.2.1.6  of  the  Draft EIS.

     A  primary energy  analysis using CAPDET output and  engineering estimates
for each of  the alternatives was performed.  Alternative 7  would have lowest
energy  use.   This primarily is  due to converting the treatment  plant at St.
Peters  to  a  pumping  station.   The pumping station would use much less energy
than an activated sludge  plant.   Also, with  Alternative 7, the St.  Charles
Mississippi River STP sludge incinerators and filter presses would be replaced
by  aerobic  digesters  and belt  filter  presses, saving additional  energy.
Alternatives 6  and 8 are comparable to  Alternative 3  which requires slightly
less energy due to a lower pumping head at the Harvester-Dardenne pump system.
Pumping wastewater to the St. Peters collection system would result in the use
of  smaller pumps rather  than  pumping  over  a ridgeline  to  the Duckett Creek
STP, as'would be required in Alternatives 6 and 8.

     •  Implementability—Implementability refers  to the  political and admini-
strative actions  that  are required for  an alternative to be successful.  For
example,  implementability  is  difficult  when  more  than  one  agency  must
cooperate.    Implementability  is  also  difficult if voters  are  reluctant  to
authorize a regional sewer district.

     Implementation  of each alternative is  a key issue because of political
impacts on the  three  existing sewer agencies.  Alternatives 3 and 8 combine
the St. Peters and Duckett Creek service areas, while leaving St. Charles with
its  existing service  areas.   Alternative 7  combines  the St.  Peters  and St.
Charles service areas.  The  City of St. Charles  has  expressed opposition to
any plan to  serve other than their existing service area with their treatment
facilities.  St. Charles has sized their facilities for future growth and does
not wish to  subsidize  wastewater treatment for other areas.  With Alternative
6, each agency would retain its current  service areas,  and this alternative is
supported  by the Duckett  Creek  Sewer District,  and the  cities of  St. Peters
and St. Charles.
                                    2-19

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                                 TABLE 2-1
              EVALUATION OF COSTS FOR THE FOUR FINAL ALTERNATIVES
                                              Alternative (Million $)
                                          3         6         7         8
PROJECT COST
1.  Treatment                           34.4      34.0      31.3      36.2
2,  Transmission                        10.8       7.4      19.3       7.9
3.  Total                               45.2      41.4      50.6      44.1

ANNUAL O&M COST
1.  Treatment                           1.69      1.66      1.64      1.74
2.  Transmission                        0.11      0.18      0.23      0.15
3.  Total                               1.80      1.84      1.87      1.89

TOTAL PROJECT COST                      45.2      41.4      50.6      44.1

TOTAL PRESENT WORTH*                    51.4      46.0      50.5      47.3

APPROXIMATE LOCAL SHARE
1.   Duckett Creek Sewer District
     Capital                            4.10      8.25      5.05      5.90
     O&M                                0.34      0.66      0.54      0.60
2.


3.


St. Charles
Capital
O&M
St. Peters
Capital
O&M

9.04
0.90

11.12
0.66

9.04
0.80

4.43
0.38

12.61
0.92

9.27
0.41

9.04
0.80

8.54
0.49
     The present worth analysis uses an 8% discount rate over a 20-year
     planning period and considers salvage value of equipment for the staged
     construction of the projects.

     These values are for comparative purposes only.  Several project items
     that are common to all alternatives are not included in the cost figures.
     Absolute costs may be higher than those indicated in the table.

     Source:  Sverdrup & Parcel and Associates, Inc.  (1984)
                                     2-20

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     All four final alternatives would contribute to the goal of reducing
pollution in the planning area.  Each wastewater treatment option considered
in the facilities plan is capable of meeting effluent limitations.  The abili-
ty to expand wastewater treatment and collection/conveyance facilities in the
future is an important consideration in ranking service area and treatment
plant alternatives.  Generally, for all alternatives, the proposed treatment
facilities could be readily expanded.  Alternatives with extensive pumping,
such as Alternative 7 (where flow pumped from St. Peters to the Mississippi
River Plant), would be more difficult to expand.  Finally, public opinion is
not expected to differ substantially among the four final alternatives consid-
ered in the facilities plan; all action alternatives generally should be ac-
ceptable to the public.

2.3.7  Description of Recommended System Alternative

     Following a detailed evaluation of each of the final action and no action
alternatives,  a  recommended  alternative  was  selected.   The intent  of this
section  is  to summarize the components associated with the recommended alter-
native.  A  discussion of the proposed plans  for onsite systems, private sys-
tems,  and  small systems outside the planning area also are discussed and cost
estimates for all of  the proposed improvements are presented.

      In  the facilities  plan  and the  EIS, Alternative  6 was selected as  the
most  cost-effective system that would satisfy both the needs  and requirements
of the Duckett  Creek Planning Area  and  fulfill environmental and regulatory
requirements.   Alternative 6  consists of  expanding  the Mississippi River  and
Spencer  Creek  STPs,  constructing  new facilities  at the  Missouri River  and
Duckett  Creek  STPs,  abandoning  the Highway  94-South and Harvester-Dardenne
STPs,  and upgrading  the wastewater collection and transmission system.  Fur-
ther,  construction also would  begin  in  the near future  and  various  stages of
 the overall  plan would be put into  effect  at different times during the  20-
year planning period.  The implementation schedule  is  presented  in  Figure  2-14
 on page  2-100 of the  Draft EIS.

      Wastewater Collection and Conveyance Facilities

      The proposed gravity  interceptors,  force mains,  and pumping stations re-
 quired for Alternative  6  are  illustrated in Figure 2-1.   Four major intercep-
 tor routes are  proposed:  (1)  South Plant to  the Harvester-Dardenne  site; (2)
 Spencer Creek  STP  to the Mississippi  River;  (3)  Boschertown lagoon  to  the
 Missouri River STP; and (4) St. Charles Trails STP to 1-70.
                                     2-21

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     Wastewater flows pumped from the South Plant service area would be inter-
cepted by  a gravity sewer.  The  sewer  line would follow Dardenne  Creek  to  a
pumping station north of the Harvester-Dardenne STP where the wastewater would
be pumped  to the Harvester-Dardenne pumping  station.   The  Harvester-Dardenne
pumping station  would pump  both the South  Plant and  the  Harvester-Dardenne
service area  flows to the  new  5 mgd Duckett Creek STP.  Once  the  downstream
treatment facilities  are  constructed the interim South Plant would be elimi-
nated.   Effluent  from  the  Spencer  Creek  STP  will  be  pumped   into  the
Mississippi River.   The force  main would  follow  Spencer Creek  and then run
northward, across the floodplain, to the Mississippi River.

     The Boschertown  interceptor would  run from the Boschertown lagoon to the
Missouri River STP.  Gravity  sewers would be used with  an intermediate lift
station.   This  interceptor would  eliminate  the  Boschertown  lagoon  and the
Hutchins, Riverview, Princess Jodi, and Bedford pumping stations.

     The Missouri River interceptor stops at 1-70.  An extension of this sewer
line  would  eliminate the St. Charles Trails STP, Timbercrest and Heatherbrook
lagoons, Riverview Hills septic  tank and sand filter, and Heatherbrook pumping
stations numbers 1 and 2.   The  alignment of the sewer line would run from the
St.  Charles Trails STP along Taylor Branch, and then follow the MK&T Railroad
to the existing  Missouri River  interceptor.

      Wastewater  and  Sludge  Treatment Facilities

      * Mississippi River Plant

      The Mississippi River STP  would be  expanded  from a  capacity  of 5.5 mgd  to
      7.0  mgd.   The  existing  unit processes  would  be  maintained; however,
      expansion  or  replacement  of certain  items  would  be  required.   The
      mechanically-cleaned  bar  screen installed  in  1968, would be  replaced by a
      similar  piece of equipment  during  the planning period.  The existing raw
      sewage pumps would  be replaced with  centrifugal type  pumps, sized for
      peak  flow.
      The  aerated  grit  chamber  also would  be replaced.  The existing blowers
      could be used with the new, smaller  grit  chamber.   It may be  possible  to
      modify the existing  grit  chamber or salvage the  grit  dragout  system;
      however,  these decisions  should be made  during final design.
                                     2-23

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Three existing primary  clarifiers  were recommended to be supplemented by
two  additional  clarifiers  of  similar size  and design.  Two  additional
clarifiers are necessary  to comply with State design guidelines on over-
flow rates at peak flow.

The existing aeration tanks can handle the additional waste  load.  Deten-
tion times would be shortened,  but should not pose a problem.  The exist-
ing blowers also  are  adequate.   One additional final  clarifier would be
required.  One additional  clarifier would  be  sufficient  to meet State
guidelines  for peak  flow  overflow  rates.   The existing  chlorination
system is  inadequate  and  a contact chamber and additional  chlorine feed
equipment  capacity would  be required.   All of the sludge handling equip-
ment was  determined to have  sufficient reserve  capacity to meet future
needs.

A  new  effluent pumping station would be required.   Currently,  when the
Mississippi River is  at  high  stage, effluent wastewater must  be pumped
through an empty  activated carbon filter to provide enough head to allow
gravity flow  to the  river.   The new pumping  station would  contain three
centrifugal sewage pumps  and would pump effluent through a  force main to
the river.

The  entire plant  requires  an  alternate source  of electrical  power for
emergency  conditions.   This would be provided by generators or two sepa-
rate commercial power feed  lines.  The City of St. Charles is having this
situation  studied and  should  have emergency power for  their  treatment
plants soon.

• Missouri River Plant

The Missouri River STP would be expanded from a 3 mgd primary facility to
a  5  mgd secondary system.  The  plant  was  built in  1966  and most of the
mechanical equipment  would require replacement.   The  Missouri  River STP
would require a mechanical  bar screen to remove trash from the wastewater
to protect equipment and prevent  interference  with downstream treatment
processes.

The  two  existing  sewage pumps  would be replaced by three new centrifugal
pumps.  A  new pumping station would be constructed to house  the new pumps
and  mechanical  bar screen.   It is proposed  that the  existing detritus
tank be replaced by a new aerated grit chamber.

Two  additional primary  clarifiers would be needed  to supplement the two
original  primary  clarifiers.   The  mechanical equipment  in the existing
clarifiers also would need to be replaced, but the concrete tanks should
be salvageable.

An  oxidation ditch  system is  proposed  to provide  secondary  treatment.
Two  parallel  ditches would be  required with return sludge pumping.  An
intermediate  primary  effluent  lift station also  would  be needed to pump
to  the  oxidation ditch  system  and allow  gravity flow  to  the Missouri
River.
                               2-24

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Two final  clarifiers  would be required following  the  oxidation ditches.
Some of  the solids that  are  removed would be returned  to  the oxidation
ditches, while  the  remaining  solids would be sent to the sludge handling
system.  The  existing sludge  handling  system at  the  Missouri River STP
currently is not  used;  however,  the building could  be modified to house
the new sludge dewatering equipment.

A gravity  thickener is  proposed to thicken primary  and  secondary sludge
prior  to dewatering with  two new filter  presses  and associated chemical
conditioning equipment.  The filter presses, similar to those used at the
Mississippi River STP,  would be housed in  the  existing  sludge building.
Once   the  sludge   is  dewatered,  the  cake  would  be  trucked  to  the
Mississippi River STP for incineration.

Changes in  the  existing yard piping would be required along with modifi-
cations  to   the   existing  buildings.    Also,   as   mentioned  for  the
Mississippi River Plant,  an emergency power source would be required for
operational  reliability.   Most laboratory work would  still be performed
at  the Mississippi  River  STP.  Provisions  for  simple  onsite tests would
be made.

•  Duckett Creek Plant

The 1  mgd Duckett Creek package plant would be replaced by a 5 mgd treat-
ment facility.  None of the existing equipment would  be used at the new
plant.  A mechanically-cleaned bar screen, integral with a new raw sewage
pumping station and control and maintenance building, would be the first
step in the treatment process.  Three centrifugal sewage  pumps would be
used  to lift the  sewage  for  gravity flow through  the treatment plant.
Next,  an aerated  grit  chamber would be used  to remove sand and heavy
inorganic  solids  from the  wastewater.  Bypass  provisions  and a Parshall
flume  to measure the  flow would also be provided.

Two  oxidation  ditches,   operated  in parallel,  would  provide secondary
treatment  and  aeration rotors would provide  the necessary oxygen.  Two
final  clarifiers  would be  required  to remove  solids from the wastewater
prior  to  discharge  to Duckett Creek.   A  sludge pumping  system would
recycle activated sludge  to the oxidation ditches.   Waste sludge would be
conveyed to  the sludge handling system.

Waste  activated sludge would  be thickened in a gravity thickener prior to
stabilization  in two aerobic  digesters.   The  digested sludge would  then
be  dewatered by  two belt  filter  presses.   The  belt filter presses and
chemical  conditioning  equipment  would be  housed in  a  sludge treatment
building.

Final  disposal of  dewatered  sludge  would  be by  land application,  when
possible.   Sufficient  (30-day)  cake  storage facilities  and alternate
sludge disposal methods,  including  landfilling, would  be necessary.   Most
of  the  farms  that could  utilize  wastewater  sludge  are  located in the
Mississippi River  and  Missouri  River floodplains.  Availability of  pri-
vate  sites for land  application  of sludge  may  be difficult to ascertain.
Farm  demand may vary,  and  odor problems, spreading/application problems,
or  any adverse publicity  could  disrupt  the working arrangement.  A  more
flexible   system  was  therefore  proposed.    The   proposed  plan  includes

                                2-25

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onsite storage,  land application of  sludge to the greatest extent  pos-
sible, or landfilling of sludge cakes.   Final application sites  currently
are not  known,  but  would  be  selected  during the project  design  stage.

Sludge disposal  facilities  and equipment would include  a  sludge  storage
shed  for  the dewatered  cake and a  land application truck and a  feeder
tank  truck  would be required  for farmland  subsurface  injection.   Sludge
cake would  be produced  when land application is  not  feasible  and stored
until it  could be applied  to  land or until storage  capacity is reached,
whereby the sludge would be hauled to a landfill for  disposal.

A process  control and  laboratory building  also  would be  required.   In
addition,  an alternate  power  source for  emergency  situations would  be
necessary.   Two  separate commercial  power feed lines  would be  provided.

• Spencer Creek Plant

The  Spencer Creek  STP  would  require  upgrading  from  a 3 mgd  extended
aeration  plant  to a  4.0 mgd  contact  stabilization  plant.  Much  of the
existing  equipment  was  installed  in 1980 and could be  utilized  in this
upgrading plan.

The  raw  sewage  screw pumps and  bar screens are in good  condition and
could accommodate wastewater flows  to the year 2005.  A new aerated grit
chamber is  proposed  for removal of sand and heavy inorganic solids.  The
existing  aeration tank  would  be modified by converting  it to  a  smaller
contact stabilization unit with diffused aeration.  This process would be
more  energy  efficient  than  extended  aeration  with  surface  aerators.

The  existing final  clarifiers  would  be  able  to handle  any  additional
flows.  The  return sludge pumping system also would have adequate reserve
capacity  to handle  the additional sludge.   Whereas  any discharge  to the
Mississippi  River requires  chlorination during summer months,  a  contact
chamber  and chlorination  system would  be added.  The  effluent  pumping
station would have  three centrifugal sewage pumps which should eliminate
back-up of  the gravity effluent  line and flooding problems experienced by
the  plant   during  wet  weather.   Also,  pumping the  effluent  to  the
Mississippi  River would  eliminate the need  for nitrification, which would
be required  if discharge to  Spencer Creek was continued.

To handle sludge, a  gravity  thickener would  be added prior  to aerobic di-
gestion.   Two  new  diffused  air  digesters  would  replace  the  original
digester, which  uses a 40-hp  surface aerator.  Digested sludge would be
dewatered  by two -belt  filter presses  housed  in a  new sludge handling
building.

The  City of St.  Peters  has  been investigating land application of sludge
because  the existing sludge handling method (lagoon)  is not acceptable.
In this  regard,  the  City has acquired a  sludge application  vehicle and is
now applying sludge  from both  their water  and wastewater plants.  The use
of  a landfill also is  being  considered as an alternate sludge disposal
method.   A  flexible  system,  including  storage  facilities for dewatered
cake, also  is required.
                                2-26

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     The Spencer  Creek  STP  has  a 500-KW electric  generator sufficient  for
     standby power during emergency  situations.   The existing laboratory also
     is sufficient and would  require  no upgrading.
     * Portage des Sioux Plant
     The Portage  des  Sioux  STP would  be upgraded  to  a secondary  facility.
     However, it  is  recommended that  an extended aeration  package plant  be
     constructed in lieu of  the 1978 selection of a  rotating biological con-
     tact plant.

     Onsite Systems
     There are three  general  classifications  of existing onsite system areas:
(1) developments  along the Mississippi  River and in the  floodplain  that are
serviced by individual  shallow  wells and onsite systems;  (2)  the upland por-
tion of the planning  area;  and (3) residences in areas with karst topographic
features,  mainly  around Taylor Branch.   The  final  facilities  plan concludes
that the use  of  onsite systems in densely populated areas in the upland por-
tions  of  the  planning area  (area  2),   and developments in  karst  topography
(area 3),  should be discontinued as interceptors are constructed.  Local ordi-
nances exist  that can  require  individual discharges to connect  to the sewer
system when interceptor lines become available.

     Although  the  residences  currently  served  by  onsite  systems  in  the
Mississippi River floodplain  (area  1)  were  originally recommended  (in the
draft  facilities  plan) to  be served by  centralized collection and treatment
facilities where the density of residences was sufficient, it has subsequently
been determined  (by  the facilities planner)  that these floodplain communities
cannot afford the cost of collection and transmission systems for treatment of
sewage at the nearest centralized facility.  As such, a centralized collection
system for the  major floodplain communities was not considered implementable.
Instead,  a plan was proposed  that could  mitigate  problems  without  being
capital-intensive.  The  proposed plan  would  include  the  following measures:

     » Establishment of a centralized management agency that would institute
       programs for upgrading and maintaining onsite systems;
     • A public education program on proper septic tank and absorption
       field operation;
     • Emphasis on the need for community wells to replace individual
       shallow wells;
                                    2-27

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     • Clustering homes to small onsite systems;
     • Holding tanks for riverfront properties;  and
     • Flow conservation practices and devices to reduce the load on
       existing onsite systems.

This EIS concurs  with these recommendations for the  unsewered  areas based on
several factors:

     • Approximately 50% of the residences are occupied seasonally;
     • The  groundwater contamination potential  is  limited  because the perme-
       ability of the  soils is  low;
     • Contamination  of shallow wells, specifically  from  failing onsite sys-
       tems,  was  investigated  and  available  evidence suggests  deficient well
       construction and floodwater contamination as being the problems rather
       than  onsite  systems  (by telephone, Roger  Dunacik,  St.  Charles County
       Health Department, to WAPORA,  Inc.  19 April  1984);
     • The  investment in infrastructure in areas that  flood frequently should
       be  kept to  a  minimum  so  that the  residences  can be phased out; and
     • The  onsite  system wastewater  management  option would  likely be less
       costly  than the centralized  option for  the floodplain areas, although
       the  cost  comparisions were  not developed  in  the  facilities  plan.

The continued use  of  some  onsite systems in the  upland  areas also would be
necessary  for numerous residences  because interceptor  sewers are  not and will
not be located  sufficiently  close  to provide  service.  Sufficient  data have
not been presented  in the  facilities plan  to  ascertain whether or not con-
tinued use of onsite  systems  in these areas would be  technically feasible if
centralized management and systematic upgrading of failing systems  were  to be
implemented.   Regardless of  the final wastewater management options selected
for the  respective  "problem  areas," implementation of  an onsite  management
district  would  be  required for those  residences  that  would not  be  served by
centralized alternatives.

      Private Systems

      Two  wastewater  treatment facilities, the  Tee Kay lagoon  and the  Martell
 lagoon,  serve isolated communities in the South Plant service area.   Intercep-
 tors are not  yet available due to cost related to low population density.   As
                                     2-28

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the population grows,  interceptors  would be extended to  these  outlying areas
and the  facilities plan  recommends that these lagoons  should  be eliminated.
Meanwhile, strict  enforcement  of NPDES permits should reduce the impact that
these lagoons may have on water quality in the planning area.

     Small Systems Outside the Planning Area

     The  draft facilities  plan  indicates  that  pollution  to  upper Dardenne
Creek  by small  treatment plants  located just outside  of  the  planning area
could  be reduced  by  strict enforcement  of NPDES  permits conditions.   The
Weldon Spring  Elementary School, Francis Howell High School, and Safari Camp-
ground each  have  treatment  plants  (lagoons)  that  may affect  Dardenne Creek
water  quality.   Eventually,  these  areas  should be  eliminated  as interceptors
are constructed.

     Summary of Costs

     Construction  cost and  operation  and maintenance cost estimates for the
selected  wastewater  collection systems and treatment facilities are presented
in Tables 2-2 and  2-3, respectively.   Costs are provided  for both the 1985 and
2005 design years.  The  1985 costs  include those  facilities  that are necessary
to handle existing sewage flows.   The 2005  costs include capacity to support
the  population growth during  the  20-year  planning period.  The  1985 design
costs  determine the amount of the project costs that are  grant eligible.  This
is discussed  in more detail in  the following section.   For Portage des Sioux
and  the  Mississippi  floodplain, sewage  flows are not anticipated to be signi-
ficantly  different in the  future,  so the 1985  and 2005 costs are the same.
The total estimated 2005  construction  cost for the  facilities plan recommended
alternative  (Alternative 6)  was $34,314,800, while the total estimated annual
(2005)  operation  and  maintenance  cost  was  $2,863,400  in  June  1984 dollars.

     Consumer  Cost

     An acceptable user  charge  system  to determine  the service charges to con-
sumers  for support  of the  wastewater treatment  facilities will be developed
during the  final design  stage.   Service charges  ideally should be  structured
                                     2-29

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so each user pays  the operation and maintenance (O&M) costs,  as well as capi-
tal costs, for  the wastewater treatment and disposal  system  in proportion to
its wastewater  contribution,  although  capital  costs  are  not required  to  be
assessed proportionately by EPA regulations.

     Preliminary calculations for  user  charges  are presented in Table 2-4 for
each  sewer agency.   User charges  are  calculated  for design years  1985  and
2005.    Calculations  for  1985  include  debt service  for only  those projects
underway  during 1985.   Calculations for 2005  include all projects.   Annual
debt  service  pays  the local  capital cost  of improvements and  is  based on an
annual  interest rate of  10%  for a 20-year payment period.   Annual  O&M costs
include the cost to run the existing and proposed facilities as well as exist-
ing debt  service.   The  annual user charge is calculated by dividing the total
annual cost by the projected number of users.  Costs are in June 1984 dollars.
                                     2-30

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                                  TABLE 2-2

                     FACILITY PLAN RECOMMENDED ALTERNATIVE
                          CONSTRUCTION COST ESTIMATES
                                (June 1984 Costs)

A.
(1)
(2)
(3)
(4)
DUCKETT CREEK
Duckett Creek Plant
Boschertown Interceptor
South Interceptor
Harvester-Dardenne Interceptor
TOTAL ESTIMATED CONSTRUCTION COST:
2005
Design
$10,788,700
385,000
2,520,100
1,275,800
$14,969,600
1985
Design
$ 8,803,000
374,000
2,289,100
1,152,000
$12,618,100
B.   ST. CHARLES
  (1)  Missouri River Plant
  (2)  Mississippi River Plant
  (3)  Missouri River Interceptor
     TOTAL ESTIMATED CONSTRUCTION COST:

C.   ST. PETERS
$ 7,039,000
  2,899,000
  1.616,000
$11,554,000
$ 5,811,000
  1,034,000
  1,511,000
$ 8,356,000
  (1)  Spencer Creek Plant
  (2)  Effluent Pipe (Force Main)
     TOTAL ESTIMATED CONSTRUCTION COSTS:
D.   PORTAGE DES SIOUX
$ 4,595,000
  2.371.000
$ 6,966,000
$ 1,535,000
  1,858,000
$ 3,393,000
          2005 & 1985
            Design
  (1)  Portage des Sioux Plant
  (2)  Portage des Sioux Transmission System
  (3)  North Area Transmission System
  (4)  Northeast Area Transmission System

     TOTAL ESTIMATED CONSTRUCTION COST:
          $  511,400
             214,700
             146,300
             141,400

          $1,013,800
Source:  Adapted from Sverdrup & Parcel and Associates, Inc. (1984)
                                    2-31

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                                  TABLE 2-3
                     FACILITY PLAN RECOMMENDED ALTERNATIVE
                       ANNUAL OPERATION AND MAINTENANCE
                                COST ESTIMATES
                               (June 1984 Costs)
A.  DUCKETT CREEK                                 2005 Design
  (1)  Duckett Creek Plant                       - $  394,000
  (2)  Transmission System (1, 2, & 3)               203,000
  (3)  Remaining Facilities (4)                       86,000
  (4)  Administrative                                183,000

          TOTAL ESTIMATED ANNUAL O&M COST:        $  866,000
B.   ST. CHARLES
  (1)  Mississippi River Plant                    $  585,000
  (2)  Missouri River Plant                          359,000
  (3)  Transmission System (5)                         8,000
  (4)  Remaining Facilities  (6)                       99,000
  (5)  Administration                                329,000

          TOTAL ESTIMATED ANNUAL O&M COST:        $1,380,000
C.  ST. PETERS

   (1)   Spencer  Creek Plant                         $   353,000
   (2)   Transmission System  (7)                          2,000
   (3)   Remaining Facilities (8)                       113,000
   (4)   Administration                                117,000

           TOTAL ESTIMATED ANNUAL O&M COST         $   585,000
                                     2-32

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Table 2-3 (concluded).
D.  PORTAGE DBS SIOUX                             2005 Design
  (1)  Portage des Sioux Plant                    $   25,800

  (2)  Transmission System                        	6,600


          TOTAL ESTIMATED ANNUAL O&M COST:        $   32,400
Notes:


1.    Includes Harvester-Dardenne, South, and Dardenne pump stations
2.    Includes Harvester-Dardenne and Dardenne pump station force mains
3.    Includes South  interceptor
4.    Includes existing  sewers  and pump  stations
5.    Includes Missouri  River Interceptor (Phase  III)
6.    Includes building  maintenance, existing sewers, and pump stations
7.    Includes Spencer Creek Plant effluent  line  to the Mississippi River
8.    Includes existing  sewers  and pump  stations
 Source:   Adapted  from Sverdrup  & Parcel  and Associates,  Inc.  (1984)
                                     2-33

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                                  TABLE 2-4
                    PRELIMINARY CALCULATION OF USER CHARGES
                                (June 1984 Costs)
•  DUCKETT CREEK SEWER DISTRICT

     Local share of capital cost
     Annual debt service (1)
     Annual O&M cost (2)
     Total annual cost
   1985
$6,323,000
   149,000
 1.022,000
$1,171,000
   2005
$6,323,000
   743,000
 1,460.000
$2,203,000
     Projected users
     ANNUAL USER CHARGE
    10,800
      $108
    19,000
      $116
•  CITY OF ST. CHARLES
     Local share of capital cost
     Annual debt service (1)
     Annual O&M cost (2)
     Total annual cost
$3,869,000
    91,000
 1.665,000
$1,756,000
$6,695,000
   787,000
 1.605.000
$2,392,000
     Projected users
     ANNUAL USER CHARGE
    18,300
       $96
    29,900
       $80
•  CITY Of ST. PETERS
     Local share of capital cost
     Annual debt service  (1)
     Annual O&M cost  (2)
     Total annual cost
$5,709,000
   134,000
   340.000
$  474,000
$5,709,000
   671,000
   616.000
$1,287,000
     Projected users
     ANNUAL USER CHARGE
     9,400
       $50
     16,200
        $79
                                    2-34

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Table 2-4 (concluded).
•  CITY OF PORTAGE DES SIOUX

     Local share of capital cost
     Annual debt service (1)
     Annual O&M cost (2)
     Total annual cost
   1985
$  405,400
    23,800
    32.400
$   56,200
   2005
$  405,400
    47,600
    32.400
$   80,000
     Projected users
     ANNUAL USER CHARGE
       200
      $281 (3)
       230
      $348 (3)
 (1)  Based  on a  10%  annual  interest  rate and a 20-year payment period
     capital recovery  factor = 0.1175).  Assumes 20% of the bonds are
     issued during 1985.
 (2)  Includes O&M, debt  service,  and other  costs of the existing system
     and  O&M of  proposed improvements.
 (3)  Assumes that 50%  of the bonds are  issued in 1985.  Annual user
     charges, if North Area and Northeast Area Transmission
     System projects are not constructed, are estimated at $242/yr for
     1985 and $266/yr  for 2005.
 Source:   Sverdrup & Parcel  and Associates,  Inc.  (1984)
                                     2-35

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     The annual user charges that are presented are preliminary values.  Vari-
ous methods of  financing  are available,  as discussed in section 2.3.4.7,  page
2-116 of the  Draft E1S and additional charges for items such as bond coverage
are not  included.   Additional receipts such as from  industrial contributors,
connection fees, special  fees,  or taxes  can be used  to offset capital costs,
thus lowering the  annual  debt service, which, in turn,  lowers the annual  user
charge.   Numerous  financing alternatives  are  possible  for  each sewer agency
and the number of different combinations  would make them difficult to present.
For this  reason,  the  approach  was  taken to identify the major components in
the user  charge determination  and  to present  a  preliminary  baseline annual
user charge  for each  agency to adjust according  to  its  particular financing
capabilities or other needs.

2.4  Environmental Consequences of Recommended Alternative

     Some beneficial and adverse impacts  can be expected from the construction
and operation of the various wastewater  collection and treatment alternatives
considered  for   the  planning area.   Impacts  of   the recommended alternative
(Alternative  6)  will  generally be  beneficial particularly  with  regard to
surface and groundwater resources.   The  recommended alternative would replace
or  eliminate  inadequate   wastewater  treatment  plants  and provide suitable
collection  and   treatment  systems  for  communities  with  problems  of failing
septic tanks systems.

     The most significant potential  environmental  consequences of the recom-
mended  wastewater  management  alternative are  summarized  in  the following
paragraphs.   The reader  is  referred to  Section  4.0 of  this  Draft EIS for a
more  thorough  and detailed  discussion   of  environmental  consequences.   The
environmental effects are classified as  either primary or  secondary impacts.
Primary  impacts  result directly from the  construction and/or operation of the
proposed project.  Short-term primary impacts generally occur during construc-
tion, while long-term primary impacts occur throughout the life of the project
and generally result  from  the operation of the proposed facilities.  Secondary
impacts  or  indirect effects of  the project, occur principally  from  changes in
population and land use that  induce further actions or effects.
                                     2-36

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Primary Impacts

     Primary  impacts  would  result  from  construction,  operation,  and fiscal
requirements of the recommended alternative (Alternative 6).

     Construction Impacts  — Construction  impacts  are  related  primarily to
land-disturbing  activities,  such  as  site clearing  and  excavation, that will
occur  at STP  sites  and along proposed sewer  line collection and interceptor
routes.   Soil exposed  during construction will  be subjected  to accelerated
erosion  until it is  stabilized by revegetation or  other  means.   Storm water
runoff from construction sites will transport eroded soil into stream channels
and  drainageways where sedimentation will occur.   Adverse  impacts resulting
from construction-related erosion and  sedimentation  include:   nutrient and
other  pollutant  inputs to streams;  possible  crop damage  and interruption of
agricultural  activities;  possible  siltation,  clogging of road culverts, and
localized  flooding  where  drainageways are filled  with sediment; and damage to
structures, roads, and  ditches.

     Increased  sedimentation resulting  from  facilities  construction could
degrade  surface  water  quality.   Adverse  surface  water quality impacts would
include  increased nutrient  inputs,  increased  turbidity,  and siltation;  how-
ever,  these  impacts  would  vary in  magnitude  and duration  depending on the
extent  of rainfall  during construction,  the  length of the  sewer lines, the
placement  of  lines  in relation  to drainageways,  and the  effectiveness of
mitigation measures used  to  reduce runoff and  sedimentation.

     Adverse  surface  water quality impacts would  likely  result  in a short-term
decrease in  aquatic  productivity.  However,  severe erosion  and  sedimentation
from sewer line construction are  not expected since mitigation measures,  such
as  sedimentation  ponds and  other erosion prevention  techniques  (hay,  mats,
etc.),  will be  required provisions in construction permits  and  grant awards.
Therefore, adverse impacts  on aquatic life  are  expected  to be  temporary and
insignificant.

      Construction activities would result in impacts to terrestrial  biota  to
varying extents.  Construction of interceptor lines would result in temporary
                                     2-37

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losses of vegetated areas  during initial earth moving operations.   Disruption
of backyard vegetation  and the  presence of construction equipment  and  noises
would cause temporary displacement of most vertebrate species and mortality of
a  few of  the smaller,  less  mobile species.   Revegetation  and cessation  of
construction  activities  would allow re-establishment of animals in disturbed
areas.

     Proposed sewers  and  force  mains  generally would be  located parallel to
and contiguous with existing road rights-of-way and stream corridors.  A strip
of approximately 20  feet of roadside vegetation would be removed during sewer
line construction along county road rights-of-way, and a strip of approximate-
ly 20 to  40 feet would be disrupted for placement of force mains.   This would
disrupt some  hedgerow/fencerow  vegetation and associated  animal life  in both
residential and agricultural portions of the planning area.

     The  dominant  land  cover types along  the  proposed  wastewater  collection
lines are residential,   commercial,  and agricultural.   Small  woodlots border
the  collection  line  routes  at scattered  locations; second-growth roadside
shrub vegetation would  likely  be destroyed.   Most  birds, mammals, reptiles,
and amphibians  that  reside on or near the proposed collection line routes are
expected  to  relocate  in  adjacent  areas  during construction,  however,  less
mobile  animals  would  incur some mortality from construction.  The proposed
project is  not expected to impact  any threatened and  endangered  species or
their habitat,  therefore no further consultation is  required  under Section 7
of the Endangered Species  Act of 1973, as amended.

     Expansion  of  existing STPs  under the  recommended  alternative would re-
quire the purchase of only minimal additional land (10 acres for Duckett Creek
STP) outside  present plant boundaries.  Therefore, construction of new facili-
ties  at the plants is  not expected to affect or change existing  land use in
the  immediate vicinity  of the  STPs.   It is possible,  however, that current
land  use  and certain  future land  uses potentially  could be  affected, to an
unknown  extent, by  increasing  treatment  capacities or  abandoning existing
treatment facilities.

      Proposed interceptor  line  routes which  are parallel  to stream courses
                                     2-38

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and/or road rights-of-way  are  predominantly in areas currently used for agri-
culture or  low density  residential  development.   Construction  impacts would
include crop  damage,  temporary disruption of farm operations,  and compaction
of  soils  during  construction and  backfilling activities.  Wetland  acreages
directly  affected  by new  interceptor  line construction  and plant expansions
were  not  quantified  because  information  for  all  final  alignments  was  not
available.  However,  acreages  are  expected  to  be  small  and  discontinuous;
therefore, impacts are not expected to be significant*.

     Truck  traffic  associated with  the  construction  of wastewater collection
and  treatment systems  would  increase  traffic congestion and  disrupt local
traffic patterns, particularly in urban areas.  Temporary road closures during
excavation,  grading,  and  backfilling  along  roadways would modify vehicular
traffic patterns  and inconvenience motorists.  The  temporary  closure of some
roads  also would  inconvenience permanent  residents  and  result  in increased
traffic congestion on adjacent roadways.

     Under  the recommended alternative, no known cultural resources  would be
affected  by expansion of the  existing  STPs,  however,  three prehistoric sites
and one multicomponent site were located within or adjacent to proposed inter-
ceptor  line rights-of-way.   If these sites cannot be avoided, further testing
would  be  necessary  to  determine   their  eligibility  for nomination  to  the
National  Register  of Historic Places.  If  a  site is found eligible, then the
agency  must assess  the  degree and extent  of  adverse  effect  and plan activi-
ties,  such as data recovery in consultation with the State Historic Preserva-
tion  Officer  and the Council  on Historic Preservation to mitigate  any adverse
impacts.

     Operation Impacts  --  Operation impacts  are  primarily related to effects
from  the  elimination  or  rehabilitation  of failing onsite wastewater management
systems and the discharge  of higher  quality wastewater treatment  effluent from
upgraded  facilities  to area  streams.  These activities are  expected to  improve
stream  and  groundwater quality within the planning area.

      In  Dardenne  Creek,  current   water   quality   standards   for  un-ionized
ammonia-nitrogen  and  dissolved oxygen  are being violated for several miles
                                     2-39

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below both the Harvester-Dardenne  and Spencer Creek STPs.   Water quality data
indicate  that  tributaries  of Dardenne  Creek are  severely polluted  due  to
wastewater effluent  discharges  from both STPs.  Implementation  of  the  recom-
mended  alternative  would eliminate  the  present discharges to Dardenne  Creek
from the Harvester-Dardenne plant and the Spencer Creek STP, and  thereby would
reduce the pollutant loadings to Dardenne Creek.

     Under the  recommended alternative,  dissolved oxygen and  total suspended
solids  concentrations  should  improve  in  upper Dardenne Creek  and  lower
Harvester Creek  due to  the closure of the Harvester-Dardenne STP  since this
would eliminate  wastewater effluent currently being  discharged  into Dardenne
Creek.  The  expansion and  increased treatment efficiency  of  the new Duckett
Creek  STP as  proposed  in  Alternative  6,  should  improve  water  quality  in
Duckett Creek downstream from the Duckett Creek STP outfall.  Upon completion
of  all plant  modifications,  the  improved  stream  water   quality  conditions
should  result  in  an  increased  diversity  and  abundance  of  aquatic  biota.
Stream  conditions also  should improve throughout the Dardenne  Creek system as
water quality  improves  from more efficient wastewater  collection systems for
outlying  residential areas  that were previously dependent  on  small plants or
onsite  systems.   With improvements in the siting,  operation,  and maintenance
of onsite systems  in general, surface water quality is expected to improve in
these areas.

     Land uses  within the  rights-of-way of wastewater  conveyance lines would
be affected  temporarily  when maintenance or repairs are performed on sections
of the  sewer lines.  Periodic excavation and filling also would disturb vege-
tation  and  soil along  conveyance lines.  The release  of  low-level odors and
aerosols  from STPs and the  awareness that potentially hazardous  and/or malodo-
rous  gases  could be released from these plants, may adversely  affect future
land uses adjacent to the facilities.

     Operations  of  existing  and  planned  centralized wastewater treatment
plants,  sewer  lines,  and  ancillary facilities  should have  minimal adverse
impacts on groundwater  resources in the planning area. Proper  operation and
maintenance  procedures  should  minimize  the  potential for groundwater con-
tamination due  to spills or  leakage of untreated or partially treated wastes.
                                    2-40

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Primary dangers of  groundwater  contamination would be associated with leakage
along sewer  lines and  around sewage lagoons, and leachate from sludge storage
and/or application sites.  Any sewer lines located near floodplain areas could
pose potential  problems unless properly  constructed  and  maintained.   Ground-
water quality in  floodplain areas and downstream  from  all  existing treatment
plants is  expected  to  improve under the recommended alternative.  Water qual-
ity  in  alluvial aquifers  should remain  high  or  improve with more effective
wastewater treatment in the planning area.

     The continued  use of inadequate onsite systems and the future use of new
onsite systems  (if not  properly sited  and  maintained) has  the potential to
cause groundwater contamination problems, especially in those localized areas
developed  in floodplains  where  individual alluvial  wells  are  the  source of
potable  water.   New developments  in these parts  of  the  planning area should
consider cluster  systems,  where suitable, and mound  systems  in areas of high
water  levels.   Increasing development in  floodplain  areas  and development of
more water supply wells as potable water  sources also could cause migration of
contaminants from waste treatment areas  to these wells.

     Direct  impacts on  existing wetlands and  floodplains  from operation and
maintenance  activities  associated  with  the recommended alternative  are ex-
pected to  be minimal.  Any new  interceptor lines located in or near floodplain
areas will be underground  and should not degrade the  quality of  floodplain and
wetland  resources  during  the operational phase.   Maintenance work requiring
redisturbance  of floodplain  areas  is expected  to be  very infrequent and of
short duration.

      Implementation of the recommended alternative should not  impose a  signif-
icant  financial burden on residents in  the  service areas.   This  is suggested
by a  high  growth  rate,  relatively  high  income   levels,  a  relatively  young
population which suggests fewer people  on fixed incomes (6%  of residents are
over 65 years  old  in St. Charles County compared to the state percentage of
 13.2%),  and  commercial growth in the planning area. As  indicated in Table 2-1,
Alternative  6,  the  recommended  alternative,  was  determined  to  be the most cost
effective  (lowest  total  project cost)  among the  four final action  alterna-
tives.   Table 2-4  provides  a breakdown of local user charges  by jurisdiction.
                                     2-41

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The reader also  is  referred to Section 4.2.3, page  4-20  of the Draft EIS for
the detailed fiscal analysis.

Secondary Impacts

     Within the facility planning area, factors other than the availability of
centralized  wastewater treatment are  heavily influencing  population growth.
St. Charles County is currently experiencing significant population growth and
urbanization due to a number of factors, including:

     • Improved transportation access between the planning area and
       St. Louis;
     • Existence of  large  amounts of vacant buildable land suitable for resi-
       dential and commercial development;
     • Pro-growth  planning  policies  that  serve  to  facilitate population
       growth; and
     • Siting of major new employment centers in nearby areas.

Given  these  factors and  recent trends in the demography and urbanization of
the area,  population growth appears to be an assumed condition and would not
result only  from the expansion of wastewater treatment facilities.  Therefore,
the recommended  alternative would have more  impact  on  where growth may occur
rather than  on absolute population growth.

     Land  use impacts associated with  the  recommended  alternative  are pri-
marily  related  to  any changes  from agricultural  uses to  urban  uses, i.e.,
residential, commercial and/or industrial uses.  Due to the  availability of an
expanded  central collection system, growth would  tend to concentrate  or occur
first in  those areas where  centralized  sewage services are  available.  Without
development  of the  recommended  alternative, there  would be more reliance on
onsite systems for wastewater treatment.  Therefore, development would be more
likely  to be  dispersed.   With  a  concentration of  development in areas with
centralized  sewer services, changes  in  land use and  growth  may  be more orderly
and impact less  total  land  area.
                                     2-42

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2.5  Issues and Comments in Response to the Draft EIS

     The primary issues and comments in response to the Draft EIS are detailed
in Section 4.0  of the Final EIS.  The primary areas of concern are summarized
below:

     • Concern  about  the effects  of sewage overflows  and  malfunctioning on-
       site systems on surface water and groundwater resources.

     • Concern about how land application of sludge would be performed.

     • Concern about treatment and disposal of toxic waste products that enter
       the municipal treatment plant.

     • Concern  about  the impact of wastewater treatment facility construction
       on existing farm operations and the policy for compensation for damages
       or lower crop yields.

     • Concern  about  expediting the  approval  of  the EIS  in order  to take
       advantage  of available Federal  funding and initiate the construction of
       much needed wastewater management facilities.

     • Concern  about  following the proper procedures for mitigation of project
       impacts  on cultural  resources.

     • Concern  about  the effects of proposed wastewater treatment and collec-
       tion  facility  improvements on  state highway  rights-of-way  and  state
       highways themselves.

      • Concern  about  the  indirect effects  of  the proposed project including
       induced  development and  its effect on wetlands, floodplains, and  other
       fish and wildlife habitats.

      • Concern  about project impacts  on existing  recreational lands developed
       or  acquired with Land and Water Conservation Fund  (LWCF) monies.
                                     2-43

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     • Concern about  compliance  with. Section  7(c)  of the Endangered Species
       Act of 1973,  as amended.

     • Concern about potential impacts from  the Findett  Corporation hazardous
       waste site on proposed project activities,  and  vice versa.

     • Concern about  the  cumulative impacts  on  floodplain  and wetland  re-
       sources as a result  of  improved  wastewater management  facilities  and
       the  L-15  levee  project  under  evaluation  by  the U.S.  Army Corps  of
       Engineers.

     • Concern about  the  local  share of  cost for  St.  Peters'  proposed facili-
       ties.

2.6  Additional Considerations Since the  Draft E1S

     In  the period  between the  Draft  EIS  and Final EIS, consideration  was
given  to an  alternative  site  for  construction  of  the proposed  new  5  mgd
Duckett  Creek  Wastewater Treatment  Facility identified by the Duckett Creek
Sewer  District  in  cooperation  with  their  facility  planning  consultant,
Sverdrup &  Parcel and Associates, Inc.  The  alternative  site occupies  a more
upland  location  approximately  1,300  feet  to the  northwest  of  the  existing
floodplain  site.  A site visit was  conducted  by  EPA  and MDNR personnel and a
public  meeting was  held near the  alternative site  on  November 13,  1985 to
present  the alternative  to  the  public and to  receive  comments.   Following
review  of  information received at  the  meeting  and  considerable discussions
with the grantee and MDNR, EPA has determined that the alternative site is not
impleraentable.

     The  Agency  recognizes  the  need to implement  a  solution  to the Duckett
Creek  Sewer District's wastewater treatment problems  in a timely manner.  The
unlikelihood of  being able  to construct a facility at the upland site without
a  long delay brought  on  by  litigation, and  as yet unquantified archaeological
impacts, eliminates  the  upland site  as a practicable  alternative to the  flood-
plain  site.
                                     2-44

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     Factors bearing  upon  the  decision  to eliminate  the  upland  site  from
further consideration are as follows:

     • Archaeology - The  proposed  upland  site  was registered (#23SC51)  in the
       early 1950s with  the State  as  the "type"  site  for  the Archaic Culture
       for  eastern Missouri.   A  preliminary  archaeological  survey of  the
       Gronefeld site, also  known  as  the  upland  site,  funded  by EPA and com-
       pleted  in  January  1986,  indicated  the  proposed  construction  would
       impact areas  which demonstrate the possibility  of  containing signifi-
       cant  archaeological  deposits.   The  survey  revealed  the presence  of
       artifacts from  both Archaic and  Woodland societies.   The presence of
       Woodland  artifacts  indicates the possibility that  subsurface features
       (storage  pits  and  possibly graves)  may  be  directly affected by the
       proposed  construction.  Evaluation  and  possibly the salvaging of arti-
       facts and human  remains  would be  an added expense  and delay to the
       timely implementation of  a  solution to  the Sewer District's  presently
       growing  problems.   The same archaeological survey  examined  the  flood-
       plain plant site  and the  borrow material site.   Both sites were devoid
       of archaeological features.

     • Water Quality  -  The  Harvester-Dardenne Treatment  Plant  is  presently
       hydraulically overloaded.   It  is  currently receiving wastewater at the
       rate  of  150 percent  of  design capacity.  Because  of the loading, the
       plant often exceeds its discharge permit limitations.  These conditions
       have  led to  sludge  deposits  in  Dardenne Creek.   The  creek  has been
       designated  "Water  Quality  Limited"  by  the   Missouri Department  of
       Natural  Resources.   There  have also been  numerous  complaints  about
       water quality  from residents living in the neighborhood of the receiv-
       ing stream.

       The current operating strategy is to pump up to 200,000  gallons per day
       (gpd) of untreated waste  to the Duckett Creek plant, which has 300,000
       gpd  of  excess  capacity.   This solution  is only temporary because both
       service  areas  continue to  connect new  hook-ups at  a  fast  rate.  The
       long-range  solution as identified  in the  State-approved facility plan
       is to decommission the plant and pump  all of the Harvester-Dardenne1 a
                                     2-45

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  wastewater to  the new Duckett  Creek plant.  In the  interim,  Dardenne
  Creek continues to be degraded at an increasing  rate.

• Aesthetics -  Numerous local  residents  have filed complaints  with  the
  County Commissioners about objectionable odors and  noise levels result-
  ing from  the existing Duckett  Creek plant.  The  Duckett Creek  Sewer
  District has responded by saying the odor and noise would be  eliminated
  by the construction of the new plant.  Local residents have unanimously
  expressed their opinion  that  they do not want  the  new treatment plant
  built closer  to their homes than the existing  plant.   The upland site
  would be  approximately  1,000  feet  closer to  established residential
  areas and would,  therefore,  have a potential for higher odor and noise
  impacts to the residents.

• Opposition -  Numerous sources of opposition to  siting the new plant at
  the  upland  site   exist.   Strong  opposition to  the  upland  site  was
  expressed by  approximately  250  residents living in the vicinity of the
  upland  site  at a  public meeting on November 13,  1985.   Subsequent to
  that  meeting, the  County Commissioners  received  122 letters  and  510
  petition  signatures  urging  them not to build on the upland site.  Many
  of  the  letters   threatened  suit  to  recover  alleged  property  value
  losses.  The owner of the upland site (Armin Gronefeld) has retained an
  attorney  and  has  stated  he will not  sell the  upland site to the Sewer
  District.   County  Commission  members,  in  a   meeting  with   the  EPA
  Regional Administrator on January 27, 1986, stated they did not want to
  initiate  condemnation proceedings  against  the landowner.   The Sewer
  District  and the  County Commission have  withdrawn  their support from
  the upland  site.   They have  estimated  that if  the upland site was the
  selected  site,  the resulting litigation would  take  a minimum of three
  years to  resolve.

  In  contrast, the  floodplain  site  is  (1)  available  for purchase,  (2)
  supported by the  County Commission, Sewer  District,  and  the area resi-
  dents,  and  (3) has  been carefully evaluated  during the  Environmental
  Impact  Statement  process.  It  is  overwhelmingly  supported as  the most
  practical  location  for  the  Duckett Creek treatment plant expansion.
  There are no threats  of  litigation  involving this  site.
                                2-46

-------
     The  Agency recognizes  the immediate  need  of  the  Duckett Creek  Sewer
District to rectify existing wastewater treatment problems that are continuing
to grow  at  an alarming rate.  The Agency  fully understands the impacts asso-
ciated with  the construction of the proposed facility at the floodplain site.
The  extent  of  those  projected impacts are  disclosed in  the  Draft and Final
Environmental Impact Statements for Eastern St. Charles County, Missouri.  The
MDNR has approved  the final Facility Plan  for  the Eastern St. Charles County
planning area,  which  included the siting of  the  new Duckett Creek Wastewater
Treatment  Plant at  the  floodplain  site.   Because  of the  reasons presented
above,  EPA believes  that construction  of the  new Duckett  Creek plant at the
upland  site  could  not be  accomplished  in  a  timely manner.  It  is EPA's posi-
tion,  therefore, that it is in the best interest of  the environment and the
community to  designate  the upland  site  as  noniraplementable  and, therefore,
eliminate it from further consideration.
                                       2-47

-------
     The  Agency recognizes  the immediate  need of  the  Duckett Creek  Sewer
District to rectify existing wastewater treatment problems that are continuing
to grow  at  an alarming rate.  The Agency  fully understands  the impacts asso-
ciated with the construction of the proposed facility at the floodplain site.
The extent  of  those  projected impacts are  disclosed in the  Draft  and Final
Environmental Impact Statements for Eastern St. Charles County, Missouri.  The
MDNR has  approved  the final Facility Plan for  the Eastern  St. Charles County
planning area,  which  included the  siting of the new  Duckett Creek Wastewater
Treatment  Plant at  the  floodplain  site.   Because  of the  reasons  presented
above, EPA  believes  that  construction  of  the  new Duckett Creek plant at the
upland site could  not be accomplished  in  a  timely manner.   It is EPA's posi-
tion,  therefore,  that it  is  in the  best interest of  the environment and the
community  to  designate  the upland  site  as  nonimplementable  and,  therefore,
eliminate it from further consideration.
                                    2-48

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3.0  CORRECTIONS AND ADDITIONS TO DRAFT EIS

     This  section  contains revisions  made to the  Draft EIS based on  new or
more  complete information,  or errors  and  omissions  identified through  the
public  review process.   The  following  changes  to the  Draft  EIS have  been
incorporated  as  errata  and are either editorial  or clarifying  in nature,  and
are relatively minor.   Consequently,  the affected pages in the  Draft  EIS have
not been  reprinted  in full.  The changes listed below are hereby incorporated
into  the  Draft  EIS.   With  respect  to  the page  and paragraph  numbering,
paragraph  1 is considered to be the first full paragraph on a page.
Revision
Comment No.
Page iv, paragraph 1, line 1:  Delete "...St. Charles..."
and replace' it with "...St. Peters..."
W-12
Page xv, paragraph 1, line 4:  After "The Weldon Spring          W-13
Elementary School..." add "...Francis Howell High School,..."
Page xxiii, paragraph 3, line 2:  After the word "improve"
add parenthetically "(i.e., increase and decrease,
respectively)..."
EPA Review
Page xxix, paragraph 2, line 2:  Delete "...Duckett Creek
Sewer District..." and replace it with "...grantee,..."
W-14
Page 2-7, Table 2-2:  Under  the bullet for the "City of St.
Peters," place double asterisks (**) after "Old Town,"
"Country Hill No.  1," "Country Hill No. 2," and "Missouri
Cities Dardenne Creek."  Add the double asterisk under the
single asterisk at the bottom of the table and note after
the double  asterisk "No  longer in  service."
W-15
 Page  2-86,  paragraph  1,  line  1:  Delete  "...St. Charles..."
 and replace it  with "...St. Peters..."
W-12
                                    3-1

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Revision
Comment No.
Page 2-87, paragraph 2, line 2:  Change "...1.0 mgd..." to
"...0.5 mgd..."
EPA Review
Page 2-87, paragraph 3, line 1:  Change "...an..." to
EPA Review
Page 2-112, paragraph 2, line 4:  After "The Weldon Springs
Elementary School..." add "...Francis Howell High School,..."
W-13
Page 2-125, paragraph 2, line 2:  Delete "...Duckett
Creek Sewer District..." and replace it with "...grantee,...11
W-14
Page 3-63, paragraph 1:  Add the following new paragraph         W-10
after paragraph 1 under "Industrial," "Of potential interest
may be the Findett Corporation industrial site which is within
the planning area (see Figures 3-9a and 3-9b) and is included
in Group 7 of EPA's National Priorities List (NPL) for sites
proposed for cleanup of hazardous wastes.  The recycling of
polychlorinated biphenyls (PCBs) is known to have occurred at
the Findett site and PCB contamination has been confirmed;
however, the full areal extent and concentrations of PCB con-
tamination are not currently known.  No determination has been
made as to whether or not any contaminants have migrated beyond
the Findett property boundary although site investigations are
continuing.  When the outcomes of these studies are known, a deter-
mination can be made as to what extent site conditions affect
the proposed project and vice versa.

Page 4-7, following first partial paragraph at the top of the    W-10
page: Insert the following new paragraph before section 4.2.13
"Surface Water," "In section 3.2.1.1 (Existing Land Use) of the
EIS, it was noted that the Findett Corporation site, a hazardous
waste site proposed in Group 7 of EPA's National Priorities List
(NPL) of hazardous waste clean up sites, is located within the
                                   3-2

-------
                                     51
                                     i!
3-3

-------
           Figure  3-9b



       Findett  Study Area
3-4

-------
Responses                                                        Comment Ko.

201 planning area (Mississippi Subarea, St. Charles planning     W-10
jurisdiction, 1.5 miles north of 1-70).  Although proposed       (cont'd.)
project plans do not call for any construction of new inter-
ceptor lines in the vicinity of the Findett site, an existing
interceptor line is located about 1 mile from the site.  EPA
is now negotiating with the Findett Corporation relative to the
remedial site investigation, therefore, the extent of potential
contamination of soils and/or groundwater beyond the Findett
site boundary currently is not known (Personal communication,
by telephone, Diana Bailey, EPA, and D. Keith Whitenight, WAPORA,
Inc., June 19, 1985).  To avoid any risk of working in, disturb-
ing, and transporting and disposing of potentially contaminated
soils (during possible interceptor line maintenance activities),
the grantee should consult with EPA, Region VII prior to schedul-
ing any maintenance activities in this area in order to deter-
mine the status and results of the remedial site investigations
at Findett.  If off-site contamination is confirmed, the extent
to which it affects any proposed sewerline maintenance activities
in the area must be ascertained by the grantee and precautions
taken as appropriate prior to any line maintenance work."

Page 4-8, line 10 from the top:  Change "propertly" to           EPA Review
"properly."

Page 4-9, between paragraph 2 and paragraph 3:  Add the          W-9
following new paragraph, "With regard to threatened and
endangered species, it was determined that the bald eagle's
range includes parts of the planning area although there is
no designated critical habitat in the project area at  this
time.  The proposed project is not expected to impact  any
diurnal perches, roost sites, food sources, or other pre-
ferred habitat of the bald eagle, therefore no further
consultation is  required under Section 7 of the Endangered
Species Act of 1973, as amended.
                                    3-5

-------
Responses                                                        Comment No.

Page 4-9, paragraph 4, line 4:  Add "direct" in between the      W-7
words "of" and "damage..."

Page 4-10, first partial paragraph at top, lines 1 and 2:        W-7
Delete the sentence, "Affected wetland acreages are insigni-
ficant" and replace it with, "Wetland acreages directly
affected by new interceptor line construction and plant
expansions under the four final action alternatives are
expected to be small (cannot be quantified accurately
until final alignments are known)."

Page 4-10, section 4.2.1.7, "Land Use," following paragraph 2:   W-6
Add the following new paragraph, "With regard to impacts to
existing public outdoor recreational lands in the planning
area, including those assisted through the Land and Water
Conservation Fund (LWCF) program, no acquisition of these
lands or conversion of existing recreational uses to other
uses is proposed as a direct  result of constructing any  of
the four final action alternatives."

Page 4-18, under section 4.2:2.6, paragraph  1:  Delete lines     W-8
1  and 2 and replace them with the following  new paragraph,
"Direct  impacts on existing wetlands and  floodplains from
operation  and maintenance  activities associated with any of
the four action alternatives  are expected to be minimal.  Any
new interceptor lines  located in floodplain areas will be
underground and should not degrade  the quality  of floodplain
and wetland resources  during  the operational phase.  Main-
tenance  work  requiring redisturbance of  floodplain  areas is
expected to be  infrequent  and of short duration.

Page  4-29, section  4.4.2,  paragraph 1, line 10:  Add the        W-5
 following, "Previously undeveloped  areas  (e.g.,  floodplain
 areas) may receive  more  development pressure as  more effec-
                                    3-6

-------
Responses                                                        Comment No.
tive centralized and decentralized wastewater treatment          W-5
methods are implemented.  Any increased development in these     (cont'd.)
areas will alter the existing land use and therefore could
indirectly impact some existing wetlands or other wildlife
habitat.  It is expected, however, that impacts from land use
changes will be more concentrated and predictable, and thus
more controllable (e.g., via local land use controls) than
would have otherwise occurred under the no action alternative."

Page 4-34, paragraph 2, line 5:  Add the following after         W-l
..."sites,..." "...then in accordance with Section 106 of the
National Historic Preservation Act,..."

Page 4-34, paragraph 2, line 6:  After the sentence ending       W-l
with "...Historic Places." add the following, "If a site is
found eligible, then the agency must assess the degree and
extent of adverse effect and plan activities, such as data
recovery in consultation with the State Historic Preservation
Officer and the Council to mitigate adverse effects in
accordance with the regulations contained in 36 CFR Part 800."
                                   3-7

-------

-------
4.0  COMMENTS ON THE DRAFT EIS AND EPA RESPONSES

     The Draft  EIS on  proposed wastewater management  facilities  for eastern
St.  Charles  County was published by  EPA and made available to  the  public in
late March 1985-  The  Draft  EIS was  provided to various  Federal,  State,  and
local agencies,  concerned  individuals,  and interest groups.  The public hear-
ing  on  the Draft  EIS was held  in  St.  Charles,  Missouri on May 9,  1985.   In
addition to the  public comments received at  the  hearing (a transcript of the
hearing  is presented herein),  a number of comment  letters were received and
are included in this section of the Final EIS.

4.1  Written Comments and Responses

     The alphanumeric  designations  (W-l, W-2, etc,) along the right margin of
the comment letters identify specific written comments for which responses are
given.   The  (W)  designation  indicates  it  is  a written  comment  while  the
numeric  (1,  2,   3,  etc.)  designation  indicates  the sequence  of the comment.
The  responses  are presented  at the  end of  all  the comment  letters  and are
assigned alphanumeric designations (R-l,  R-2,  etc.) which correspond to the
respective  written comments.   Similarly, designations  (H-l,  H-2,  etc.)  are
marked  in  the  right hand margin of the public  hearing transcript identifying
verbal comments  for which responses (R-l, R-2, etc.) also are provided follow-
ing  the full  hearing  transcript.   Where  the  public  hearing  comments  were
similar to the written  comments, the hearing responses refer the reader to the
written  comment response.  Indexes of  all written  and  hearing (verbal) com-
ments  received  on  the  Draft EIS  are presented  in  Table 4-1  and  Table 4-2,
respectively.
                                    4-1

-------















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4-2

-------
             Table 4-2.   Index of verbal comments received at the
                 public  hearing on the Draft EIS, May 9,  1985


                                                                  Page No.  in
  Hearing                          Agency, Organization,              Final
Comment No.    Name                     Individual                    EIS
H-l thru H-6   Richard E. Bone     Citizen                        4-55 through
                                                                       4-60

H-7 and H-8    Joe Nichols         Duckett Creek Sewer District      4-61
                                    4-3

-------
Advisory                                                 HtCEiVtu
Preservation                                         Eis/404  BRANCH

The Old Post Office Building
1100 Pennsylvania Avenue, NW, #809
Washington, DC 20004
   APR i  3  1385
Mr. Edward Vest
Chief, Environmental Impact Section
U.S. Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS  66101

REF:  Draft EIS; Proposed Wastewater Treatment Facilities for Eastern St.
Charles County, MO

Dear Mr. Vest:

The Council has reviewed the referenced Draft Environmental Impact
Statement (DEIS)  with respect to potential impacts on historic and
cultural properties.  We note that studies have been undertaken to identify
properties that may be affected by the proposed treatment facilities.
These studies have concluded that no historic properties will be affected
by expansion of sewage treatment plants but that rights-of-way for proposed
new sewers contain several archeological sites and one multi-component
site.

We are pleased to see that studies have been undertaken at an early  stage
of planning.  However, the DEIS does not reflect an accurate awareness of
the proper planning for these historic properties.  Section 4.5.1 (page
4-34) correctly states that the properties should be tested to determine
their eligibility for the National Register of Historic Places.  However,
it seems to conclude that this testing and determination are sufficient to
mitigate adverse effects.  Determining the eligibility of a site is merely
an initial step in the responsibility of a Federal agency pursuant Co
Section 106 of the National Historic Preservation Act.  If a site is found
eligible, an agency then has a responsibility to assess the degree and
extent of adverse effect and to plan activities, such as data recovery, in
consultation with the State Historic Preservation Officer and the Council
to mitigate adverse effects.  The entire procedure is set out in the
Council's regulations, 36 CFR Part 800 (copy enclosed).
W-1
                               4-4

-------
He hope that:  the EIS and EPA's  schedule for this project will accurately
reflect the planning needs  for  historic properties that are prescribed by
law.  If we can be  of  any  assistance in this matter,  please contact Michael
Quinn at (202) 786-0505.
        astern Division
   if Project Review
                                 4-5

-------
                                       U.S. Department of Housing and Urban Development
                                       St. Louis Area Office, Region VII
                                       210 North Tucker Boulevard
                                       St. Louis, Missouri 63101
April 25, 1985

Mr. Ed Vest
Chief, Environmental Impact
  Section
Environmental Protection Agency
726 Minnesota
Kansas City, KS  66101

Dear Mr. Vest:
   PR :!
E1S/404 BRANCH
SUBJECT:  Draft Environmental Impact Statement:   Proposed
            Wastewater Treatment Facilities, Eastern St. Charles
            County, Missouri

     The Draft  has been  reviewed by this office and was found to
be satisfactory in meeting the  spirit and intent  of the National
Environmental Policy Act  (NEPA) of  1961.

     This determination  was made on the basis of the following consi-
derations:  (1)   HUD's areas of review  responsibility  in accordance
with NEPA; and (2) HUD's  activities in  Eastern St. Charles  County
that might be affected by the proposed  action.  In this regard  there
was found no apparent adverse environmental  impact on  any HUD housing
or community development  activities.

     This is indeed a  sobering and  well prepared Environmental
Impact Statement.  Governmental agencies, public  officials,  and the
citizenry of eastern St.  Charles County should read carefully and
heed carefully the scope  of the existing wastewater issues.  The
challenges are exhilarating.

     Wastewater management alternatives are  clearly explained and the
statement outlines the basic systems to adequately serve the area.
Failure to move forward in solving these wastewater problems will
in all likelihood mean only greater expense at a  later date.

     The statement provides the  means  to coordinate and evaluate
existing wastewater systems.  It also outlines the most usable
designs and components for the  lowest cost by avoiding needless
duplication, providing for the  connection of portions  of systems, and
considering the areas of  greatest and least growth.
                              W-2
                               4-6

-------
    The challenges outlined in the draft statement are not unique to
St. Charles County;  they are confronted by rapidly expanding counties
throughout the nation.  Nor are they .challenges which the County can
solve by itself; the co-operation of all levels of government and of
all residents will be required.

    Adequate wastewater collection and treatment systems are the most
vital facilities necessary for orderly development; these features
are among the strongest available means to shape and guide quality
growth in a desirable way.  Fortunately,  for the eastern portion of
St. Charles County,  there are effective wastewater systems which can
provide effective solutions to the environmental concerns in sight.
The project area has both the potential and the capacity to provide
for what it must have in its own safety interest.

    We are pleased to be  of assistance in this review process.  For
the entailed processing of HUD subdivision environmental assessments
in St. Charles County, we would appreciate receiving a copy of the
Final Statement.

                             Sincerely,
W-2
                             Walter L. Eschbach
                             Environmental Officer
                                  4-7

-------
              EAST-WEST  GATEWAY
              COORDINATING  COUNCIL
              100 SOUTH TUCKER BOULEVARD
              ST. LOUIS, MISSOURI 63102
              314 421-4220  618 274-2750
   Board t>1 Directors

      CHAIRMAN
    Jerry F.Costello

    SI. CUr Courty BMfl)

   VICE CHAIRMAN
     HughMcCane
      FnMdnCaviy

      TREASURER
      Robert Cohn
      3t.UuiiCa««gr

     GeneMcNary
     County EnKUDM
    Nelson Hagnausr
        ClWninn
    MMMnCounlrBoM

Vincefit C. Schoemehl, Jr.
      Carl Officer
         MOW
     CUY oi EMI Si uxt*

    Ralph Krodlnger
      •WfMori coo«iy

    Harry R.RaiChert
      Monn»Cour«»

     Richard Green
      Paul Schuler
   fmmtn.aaOHivan
   IMIM OBuneN e( M*yon

 Roger C. Zimrnermann
  ftwttiKt. St. UU*Cov*y
     GaryMackey
    Thomas E. Zych
 fntlan. Bo«a oi
    William Walihes
    PumngCoimluliin

     Carl E, Malhtas
        ChUmon
 BtSUH Pntlopnwil Agvicy

    Robert N. Hunter
      ClwlEnginw
   GeneMcCormick
         onoor

     M tit Ti mtporuttn

     JohnA.Peteer
        tfOffic*
      atfanntaecn

   Michael T.Wbelffer
        Dne»
   .mdCannuMyOTlin

 REGIONAL CITIZENS
    Charles Billups
   Anabein Calkins
   Or. James R. Buck
      Darby Tally
    David M. Witter

EXECUTIVE DIRECTOR
     Las Sterman

      An Equal
 Opportunity Employer
April  26,  1985
Mr. Morris Kay
Regional  Administrator
726 Minnesota
Kansas  City, KS  66101

Dear Mr.  Kay:

   RE:  Comments on Draft  Environmental  Impact Statement
        for the Proposed Wastewater Treatment Facilities
        for Eastern St.  Charles County,  Missouri

The East-West Gateway Coordinating Council, in its  capacity as
the designated regional  clearinghouse, has completed  the review
of the  Draft Environmental Impact Statement for the Proposed
Wastewater Treatment Facilities for Eastern St. Charles  County.

This document was reviewed by the Board  of Directors  at  its
meeting on April 24, 1985, at which time the following comments
were approved:
                  1.
                 2.
   3.
The  EIS  satisfies all  federal EIS requirements of Sec-
tion 102(2)(c) of the  National Environmental Policy  Act
of 1969  (Public Law  91-190).   The EIS  is  also consistent
with EWGCC's population  andland use  projections.


Alternative 6 meets  all  state and local water quality
goals, since many small  facilities will be phased out.
All  study area effluent  will  be discharged to the
Missouri/Mississippi Rivers,  virtually eliminating all
discharges to small  streams which will significantly
improve  water quality  in these streams.


The  proposed Alternative is consistent with the State
208  Water Quality Plan since  it was  measured against
the  State's 208 sub-regional  plan (Alternative 7) and
found to be more cost-effective.  This cost analysis is
the  proper procedure and role of the Facility Planning
Process  for updating 208 Water Quality Plans.
                                         RECEIVED
                                                                    W-3*
                                         4-8
                                               MAY 1 11985

                                             EIS/404 BRANCH
              THE ST. LOUIS AREA COUNCIL OF GOVERNMENTS

-------
As a part of our review process, we have notified interested
or affected parties of this document and no comments have been
received.

If you have any questions concerning this review, please feel
free to contact Mr. Michael Coulson of our staff.
SipncerelyV'
          Director

cc:  Ms. Lois Pohl
                          4-9

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EUGENE 1. FELDHAUSEN, chairman
  Suit! 430
  109JO Ambuudor Dr.
  KwiUl CHy 64153

CARL E. YATES, Vice Chairman
  f, O. Box 3737 G.S,
  Sprinfflcld 65BOB

WM. F. SCHJERHOLZ, Member
  P. O. Box 31000
  D« Pern  63131

HELEN T. SCHNARE. Member
  1701  P«rk Am.
  St. Cbvln 63301

PAUL L. EBAUGH, Member
  p. o. BOX sat
  Ctpt  GirtrdMU 63701

C R. JOHNSTON, Membtr
  P. O. Box 658
  J«ffenon City  65102
          May  10,  1985
             MISSOURI
HIGHWAY AND TRANSPORTATION COMMISSION
ROBERT N. HUNTER, c*i>/ Engineer

BRUCE A. RING, Chief Countel

L. V. MCLAUGHLIN. Ast't. Chief Engineer

MARI ANN WINTERS. Secretory

   P. O. Box 270
   Jeffenoit City, Mloouri  65102
   T*t«phoni (314) 751-J551
          GENERAL:   Application No.  85050015
                     A-95 Review
                                                                        1 0 1985
                                         DIVISION OF
                                     BUDGET AND PLANNING
          Ms. Lois  Pohl
          Coordinator of Local & Regional Planning
          Division  of State  Planning  &  Analysis
          State Capitol Building
          P.O. Box  809
          Jefferson City, Missouri  65102

          Dear Ms.  Pohl:

          The draft  environmental impact  statement  by the U.S.  Environ-
          mental  Protection  Agency for  proposed water treatment facilities
          for eastern St. Charles County  involving  the Duckett  Creek,
          St. Peters, St. Charles, and  Portage de  Sioux sewer  districts
          indicates  an effect  upon state  highways  in  the area.

          The applicant should be informed  that the  location of utilities,
          public or  private, on state highway righr.-ot'-way, and the condi-
          tions of  occupancy of such right-of-way,  arc under the control  of
          the Highway and Transportation  Commission.   Detail plans for  the
          work affecting state highways should be approved by  our District
          Office at  329 South  Kirkwood  Road  in Kirkwood before  advertising
          any of the  work for  bids.

          Very truly  yours,
                                                        W-4
         L.  V.  Me Laugh 11n
         Assistant Chief Engineer
         A-95  Review  Agent
                                           4-10

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            United States Department of the Interior

                OFFICE OF ENVIRONMENTAL PROJECT REVIEW
                        175 WKST JACKSON BOULEVARD
                          CHICAGO, ILLINOIS 60604

                                 May 14, 1985
ER-85/579

Mr. Morris Kay
Regional Administrator
U.S. Environmental Protection Agency
726 Minnesota Avenue
Kansas City, Kansas  66101

Dear Mr. Kay:
r,:-,;:vEu
    i- DRAMCH
The Department of the Interior  has  reviewed the Draft Environmental Impact
Statement (DEIS) for the Proposed Wastewater Treatment Facilities for
Eastern St. Charles County,  Missouri and offers the following
comments.

General Comments

The statement adequately describes  the existing fish and wildlife resources
and evaluates general project construction impacts.  We were pleased to find
that the environmental consequences were identified in terms of direct and
indirect impacts, and also in short-term and long-term impacts.  We suggest,
however, that a more detailed discussion be provided regarding the Indirect
and long-term impact the project will have on land use changes in the
floodplain.  Specifically, while project construction may not directly
impact wetland and other valuable fish and wildlife habitat, the potential
for urbanization in the floodplain  is a reality that should be documented.
This issue is of particular  importance, as is indicated in the DEIS, the
lack of wastewater treatment capacity has, to date, been a factor in
limiting such development in the floodplain.
                             W-5
The maps furnished with the review document are not in sufficient detail to
enable a definite determination of which, if any, of these areas may be
affected.  Therefore,  all of the areas  In the vicinity of the project which
received Land and Water Conservation Fund (LWCF) matching assistance are
listed below:

   McNair Park (Projects 29-00085, 132  and 470), City of St. Charles

   Boonslick Park (Project 29-00726), City of St. Charles

   St. Peters City Park (Project 29-00578)

   YMCA Park (Project  29-00709), City of St. Peters

   St. Peters Sports Center (Project 29-01072, Element L), City of St.
   Peters
                            W-6
                                4-11

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    Prongue Tract Acquisition  (Project 29-00869), near Elm Point Creek

    Spencer Creek - Laurel Park Acquisition (Project 29-01147), near Spencer
    Creek

The project sponsor should consult with Hr. Stephen L. Powell, Director,
Recreation Grants, Department of Natural Resources, Post Office Box 176,
Jefferson City, Missouri 65101, to determine the potential conflicts with
Section 6(f)(3) of the LWCF Act (Public Law 88-578, as amended).  Section
6(f)(3) requires that no property acquired or developed with assistance
under this section be converted to other than public outdoor recreational
uses without the approval of the Secretary of the Interior.

The final statement should include the details of any proposed Section 6(f)
conversion, including the full proposed replacement package.

Please contact the Regional Director, Midwest Region, National Park Service,
1709 Jackson Street, Omaha, Nebraska 68102 (telephone:  FTS 864-3431 or
commercial:  402-221-3431) for technical advice pertaining to potential
Section 6(f) involvement.

Specific Comments

   Page 4-10, First Paragraph

   The sentence "Affected wetland acreages are insignificant" should be
   quantified and specifically attributed to acres affected by project
   construction. >The amount of wetlands that are at risk by future
   development are substantial in size and of considerable importance to
   recreational and regional economic development interests (waterfowl
   hunting clubs, etc.).

   Page 4-18, Part 4.2.2.6

   The statement regarding "no effect" on wetlands and floodplains needs to
   be supported in text, and appears to be contrary to the statement made on
   page 4-10.

To facilitate compliance with Section 7(c) of the Endangered Species Act of
1973, as amended, federal agencies are required to obtain from the Fish and
Wildlife Service information concerning any species, listed or proposed to
be listed, which may be present in the area of a proposed action.
Therefore, we are furnishing you the following list of species which may be
present in the concerned area:

    Endangered

    bald eagle                   (Haliaeetus leucocephalus)

There is no designated critical habitat in the project area at this time.

The scope and nature of the subject project indicates that diurnal perches,
roost sites,  food sources, or other preferred habitat will not be affected.
Therefore, the project will not affect the bald eagle.  This precludes the
W-6
 W-7
 W-8
W-9
                                   4-12

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need for further action on this project as required under Section 7 of the
Endangered Species Act of 1973, as amended.  Should this project be' modified
or new information indicates endangered species may be affected,
consultation should be reinitiated.

Section 4 of the draft statement does not contain a reference to the
project's impact on threatened endangered species.   He recommend that an
affect determination statement similar to the one provided above be included
in the final document.
                                                                                W-9
Addendum

The DEIS does not mention that a major contaminant site is  located within
the planning boundaries.  The Findett Corporation site is in Group 7 of the
EPA National Priorities List (NFL).  From the plates supplied with the  DEIS,
there appears to be an existing interceptor sewer line going through the
Findett property.  There is also a pump station in the vicinity.   To date it
has not been determined if there is any off-site movement of contaminants
(PCB's).  With this uncertainty issue, if there is to be any disturbance of
soils that could potentially contain PCB's, then the DEIS should  address
this issue.  For example. Figures 2-4, 2-5, 2-8, and 2-10 indicate that
construction is proposed for locations immediately downstream of  the Findett
Corporation site.  This construction and the Findett site Itself  are located
in a flood prone area, according to Figure 3-6.  Therefore, due to the  risk
of working in, disturbing, and moving contaminated soils, the DEIS should
adequately address this NFL site and its relationship to the potential  new
sewer construction.

Additionally, the DEIS does not identify a proposed major levee project
(Levee L-15) affecting the planning area that is presently  being  studied by
the U.S. Army Corps of Engineers, Kansas City District.  Our stated concerns
regarding the wastewater project's potential for Inducing the floodplain
development would be compounded with the subsequent completion of the levee
project.  Thus, the cumulative impacts of these federal projects  need to be
adequately addressed in a subsequent document.

In order to implement a solution to our concerns at the earliest  possible
time, you may contact Mr. Joe Tieger, Field Supervisor, U.  S. Fish and
Wildlife Service, Ecological Services Field Office, 705 Hltt Street,
Columbia, Missouri  65211, (314) 875-5374 or (FTS) 276-5374.

We appreciate the opportunity to review the DEIS and look forward to
continued coordination.

                                     Sincerely yours,


                                     <  V
                                                                               W-10
                                                                                W-1 1
                                       ^ti^^^^A'
                                       •S " —       f         -It
                                     Sheila Minor Huff        ''
                                     Regional Environmental Officer
                                  4-13

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               CITY  OF  ST.  PETERS
           CITY  HALL   MEXICO ROAD AT VENTURE DRIVE    ptrrrlVEU
            P.O. BOX 9     ST. PETERS, MISSOURI   63376     Ktv-»-
                            (314) 928-1800                     i^y ,J

                            May 17'  1985                       cleM04 BRANCH
U.S. Environmental Protection Agency
ATTN:  Mr.  Edward Vest
Chief, Environmental Impact Section
726 Minnesota Avenue
Kansas City,  Kansas  66101
                                  KE:  Draft  E.I.S.
                                       Proposed Wastewater Treatment
                                       Facilities - Eastern
                                       St.  Charles County, Missouri
Dear Mr. Vest:
In behalf of the City of St. Peters, I am responding to the opportunity
afforded us to comment on the Draft Environmental Impact Statement
identified above.   The document dated March,  1985, was provided the City
prior to the May 9  public hearing at St.  Charles.  Having been very
active in the plan  development, via the Citizens Advisory Committee,
I regret that a Board of Aldermen meeting on  the same night of the
public hearing prevented me from making comments in person.

The Draft E.I.S. appears to be well written and quite thorough.  From
our standpoint, only a few minor comments are in order.

1.  On page iv of the Executive Summary,  it is stated that the Spencer      I W~12
Creek STP is in St. Charles.  This is in error as the plant is in           I
St. Peters.  This same error is repeated on Page 2-86.

2.  On page xv, under Small Systems Outside Planning Area, I feel the       I
Francis Howell High School Lagoon should be mentioned also.  It is near     I W— 1 3
the two facilities  named and is much larger.                                '

3.  On page xxix, under Alternative Available to EPA and Alternatives       I
Available to Other  Agencies, why are Cities of St. Peters and St. Charles   I VV-14
not included with Duckett Creek Sewer District?  This same comment would    I
apply to Page 2-125.

4.  On page 2-7, four of the listed seven pump stations have been out of    I
service for approximately two years.  They are:  Old Town, Country Hill     I W —15
Number 1, Country Hill Number 2 and Missouri  Cities Dardenne Creek.         |
5.  On page 2-118,  table 2-16, the City would like  to be on record that
we are not in agreement with respect to the calculations for Local Share
of Cost for St.  Peters proposed facilities.   Establishment of water
quality standards now for Spencer Creek may have  an impact on the agency{s)
final decision in this regard.  The possibility of  proceeding with advanced
treatment in lieu of an effluent pipe to the Mississippi River may have a
significant affect  on the final sharing of costs.
                                4-14

          THE CENTER OF DYNAMIC GROWTH IN ST. CHARLES COUNTY
W-16

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Mr. Edward Vest
May 17, 1985
Page Two
The City looks forward to the total completion and acceptance of the
201 Facility Plan and Environmental Impact Statement in the near
future to allow us to move forward quickly with design of our improve-
ments.

Should there be any questions or should additional information be
required of us at this point in time, please do not hesitate contact-
ing me.
                                        Earl F. Holtgraewe, P.E.
                                        Director of Engineering
                                        City of St. Peters
cc:  Robert Irvin, City Administrator
     Ron Redder, Missouri D.N.R.
     Robert Harbour, Sverdrup & Parcel
     Joe Nickols, Duckett Creek Sewer District

EFH/lmd
                                    4-15

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John Ashcroft
  Governor

                                State of Missouri
                          OFFICE OF ADMINISTRATION
                              Post Office Box 809
John A. Pfelzer                        Jefferson City               Perry M. McGinnis, Director
Commissioner                           65102                 Division of Budget and Planning

                                May 28,  1985
     Mr. Edward Vest, Chief
     Environmental Impact Section
     726 Minnesota Avenue
     Kansas  City,  Kansas 66101

     Dear Mr.  Vest:

     Subject:   85050015 - Draft EIS -  Proposed Wastewater Treatment
                           Facilities for  Eastern St. Charles County,  MO

     The Missouri  Federal Assistance Clearinghouse, in cooperation
     with state and local agencies interested or possibly affected,
     has completed the review on the above  project application.
We are enclosing the comments received for  your consideration
and appropriate  action.  The remaining agencies involved in
the review did not have comments or recommendations to offer
at this time.

A copy of this letter is to be attached to  the  application
as evidence of compliance with the State Clearinghouse
requirements .

                                 Sincerely,
                                                                         VV~ 1 7
                                         J
                                      Lois  Pohl,  Coordinator
                                      Missouri Clearinghouse
     LP: cm

     Enclosure
                     i
     cc:  East-West Gateway Coordinating  Council
                                                          RECEIVED


                                      4-16                E\sMOA BR*NCH

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         Response to Advisory Council on Historic Preservation Comment
                          Letter Dated April 18, 1985
Response #1 (R-l) - The  Section 106 procedures have been  expanded  and clari-
fied as requested.
                                                                       *

  Response to U.S. Department of Housing and Urban Development Comment Letter
                             Dated April 25, 1985

Response #2 (R-2) - Comment noted.  Response not required.

       Response toEast-West Gateway Coordinating Council Comment Letter
                             Dated April 26. 1985

Response #3 (R-3) - Comments noted.  Response not required.

   Response to Missouri Highway and Transportation Commission Comment Letter
                              Dated May 10. 1985

Response #4 (R-4)  - Your  comment is acknowledged;  it  is understood that any
design plans which potentially  could affect the state highway system should be
sent  to the District  Office for review and  comment prior to advertizing for
bids.

  Response to U.S. DPI,  Office  of Environmental Project Review Comment Letter
                              Dated May 14. 1985

Response #5  (R-5)  - We agree that the potential for  future urbanization  in the
floodplain  is a  reality.   We  further believe  that  this growth is inevitable
and will occur with or without  the provision  of adequate  wastewater treatment.
The  intent in providing adequate wastewater  management for the planning area
is  to accommodate planned growth and development  and not to  induce or encour-
age  currently unplanned development.   With  the  implementation of the  recom-
mended  alternative (Alternative 6), planned future development should  occur  in
a more  orderly and less  dispersed manner  than under  the No Action Alternative.
Also,  it should be made clear  that  now,  under the recommended alternative,  no
                                     4-17

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centralized  wastewater  treatment  facilities  or  new  interceptor lines  are
proposed  for the  Mississippi River  floodplain  communities  in  the  planning
area.  Although the  draft facilities  plan proposed sewering  these areas,  the
final  facilities  plan  determined  that  such  a  plan  was  not  cost-effective
(i.e., affordable) and  thus  was  judged not implementable.   Instead a plan for
the  floodplain  communities  is  proposed  that  provides  for  less  capital-
intensive  decentralized wastewater management  solutions  including considera-
tion of the  following:

     • Establishment  of a centralized management  agency that would institute
       programs for upgrading and maintaining on-site systems;
     • Emphasis on the  need for community wells to replace individual shallow
       wells;
     • Clustering homes to small on-site systems;
     • Holding tanks  for  riverfront properties; and
     • Flow  conservation  practices  and devices to reduce the load on existing
       on-site systems.

     One  other clarification  is  in  order.   Figure  2-9 on  page  2-72  of the
Draft  EIS  graphically  illustrates   the  proposed  recommended  alternative
(Alternative 6).  A proposed effluent outfall pipeline is shown to extend from
the  Spencer  Creek plant  to the Mississippi  River.   The line will be carrying
treated   effluent  from  the  Spencer   Creek  STP  and  discharging  it to  the
Mississippi  River.   As such, no tie-ins to this  line from any adjacent devel-
opment will  occur.

Response  #6  (R-6)  -   Consultation with local officials  (Mr.  Joe Nichols, St.
Charles County, Mr. Earl  Holtgraewe,  City of St.  Peters, and Mr. Keith Devalt,
City of  St.  Charles) was made to  determine  whether  any of the listed proper-
ties that  have  been  acquired  or  developed  with  assistance  under Section
6(f)(3)  of  the  LWCF Act would  be  converted  to other  than  public outdoor
recreational uses as  a  result  of  the proposed project.   By  reviewing the
locations  of  the listed  properties   and  comparing   these  with  the  proposed
locations  of wastewater treatment and collection  facilities,  it was determined
that none  of the  park properties would be affected with the possible  exception
of the Prongue Tract.  If the Prongue Tract  is affected, it would  only involve
                                     4-18

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an easement to allow placement of an underground collection line.   No acquisi-
tion or  conversion of  existing  recreational lands is proposed;  however,  the
final determination is  the  responsibility of the National  Park  Service (NFS)
in cooperation with Missouri  Department of Natural Resources  (MDNR).   If  any
replacement  lands  are   determined  to  be  necessary,  the  grantee will  work
directly with the NFS and MDNR to reach an equitable settlement.

Response #7 (R^ll  - The precise  areal extent of wetlands affected directly by
proposed project construction was not  calculated because  the  exact locations
of interceptors  lines  have not been finalized.  However, the total acreage is
expected to be  small due  to  the need  for  only  minimal  (10 acres) additional
acreage for expansion of existing sewage treatment facilities, and the  revised
plan  to  drop  centralized  treatment and  collection  facilities for the flood-
plain  communities.   We  agree  that  the  amount  of wetlands  that  could be
affected indirectly as  a result  of  future development is greater; however, the
influence  of  the recommended  alternative  itself  in inducing growth and  urbani-
zation  in   the floodplain  areas  is  expected to  be  low  and was discussed  pre-
viously  under   "Response  #1."   Furthermore,   the  discussion  on  Page 4-10,
Section  4.2.1.6  was limited  to  direct  impacts  to wetlands  and floodplain  from
construction  activities only.

Response #8 (R-8) - This "no effect"  statement on page 4-18  refers  to direct
 impacts  on wetlands and  floodplains  from operating  any of the final  four
 action  alternatives.   The statement  on  page  4-10  was  referring  to direct
 construction-related impacts  on  these resources.

 Response #9 (R-9)  -  We  agree  that  Section 4.0,  Environmental  Consequences,
 should  include  a determination  as  to  the project's impact on  threatened and
 endangered species.   This  determination  statement  has been  added  to  Section
 4.2.1.5  of the Draft EIS, and is contained in Section 3.0, "Revisions to  Draft
 EIS," in this Final EIS.

 Response #10 (R-10) -  The  EIS has  been modified to  address  the status of the
 Findett Corporation  site and  its  relationship to  the proposed  project.  It
 should be  noted that  under  the  recommended alternative  (i.e.,  Alternative 6,
 Figure 2-9 in Draft EIS) no  construction activities are proposed for locations
                                     4-19

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downstream  of the  Findett site.   If fact,  three  of the four  alternatives
referred to  in your comment letter on the Draft  EIS (i.e.,  Figures 2-4,  2-5,
and 2-8; Alternatives 1, 2, and 5, respectively) were not included in the  four
final  action alternatives.  The  other alternative  mentioned  in your  letter
(Figure 2-10  or  Alternative 7) was one of the  final four action alternatives
but was not selected as the recommended alternative in the facilities plan and
EIS.  However, we  agree with your concern regarding  the  relationship of this
proposed NPL  site  and  the recommended alternative (Alternative 6).   As stated
in Section 3.0 "Revisions to Draft EIS," this relationship will be ascertained
following the results  of the ongoing remedial  site  investigations  at Findett
and any additional safety precautions will be developed accordingly.

Response #11  (R-ll) -  The  status  of the Levee Unit L-15 project was discussed
with Mr. Don Hammond, Study Manager, U.S. Army Corps of Engineers, Kansas City
District.   The  L-15 study  area consists of  the combined Missouri River and
Mississippi  River   floodplains  from St. Charles,  Missouri downstream  to the
Mississippi  River  and  from  just  upstream of Portage  des  Sioux downstream to
the Missouri River.  The Kansas City District, Corps of Engineers published an
announcement  in  October  1984  concerning  the  initiation  of the L-15  study.
Study Status  Reports  were published during May  1985  and December  1985, and a
public  workshop  meeting was held on July 2, 1985  in Orchard  Farms, Missouri
(see Appendix).

     The construction  of Levee Unit L-15 was authorized  by  the Flood Control
Act of  1944.   The  levee unit  was  further  studied during the early  1970's and
the project was  classified inactive after the  study because there was strong
opposition  to future  development  that could occur with 100-year protection,
and because the  risk of catastrophic  failure associated  with  lower  levels of
protection  was  considered unacceptable.  In  1983-84,  local  interest in  flood
protection  rekindled  and Congress included $250,000  in  the  Corps'  budget for
Fiscal  Year  (FY)  1985  to  review  the feasibility of  the  L-15  project and to
determine the nonfederal cost sharing requirements.   Congress  appropriated an
additional  $210,000 to continue  study during  FY  1986.   A notice of  study
initiation  and  a field trip to St.  Charles  County began the study in October
1984.   Responses from the notice  of  study  initiation were heavy indicating a
high  level  of interest in  the  project.   The Corps received about  500 comment
                                     4-20

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letters which were evenly divided between support and opposition to levee con-
struction.   Basically,  persons  residing east  of  the  Mississippi River ex-
pressed opposition to levee construction, while Missouri residents were nearly
unanimous in  support  of levee construction.  A petition bearing 2,445 signa-
tures  in  support of  levee  construction was also received in  addition to the
cards and letters.

     Common reasons cited for opposition to levee construction were:

     (1)  Levee construction would increase flood heights on the Illinois side
          of the Mississippi River.

     (2)  Additional  commercial  and  industrial development would be attracted
          to  the area  changing  the  land use from  agricultural  to urban.  It
          was  felt by  some  that this  would introduce  competition  to  com-
          mercialized  communities across the Mississippi, while  others  sug-
          gested  that an urban area across the  river would  be less aestheti-
          cally pleasing.

          However,  both Missouri  and  Illinois residents  now  appear  to agree
          that  the area would  be best  served by protecting the agricultural
          character  of  the  area without  additional  industrialization.   In
          addition, the U.S.  Fish and Wildlife Service  is considering a pro-
          posal  to designate a  portion of the floodplain areas as a recrea-
          tional/agricultural preserve,  thus  promoting  the intent to maintain
          the   present  character,  value,   and   resources   of  this  area.
          Initially,  the  only levee  alternative evaluated by the Corps was an
          agricultural  levee  that  would provide  a 25-year  level  of  flood
          protection  on  two  levee  alignments.   The primary  function of the
          25-year  agricultural  levee  would  be  to  provide  some additional
          protection  for the agricultural fields  that  already exist, and not
          to  protect  against  an urban design flood.  Higher levels of protec-
          tion  were  not evaluated because the impacts associated with induced
          flooding  that  could  accompany protection at levels  above 25-year
          were  expected to be unacceptable.  Also,  to  save  time and  expense,
          the  benefits and costs for higher protection levels  were not cal-
                                    4-21

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culated during  the preliminary analysis.  Although the  outlook  for
higher levels of  protection has  not changed, the Corps  is  required
by  regulations   (e.g.,  Economic  and  Environmental  Principles  and
Guidelines  for  Water  and  Related  Land  Resources  Implementation
Studies,  and  others)  to  evaluate  a wide  range of alternatives  to
ensure a complete analysis.  Consequently,  several additional alter-
natives will  be  studied  and documented,  including (1)  levees  that
would provide protection  from 25-,  50-, and 100-year  floods on four
alignments; (2)  construction of ring  levees  to protect development
subject to  flood  damage (the nonstructural alternative); and (3) no
action.

The Kansas  City District  is continuing with the L-15  study based on
a  letter  of  support   from the  St.  Charles  County  Commission  on
November  26,  1985.  The District now plans  to  complete its evalua-
tion of the alternatives  during 1986 and to provide Federal, State,
and  local  government  agencies  and interested  individuals with  a
draft  report  and draft environmental  statement  for review  and com-
ment  early in  1987.   Following public review, the  District  would
determine  whether or  not  to recommend  construction of any  flood
control works for the  study area.  A final report,  including  the
District  Engineer's  recommendations,  would  be  sent  to headquarters
for approval during the fall of 1987.   If a construction alternative
is  recommended  and approved,  about 4  years of additional  detailed
investigations  would  be  required  before  construction  could begin.

The  cumulative   long-term  indirect  impacts  from  the  recommended
wastewater  management alternative and  the L-15  levee project are not
quantifiable  at  this time;  however, although some indirect impacts
are inevitable  over the long-term, the  recommended wastewater treat-
ment  plan  is not expected  to encourage urbanization in the flood-
plain.
                           4-22

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             Responses toCity of St. Peters CommentLetter Dated
                                 May 17. 1985

Response #12 (R-12) - The corrections have been made.

Response #13 (R-13) - The  Francis Howell High School Lagoon has been added as
requested.

Response #14 (R-14)  - These  were  apparent oversights; the  corrections have
been made.

Response #15 (R-15) - Comment noted.

Response #16 (R-16) - Your comments  are noted.

             Response to Missouri Office of Administration Comment
                           Letter Dated May 28. 1985

Response #17 (R-17)  - The  comments  forwarded to  us  by the Missouri Office of
Administration  were  copies of comment  letters already  received from the East-
West  Gateway  Coordinating Council  and Missouri Highway  and Transportation
Commission.  Responses to  these  comments are  included elsewhere.
                                     4-23

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4.2  Responses to Public Hearing Comments

     The  following  responses to  oral  questions and comments  received  at the
public  hearing  on  the  Draft EIS  also  have  been  assigned  an  alphanumeric
designation  (H-l, H-2, H-3,  etc.)  which,  corresponds  to the  hearing comment
(see hearing transcript which follows).
                                     4-24

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 1                    UNITED STATES OF AMERICA

 2                 ENVIRONMENTAL PROTECTION AGENCY

 Q     •! __ _ ^ _ n» «, __ _^ ^ ^ ^ j^, J—, _ _^ _^ ^
                                            ;
 4     In re:

 5          Environmental Impact Statement

 6          Proposed Wastewater Treatment

 7          Facilities for Eastern St.

 8          Charles County, Missouri

 9     ____________________

10                                   City Council Room
                                    St.  Charles City Hall
11                                   200  North Second Street
                                    St.  Charles, Missouri.
12
                                    Thursday,  May 9, 1985.
13
                The public hearing in the above-entitled matter
14
      was  convened,  pursuant to notice,  at 7:00 o'clock p.m.,
15
      Kent Johnson presiding.
16
      BEFORE:
17
                              PANEL
18
                KENT JOHNSON,  Hearing Officer,  U.  S. EPA, 726
19
                          Minnesota Avenue,  Kansas City, Kansas,
20
                          Chariman.
21
                TOM LORENZ,  U.  S.  EPA, 726 Minnesota Avenue,  Kansas
22
                          City,  Kansas 66101.
23
                ROBERT  BARBOUR,  Sverdrup and  Parcel and Asso-
24
                          ciates,  Incorporated,  801 North Eleventh
25
                          Street,  St.  Louis,  Missouri 63101.

                             4-25

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 1               KEITH WHITENIGHT,  WAPORA, Incorporated, 6900





 2                         Wisconsin Avenue, Chevy Chase, Maryland





 3                         20815.




 4





 5





 6





 7





 8





 9





10





11





12





13





14





15





16





17





18





19




20





21




22





23




24





25







                             4-26

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2              HEARING  OFFICER JOHNSON:   I  would like to convene




3    this hearing at  this  time.




4              This is  a hearing  in  reference  to the  draft




5    environmental impact  statement  of the  proposed wastewater




6    treatment facilities  for  eastern St. Charles County,




7    Missouri.  The draft  environmental  impact statement




8    includes the Ducket Crrek, St.  Peter's, St.  Charles and




9    Portage de Sioux sewer districts.




10              This hearing is being held on May 9, 1985,  in




11    the City Council Chambers of  the St. Charles City Hall,




12    located at 200 North  Second  Street,  St. Charles,  Missouri.




13              My name  is  Kent Johnson.   I  am  with the Environ-




l4    mental Portection  Agency.  I  am with the  Office  of Regional




15    Counsel.  I will be acting as the Hearing Officer in this




16    proceeding tonight.




17              With me  are Tom Lorenz from  the EPA.   He is at my




18    far right.  He is  also from  Region  7,  and he is  the work




19    assignment manager for the environmental  impact  statement.




20              Also here is Bob Harbour, with  Sverdrup and Parcel




21    and Associates,  Incorpirated.   He is the  second  one down




22    to my right.  He is the facilities  planning consultant.




23              Also here to my immediate right is Keith Whitenigh




24    with WAPORA, Incorporated, and  they are an environmental




25    consluting firm, and  they consulted on this environmental





                            4-27

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 1    impact statement.




 2              The purpose of this hearing is to receive  comments




 3    regarding the draft of this environmental impact  statement,




 4    and if you wish to make a statement tonight, there are




 5    cards at the door, and I believe that everyone that  is here




 6    has filled one out.




 7              This document is being submitted under  the




 8    provisions of the Natinal Environmental Policy Act,  Public




 9    Law 91-190, which requires an environmental impact state-




10    ment to be prepared on major federal actions signifi-




11     cantly affecting the quality of the human environment.




12     This hearing is part of that process.




13               Notice of this hearing was published in the




14     Federal Register on April 5, 1985.  Notices were also pub-




15     lished in the St. Louis Post-Dispatch on April 5, through




16     April 7 of this year.  Also published in the St. Charles




17     Journal,  beginning on April 5 for three consecutive  issues.




18     I understand that publication is every other day.




19               Proofs of publications are on file at Region 7's




20     Regional Office, which is located at 726 Minnesota Avenue,




21     Kansas City, Kansas 66101.   These are available for review




22     upon request.




23               All comments on this document must be submitted tc




24     the Environmental Protection Agency within 45 days after




25     the Notice of Availability of this document was published





                             4-28

-------
l    in the Federal  Register.   In  this  case,  the closing date




2    for submitting  comments will  be  May 20,  1985.   Copies of




3    the Draft  EIS are  available for  review at the  Katherine M.




4    Linneman Branch Library,  2323 Elm  Street, St.  Charles,




5    Missouri,  and also at  the Spencer  Road Branch  Library,




6    425 Spencer  Road,  St.  Peter's, Missouri.   We also brought




     several copies  of  it tonight,  so if you  don't  have one  and




     would like one,  I  think we can provide you with one.




                As I  stated  before, while this  hearing is being




10    held tonight, written  comments can  be  submitted up until




     May 20th,  so just  because we're  having a  public hearing




12    tonight does not mean  that the comment period  closes.   That




13    closes on  May 20th.  If you have written  comments,  they




     should be  sent  to  the  attention  of  Edward Vest,  who is  the




     Chief of the Environmental Impacts  Section,  726 Minnesota




16    Avenue, Kansas  City, Kansas 66101.




                There  aren't going  to  be  any restrictions as  to




18    comments made tonight.  We would ask that you  limit it  to




     a test of  relevance, however, and  if you  do  have a written




20    statement  that  you're  going to read, we'd appreciate  if it




     you could  give  us  a copy  of it,  if  that's possible.




22               The hearing  will be informal.   No  one making  a




23    statement  will  be  sworn in, and  there  will be  no cross-exam-




24    ination of anyone  making  a statement.




25               Again, we remind you about the  cards.   If you do






                                4-29

-------
 l     want to make a statement,  let us know,  and I think we will




 2     get to everybody who wants to make a statement tonight.




 3               Thank you for coming,  and right now I'd like to




 4     turn over the floor to Mr. Lorenz for this presentation.




 5               MR. LORENZ:  My  name is Tom Lorenz.  I am the




 6     Work Assignment Manager for the  Environmental Impact State-




 7     ment that's been prepared  on this project.




 g               What I'd like to address at this point is the EIS




 9     process,  how it got here,  where  we're headed with it, to




10     give you an idea of the agenda for this particular document.




11               On October 9, 1982, the Environmental Protection




12     Agency issued a Notice of  Intent to prepare an Environmental




13     Impact Statement.




14               On November 17 of 1982, a scoping meeting was




15 ]   held in this room for the  purpose of receiving public com-




16     ment and for denining the  scope  of the project.  During




17     the 201 planning process,  the Environmental Protection




18     Agency participated in a full-scale public participation




19     program,  in which an advisory committee, a citizens' ad-




20     visory committee was formed, and that committee met on a




21     regular basis and at key points  in the project, to discuss




22     any represent the issues as they pertain to the particular




23     communities and individuals represented.




24               In November of 1983, the draft 201 facility plan




25     was completed and submitted to the public, and in February,






                            4-30

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      February  15,  1984,  a public hearing was held on that 201



      facility  plan.



                In  October of 1984,  the final facility plan was
 3


      submitted to  the State, and on April 5, 1985, a Notice of
 4


      Availability  of the draft Environmental Impact Statement
 5


      was  published in the Federal Register.
 6


                On  May 9, 1985, which is tonight,  we are holding



      a public  hearing in accordance with the regulations that
 8


      govern the preparation of an Environmental Impact State-



      ment.   On May 20, the public review period will clo-e for



      that document.   The Environmental Protection Agency will



      take all  oral and written comments concerning the document



      and  the project, and will prepare responses for those com-
13


      ments. Those responses will be addressed in the final En-
14


      vironmental Impact Statement,  which we anticipate being
15


      available around the end of June of 1985.
16


                After the final Environmental Impact Statement has



      been published and distributed, a 30-day no-action time
lo


      period will be allowed to receive comment on that document.
i»?


      After that no-action period has closed, a Record of Decision



      will be published by the Environmental Protection Agency,



      delineating the project, that the Environmental Protection



      Agency will be willing to provide public funds in support
23



24     Of'


                The legal basis for the Environmental Impact State
25
                              4-31

-------
     merit, as mentioned earlier by the Hearing Officer,  is  the




2    National Environmental Policy Act of  1969, and the  amend-




     ments to it, Section 511-(C)-(1) of the Clean Water Act, and
o



     EPA's NEPA  implementing regulations which are in  40 CFT,




     Part 6.  The Environmental Protection Agency decided that
O



6    the project as it was scoped had the potential to signifi-




     cantly affect the quality of the human environment.




g              The planning area, or study area, for this parti-




     cular project includes the upper Mississippi River, Salt




0    River Basin watersheds of Dardenne, Spencer, Sandtart,




     Cole and Boshert Creeks; the lower Mississippi Basin water-




     sheds of Duckett and Taylor Branch, the City of St. Charles,




     the City of St. Peter's, the Village of Portage de  Sioux,




14    and the unincorporated portions of St. Charles County,  be-




1K    tween the Mississippi River and the Missouri River, east of
10



 „    the St. Peter's city limits.




               The jurisdictions involved, that will be  the




18    sewer districts involved, in the City of St. Charles they




     have the Mississippi River sewage treatment plant,  the




20    Missouri River sewage treatment plant, Charles Trails  sew-




     age treatment plant, and the Heatherbrook Lagoon.




22              In the City of St. Peter's the Spencer  Creek




23    sewage treatment plant, and in the village of Portage  de




     Sioux, the community spetic tank system there




25              In the Duckett Creek Sewer District, the  Duckett






                             4-32

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     Creek  sewage  treatment  plant,  the  Harvester Dardenne sewage




2    treatment plant,  the  Highway  94  South plant,  and the Boscher




3    town Lagoon.  And then  there  are six  privately operated




4    wastewater  treatment  facilities  in the project area.




5              To  see  where  those  particular wastewater  facil-




6    ities  are,  we refer you to  Figures 1-2 and  2-2 in the hand-




     out that you  received as you  came  in.




8              I now turn  you over  to Bob  Barbour,  who is the




9    engineer in charge of the facility plan for this project.




10              MR. BARBOUR:   Thanks,  Tom.   As Tom mentioned,  my




11    name is Bob Barbour,  and I  was the project  manager  on the




12    facility plan for this  project.  I think Tom has described




     the study area and the  jurisdictions  involved.




               This facility plan was funded jointly by  the




15    Duckett Creek Sewer District,  the  City of St.  Charles and




16    the City of St. Peter's.  The  Federal  Clean Water Act of




     1972 and '77, as  amended in 1977,  established  the goals




     of fishable and swimmable waters,  and  without  going into a




19    lot of detail, basically one of  the requirements is that




20    there will  be secondary treatment  for  municipal facilities




21    by July of  1988.




22              These Acts also established  construction  grants,




23    funds available for sewer districts arid municipalities to




24    build wastewater  facilities.   In any construction grant




25    process, there are three phases, there is the  planning phase





                           4-33

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                                                               10
 1     the design  phase,  and the construction phase.   The 201




 2     facility plan is the first phase,  and this must be approved




 3     before  any  other phases  can proceed with grant  funds,  either




 4     State or Federal.




 5              The 201  process includes an assessment of the




 6     current situation,  revising the existing facilities,  waste-




 7     water collection and treatment facilities, projection of




 8     future  conditions  over  the 20-year design planning life,




 9     identification of  the wastewater treatment alternatives,




1°     and evaluation of  these alternatives, including cost-effec-




11     tiveness and  selection  of a recommended alternative,  and




12     then includes implementation arrangements, including  cost




13     schedules and operating entities.




14              Another  aspect that is required is an environmen-




15     tal assessment.  And in this particular project, the environ-




16     mental  assessment  was split up and an environmental im-




17     pact statement was performed,  and  that's what  the hearing




18     is  about tonight.




19              I'm not  going to go into any detail  on the  al-




20     ternatives.   They  were  in the facility plan, and I under-




21     stand Keith Whitenight  from WAPORA is going to describe




22     the environmental  impact of those  alternatives, and discuss




23     them in his section.




24              As  Tom mentioned, we did have a full public par-




25     ticipation  program,  we  had an advisory group and they helped





                             4-34

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                                                              11
1    us with the selection of alternatives, helped us cull  those




2    alternatives from eight down to four, and then helped  us




3    with the final selection.




4              I think Tom has mentioned that the final facility




5    plan was published in August, 1984, and has been available




6    since that time.  With that, I'm going to turn it over to




7    Keith. •




8              MR. WHITENIGHT:  Again, my name is Keith White-




9    night, and I am with WAPORA.  We were retained by EPA  to




10    assist them in preparing the Environmental Impact Statement.




11              I'm sure, as probably most of you know in this




12    room, the primary reason for initiating this whole waste-




13    water management planning process, including the EIS and




14    facility plan , is the extent of past and future growth, as




15    projected for the Duckett Creek planning area, specifically




16    eastern St. Charles County.  This, combined with the fact the




17    a number of treatment plants in the area have not been able  to




18    meet effluent limitations, and some malfunctioning of  on-




19    site systems in the flood plain areas, has dictated the need




20    to take a hard look at the planning area and come up with




21    some long-term solutions to these kinds of problems.




22              What I'd like to do, and I'll call your attention




23    again to the handout, is I'm going to try to follow the re-




24    maining sections in the handout so if you want to follow




25    through I'll be referring you to maps and various things at






                               4-35

-------
                                                          12
 1    different points  in  time.  But the first thing  I thought mig



 2    be useful, and  I  won't read each one per se,  is the page on



 3    EIS issues.  There are a number of areas of concern that



 4    were identified,  I guess initially, during the  EIS scoping



 5    meeting, and subsequently during the past public partici-



 6    pation process.



 7              I'd like to just highlight those issues for you.



 8    Of course, one of the main ones was the concern surrounding



     the population growth and the impacts on various natural



10    and manmade resources that are listed there.  You can read



     those for yourself.  Of course, there is concern regarding
12
14
     the effects of discharging inadequately treated sewage, i.e.
13    treated effluent, on water quality and public health in
     the planning area.
15              I guess you could group the next three bullets




16    there, and they indicate concerns about the need to develop




     a plan that is reasonable, that's cost effective and environ-


1ft
     mentally sound, and one that addresses all the problems of




19    the planning area.  We've got a number of user jurisdictions


ort

     as Tom mentioned, and it was no small effort to look at all



21
     those plans and decide what needed to be done.



22
               Due to again, the large planning area and the



23
     multiple sewer authorities, there was concern expressed



24
     initially on the ability to coordinate effectively among



25
     all these groups, including EPA and the State, and I think




                               4-36

-------
                                                          13
 1    that has been done pretty effectively.  I think most of




 2    you know that this was something called a piggyback EIS




      process, which simply means that the EIS has developed




      pretty much concurrent with the facility plan, so there




      was a great deal of interaction with Bob's firm and with




 6    the public throughout the whole process.


 *7

                The last bullet there deals with concerns sur-


 B
      rounding construction-related impacts.  They are the normal


 g
      ones that you would anticipate, the traffic flow disrup-




      tions and impacts on existing land uses and local business,




      and some of the commuting patterns, which I will go into




      that a little bit later in more detail.



13
                Of course, there are a number of other issues




      that have been voiced.  I think most of them you could re-



15
      gard as sub-sets of a lot of these more general issues that


ifi
      were described.



17
                Let me go on now to say a few brief things just



18
      about the development of alternatives for those of you that



19
      weren't directly involved in the process.  Once the waste-


20
      water management needs for the planning area were well under



21
      stood, and this happened through surveys and a number of


22
      studies that were documented in the facilities plan, there


23
      was an initial set of eight preliminary alternatives that


24
      were developed by Sverdrup and Parcel.  I don't go into and


25
      describe each one of these, because they've undergone detail




                              4-37

-------
                                                              14

      ed description in the past and have been screened and looked
      at in great detail,  but there are a couple of elements that
      are common to all eight of those alternatives, and they
 3
      are listed here in the handout.   They all call for abandon-
 4
      ment of five sewage  treatment plants and six pumping sta-
 5
      tions,  following construction of the new interceptor sewers.
 6
      And the Highway 94 South treatment plant would serve as an
 7
      interim facility for each one of the alternatives.
 O
                These preliminary alternatives were screened and
 «/
      ranked  according to  various factors—monetary factors, non-
      monetary factors, and environmental considerations.  For
      those of you that have a copy of the EIS with you, see
      Page 283,  Table 2-10, which is simply a culmination of that
13
      screening process and shows how the alternatives rank in
14
      relation to each other.
lo
                The CAC carefully looked at these rankings, and
16
      ended up recommending that the top four alternatives be
      evaluated in more detail.  The four alternatives chosen,
18
      that were referred to in the facility plan and the EIS, are
1*7
      referred to as the final four alternatives, and they are
£V
      alternatives 3, 6, 7, and 8, as they were referenced
      in these documents.
ftft
                I'd like to talk just briefly about these final
Zo
      wastewater management alternatives.  These also included
      the no-action alternative, which is required by law to be
25
                              4-38

-------
                                                              15
 1    look at.  What I'd like to do  is  simply  highlight each




 2    one and refer you to the corresponding figure  that is in the




 3    handout if you want to see the graphic illustration of how




 4    these things compare.




 ^              First is Alternative 3, the corresponding figure




 ®    is Figure 2-6, which is several pages back.  Alternative




 7    3 would involve the continued  use of the  Spencer  Creek




 8    plant, Duckett Creek, Missouri River and  the Mississippi




 9    River STPs.  Again, as I mentioned, the  Highway 94 South




 10    plant would serve as an interim facility  and would be




 11    initially expanded to a 0.5 mgd plant.   The Spencer Creek




 12    plant would be expanded to a 7.5 million  gallon per day




 13    contact stabilization activated sludge facility,  and




 14    the final sludge disposal would be by land application.




 15              The existing Duckett Creek plant would  be re-




 16    placed by a new 1.1 mgd oxidation ditch  system, and the




 17    final sludge disposal there would again  be by  land appli-


 1 A

      cation.  The Missouri river plant would  be expanded



 1Q
      from a 3 mgd primary facility  to a 5 mgd  contact  stabili-



 20
      zation facility, which is a secondary plant.   The de-waterec




 21     sludge would be hauled, in this case, to  the Mississippi



 22
      River plant for incinceration, and then  the ash would be




 23     landfilled.  .



 24
                The Mississippi River plant would be expanded



25
      from a 5.5 to a 7.0 mgd activated sludge  facility, and




                             '4-39

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                                                           16
       the sludge would be disposed of by incineration and the



  2     residual ash,  again, would be landfilled.



  3               Another plan alternative that was chosen was



  4     Alternative 6, which turned out to be the alternative



  5     that was recommended in the facility plan as  the preferred



       alternative.   It also has been adopted officially as the



       EIS-recommended alternative.  The corresponding figure for



       this one is Figure 2-9 in the handout.  Alternative 6



  9     would likewise involve the continued use of the Spencer Cre



       Duckett Creek, the Missouri River and Mississippi River



       plants.   Again, the Highway 94 South plant would be an



 12     interim facility, and the Spencer Creek plant would be
 13
       upgraded from a 3 mgd extended aeration plant {it says
 14     extended activation plant in the handout, but it should be



       extended aeration activated sludge plant) to a 4 mgd con-



 16     tact stabilization facility.  The sludge management scheme



 17     would be identical to that described for the previous alter



 18
       native,  Alternative 3.



                 The existing Duckett Creek plant would be replace




 20     by a new 5 mgd oxidation ditch activated sludge system, and


 21
       the sludge would be aerobically digested and the final dis-



 22     posal would be by land application.  The Missouri River



       STP would be expanded to a 5 mgd facility, as described


24
       under the Alternative 3 scenario.  The Mississippi River



25     plant would be expanded from a 5.5 mgd to a 7 mgd activated




                             4-40

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                                                               17



      sludge facility,  as proposed in Alternative 3, although the




 2
1


     treated effluent would be pumped instead of flow by gravity
      to the Mississippi River.
 t>


                Another plan alternative is Alternative 7; Figure



      2-10 is the corresponding illustration.  This would again
 D


 .,    involve the continued use of Duckett Creek, the Missouri
 D


      River and the Mississippi River treatment facilities.  The



 0    94 South plant would again serve as an interim facility, and
 o


      Spencer Creek would be abandoned in 1995, rather than remain

                                          %

10    operational throughout the entire 20-year planning period.



                In 1995, the plant would then become a pumping



12    station, and wastewater would be pumped to the Mississippi



      River plant for treatment there.  The Duckett Creek plant



      would be replaced by a new 3.5 mgd oxidation ditch acti-



      vated sludge system.   The sludge management scheme would



      be identical to that of the preferred alternative, or
lb


      Alternative 6.



18              I left out here the Missouri River plant, but it



19    would be expanded again to a 5 mgd secondary facility, as




20    proposed for Alternative 3.



21              The Mississippi River plant would be expanded and



22    upgraded to a 12 mgd secondary plant.  The treatment scheme



23    would be identical to that proposed under the recommended



24    alternative, Alternative 6, and sludge would be aerobically



25    digested, which is slightly different  than the other alter-





                            4-41

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                                                         18
 1     native.




 2               The last of the final action alternatives is




 3     Alternative 8.  The corresponding figure there is 2-11 in




 4     the handout. This one would involve again the continued use




 5     of Spencer, Duckett, Missouri River and Mississippi River




 6     STPs;  the Highway 94 South plant would be an interim facil-




 ?     ity again.   Spencer Creek would be upgraded to a 5 mgd fa-




 8     cility, with the treatment processes being similar to the




 9     other  alternatives  that I described.



in                           ""
1U               The existing Duckett Creek plant would be replaced




11     by a new 3.5 mgd facility, as described under the Alterna-




12     tive 7 scenario.  The Missouri River plant would be




13     upgraded to a 5 mgd contact stabilization facility, and that




14     is identical to that proposed under all the other action




15     alternatives.




16               Finally, the Mississippi River plant would be




17     expanded to a 7 mgd activated sludge facility, and that




18     would  be identical to the scheme proposed under Alternative




19     6.   As I mentioned, EPA is required to consider the no-actio




20     alternative, and just for clarification purposes, this, of




      course, would assume no Federal participation on the part



99
"     of EPA to build or otherwise upgrade any of the wastewater


OQ

      systems in the planning area, and I'll touch a little bit


ftA

      more on that later under the environmental consequences.




25               Let me turn ahead now to the EIS and facility plan





                            4-42

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                                                              19






1    recommended alternative.  They are one and the  same, and to




2    arrive at the final four action alternatives, as we call




3    them, and as I just described, they were  further screened




4    and evaluated by Bob's firm and by the citizen  advisory  com-




5    mittee, as well as the public at  large, through various  pub-




6    lie meetings.  I have listed here the primary criteria  (fac-




7    tors) that were looked at during  that screening.   I might




8    draw your attention to the cost comparison.  I  did include




9    Table 2-12, which I think immediately follows this one,




10    where you can see a breakdown of  the costs for  the four




11    final alternatives.  Basically, the table just  shows a com-




12    parison of the costs, an approximate breakdown  of  the local




13    cost-share by user jurisdiction.




14              Again, Alternative 6 in that table is the recom-




15    mended alternative, and it turns  out it is also the most




16    cost effective alternative.  Based on these  further evalua-




17    tions, Alternative 6 was selected.  It was the  most cost




18    effective, and it was also determined to  be  the most envir-




19    onmentally sound.




20              I won't go through and  describe the major compo-




21    nents again.  They're the same as I described for  the Altern




22    tive 6 scenario before, but there are a few  other  aspects




23    of the recommended plan that I'll highlight  for you.   There




24    is a 1 mgd interim Duckett Creek  facility that  has been  de-




25    termined  to be needed to provide  the needed  interim capacity




                           4-43

-------
                                                             20
 1     until  the  new 5  mgd  facility  is  constructed,  which won't be
 2     until  '88  or  '89,  I  believe.
 3               Portage, the  plant  there,  it's  recommended  that
 4     that would be upgraded  to  an  extended  aeration package plant
 5     instead of the rotating biological   contactor plant which
 6     was proposed  back  in the '78  facilities plan.   In terms of
 7     on-site systems, and this  would  affect the  floodplain com-
 8     munities in the  planning area which  are now served by the
 9     individual on-lot  treatment systems, it was determined in
10     the final  facilities plan  that a centralized  treatment and
11     collection system, even for the  higher density areas,  would
12     not be cost effective,  and therefore was  determined not
13     implementable.   As such, the  overall recommended  plan,  as
14     now proposed  includes a much  less extensive,  less capital
*5     intensive  solution for  these  areas.  It would involve a
16     number of  things that are  discussed  in some detail in the
17     facilities plan, but basically it calls for establishment
18     of a central  management district that  would oversee on-lot
19     systems, additional  public education in terms of  siting and
^     functioning of septic tanks,  and so  forth,  flow conservation
21     measures,  use of community wells, and  use of  cluster  systems
22     or mound systems where  they are  appropriate.   These are the
23     kinds of things  that would be far less capital intensive
24     than the centralized treatment.
^               Let me now go into  the environmental consequences.
                              4-44

-------
                                                         21
 1     Just for clarification purposes,  in  the EIS we  classified




 2     the impacts in a number of categories.  Most  are  self-explan




 3     atory—construction-related, operation-related, primary




 4     and secondary, short-term and  long-term.   The only  ones  I




 6     might expand on a little bit are  primary  and  secondary.




 6     Primary, we are talking about  direct effects  that occur  as  a




 7     result of construction or operation  of the facility.   The




 8     secondary impacts, we are referring  to indirect effects  that




 9     would be induced from changes, principally in land  use and
10
population, that would occur from implementing the project.
11     there is some distinction  there  that  is  helpful  to know.




12               First,  let me  talk  a little bit  about  the no-ac-




13     tion alternative  and the environmental consequences of




14     that.  Again, by  no-action, we mean no Federal grand par-




      ticipation by EPA, which presumably would  mean that the




16     project could not be implemented as proposed.  Now in prac-




      tice, what normally happens is the whole process comes  to




18     a screeching halt, or  it certainly is delayed considerably




19     if that kind of an action  is  taken.   The project is normal-




20     ly reevaluated, it's scaled down, there  would be alternative




21     financing schemes that would  have to  be  looked at, and  in




22     the meantime, literally  nothing  happens.  This could result




23     in a number of undesirable consequences  in the case of  the




24     Duckett Creek planning area.




25               The existing treatment and  collection  facilities




                             4-45
                                                                   so

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                                                             22





 l    that are already overloaded would continue to operate,  and




 2    they would receive even more wastewater in future, re-




 3    suiting in more by-passing or discharging of untreated  or




 4    partially treated sewage into the area streams.




 5              Dardenne Creek also would continue to receive




 6    wastewater discharges, which would serve to further degrade




 7    water quality in that area.  Aquatic resources certainly




 8    would be affected adversely, possibly for distances farther




 9    downstream than they are now.  Sludge handling problems at




10    the existing treatment plants would increase.  There would




H    be an increased frequency of sewage backups from over-capa-




12    citated pumping stations and interceptor lines, which




13    could result in property damage and potential public health




14    hazards.




I5              In terms of the on-site failures, these would




16    continue to occur to some degree, and the potential for




17    groundwater contamination would still exist.  Certainly as




18    future growth would occur in the planning area, which will




19    occur in large part with or without the expanded treatment




20    facilities, at least the growth in the unsewered areas, there




21    would be a lot more dependency on on-lot systems--the indi-




22    vidual septic tank systems.  And where the soils have limitec




23    capabilities, or where high water tables occur, certainly




24    there could be groundwater problems that would be aggra-




25    vated there.




                            4-46

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                                                          23
 1               In addition, the increased lot sizes that would


 2     be needed for the individual on-site systems could result


 3     in some inefficient use of land and development patterns


 4     would tend to be less orderly and more dispersed I think,


 5     overall.


 6               So, in essence, under the no-action alternative,


 7     the municipalities and the sewer districts would be left


 8     without any well-defined plan for facility upgrading in the


 9     planning area,  and I suspect any plant improvements  that


10     would be done would be done as stopgap measures to try to


11     resolve an immediate problem, rather than the real intent


12     of this process, which is to come up with some longer term


13     solutions.


14               Next, I'd like to summarize the environmental


15     consequences of the action alternatives, and because of the


16     similarities between those alternatives, impacts really


17     can be grouped for each one of these resource areas.  There


18     are some exceptions to that, but by and large the action


19     alternatives will have very similar impacts in these differ-
                                                             ^

20     ent areas.


21               First is air quality—the adverse impacts on air


22     quality during construction.  What I'll try to do is to


23     discuss construction and operation-related impacts for each


24     resource area if you will, and I'll qualify them if it's not


25     clear what I'm talking about.  The adverse impacts on air


                            4-47

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                                                              24







 1    quality during construction should be short-term.  They




 2    will primarily involve dust emissions, fumes, and noise




 3    from construction equipment.  Existing STPs are not located




 4    in densely populated areas, so the impacts should be largely




 5    confined to those residences that are in the immediate vi-




 6    cinity of these upgraded facilities.




 7              During the operation phase, there is potential




 8    for some odors and gases arid aerosols to be released from




      the various treatment processes.   This is normal.  It's




10    fully recognized by the design engineers, and it should be




      controlled through proper design, and operation and main-




12     tenance procedures that will be forthcoming.




                So,  overall,  the air quality is expected to improv




1     due to improvements in plant efficiencies throughout the




      planning area.




16               In terms of soil erosion and sedimentation,




17     most of these impacts will be of  short duration, again.  And




18     when I say short duration, I'm talking about the construe-
19
22
      tion period—the duration of the construction period.
20               Complete erosion control is not possible.   Some




      of the impacts that would occur,  given that assumption,
      will be erosion and sediment leaving active construction
23     sites during stormwater events in particular,  i.e., storm-




      water runoff events.   Nutrients and other pollutants will




      tend to get into the  streams, certainly in the immediate




                           4-48

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                                                             25
 1     vicinity of the construction sites.




 2               The possibility of limited crop damage and some




 3     temporary interruption of agriculture activities, certainly




 4     in the vicinity of the interceptor lines, could occur during




 5     the construction period.  There could be some localized




 6     clogging of road culverts, and localized flooding due to




 7     drainageways possibly being clogged with sediment.  During




 8     the operation, the primary impacts to soils would be from




 9     the land application of sludge.  The impacts, again,




10     would depend on specific soil properties at the land appli-




11     cation sites, which I understand have not been pinpointed




12     yet,  so we can't do any detailed impact assessment of a




13     particular site.  But it would depend on the soil proper-




14     ties, on the composition of the sludge, and the rate of the




15     sludge application.  Again, the design considerations for




16     specific sludge disposal sites would take all these things




17     into consideration.




18               Next would be surface water.  Surface water qual-




19     ity would be degraded in the vicinity of the construction




20     sites from again, nutrient inputs, increased turbidity,




21     increases in siltation, and these types of things.  However,




22     the impacts would be short-term; they would vary depending




23     on the extent of rainfall that would occur during the con-




24     struction phase.  The length and placement of sewer lines cou[Ld




25     affect the magnitude of the impacts.  And the effectiveness,




                             4-49

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                                                          26







 1     again,  of the mitigation measures,the erosion control mea-




 2     sures and so forth which would be proposed to reduce the




 3     runoff  and sedimentation, would determine the actual extent




 4     of  the  impact.




 5               Again,  in terms of surface water, with the aban-




 6     donment of the Harvester-Dardenne sewage treatment plant and




 7     improvement of the Spencer Creek plant,  I think you will see




 8     an  immediate improvement in water quality in that area, cer-




 9     tainly  in fecal coliforms and dissolved  oxygen and total sus




10     pended  solids concentrations.  The  Dardenne Creek water




11     quality should improve pretty rapidly following those action




12               Adverse  impacts to surface waters from the opera-




13     tion  of the collection systems and  pumping stations are




14     expected to be fairly minimal.  Breaks or leaks should be




15     rare  after the new systems are installed, so there is no




16     major concern associated with that.




17               With the improvements in  the operation and main-




18     tenance of the on-site systems, surface  water quality also




19     should  improve in  the areas served  by those types of systems




20     Groundwater resources could be affected  in localized




2*     areas during construction, particularly  construction at




22     pumping stations.   In areas where there  are shallow wells,




23     shallow wells could be affected.




^               The primary dangers of groundwater contamination




25     during  the operation phase would be associated with leaks





                            4-50

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                                                           27
 1    along the sewer  lines,  around  the  sewage  lagoons,  and pos-



 2    sibly any leachate  from the  sludge storage  sites.   Again,



 3    this will all be taken  into  consideration during the design



 4    stage, and with  proper  operation and  maintenance these types



      of impacts should be minimized.



 6              Groundwater quality  is expected to improve in the



 7    floodplain areas and downstream from  the  existing sewage



 8    treatment plants as the wastewater treatment in the planning



 9    area improves.   However,  I might note that  the continued



 10    use of existing  and future use of  on-site systems potential-



 11    ly could cause groundwater problems if not  properly main-



 12    tained and sited, particularly in  areas where alluvial wells



 13    are the source of potable water supplies.



 14              Biological resources—here  I'll be talking about



 15    terrestrial  and  aquatic biota. During the  initial earth



 16    moving activities during the construction phase,  there wii:



 17    be terrestrial impacts, principally from  the loss of vegeta-



 18    tion.  There will be a  temporary displacement of verte-



 19    brate species—deer, rabbits,  this type of  thing.   There



 20    will be some mortality, of course, of some  of the less
21
      mobile  species,  the small mammals,  and so forth.   A lot of
9°
       these  species will reestablish themselves following reve-



       getation pretty quickly,  so there should not be a signi-


24
       ficant problem there.



25                Particular attention should be paid to planning
                            4-51

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                                                           28





 1     construction activities in and around the Mississippi River




 2     floodplain area to minimize disruption of migratory water-




 3     fowl.   That is a major area for migrating waterfowl, and




 4     some very simple,  yet effective techniques like avoiding key




 5     periods when the waterfowl are there can minimize those




 6     types of impacts.




 7               The  aquatic productivity  also could be adversely




 8     affected in localized areas,  but the effect should be tem-




 9     porary  and insignificant.




10               The  overall long-term effect is expected to be




11     positive as the water quality improves in the planning area.




12               Construction-related impacts to wetlands and flood




!3     plains  will occur  primarily from interceptor line construc-




14     tion.   Any land-disturbing activities in these types of




15     areas must have a  detailed plan to  minimize disturbance to




16     floodplains and any existing  wetlands.   The Fish and Wild-




17     life Service gets  involved in this  and a number of other re-




18     source  agencies,  so the mitigation  should be adequate to




19     satisfy them.   If  it  is, then the impact should be minimal.




20               The  potential also  exists for some secondary im-




21     pacts to wetlands,  which could occur from future development




22     that might be  encouraged as a result of the better waste-




23     water treatment in the area.   Again,  this gets into the area




24     of local land-use  controls and land-use ordinances, dis-




25     couraging development of floodplains for obvious reasons,





                            4-52

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                                                            29






 l    the HUD regs., and so  forth.




 2              I have combined  land-use and demography into one.




 3    Significant land-use and demographic changes  are  really not




      expected to occur solely from the impleitienta-tion  of  any of




 5    the action alternatives.   It is possible  that some current




 6    and future land uses could be affected to an  unknown extent




      by the provision of upgraded treatment facilities (or aban-




 8    doning STPs.)




 9              Prime farmlands, since only a very  minimal addi-




 10    tional acreage, I think about 10 acres in the case of the




      Duckett Creek plant, will be rquired for  expansion,  im-




 12    pacts on farmland should be minimal.  However, construction




 13    of the interceptor lines could, in some locations, inter-




 14    rupt parts of agriculture operations during the construction




 15              The next four categories I have lumped  again,




 16    economics, public services, transportation, and energy.




      Construction activities would benefit the local economy to




      some degree through creating a limited number of  construc-




 19    tion-related jobs, short-term jobs, and it would  be  the




 20    normal purchasing of equipment and materials  that could




 21     benefit the local economy.




 22               Disruption to public services should be minor,




 23     and of relatively short duration.  There  is likely,  however,




      to be some increase^ in  localized traffic,  which is going to




25     lead to some localized traffic congestion and some incon-





                            4-53

-------
                                                            30
  1     eniences  to  people  that  use  the  affected  roadways.   This




  2     will  continue  throughout the construction phase,  along those




  3     roadways  that  are affected.




  4               There would  be some temporary increases in demand




  5     for local energy resources,  ostensibly  here  I'm talking




  6     about gasoline and  fuel  oil.   The  overall energy supply,




  7     though, is not expected  to be affected  during the construc-




  8     tion  or operation phase.




  9               In terms  of  cultural resources, which have a great




 10     deal  of legislative authority behind  them, there was a de-




 ll     tailed archeological survey  done of all the  proposed inter-




 12     ceptor line corridors  and the plant sites.   No known cul-




 13     ture  resources are  expected  to be  affected by expansion of




 I4     the existing STPs,  per se.   However,  there were,  I believe,




 16     four  sites located,  i.e., archeological sites.  They were




 16     located in or  very  near  one  or more of  the proposed inter-




 17     ceptor line corridors.   If the sites  cannot  be avoided, ther




 18     further testing would  be required, by law, to determine




 I9     their eligibility for  nomination to the National Register




 20     of Historic Places,  and  if the testing  indicates that they




 21     are eligible,  then  further mitigation would  have to be look-




 22     ed into.   It may include data recovery, working with the




23     State Historic Preservation  Officer,  that kind of thing.  I:




24     that was  done, then the  impacts  would be  minimal.




25               Last, but certainly not  the least of concern, is






                           4-54

-------
                                                            31
 1    the fiscal-related  impacts.   I would  call  your attention




 2    to the last two  tables  in  the handout,  Tables 2-17 and 4-3.




 3    The implementation  of the  recommended alternative is not




 4    expected to impose  a significant  burden on residents in




 5    the service areas.  If  you look at  Table 2-17,  really what's




 6    shown here is  a  breakdown  by  user jurisdiction.of the annual




 7    user charges for the current  year and for  the year 2000.




 8              And  the following table,  which may be a little




 9    more revealing,  compares or presents  the annual user charges




10    as a percentage  of  median  household income,  which is the




11    far right column.   And  you can see  there that it ranges




12    from a low of  .02 percent  for St. Peter's  to a high of over




!3    3 percent for  the floodplain  communities.   The latter was




14    judged cost prohibitive, as I mentioned earlier, and that




15    particular centralized  treatment  for  that  area was deemed




16    not implementable.




17              The  last  point I wanted to  make  was in connection




18    with mitigation  of  impacts.   As indicated, there will be




19    some adverse impacts associated with  the proposed plan.




20    However, in order to receive  Federal  monies, adequate miti-




21    gation measures  must be included  in the constructions plans




22    and specifications, which  are reviewed  by  the State, and a




23    number of other  entities.   If properly  designed and imple-




24    mented, and these measures would  include design, legal mea-




25    sures and planning-related considerations, they should sig-





                            4-55

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                                                              32




 l    nificantly reduce the adverse  impacts  from  the  project.




 2    For those of you that are  interested,  I won't go  through the




 3    detailed listing, but in the EIS there were  specific miti-




 4    gation measures identified that could  be  adopted  to mitigate




      adverse impacts in the various resource areas.  I think




      that's on Page 4-31.




                This concludes my remarks.




 8              HEARING OFFICER  JOHNSON:  Thank you,  Mr. White-




 9    night.




10  .            We will now open the floor to persons wishing to




      make comments or statements.   I have received cards, and




12     there are at least two persons who  indicated they would like




13     to be heard, and we will take  them  alphabetically.  Mr.




14     Richard E. Bone, and Mr. Bone, would you  mind going up




15     to the mike so we could all hear you.




16               Mr. Bone, let me get some preliminaries.  You




17     live at 16 Knight Lane, 0"Fallen, Missouri?




18               MR. BONE:  That's correct.




19               HEARING OFFICER  JOHNSON:  And you don't represent




20     any organization, you're just  a citizen?




21               MR. BONE:  I'm just  a citizen,  yes.




22               HEARING OFFICER  JOHNSONS  The floor is  yours.




23               MR. BONE:  Thank you.  During your presentation
24
I noted several questions, and the first question I had is,
25     what percentage of  overflow is  there  into groundwater and





                          ,,  4-56
                                                                   H-1

-------
                                                           33





 1     local streams dur to insufficient water treatment facil-




 2     ities available?  Has that type of an impact been noted




 3     during your investigation?




 4               MR. WHITENIGHT:  The impact has been noted, but




 5     I couldn't give you percentage of overflow.  I'm trying to




 6     recall, I think there was a statistic in the facility plan




 7     that estimated the number of failing septic tanks, and I




 8     don't recall that statistic.  I think we had estimated about




 9     5,000 individual on-site treatment systems within the plan-




10     ning area.  I can't tell you the percentage of failing sys-




11     terns.




12               MR. BONE:  My next question was, how often do on-




13     site failures occur, and what are the results of these fail-




14     ures?  As far as the sewage treatment plant is concerned?




15               MR. WHITENIGHT:  They occur more frequently during




16     high rainfall events, obviously.  Where the soils are inade-




17     quate to begin with, the failing could continue indefinitely




18     The effects from that are either untreated or partially




19     treated sewage elevating itself to the top, and either run-




20     ning out horizontally over the surface of the ground, or




21     conceivably getting into the groundwater system and percolat




22     ing out into the groundwater horizontally in a sub-surface




23     fashion.  The impacts can be highly localized or they can be




24     fairly far-reaching, depending on the volume of effluent




25     and the extent of treatment it's received before it got out





                           4-57
H-2

-------
                                                          34
 1     into  the  area.   There  is potential  for  significant adverse


 2     impacts,  particularly  if there  are  any  nearby water supplies


 3     in  the aquifers  in  that  area.   There  is potential  for contain


 4     ination of  the aquifers.


 5              MR. BONE:  It  was  also mentioned  that the sludge


 6     would be  applied  to  the  land.   How  is this  done,  is it
                                                                   H-3

 7     applied directly  to  the  surface of  the  land,  plowed under,


 8     or exactly  how is this done?


 9              MR. WHITENIGHT:  It's applied to  the surface.   I


1°     might give  that to my engineer  friend here  to give you a


11     thumbnail sketch, but it  would  be surface applied.   There


12     are a variety of  techniques, which  I  don't  know if they


13     have been finalized  yet  in the  sludge plan.


14              MR. HARBOUR:   There is different  techniques.   Some


15     of them are direct injection, which is  actually dirt below


16     ground.  Others are  applied and plowed  in as  the vehicle


17     goes along.  St.  Peter's, the City  of St. Peter's,  are ac-


18     tually doing land application at the  moment.   They weren't


19     at the time that we  did  the facility  plan,  but since that


20     time they have been.  And the City  of St. Charles  is also


21     now actively applying sludge to the land.   In the  case of


22     St. Peter's the sludge is aerobically digested and stabil-


23     ized before it is land-applied.  And  in the case of St.


24     Charles, I  think  it's lime-stabilized before  it's  land-appli


25     ed.  Ron, I don't know if you know  anything?



                          4-58

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                                                          35
 1              RON: I'm not sure about St. Charles.


 2              MR. WHITENIGHT: Before any  sludge  is  applied  to


 3    land and any areas except the extensive  testing and  monitor-


 4    ing that has to go along with land application  of  sludge,


 5    which is required by  the State  to maintain or insure that


 6    there isn't contamination of the groundwater. And  also,


 7    the sludge has got to be tested itself to make  sure  that


 8    there aren't any hazardous materials  or  harmful materials


 9    that are going to destroy the soil, in other words.


10              MR. BONE:   The impacts of the  construction, then,


11    the implementation of your proposed plan would  determine


12    the short-term, particularly in the environmental  impacts

                                                                   H-4

13    as far as the land use and the  farms  that were  impacted by
14
23
      the  new  lines  that  are  going  to have  to be added.   How long
15    do you  calculate  a  short-term?


16               MR.  WHITENIGHT:   For  purposes of the EIS,  short-


17    term  is defined as  the duration of  the construction  period


18    when  there would  be active land-disturbing activities going


19    on for  purposes of  interceptor  line construction or  treat-

on
     ment  plant expansion,


21               MR.  BONE:  This  is a  question that I had on my


22    own,  and  I wanted to bring this in  and hope we get an
      answer:   how are toxic waste products removed or treated
24     in the sewer treatment plants?  There is definitely an


25     awareness in the St.  Louis metropolitan area about a lot of




                            4-59
H-5

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                                                              36
 1     toxic wastes being dumped on the ground,  and it varies,  all


 2     different types of forms.  How is this really treated?


 3               MR.  BARBOUR:   In essence,  depending on what the


 4     toxic material is and the concentration,  but most cities and


 5     municipalities have got ordinances that prohibit the dumping


 6     of  toxic  wastes into the sewer system, with a series of


 7     fines to  stop  that.   Again,  depending on  how much or what


 8     the concentration,  or what the actual toxic is, some toxics


 9     would be  broken down in a treatment  plant,  whereas,  others


10     could actually cause major damage to the  treatment plant


11     and actually,  if it's a biological process, essentially


12     knock the process out,  and have some serious effects until


13     such time as that could be reestablished.   In the study


14     here,  most of  the area  consisted of  residential area. There


!5     are very  few major industrial facilities,  and the ones that


16     there are,  I think,  are fairly conscious  of the materials


17     they produce,  and the ordinances prohibiting them from dump-


18     ing into  the sewer system.


19               MR.  BONE:   My next question, and this is my last


20     question,  what will the government do for  those farms that


21     are interrupted and cannot produce actively during the

                                                                   H-e
22     construction period of  the interceptor lines?  Is there  some


23     kind of reimbursement for crop yield not  achieved?


24               MR.  LORENZ:  I think I can address that.  In most


28     cases as  a mitigative measure, we recommend that the com-



                             4-60

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                                                                37





 1    munity that is implementing a facility like this,  say  laying




 2    an interceptor line or something to that effect, that  they




 3    take into consideration the agricultural cycles that are




 4    taking place in their community and that they avoid such




 5    things when there are crops on the ground.  This means that




 6    there are several times during the year, from late fall to




 7    winter, early spring before planting, that ground disrup-




 8    tion can take place without interrupting agricultural  cycles




 9    Most of the time those pipes are set low enough below  the




 10    surface that they can go ahead and plant over them later on.




 11              MR. HARBOUR:  Another aspect I might mention is




 12    that if any sewer line is going to cross private property,




 13    farmland, or that invariably the municipality or sewer dis-




 14    trict has to obtain the easement to go across that land, and




 15    at which time there is usually some negotiation takes  place,




 16    in terms of either compensation, monetary or otherwise.




 17    It's not something that the State or Federal grant program




 18    will fund, but it's usually negotiated between the land-




 19    owner and the sewer district or municipality.




 20              MR. BONES:  All right, thank you.  That's all the




 21     questions I have.




 22               HEARING OFFICER JOHNSON:  Thank you, Mr. Bone.




 23     Next is Joe Nichols, and you represent the Duckett Creek




 24     Sewer District, 50 Daniel Boone Plaza, St. Charles, Missouri




25     is that correct?




                             4-61

-------
                                                          38





 1               MR,  NICHOLS:   Yes,  sir.   My name is Joe Nichols.



 2     I  am the  director  of  the Duckett Creek Sewer District.



 3     First of  all,  I'd  like  to thank Tom Lorenz for all his work



 4     on getting the environmental  report together and to the



 5     point that it  is now.   It is,  of course,  very important,



 6     and we realize that the environmental impact statement has    H-7



 7     to be along with and  as a part of  the facility,  201 facilit-



 8     ies plan.   We  appreciate all  of his work  in regard to that,



 9               We want  our projects,  speaking  now for Duckett



      Creek Sewer District, we want our  projects to be environ-



11     mentally  sound.



12               Tonight  I would like to  raise another  issue, and



13     that is,  the importance of getting the EIS,  the  environmen-



      tal impact statement, approved,  and getting on with the



15     completion of  the  improvements.  Mr.  Smith and I just got



16     back from Jefferson City this afternoon,  and we  are listed



17     as fourth on the State  grants fundable list.   We feel that



18     this is our only opportunity,  due  to the  cutback in Federal

                                                                   H~8


19     funds,  of getting  Federal funds to help correct  our sewer


90
m     problems.



21               St.  Charles County  is one of the fastest growing



22     counties  in the entire  nation.   There are problems with



23     sewers in St.  Charles County,  and  we need Federal funds to



24     do that.   We feel  that  this is our opportunity,  we are high



25     on the list, we are eligible  for funding, and we want to




                             4-62

-------
                                                              39
      take  advantage of that.



 2               The people of  the sewer district recognize this



 3     fact,  and  they passed a  six-and-a-half million dollar bond



 4     issue  overwhelmingly this past year.   It was 78 percent



 5     of  those people who  voted there were  in favor of the bond



 6     issue.


 7 '
                In  order to take advantage,  we must be ready to



 8     proceed by October 1, which is the start of the Federal bud-



 9     get year.   That's when the Federal government tells the State;



10     of  Missouri how much funds they are going to have available



      and if we  are not ready,  then,  of course, we will be dropped



12     from  the list.   We are,  in anticipation of this, starting
13
     design on June  1,  so  that  our  plans  will  be ready by the
14    deadline, which  is  January  31.   We  are  not going to wait and




15    see  if Federal funds  are  in effect,  available.   We feel con-




16    fident that  they will be, and we feel that we must proceed




17    now  in order to  get the designs  completed  within that time




18    limit.



19
               If we  are denied  this  funding for any reason, the




20    effect, we feel,  on the environment will be far worse in




     the  polluted creeks and the health  hazards that will result



22
     than the impact  of  the improvements that we are proposing,


no

     or that are  being proposed  to be constructed as part of this




24    plan.


25
               We ask that the environmental impact  statement be
                               4-63
H-8

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                                                               40




 l    approved prior to October  1,  1985.  We  feel  the  time  has




 2    come to quit studying and  to  start constructing  these much-




 3    needed improvements.  Thank you very much.




 4              HEARING OFFICER  JOHNSON:  Thank you, Mr. Nichols.




 5    I have two cards here that it's not indicated if  they want




 6    make a statement or not.   I'll just ask you, and  let  me  know




 7    Who is Dick Berber?




 8              MR. HERBER:  I don't have anything.




 9              HEARING OFFICER  JOHNSON:  Thank you.  And Armin




10    Gronefeld?




11               MR. GRONEFELD:  No, I just came here to see what's




12     going on.




13               HEARING OFFICER JOHNSON:  Thank you, Mr. Grone-




14     feld.  Does anybody else want to make a comment?




15               Before we close, then,  I'd like to mention  again




16     that the comment period does not close until May  20,  which




17     is 11 days, and any written comment should be sent to the




18     attention  of Edward Vest, Chief Environmental Impact  Sec-




19     tion, 726  Minnesota Avenue, Kansas City, Kansas 66101.




20     And if you need that address more clearly I can give  it  to




21     you as soon as we close.




22               Thank you for coming, and I declare this hearing




23     adjourned.




24               (Whereupon, at 8:05 o'clock p.m., the hearing  in




25          the above-entitled matter was closed.)
                             4-64
H-8

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                   CERTIFICATE




       I hereby certify that this is the transcript of


the proceedings held in the following matter:




       Before:.  Kent Johnson
       TJtle: Environmental  Impact Statement  Proposed
              TSasTewaTer' ~Tre"a"tWtTt~I^TrrtTe"s  for Eastern
              St. Charlee  Count/, MO
        Case No.
       Date:   Ma-'  9j
       Place:    St.  Charles,  MO
and that this is a full and correct  transcript of the

above referenced proceedings to  the  best.of my knowledge


and belief.




                                   (Reporter)




                             Eernlce W. .T2ckson Reporting  Co,


                             Kansas  City, Missouri  6^310


                            (816-523-3030)
                        4-65

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     Responses


H-l. An  overall  percentage  of overflow  volume which  enters groundwater  or

     surface water  from insufficient wastewater  treatment facilities  in  the

     planning area has not been estimated; however,  overflows  or  bypasses have

     been documented at  the  Missour River STP and Mississippi River STP.  The
     status of existing  flow and  BOD capacities as well  as NPDES permit com-

     pliance for each major STP is as follows:


     • Duckett Creek Plant -  plant is  operating  at 54% of flow capacity  and
       50% of BOD  capacity;  plant effluent does not consistently meet BOD  and
       TSS permit limits.

     » Harvester-Derdenne Plant -  plant is  operating  at 80% flow capacity  and
       78% BOD capacity; plant effluent does not consistently meet BOD and  TSS
       limits.

     * South Plant - plant is operating near flow capacity; no compliance data
       available.

     • Boschertown Lagoon  -  no flow meters available,  effluent  does not con-
       sistently meet BOD and TSS permit limits.  NPDES permit requires lagoon
       to be abandoned within 90 days after a trunk sewer is available.

     • Mississippi River Plant  -  plant  is operating at 75% flow capacity  and
       49% BOD  capacity;  plant consistently meets effluent limitations except
       for fecal  coliforms.   There are times when  a  portion  (unestimated) of
       the  flow bypasses  secondary treatment because  of  excessive flows  and
       mud infiltration.

     • Missouri River Plant - plant is  operating at 106% flow capacity, making
       it  necessary to bypass  raw sewage to the Missouri River at the Adams
       Street pumping station  (frequency of bypasses not estimated).

     • St. Charles Trails  Plant -  plant is operating at 34% flow capacity and
       does not  consistently meet effluent BOD and TSS permit limits.  Plant
       must  be  abandoned within  90  days after  a  trunk  sewer  is  available.

     • Heatherbrook Lagoon  -   lagoon   is  operating  at  39%  flow  capacity,
       although  effluent BOD,  TSS and pH permit limits  are  not consistently
       met.   The lagoon must be abaondoned within  90 days after a trunk sewer
       is available.

     • Spencer  Creek Plant - plant  is  operating at  57%  of  flow capacity and
       51%  of BOD  capacity.   The  effluent  does  not  consistently meet  permit
       limits  for  TSS,  but  does  meet BOD  limits.   Major  operational pro-
       blems  have  been  reported  during  excessive rainfall  events.    Inflow
       of  runoff  into  sewer  manholes  has  caused  major  increases in  waste-
                                     4-66

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       water flows during  storms.   Also during rainfall events, effluent  has
       had difficulty  in  flowing by  gravity to the receiving  stream  because
       the stream  level  during heavy  rains  is higher than the effluent  dis-
       charge  point  which  requires   the effluent  flow  to  be  temporarily
       diverted to the sludge holding  pond.
     • Portage Community Septic Tank - flow is not monitored,  but is estimated
       to be  about 62% of capacity.   The effluent consistently violates  BOD
       and TSS permit limitations.

With regard  to  the onsite wastewater treatment systems  in  the planning area,
most of  the  estimated 5,000 onsite systems  are either  septic tanks with soil
absorption  systems  or aerated  tanks  with  surface  discharges.   Many  (not
quantified)  of these  systems were observed to be  failing,  as evidenced  by
surface  discharges  of partially  treated effluent; however,  the  frequency of
failure  has  not been determined.   In general, the onsite systems appear to be
poorly maintained.   Septic tanks  are  usually not pumped until they have over-
flowed   and  backed  up.   The  facilities  planner  (Sverdrup  &  Parcel  and
Asssociates,  Inc.)  identified numerous  specific  problem areas  where  on-site
systems  were  observed as  failing; these areas were illustrated on Figure 2-3,
page 2-23 of the Draft EIS.

     The primary  environmental effects from onsite systems have been noted in
the  Draft EIS  and  include potential  degradation of either  surface water or
groundwater  quality.   Although each  failing  onsite  system generally contri-
butes  only  small quantities of contaminants  to ground  or surface waters, the
total  flow of  partially  treated onsite  system effluent in the planning area
was  calculated in the facilities plan  to be  approximately  0.5 mgd, based on a
50%  failure rate, i.e., 2,500 failing  onsite  systems.  (Although several local
officials claim that  nearly 100%  of  the onsite  systems  are failing in some
manner,  a 50%  failure rate was  chosen as a more  conservative estimate, based
on field observations.)   Many of  the  interior streams  in the planning area
already  have poor  water  quality.  The addition  of  partially treated onsite
system effluent,  either as continuous  discharge  or as  non-point source runoff
following rainfall events, would contribute  to the already poor water quality
caused by  urban  runoff,   sewer overflows or  bypasses,  and point-source dis-
charges.  Surface and groundwater contamination  increases the potential  for
public  health  hazards from contact  with,  or ingestion of,  water  containing
harmful  bacteria and other pathogens.
                                     4-67

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     The severity of  the  failing  onsite system problem centers on  the  poten-
tial public health hazard issue.   Some problems exist in the  floodplain  devel-
opments  due  to  the potential  for contamination  of private  drinking  water
systems  by onsite  system effluents.   A significant  problem occurs  in  the
densely populated, unsewered  developments in  the upland portions  of the plan-
ning area.  Surface discharge of  onsite system effluent onto lawns, pastures,
or vacant  lots,  or  into roadside  ditches or creek beds, is common practice in
many parts of  the planning area.   Contact with these bacteria-laden waters by
pets,  domestic  livestock, or  children creates a potential  health  hazard  for
area  residents.    In  addition,  many  areas  have  formally  developed  common
effluent collection pipes  to  transport the  effluent from  failing  onsite sys-
tems to  vacant  lots  or  small creeks.  This practice  increases  the concentra-
tion at  point  of discharge and can cause further water quality degradation in
streams  now  classified  as effluent-limited.  Another,  more  localized  problem
occurs in  those  areas with sinkholes and other characteristics of karst topo-
graphy.   Discharge  of  onsite system  effluent  into  sinkholes  may  result in
groundwater contamination  and a potential public health hazard if the  aquifer
is  a  source  of  potable  water.   Following  rehabilitation or elimination of
these  failing  onsite  systems,  combined with better  technical  guidance  in
siting and operating onsite  systems,  the adverse  impacts from these  systems
should be  reduced significantly.

H-2. See response to H-l above.

H-3. For  the  purposes  of  this EIS,  land application  is  differentiated from
     landfill disposal by the fact that land application is a surface disposal
     method whereas  landfill  is  a burial technique.  Land application usually
     utilizes  stabilized  sludge as a soil conditioner.  Liquid sludge, sludge
     cake, or  dried sludge can be applied and, normally,  the sludge is tilled
     into  the  soil  after application.  Land application is a relatively inex-
     pensive  method  of   disposal  if  suitable  sites  are  available  and,
     especially,  if  liquid   sludge  applications are  used,  thus  eliminating
     costs of dewatering and  related treatment.
                                    4-68

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H-4. For purposes of this EIS, short-term impacts are defined as those impacts
     which would occur during the construction period when active land distur-
     bing activities are  taking place.   Long-term impacts (e.g., land use and
     population charges) will occur following the construction phase and could
     continue throughout the 20-year planning period.

H-5. Toxic wastes  entering  a municipal treatment system can be very problema-
     tical; however, the  best policy is to implement and enforce local indus-
     trial  pretreatment ordinances  that  strictly  prohibit the  discharge of
     toxic  wastes  into public  sewers systems and that place  limits on other
     industrial wastes  that can be discharged into a publicly-owned treatment
     facility.   However,  if toxic materials  do enter a  municipal treatment
     system,  depending  on the quantity, type, and concentrations of the toxic
     constituents,  selected  toxics  can be broken  down  in  the plant while
     others  could  cause  a  serious  plant  upset especially  if  the facility
     relies on biological processes for treatment.  Since the predominant  land
     use in the planning area is agricultural  in nature, very few major indus-
     trial  discharges  exist  and  those that do, have  a  good discharge record
     and/or are regulated by industrial pretreatment ordinances.

H-6. In most  cases as a mitigation measure,  EPA recommends that the grantee,
     during  the scheduling  of  facility construction,  take into consideration
     the agricultural  planting/harvesting  cycles in their respective communi-
     ties  in  order to avoid  or minimize  interruption of normal farming prac-
     tices.   Also  following facility  construction (e.g., laying an  interceptor
     line),  farming activities  generally can  resume in the immediate vicinity
     of  the  line  without   any  adverse problems.   Also,  if  any  sewer  line
     crosses  private  property,  the  grantee nearly  always  must  obtain an
     easement to allow  traversing  the property.  At  this time some  negotiation
     usually  occurs in terms of  compensation, monetary or otherwise,  between
     the landowner and  the  sewer district  or  municipality.

H-7. Comment  noted.

H-8. Comment  noted.
                                     4-69

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                        APPENDIX A



                    KEY CORRESPONDENCE




(Status of Missouri River Levee System,  Unit L-15 Project)
                         A-l

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US Army Corps
of Engineers
Kansas City District
Missouri  River  Levee  System
Unit L-15
A
                                 General Information

    Construction of Levee Unit L-15 was authorized in the Flood Control Act of 1944. The levee unit was
further studied in the early 1970's. The project was classified inactive after the study because there was
strong opposition to future development that could occur with 100-year protection, and because the risk of
catastrophic failure associated with lower levels of protection was considered unacceptable. Local interest
in flood protection rekindled in 1983-84. In response to local interest in flood protection, Congress included
$250,000 in the Corps of Engineers budget for Fiscal Year (FY) 1985 to review the feasibility of the L-15
project and to determine nonFederal cost sharing requirements. A notice of study initiation and a field trip
to St. Charles County began the study in October 1984. The remainder of this status report summarizes the
study progress since October 1984.

                                   Completed Work

Work that has been accomplished since October 1984 includes:

      1.  Dissemination of a notice of study initiation to Federal, State, and local governmental agencies
        and to the public.

     2.  Completion of a survey of the top elevation of existing agricultural levees along the Missouri and
        Mississippi Rivers.

     3.  Completion of basic hydrologic and hydraulic investigations.

     4.  Initiation of basic social, cultural, environmental and economic investigations.

     5.  Formulation of several study alternatives.

                           Schedule for Remaining Work

    The current schedule for the study effort calls for the economic evaluation of alternatives, including a
determination of nonFederal cost sharing requirements for any feasible alternatives to be completed by the
late fall of 1985.

                         Alternatives under Consideration
Three alternatives are currently being evaluated. These are:

      •  A levee on an alignment submitted by landowners in St. Charles County that were responsible
         for initiation of this study.

      •  A levee that would follow the adopted floodway along the Missouri River and the "No Signifi-
         cant Effect" floodway boundary along the Mississippi River.  A floodway boundary for the
         Mississippi River portion of the project area has not been adopted at this time. The "No Signifi-
         cant Effect" floodway is being used in this study in order to be responsive to  the interests of
         Illinois residents regarding increasing flood elevations. Its use in this study is not an indication
         that it is approved or adopted by any Federal, State or local agency.

      •  Ring levees around improvements in the floodplain.
The enclosed map shows the levee alignments that are being evaluated.
                                     A-2

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     DEPARTMENT OF THE ARMY
KANSAS CITY DISTRICT, CORPS OF ENGINEERS
         700 FEDERAL BUILDING
         601 EAST 12TH STREET
      BULK RATE     I
  POSTAGE & FEES PAID  '
DEPARTMENT OF THE ARMYj
                  	                                                                   PERMIT Nc. 6-5    f
     KANSAS CITY. MISSOURI 64106-2896                                                        '	'

           OFFICIAL BUSINESS
      PENALTY FOR PRIVATE USE, $300
               MRKPO-A-25-1
                        Response from the Notice of Study  Initiation
         Response from the notice of study initiation was quite heavy indicating a high level of interest in the
     project. The Corps received about 500 cards and letters. Comments were about evenly divided between sup-
     port and opposition to levee construction. Basically, persons residing east  of the Mississippi River
     expressed opposition to levee construction and Missouri residents were nearly unanimous in support of
     levee construction. A petition bearing 2,445 signatures in support of levee construction was also received in
     addition to the cards and letters.
         Common reasons cited for opposition to levee construction were:

           1. Levee construction would increase flood heights on the Illinois side of the Mississippi River.
           2. Additional commercial and industrial development would be attracted to the area changing the
             land  use'from agricultural to urban.  This  would  introduce competition to commercialized
             communities across the Mississippi in the minds of some commentators while others suggested
             that an urban area across the river would be less esthetically pleasing.

         Both Missouri and Illinois residents appear to agree that the area would be best served by protecting
     the agricultural character of the area without additional industrialization.
                                        Address Corrections
         Please review your mailing label on this report and advise us of your correct name and/or address if
     there is an error (please print or type). Mail your name/address corrections to:
                               Kansas City District
                               Corps of Engineers
                               Attn: MRKPD-A
                               700 Federal Building
                               Kansas City, Missouri 64106-2896
                                                   A-4

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 THE KANSAS CITY DISTRICT, CORPS OF ENGINEERS
    CORDIALLY INVITES YOU TO ATTEND A

Public Workshop

       Meeting

        CONCERNING
MISSOURI RIVER LEVEE UNIT L-15
          To be Held at

 The Orchard Farm High School
         July 2, 1985
          7:30 P.M.
   MEETING LOCATION
   ORCHARD FARM
   HIGH SCHOOL
           US Army Corps
           of Engineers
           Kansas City District


             A-5

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    AWUV 3H1 JO INlWiUVdaa
           MISSOURI RIVER LEVEE SYSTEM
                               UNIT L-15
         The L-15 study area consists of the combined Missouri River and Mississippi
     River flood piains from St. Charles, Missouri downstream to the Mississippi River
     and from just upstream of Portage des Sioux downstream to the Missouri River.
         The Kansas City District, Corps of Engineers published an announcement in
     October 1984 concerning the initiation of the L-15 study. A Study Status report
     was published in May 1985. This meeting  is being held to allow the  interested
     public an opportunity to comment on any aspect of the study.
         You are invited to express your interest and to become involved in the study
     at this meeting.
         Please circulate this notice to any other persons whom you believe may have
     an interest in this study.
         If you need additional information about this meeting please contact Mr. Don
     Hammond, Study Manager, at 816-374-3062 or write to the following address:

                      Department of the Army
                      Kansas City District, Corps of Engineers
                      Attn: MRKPD-A
                      700 Federal Building
                      Kansas City, Missouri  64106-2896
                                      A-6

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                              Missouri  River  Levee  System
US Army Con*            UlHt H5
                              studv  uPdate
                                                                              September 1985
    On July 2,1985, staff from the Kansas City District Corps of Engineers attended a meeting with per-
sons interested in the future of Missouri River Levee Unit L-15. The meeting was held at the Orchard Farm
School in St. Charles County, Missouri, because the school is in the study area.

    The primary purpose of the meeting was to provide an opportunity for persons interested in the future
of the project to express concerns related to the need for the project and its effects. The concerns expressed
at the meeting will help Corps of Engineers staff continue planning the project. The expressions of people
from the project area are necessary to be sure that the study will adequately consider all the aspects of the
project that are important to the people of the area, and not unnecessarily devote study resources to unim-
portant issues. The process of determining the important issues is called scoping.

    The people of the project area and the Corps of Engineers are not the only groups involved in scoping.
State and local governments and other Federal agencies may also be aware of issues that should properly be
addressed in the study. However, the process for obtaining the expressions of these other study par-
ticipants is more structured and does not usually require a meeting devoted to obtaining those expressions.

    As explained at the July 2 meeting, study of the L-15 project is still in the initial stage. The determin-
ing factor in whether or not the study moves beyond the initial phase is an economic analysis the Corps will
complete later this year. That analysis will not include all  the costs, nor will it include highly  refined
estimates of the benefits of the project. Rather, it will compare an estimate of the construction cost of the
levee to the benefits that might be obtained from a 25-year level of protection for the project area.  Should
that analysis show that potential benefits do not exceed even the basic construction cost, detailed study
would not be productive and the study would be terminated. However, should the project show indications
of potential economic feasibility, the next step would be to start more detailed analysis.

    The following are brief descriptions of the concerns expressed at the July 2 meeting, together with the
Corps assessment of how those concerns may or may not relate to the scope of the L-15 study. Refining the
scope of a study is an ongoing process that reflects information as  it becomes available and conclusions as
they are reached.

Mississippi River induced flooding: The  concern most widely held and most frequently reiterated at
the meeting was for those flood damages that would occur in Illinois as a result of excluding flood waters
from the L-15 area. This concern includes property damage at Elsah, Grafton, and Alton, Illinois, interrup-
tion of use of the Great River Road, and impacts on the development of a tourist economy in Illinois.

    The Kansas City District agrees that induced flooding effects are an integral part of the L-15 study.
Before levee construction would be recommended, the amount of induced flooding would be identified.
When induced flooding produces appreciable increased flood damages, the increase in damages for the proj-
ect life is estimated and included in tallying the benefits and costs  of the project. However, the L-15 study
has already focused on a 25-year level of protection which causes an insignificant increase in 100-year flood
heights on the Mississippi River (one tenth of one foot). For so small an increase in flood height, it will not
be possible to estimate a value for induced flooding. Should the L-15 study expand  to other alternatives
that produce induced flooding for which increased damages could be estimated, that would represent a
change in the scope of the study and the Corps would estimate the damages in  that case.

Induced flooding on the Missouri River: Some areas of St. Louis County would likely experience in-
creased flood heights caused by excluding the L-15 area from the Missouri River flood plain. For a 100-year
flood on the Missouri River, the stage at some locations would be increased between 1 and 2 feet if the L-15

                                           A-7

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levee were in place to provide a 25-year level of protection. People at the July 2 meeting expressed concern
for increased flood damages in these areas and noted some areas of particular concern. The L-15 study
would identify the areas affected by induced flooding and estimate the value of the increased flood damages
for the life of the project.

Urban development of the L-15 area: At the meeting, individuals from the project area and from
Illinois expressed their determination to preserve the agricultural character of the L-15 area. Some in-
dividuals expressed concern that reducing the flood threat in the area by levee construction would provide
an incentive for investors to convert the protected area to other uses. Others expressed concern for the
displacement of wildlife by development.

    The Kansas City District acknowledges that levee construction as a general concept might affect land
use in the project area. However, decisions on the best use of private land are traditionally made by state
and local governments. The Corps of Engineers has no authority to direct private land use, although it does
have a responsibility under Executive Order 11988 to discourage unwise development of areas that are ex-
pected to be flooded more often than once in 100 years, on the average. Through zoning by St. Charles
County as part of its participation in the National Flood Insurance Program, land use in the L-15 area can
be controlled. If the L-15 25-year levee is to be recommended for construction by the Corps of Engineers,
land use controls will have to be in place to assure preservation of the agricultural character of the area for
the foreseeable future.

Sediment accumulating in the river channels will cause more induced  flooding in the
future or create the need  to raise  the L-15 Levee: Several individuals at the meeting expressed
concern for the effects of sediment accumulation on flooding. They  suggested that, after several years, the
levee would be less effective than it was designed to be because of sediment accumulated in the river channel.

    The Kansas City District agrees that future effects of the proposed levee should be fully considered
before deciding whether or not to recommend construction. The Corps of Engineers has a prior interest in
sediment movement in both the Missouri and Mississippi Rivers because the Corps has the responsibility
of maintaining commercial navigation on both. Information already available on sedimentation near the
L-15 area could be used to project the effects of sediment on the effectiveness of the levee design. The exist-
ing information indicates that the bed elevation of the river channels has not risen significantly in the past.

Corps estimates of  induced flooding or induced  flood damages will be understated be*
cause floods have been observed to be higher and more frequent than the Corps analyses
indicate: Some individuals stated that floods to which the Corps assigns an infrequent recurrence interval
appear to be occurring more often than the recurrence interval would indicate. One individual summarized
this concern by asking how often to expect a 25-year flood.

    The Kansas City District recognizes that hydraulic and hydrologic analyses of the Missouri and Missis-
sippi Rivers are within the scope of the L-15 study. These analyses for the lower Missouri River are per-
formed by the Kansas City District, and, for the Mississippi River  in the L-15 area, they are performed by
the St. Louis District. The analyses are based on historic flood records and observed conditions which are
used as a guide to estimate future conditions. The estimate of future conditions relies on the quality of the
historic records. Fortunately, the records of both the Missouri and Mississippi Rivers are some of the most
complete in the United States. The hydraulic and hydrologic analyses can only assume the rivers will
behave in the future as they behaved in the past. These estimates are not infallible. They are, however, the
best available tools to answer critical questions about the future flood threat to the L-15 area and nearby locations.

Over several decades, human activities on the rivers have caused impacts which accumu-
late from activity to activity and  from year to year. The  L-15 Levee should not be built
because it could be the one project that shifts a critical balance and triggers catastrophic
consequences all along the river system: The concept of cumulative impacts  was mentioned by
several individuals at the meeting, sometimes with respect to water pollution, sometimes with respect to
sediment, and sometimes with respect to other Corps of Engineers projects including Lock and Dam No. 26.
                                               A-8

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    The scope of the L-15 study would include examination of the possibility that levee construction could
 have cumulative effects. This examination would determine the expected effects of adding the L-15 project
 to the existing set of conditions including the combined effects of all other human activities. However, only
 the changes brought about by construction of the L-15 project would be considered in deciding whether or
 not to recommend construction. A comprehensive study of all human activity affecting the Missouri and
 Mississippi Rivers since the river basins were first settled would not be an appropriate part of the L-15 study.

 The new Lock and Dam No. 26 will change the  Mississippi River to the extent that
 adverse effects of the L-15 Levee will be worsened: At the July 2 meeting, only the Kansas City
 District of the Corps of Engineers  was represented. Lock and Dam No. 26 is a project of the St. Louis
 District. The Kansas City District requested at the meeting that statements be confined to the L-15 topic
 and the participants cooperated for the most part. Nevertheless, it was apparent that many of the same per-
 sons who were concerned about L-15 were also concerned about Lock and Dam No. 26 which adjoins the
 L-15 project area.

    Effects of the new lock and dam on the L-15 project would be considered in formulating the L-15 project
 and any effects of L-15 on the lock and dam would be considered in deciding whether or not to recommend
 levee construction. The St. Louis District has the responsibility for determining the effects of Lock and
 Dam No. 26 on the Mississippi River and for any decisions on the future of the lock and dam project. The
 Kansas City District has. the responsibility for the L-15 project. Study of, or recommendations on,  the
 future of Lock and Dam No. 26 are not within the scope of the L-15 study. However, the L-15 study will be
coordinated with the St. Louis District to assure all project effects are identified.
    The Kansas City District appreciates the public participation in the July 2 meeting. The study of a
project such as L-15 is more effective and orderly when all major concerns surface early in the study pro-
cess. In this regard, you are encouraged to make this publication available to anyone interested in the L-15
project and to make your concerns known to the Kansas City District. As stated above, developing the
scope of a study is an ongoing process.

    We do not plan any  widespread communications similar to  this one until later this year when the
preliminary economic analysis indicates whether the study should proceed to the next phase. Until then, we
at the Kansas City District will be available to answer questions related to the L-15 project. You may send
your questions or comments to the address below or you may phone the study manager, Don Hammond,
(816) 374-3062.
                                                  A-9

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US Army Corps
of Engineers
Kansas City District
Missouri  River  Levee  System
Unit L-15
Study  Update
                                                                             December 1985
  Construction of Levee Unit L-15 was authorized
in the Flood Control Act of 1944. After study in the
early 1970's, the project was classified inactive
because there was no feasible solution.
  Because  of flood problems  in  1982 and 1983,
substantial renewed interest developed for a 25- to
50-year level of flood protection. Congress included
$250.000 in the Corps of Engineers budget for
Fiscal Year (FY) 1985 to review the feasibility of the
L-15 project and to determine non-Federal cost shar-
ing requirements. Congress appropriated $210,000
to continue study in FY 1986.
  The Kansas City District began the study in Oc-
tober 1984. Two levee alignments were evaluated.
One alignment would follow existing private levees
through the area (see  map) and would protect an
estimated 29,000 agricultural acres.  The  second
alignment  would  follow  the adopted  floodway
boundary along  the Missouri  River and the "No
Significant  Effect" floodway boundary along the
Mississippi River and  would protect an estimated
24,000 agricultural acres. (A floodway boundary for
the Mississippi River portion of the project area has
not been adopted.) In October 1985, the Kansas City
District  completed  its  preliminary  economic
analysis of  the alternatives at October 1985 price
levels and 8%-percent interest. The results are:

Landowner's Alignment:
              (25-year protection)
Total Cost
  25% non-Federal cost
  35% non-Federal cost
Benefits
Annual Cost
Benefit-Cost Ratio
Net Benefits

Floodway Alignment
              (25-year protection)
Total Cost
25% non-Federal Cost
35% non-Federal Cost
Benefits
Annual Cost
Benefit-Cost Ratio
Net Benefits
     $19,370,000
     $ 4,842,500
     $ 6,779,500

     $ 2,590.000
     $ 2,181,500
            1.19
        $408,500
     $
$18,255.000
$ 4,563.750
  6,389,250
$ 2,399,000
$ 2,060,200
       1.16
  $338,800
       A-10
  The results of the analysis were presented to the
St. Charles County Commission and landowners on
October 29, 1985. The St. Charles County Commis-
sion and landowners reviewed the information dur-
ing November and the St. Charles County Commis-
sion provided a letter of support for continued study
of the project on November 26, 1985.

           Study Requirements
  The study is being conducted in accordance with
the Economic and  Environmental  Principles and
Guidelines for Water and Related Land Resources
Implementation Studies published by the US Water
Resources Council, and appropriate Corps of Engi-
neers regulations. The Corps is required to evaluate
a wide  range of alternatives. Consequently,  the
number of alternatives evaluated in the initial phase
of the study is being expanded in two ways:  1) addi-
tional levels of protection above 25-year flood pro-
tection will be studied and documented, and  2) addi-
tional alignments will be evaluated. The expanded
alternatives are  discussed in more detail below.

        Higher Levels of Protection
  During the preliminary evaluation of the project.
the Corps limited its evaluation to the 25-year level
of flood protection on two levee alignments.  Higher
levels of protection were not evaluated because the
impacts associated  with  induced  flooding  that
would accompany protection at levels above  25-year
were expected to be unacceptable. To save time and
expense, the benefits and costs for higher levels of
protection were not calculated in the preliminary
analysis. The outlook for higher levels of protection
has not changed, but investigating these alter-
natives  in some additional detail is necessary to
have a complete evaluation.

          Additional Alignments
  Two additional levee alignments have been pro-
posed  for evaluation.  (See  map) These  are
designated alignments 3 and 4.
  Alignment 3 would follow the floodway alignment
downstream from St. Charles,  Missouri, along the
Missouri River and up the Mississippi River to the
Clark bridge.
  Alignment 4 would follow the floodway alignment
downstream from St. Charles,  Missouri, along the

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A-ll

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        Missouri River to about Missouri River mile 15. It
        would then cross land to the Mississippi River just
        downstream  from Portage des  Sioux and would
        again follow the floodway  alignment upstream
        along the Mississippi River.

         Modification of  Landowners' Alignment
          The   preliminary  economic   evaluation
        demonstrated that the levee alignment originally
        submitted by St. Charles County landowners was
        not economically justified. The Corps shortened the
        alignment by crossing to the Mississippi River far-
        ther upstream from the mouth of the Missouri River
        than the landowners originally  requested. The
        resulting levee alignment (see map) is about 5 miles
        shorter than the original landowners' alignment and
        is economically feasible.

                 The Array of Alternatives
          The following is the array of alternatives for more
        detailed study:
        •   No action,
        •   Levees that would provide protection from 25-,
            50-,  and  100-year floods on four alignments as
            shown on the enclosed map, and
        •   Construction of ring levees to protect develop-
            ment subject to flood damage -  the  nonstruc-
            tural plan.

                       Study Schedule
          The Kansas City District is continuing with the
        L-15 study based on the letter of support furnished
        by  the  St. Charles  County  Commission  on
        November 26, 1985.  The District plans to complete
        its evaluation of the alternatives during 1986 and to
        provide Federal, State and local government agen-
        cies and interested individuals with a draft report
and draft environmental statement for review and
comment early in  1987. After public  review,  the
Kansas  City  District  Engineer  would  decide
whether to recommend construction of any flood
control works for the study area in St. Charles Coun-
ty. A final report including the District Engineer's
recommendations  would be sent to higher head-
quarters in the fall of 1987 for approval: If  the
District Engineer recommends  construction of  a
project and-if  his  recommendation is approved by
higher headquarters, about 4 years of additional
detailed investigations would be  required before
construction could begin. Construction of the unit
would then be considered under the cost-sharing and
financing policy in effect at that  time.

             Other Information
  Other mailings  have been  made  that have pro-
vided information on the L-15 study. These mailings
were a notice of study initiation in  October  1984, a
status report in May 1985, and  a study update in
September 1985. If you failed to receive a copy of
any of these documents, you may obtain a copy by
writing the Kansas City District Office at  the ad-
dress shown below.

            Address Correction
  Please review your mailing label and advise us of
your correct name and/or address if there is an error
(please print or type). Mail your name/address cor-
rections to:

      Kansas City District
      Corps of Engineers
      Attn: MRKPD-A
      700 Federal Building
      Kansas City, Missouri 64106-2896
     DEPARTMENT OF THE ARMY
KANSAS CITY DISTRICT, CORPS OF ENGINEERS
         700 FEDERAL BUILDING
         601 EAST 12TH STREET
     KANSAS CITY, MISSOURI 64106-2896

          OFFICIAL BUSINESS
     PENALTY FOR PRIVATE USE, $300
              MRKPO-A.2H
                                 !    FlflST CLASS MAIt
                                    POSTAGE & FEES PAID  '
                                 DEPARTMENT OF THE ARMY!
                                      PERMIT No. G-5    I
                                                     J-.  Keith  Whitenight
                                                     Wapora Corp.
                                                    Ch
                                                    Chevy  Chase,  MD.
                                                &-I2

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        APPENDIX B



MAILING LIST FOR FINAL EIS

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                                  APPENDIX 8

                                 DUCKETT CREEK
                          MAILING LIST FOR FINAL EIS
FEDERAL

Advisory Council on Historic Preservation
Washington, DC

Federal Aviation Administration
Kansas City, MO

Federal Highway Administration
Kansas City, MO

Missouri Federal Assistant Clearinghouse
Jefferson City, MO

National Park Service
Rocky Mountain Region
Denver, CO

President's Advisory Council on
 Historic Preservation
Lakewood, CO

Regional Environmental Officer
Denver Federal Center
Denver, CO

U.S. Army Engineer  District
Kansas City, MO

U.S. Army Engineer  District
St.  Louis,  MO

U.S. Department  of  Health & Human Services
Kansas City, MO

U.S. Environmental  Protection Agency
Kansas City, MO:
     Environmental  Evaluation Branch
     Grants Information Branch
     Facilities  Requirements Branch
 U.S. Environmental  Protection Agency
 Washington, DC:
     Non-point Sources Branch
      Office of Federal Activities
     Office of Legislation
     Office of Public Affairs
     Office of Water Program Operations
U.S. Fish & Wildlife Service
Washington, DC

U.S. Fish & Wildlife Service
Columbia, MO

U.S. Department of Housing & Urban
 Development
Kansas City, MO

U.S. Department of the Interior
Missouri Cooperative Fishery Research Unit
University of Missouri

U.S. Department of the Interior
Washington, DC

U.S. Department of Transportation
Kansas City, MO

U.S. Senator John C. Danforth
Washington, DC
     Jo Randolph, Washington, DC
     Rob McDonald, St. Louis, MO
     Clair Elsberry, Jefferson City, MO
     Georganne Hedges, Kansas City, MO
     Jeanne Lineberry, Kansas City, MO
     Richard  Struckhoff,  Springfield, MO
     Teresa Poole,  Springfield, MO
     Marline  Morrison, Springfield, MO
U.S. Senator  Thomas F. Eagleton
Washington, DC
     Rindy O'Brien, Washington, DC
     Debbie King, St. Louis, MO
     Woody Overton, Kansas  City, MO
     Joe Dugan, Kansas City, MO
     Girard Grimaldi, Kansas City, MO
     L.  Gene  Bickel,  Jefferson City, MO

 U.S. Congressman  E. Thomas  Coleman
 Washington, DC
     Susan Adkins,  Washington, DC
     Ruth Coffman,  Kansas City, MO
     Marylin Erganian,  St.  Joseph, MO
                                        B-l

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                                   APPENDIX B
FEDERAL (cont'd.)

U.S. Congressman Bill Emerson
Washington, DC

     Hank Harbour, Washington, DC
     Lloyd Smith, Cape Girardeau, MO
     Doris Turner, Rolla, MO

U.S. Congressman Gene Taylor
Washington, DC

     Tony Hammond, Washington, DC
     Gerald Henson, Washington, DC
     Gary Nodler, Joplin, MO
     Bonnie Grume, Springfield, MO

U.S. Congressman Harold Volkmer
Washington, DC
     Cherry Scheloman, Washington, DC
     Lee Viorel, Hannibal,
     Wiley Hibbard, Hannibal, MO
     Carol Preisack, O'Fallen, MO
     Carol Phillips, Macon, MO
     Kathleen Anderson, Columbia, MO
     Tom Politic, Washington, MO
                                        B-2

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                                   APPENDIX B
STATE

Missouri Department of Agriculture
Jefferson City, MO

Missouri Department of Conservation
Consortium of Environmental Education
St. Louis, MO

Missouri Department of Conservation
Jefferson City, MO

Missouri Department of Health & Education
 Services
Kansas City, MO

Missouri Department of Natural Resources
St. Louis, MO

Missouri Department of Natural Resources
Rolla, MO
                              jf
Missouri Department of Natural Resources
Jefferson City, MO

Representative Richard Roehl
Jefferson City, MO

Representative Thomas Barklage
Jefferson City, MO

Representative Russell Brockfield
Jefferson City, MO

Representative George Dames
Jefferson City, MO

Senator Fred Dyer
Jefferson City, MO

Soil & Water Districts Commission
Jefferson City, MO

State Extension Services
Columbia, MO
                                        B-3

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                                   APPENDIX B
PUBLIC INTEREST GROUPS

Anglers of Missouri, Inc.
St. Louis, MO

Audubon Society of Missouri
Columbia, MO

Audubon Society of Missouri
St. Louis, MO

Conservation Federation of Missouri
Jefferson City, MO

Daniel Boone Wildlife League
Columbia, MO

Home Builders Association
St. Louis, MO

League of Women Voters
St. Louis, MO

Midwest Friends of  the Earth
Columbia, MO

Missouri Chapter of the Nature
 Conservancy
St. Louis, MO

Missouri Citizen's  Action
St. Louis, MO

Missouri Sportsman  for Clean Outdoors
Florissant, MO

Missouri  State Campers Association
Kansas City, MO

Missouri Wilderness Coalition
Columbia, MO

Osage  Chapter  of  the  Sierra Club
Columbia, MO

Ozark  Area Land Trust
Drury, MO
Redbird Bassmasters
St. Louis, MO

St. Charles Countians Against Harzardous
 Waste
St. Charles, MO

Wildlife Society
Holt Summit, MO
                                        B-4

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                                   APPENDIX B
LOCAL GOVERNMENT

Patricia Boschert, City Clerk
City of Portage des Sioux
Portage des Sioux, MO

Ed Brockshire
City of 0*Fallen
0*Falion, MO

Honorable Thomas Brown
Mayor of St. Peters
St. Peters, MO

Gilbert Carey
Mississippi River Treatment Plant
St. Charles, MO

John Carpenter
St. Charles County Health Department
Wentzville, MO

Peggy Coppage
County of St. Charles
St. Charles, MO

Duckett Creek Sewer District
St. Charles, MO

East-West Gateway Coordinating Council
St. Louis, MO

Honorable Clemence Echele
Mayor of the City of Portage des Sioux
Portage des Sioux, MO

Thomas E. Glosier, Trustee
County of St. Charles
St. Charles, MO

Richard Green, Trustee
County of St. Charles
St. Charles, MO

Earl Holtgraewe, Director of Engineering
City of St. Peters
St. Peters, MO
Robert Irvin, City Administrator
City of St. Peters
St. Peters, MO

Jim Lindemann, Trustee
Cottleville, MO

Honorable Steve Linneham
Mayor of Lake St. Louis
Lake St. Louis, MO

Kathryn M. Linnemann
Branch Library
St. Charles, MO

Herbert J. Ochs,
 Assistant Superintendent
City of St. Charles
St. Charles, MO

Regional Sewer District
St. Charles, MO

Spencer Road Branch Library
St. Peters, MO

John Vinson, City Administrator
City of St. Charles
St. Charles, MO

C.V. Walkenhorst,
 Superintendent of Public Works
City of St. Charles
St. Charles, MO

George Weible, City Attorney
City of St. Charles
St. Charles, MO

Honorable  Melvin G. Wetter
Mayor of St. Charles
St. Charles, MO
                                       B-5

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                                   APPENDIX B
CITIZENS

Paul Adams
St. Charles, MO

Bob Balcom
St. Peters, MO

John M. Bogdamor
Ferguson, MO

Richard Bone
O'Fallon, MO

Hike Dougherty
St. Peters, MO

Elmer Dwyer
St. Charles, MO

Don Hallemeier
St. Charles, MO

Keith Hazelwood
St. Charles, MO

Jerry Konersman
St. Peters, MO

Allen Lanzarini
St. Peters, MO

Clifford  Metcalf
St. Charles, MO

Robert  Mulock
St. Charles, MO

Jim O'Loughlin
St. Peters, MO

William E.  Sass
St. Peters, MO

Richard Schall
Eldon,  MO
Al Schroer
St. Charles, MO

Gary Sczepanski
St. Charles, MO

Al Wiegand
St. Peters, MO

Jules Willot
St. Peters, MO
                                        B-6

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                                      APPENDIX B
OTHER

EMC
Lake St. Louis, HO

William G. Lavrrar
 Consulting Engineering
St. Charles, MO

Mark Twain Bank
O'Fallon, MO

McDonnell Douglas Electronics
St. Charles, MO
Attn:  Joe Jansen

St. Charles Journal
St. Charles, MO

St. Louis Globe - Democrat
St. Louis, MO

St. Louis Post - Dispatch
St. Louis, MO

St. Peters Courier Post
St. Peters, MO

Sverdrup & Parcel and Assoc.
St. Louis, MO
Attn:   Bob Barbour

WAPORA, Inc.
Chevy  Chase, MD
Attn:   Keith Whitenight
                                        B-7

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  REPORT DOCUMENTATION
         PAGE
1. REPORT NO.
  EPA  907/9-86-003
                                                                      3. ftaclplanf t Aeeatalon No.
 4. TWt and SuMltta
 Final Environmental  Impact Statement:  Proposed Wastewater
 Treatment Facilities for Eastern St. Charles County, Missouri
 7.Author^ u.s.  Environmental Protection  Agency, Region VII,  Edward
 Vest. Project Officer: Tom Lorenz. Work Assignment Manager	
                                               8. Performing Onanlxatfon Rapt. No.
                                                Prolect 1563
 9. PartofmlRf Organliatlon Nama and Mtfran
 WAPORA,  Inc.
 L555 Wilson Blvd., Suite  700
 losslyn, VA  22209
                                               10. Projvct/Taak/Wor* Unit No.

                                                Work Assignment No. 13
                                               11. ContraettO or GranKO) No.

                                               to 68-01-6609
 It SpORMrific Organization Nama and Addntaa
 U.S. Environmental  Protection Agency
 Region VII
 726 Minnesota Avenue
 Kansas Citv. KS   66101	
                                               1*. Typ* of (tape* * P*fiod Co»r»d
                                               Final EIS
                                               14.
 O. Supplamantary NotM
 U. Abatract (Limit: 200 worta)
 The final environmental  impact statment  addresses the social,  economic, and environmental
 impacts potentially resulting from the proposed Federal action of issuing a grant  for
 construction of wastewater management facilities within the  St.  Charles County facilities
 planning area. The  planning area includes  the Duckett Creek  Sewer District and the cities
 of St. Charles and  St.  Peters, Missouri.   Communities served   by the new system  also
 include the Village of Portage des Sioux and other unincorporated areas of St. Charles
 County. St. Charles County, located between the Missouri and Mississippi River approxi-
 mately  25 miles  from St.  Louis, is one  of the fastest growing counties in the U.S.   The
 planning area has at least 23 treatment  facilities of varying  ages, capacities,  and
 capabilities, and the southern portion has high population growth and urbanization.

 The  no-action alternative and four action  alternatives were  evaluated.  The no-action
 alternative was determined to-be unacceptable and would result in continual water  quality
 degradation, public health risks, and property damage.  Principal impact areas for the
 action alternatives include surface and  groundwater quality, biological resources, and
 infrastructures.   The recommended alternative was found to be  environmentally sound and
 cost-effective.   Most adverse impacts can  be mitigated through various legal requirements,
 planning measures,  and design/construction practices.
 a. Deeufflont Aiwlytt* •. Daacflpton
 Sewage Treatment
 Sludge Disposal
 Flow and Waste Reduction
 Effluent Disposal
 Collection Systems
         ~  i/Op*frCMM
   0. Idantlflan/
                   Tarma
                      Floodplains/Wetlands
                      Onsite Systems
                      Regionalization
                      Environmental  Impact
                      Cost-Effectiveness
Innovat i ve/Alternati ve
 Treatment
Alternative  Analysis
Infiltration/Inflow
 )uckett Creek Sewer  Authority               Portage des Sioux
 St.  Charles County                           Mississippi River
 St.  Peters; St. Charles                     Slssourt River
   c. COSATI now/Group Env.  Eng,  Bio, Hydro, Socioeconomics, Geo, Archae,  Planning, Demogra, Trans
                                                                         por
 SI. Availability Statement
  Release unlimited. Copies  are available from
  sponsoring organization  at no charge until
  supplies are depleted.
                                19. Saeurtty Clan (Thl« Raport)

                                 Unclassified.	
                                20. Sactirfty Claat (TMi Pag*)
                                 Unclassified
          21. No. of Pa(M
              150
                                                         22. (Mca
««a AMI-ZM.lt)                             SM


 ftU.S.GOVERNMENTPRINTlNGOmCE:1986 -6SM-8B6' mj006REC!ONNO.4
                                                        OPTIONAL FOMU 272 <«-77)
                                                        (Formariy NT1S-39)
                                                        Dapartmoflt of ceoumm*

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United States                 Environmental Review
Environmental Protection        Region 7
Agency                      726 Minnesota Ave.
                            Kansas City, KS 66101

Official Business
Penalty for Private Use
$300
                                EPA, (WH-546)
                                Environitental Evaluation Branch
                                401 M  Street,  SW
                                Washington, D.C. 20460

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