United States Region 9 EPA 909/9-83-002
Environmental Protection 215 Fremont Street July, 1983
Agency San Francisco, CA 94105
EPA Environmental Final
Impact Statement
Arizona
Hazardous Waste
Facility
-------
July 1983
FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR
PROPOSED ARIZONA HAZARDOUS WASTE MANAGEMENT FACILITY
Prepared by:
U. S. Environmental Protection Agency
Reg ion 9
San Francisco, California
Cooperating Agencies:
U. S. Bureau of Land Management
Phoenix, Arizona
Arizona Department of Health Services
Phoenix, Arizona
Technical Consultant:
SCS Engineers
Long Beach, California
In Association With:
Wirth Associates
Phoenix, Arizona
UJ UUL Environmental
-s—f. - : Protection Agency
C3/ John Wise Ppcrinn §
Acting Regional Administrator
EPA Reg ion 9
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SECTION VI
PUBLIC COMMENTS ON THE DRAFT EIS
This Section presents the public comments on the Draft, and
EPA's response to the comments, in two parts:
written comments contained in letters received by EPA
Region 9; and
oral comments made in testimony presented at public
hearings held on the Draft EIS.
Written comments start on p. VI-2. Oral comments being on
p. VI-92.
VI-1
-------
WRITTEN COMMENTS
Letters received by EPA have been reproduced here. Substan-
tive written comments are numbered W-1 through W-112. The
response to each numbered comment follows the letter in which
the comment was made.
The individuals and organizations who submitted comments are
listed below in the order in which their comments appear:
Alex Dely, Arizona Sierra Club
Arizona Department of Health Services, Bureau of Air
Quality Control
Arizona Department of Health Services, Bureau of Water
Quality Control
Arizona Department of Water Resources
Jim Hartdegen, State Representative, District 6
Arizona Game and Fish Department
Arizona Electric Power Cooperative, Inc.
U. S. Department of Health and Human Services, Phoenix
Area Indian Health Service
U. S. Department of Agriculture, Soil Conservation Service
ENSCO, Inc.
Dr. Chester Leathers, Arizona State University, Department
of Botany and Microbiology
Maria Abdin
League of Women Voters of Arizona
Through the Arizona State Clearinghouse:
Arizona Department of Water Resources
Arizona Agriculture and Horticulture Department
Arizona State University, Center for Public Affairs
Arizona Game and Fish Department
Arizona Department of Public Safety
Southeastern Arizona Governments Organization
Northern Arizona Council of Governments
Arizona State Land Department
Arizona Department of Transportation
Central Arizona Association of Governments
Arizona Department of Health Services
University of Arizona, Office of Arid Land Studies
Indian Affairs Commission
Arizona Natural Heritage Program
El Paso Natural Gas Company
U. S. Department of Agriculture, Forest Service
U. S. Department of the Interior (two letters)
VI-2
-------
-J/
"The good HIV is one inspired by iove anc' guided by knowledge'
THE BERTRAND RUSSELL SOCIETY, INC
Robert -x. Davis
President
Harrv Ruja
Vice- President
ret.f ;. '. , -<•- -d
:r,airr, : o*_ ^. ^ard
"* ' "
Donald w. Jsckerncz
Secretary
Dennis J. Darland
Treasurer
. 3
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Alex Dsly, Ch.-irr^n, 7
Physics [)onarnr,e"t ijniversiL>
VI-3
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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ARIZONA HAZARDOUS WASTE FACILITY
LEAD AGENCY:
U. S. Environmental Protection Agency
COOPERATING AGENCIES;
Arizona Department of Health Services
U. S. Bureau of Land Management
PROPOSED ACTION;
Sale of Federal land to the State of Arizona for siting a
hazardous waste management facility.
ABSTRACT;
The State of Arizona has asked to purchase a one-square-mile
parcel of land from the U. S Bureau of Land Management for siting
a state-owned, contractor-operated hazardous waste facility. At
BLM's request, EPA agreed to serve as lead agency in preparing the
EIS on the proposed land transfer.
This EIS addresses concerns related to selection of a facility
site. Impacts related specifically to the design and operation
of the facility itself would be addressed through future permits
issued by EPA and the Arizona Department of Health Services.
In the Draft EIS, potential impacts are assessed using represen-
tative facility designs typical of a "low technology" (land dis-
posal) facility capable of handling the types and amounts of
wastes generated in Arizona. Alternatives considered are the
State's proposed site near the community of Mobile, alternative
sites in the Western Harquahala Plain and the Ranegras Plain,
and the No Action Alternative. For each site, the EIS considers
potential impacts on ground water, air quality, public health
and safety, biological communities, cultural resources, and
other resources. Mitigation measures are identified for those
impacts which would not be addressed through the facility's
permits.
The Final EIS addresses comments on the Draft EIS by presenting
additional discussion of several major environmental issues. It
also assesses the impacts of a representative "high technology"
facility, which uses a high temperature incinerator to dispose
of PCB wastes and other incinerable hazardous wastes.
FOR FURTHER INFORMATION, CONTACT;
Chuck Flippo, EPA Region 9, 215 Fremont Street, San Francisco, CA
94105; (415) 974-8128
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TABLE OF CONTENTS
Page
TABLE OF CONTENTS i
LIST OF FIGURES iii
LIST OF TABLES iv
ABBREVIATIONS vi
I. INTRODUCTION 1-1
Background 1-1
The Draft EIS 1-4
The Final EIS 1-5
Agency's Preferred Alternative 1-6
II. ERRATA AND CLARIFICATIONS II-l
III. FACILITY DESCRIPTION III-l
The Representative Designs III-l
An Alternative Design including Incineration III-l
Potential Environmental Consequences III-5
IV. MAJOR ENVIRONMENTAL ISSUES IV-1
Alternatives IV-1
Alternative Sites IV-1
Resource Recovery and Waste Reduction IV-5
Physical Setting IV-7
Seismology IV-7
Subsidence IV-8
Ground Water IV-9
Prevention and Control of Ground Water
Contamination IV-10
Hydrogeolog ic Data IV-17
Relationship between Ground Water Data, Protec-
tive Measures, and the Facility Permit IV-19
Surface Water IV-21
Threat to the CAP Canal and to Stock Ponds IV-21
Alternatives to Surface Impoundments IV-22
Adequacy of Flood Protection Measures IV-22
Design Considerations IV-24
Air Quality IV-26
Effects of Weather Conditions on Air Emissions IV-26
Potential Emissions from a Facility with
Incineration IV-28
Monitoring of Facility Emissions IV-34
Dust Control IV-35
Public Health and Safety: Spill Risks IV-37
Risks from Transporting Hazardous Waste IV-37
Risk of a Spill at the Facility IV-51
Hazardous Waste Spill Scenario IV-51
Emergency Response IV-52
Mitigation Measures IV-54
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Page
Public Health and Safety: Valley Fever IV-57
Socioeconomics: "Quality of Life" Concerns IV-59
Irreversible and Irretrievable Commitment IV-65
of Resources
Water Use IV-65
Energy Consumption IV-66
V. MITIGATION MEASURES V-1
The Facility Permit Requirements V-1
ADHS Transportation Regulations V-12
Summary of Impacts and Mitigation Measures V-13
VI. PUBLIC COMMENTS ON THE DRAFT EIS VI-1
Written Comments VI-2
Oral Comments VI-92
Hearing Exhibits VI-169
VII. LIST OF PREPARERS VII-1
VIII. COORDINATION LIST VIII-1
IX. REFERENCES IX-1
APPENDIX A. VOLATILE ORGANIC COMPOUNDS AND TOXIC
EMISSIONS A-l
APPENDIX B. EMISSIONS CALCULATIONS FOR A HAZARDOUS WASTE B-1
SPILL
APPENDIX C. MILEAGE AND FUEL CONSUMPTION ESTIMATES C-1
APPENDIX D. POPULATION RISK FACTORS FOR TRANSPORTATION
OF PCBS D-l
APPENDIX E. MODIFIED MERCALLI INTENSITY SCALE E-1
APPENDIX F. ADDITIONAL STUDIES NEEDED FOR THE ARIZONA
HAZARDOUS WASTE SITE F-1
APPENDIX G. PUBLIC NOTICE OF HEARINGS ON THE
DRAFT EIS G-l
11
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FIGURES
Number Page
1-1 Locations of the proposed and two alternative 1-3
sites
III-1 Artist's concept of a mobile PCB/hazardous
waste incinerator III-3
IV-1 Major transit routes for PCB shipments to
proposed Arizona hazardous waste management
facility IV-40
CORRECTED FIGURES
The following figures appeared in the Draft EIS. They have been
corrected and reprinted here.
3-4 Land jurisdiction at the Mobile site II-4
3-5 Existing land use at the Mobile site II-5
3-9 Land jurisdiction at the Western Harquahala
Plain site II-7
3-14 Land jurisdiction at the Ranegras Plain site II-8
111
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TABLES
Number Page
IV-1 Percent probability of one or more flows greater
than or equal to the design flood in relation to
the years of facility operation IV-25
IV-2 Volatile organic compound (VOC) emissions for
representative facility designs IV-31
IV-3 Hazardous materials hazard class; total
hazardous materials count in pounds IV-44
IV-4 Hazardous materials carried by the Southern
Pacific Railroad in Arizona, 1982 IV-45
IV-5 Impacts of spills involving benzene and methylene
chloride IV-45
V-1 Summary of Impacts and Mitigation Measures V-14
C-1 Travel miles of hazardous waste shipments to
proposed Arizona sites and nearest out-of-state
site C-2
C-2 Estimated fuel consumption for in-state hazardous
waste shipments C-2
C-3 Travel miles of PCB shipments to proposed
Arizona sites and existing PCB incinerator
(El Dorado, AR) C-4
C-4 Estimated fuel consumption of PCB waste shipments C-5
D-1 Population risk factor for PCB transport to the
Western Harquahala Plain and Ranegras Plain sites D-1
D-2 Increase in population risk factor due to PCB
shipments to the Western Harquahala Plain and
Ranegras Plain sites D-2
D-3 Population risk factors for PCB transport to the
Mobile site D-3
D-4 increase in population risk factors due to PCB
shipments to the Mobile site D-4
F-1 Additional studies needed for the Arizona
Hazardous Waste Facility F-2
IV
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CORRECTED TABLES
These tables appeared in the Draft EIS. They have been corrected
and reprinted here.
Number Page
3-2 Temperature, precipitation, and evapotranspiration
at selected locations II-3
4-1 , Stream flow records for Waterman Wash near Buckeye II-9
App. F
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ABBREVIATIONS
ADHS Arizona Department of Health Services
ADOT Arizona Department of Transportation
ARS Arizona Revised Statutes (Compilation of Arizona
State laws)
BLM U. S. Bureau of Land Management
CAP Central Arizona Project
CFR Code of Federal Regulations (Compilation of Federal
regulations published by U. S. Government Printing
Office; 40 CFR refers to Title 40, Protection
of the Environment)
DEIS Draft Environmental Impact Statement
DOT U. S- Department of Transportation
DPS Arizona Department of Public Safety
EIS Environmental Impact Statement
EPA U. S. Environmental Protection Agency
FR Federal Register (daily publication of new and
amended Federal regulations, published by U. S.
Government Printing Office)
PEC Provident Energy Company
VI
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SECTION I
INTRODUCTION
This Final Environmental Impact Statement (EIS), together
with the Draft EIS (EPA publication #909/9-83-001, January,
1983), completes the EIS on the Arizona Hazardous Waste Manage-
ment Facility. In response to comments made on the Draft EIS,
this Final EIS presents:
Corrections of errors in the Draft (Section II, Errata Sheet)
Additional discussion of the facility description presented
in the Draft EIS (Section II, Facility Description).
Discussion of major environmental issues covered in the
Draft EIS which were the subject of public comments
(Section IV, Major Environmental Issues).
A new presentation of mitigation measures, including a
summary chart of measures and the impacts they mitigate
(Section V, Mitigation Measures).
The written and oral comments presented to EPA, and the
responses to those comments (Section VI, Public Comments
and Responses).
This document plus the Draft EIS constitute the complete
environmental impact statement on the Arizona Hazardous Waste
Facility. Additional copies of the Draft EIS are available from
EPA Region 9, 215 Fremont St, San Francisco, CA, 94105.
BACKGROUND
The State of Arizona proposes to purchase a one-square-
mile parcel of Federal land from the U. S. Bureau of Land
Management (BLM) on which to site a hazardous waste management
facility. The land is located six miles southwest of the commun-
ity of Mobile in Southern Maricopa County. The State plans to
contract with a private firm to finance, build, and operate a
facility that would treat, store, and dispose of hazardous wastes.
BLM has determined that transfer of Federal land for the
purpose of siting a hazardous waste facility requires the
preparation of an environmental impact statement (EIS) to comply
with the National Environmental Policy Act of 1969. This EIS has
been prepared to meet that requirement by providing BLM with
information about the potential environmental impacts of siting
a hazardous waste facility on the site proposed by the State,
siting the facility at an alternative site, or not transferring
land to the State for this purpose (the "no action alternative").
1-1
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The land transfer addressed in this EIS is one step in the
State's process of developing the hazardous waste facility.
This process is briefly described below.
Selection of a Site
In 1980, the Arizona State Legislature directed the Arizona
Department of Health Services (ADHS) to identify potential
hazardous waste sites in the State, and to prepare a report
presenting its recommendations to the Legislature. In its
legislation mandating the ADHS study (SB 1283, ARS 36-2800), the
Legislature set forth certain criteria ADHS was to use in selecting
potential sites. These criteria and ADHS's siting methodology
are summarized in Section IV, Alternatives.
In January, 1981, ADHS presented its finding to the Legisla-
ture in the "Final Report to the Arizona State Legislature Regard-
ing Siting a Statewide Hazardous Waste Disposal Facility" (1).*
The Report recommended selection of a site in the Western Harqua-
hala Plain siting area, but also stated that the Ranegras Plain
and the Rainbow Valley (Mobile) areas were worthy of consideration
by the Legislature (see Figure 1-1).
The Legislature chose to site the facility in the Mobile
area. In SB 1033 (ARS 36-2802), passed in February of 1981,
the Legislature directed ADHS to obtain the 640-acre parcel of
land legally described as Section 32, Township 4 South, Range 1
West of the Gila and Salt River Base and Meridian.
Following passage of SB 1033, ADHS approached BLM to buy
the proposed site. ADHS also began developing a Request for
Proposals that would be used to solicit bids from private firms
to design, build, and operate the facility. The bidding period
closed on February 25, 1983. ADHS expects to make the final
selection of a contractor in July, 1983.
The Land Transfer, the EIS, and the Facility Permit
After it received the State's request to buy its land, BLM
determined that sale of the federal land for a hazardous waste
site would be a "major federal action significantly affecting
the quality of the human environment." This meant that, under
the provision of the National Environmental Policy Act of 1969,
an EIS would be required. Because of EPA's greater expertise in
the field of hazardous waste management, BLM asked EPA to prepare
the EIS.
* Copies of this report are available from ADHS, Bureau of Waste
Control, 1740 W. Adams St., Phoenix, AZ, 85007.
1-2
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Figure 1-1. Locations of the proposed and two alternative
sites.
1-3
-------
This EIS addresses concerns specifically related to selection
of a site rather than the design of the facility. For purposes
of preparing the Draft EIS, a "representative" facility design
was used to suggest what a typical facility might be, based on
the size and nature of Arizona's hazardous waste stream. The
kinds of impacts addressed in the document, however, could be
associated with a variety of facility designs.
This approach is the most useful at this stage of the project,
given that:
BLM's decision concerns title transfer of the site, rather
than approval of the facility itself;
Since the State has not yet selected a facility contractor,
no final design proposal has been submitted; and,
Before the facility may be built and operated, it must
receive a hazardous waste facility permit, which would
be the equivalent of an EIS on the facility design.
The EIS will become part of the record BLM will use in deter-
mining whether to transfer the proposed site or an alternative site
to the State. (See DEIS pp. 1-7 to 1-9.) If the land is trans-
ferred, ADHS will complete negotiations with the facility contrac-
tor on terms of the contract to design, finance, build, operate,
and maintain the facility. The facility contractor would then
design the facility and apply for the necessary permits before
starting construction.
THE DRAFT EIS
The Draft EIS considers the potential impacts of locating a
hazardous waste facility at three alternative sites: Mobile, the
Western Harquahala Plain, and the Ranegras Plain. The analysis
of the impacts of siting a facility at these sites is based on
representative facility designs typical of existing facilities
which handle the types and amounts of wastes generated in Arizona
(see DEIS Appendix D). This representative facility is oriented
toward land treatment and landfill disposal of wastes, although
it includes a solvent recovery unit and an acid/alkali neutrali-
zation operation. Being essentially oriented toward land treat-
ment and disposal, it could be considered a "low technology"
facility in terms of existing hazardous waste treatment and
disposal technology. That is, it does not utilize "high technology"
treatment processes, such as high temperature incineration.
The potential environmental impacts of locating such a rep-
resentative facility at each of the three sites are summarized
in Table 2-1 (DEIS p. 2-8, et seq.), and discussed in detail in
Section 4 of the Draft EIS. Mitigation measures are also presented
in DEIS Section 4.
1-4
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Notice of the availability of the Draft EIS was published
in the Federal Register of January 28, 1983 (48 FR 4046), and
in legal notices in the Phoenix Gazette and the Arizona Republic
on January 14, 1983. Notices were also mailed to some 1500
individuals, agencies, and organizations, mostly in Arizona, on
January 14, 1983.
Over 300 copies of the Draft EIS were distributed for public
review. On March 1, 1983, two public hearings were held to
receive comments, one in Phoenix and one in Buckeye, Arizona.
In addition, a public meeting was held in Mobile on February 17,
1983, to discuss the EIS and answer questions. Notice of the
hearings and the meeting was included in the notice of availabil-
ity of the Draft EIS mailed on January 14. In addition, a press
release was sent to a number of newspapers in Arizona (see Appen-
dix G). Articles announcing the meeting and the hearings appeared
in the Buckeye Valley News of January 27, 1983 and February 24,
1983.
THE FINAL EIS
This Final EIS has been prepared to respond to comments on
the Draft EIS. A few commenters corrected errors in the text of
the Draft; these corrections are included in Section II. Other
commenters questioned the analysis or expressed concerns about
the proposed facility and its impacts. Many of these comments
addressed similar issues. Rather than respond to each comment
individually, the Final EIS discusses several key environmental
issues and covers a range of comments dealing with those issues.
These discussions appear in Section IV. Those comments which
are not addressed in Section IV are answered individually in
Section VI. All of the comments, including the transcript of
the public hearings held on the Draft EIS, appear in Section VI.
Several commenters, including a company bidding on the
facility construction and operation contract, faulted the Draft
EIS for not analyzing a "high technology" facility as well as the
"low technology" one. The bidder who commented proposes to
develop an incinerator if chosen as the facility contractor. In
response to these comments, this Final EIS includes an analysis
of the potential impacts of such a facility. This analysis is
presented in Section III; certain impacts are discussed in greater
detail in Section IV.
The Draft EIS summarizes the potential impacts of the proposed
facility in DEIS Table 2-1. The table does not, however, include
a summary of the mitigation measures associated with those impacts.
To provide a quick guide to the impacts and their mitigation
measures, a summary table appears in Section V of this document.
1-5
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AGENCY'S PREFERRED ALTERNATIVE
BLM supports ADHS's proposal for location of the facility
near Mobile.
1-6
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SECTION II
ERRATA AND CLARIFICATIONS
The following statements correct errors or clarify the text of
the Draft EIS.
ERRATA
DEIS Page Correction
3-3,4 "Chirioni-Gachado-Rock" should read
"Chirioni-Gachado-Rock Outcrop."
3-4 "Avondale clay" should read
"Avondale clay loam."
3-6 Errors in Table 3-2 have been corrected and
the table is reprinted on p. II-3.
3-17 Amphibians and Reptiles; The desert tor-
toise and the Gila monster are not listed
as "endangered" by the Arizona Game & Fish
Department. In the current edition of
Threatened Native Wildlife in Arizona
(approved by the Arizona Game and Fish
Commission on 10 December 1982), the desert
tortoise is listed in Group 3, which means
that its continued presence in Arizona could
be in jeopardy in the forseeable future.
The Gila monster is not listed in this
publication, but is protected by Arizona
Game and Fish Commission Order 43. This
Commission Order has the force of law and
forbids the taking (i.e., collection or
killing) of Gila monsters.
3-18 Mammals; Desert bighorn sheep are listed
in Group 3 (see above) in Threatened Native
Wildlife in Arizona. The spotted bat is no
longer listed.
3-18 "Arizona Department of Fish and Game" should
read "Arizona Game and Fish Department."
3-19 Errors in Figure 3-4 have been corrected,
and the figure is reprinted on p. II-4.
3-20 The legend for Figure 3-5 (DEIS p. 3-20a)
was omitted from the Draft EIS. The figure
and legend are given on pp. II-5, II-6.
-------
3-32 The second sentence in the third paragraph
should read: "These soils have moderately
rapid infiltration rates, possess moderate
available water capacity, and contain
moderate amounts of soluble salts in the
subsoil and substratum."
3-36 In the fourth paragraph, the figure 14.6
feet/year should be 1.8 feet/year.
3-46 Errors in Figure 3-9 have been corrected,
and the figure is reprinted here on p. II-7.
3-62 The first sentence of the sixth paragraph
should read: "The U.S. Department of the
Interior, Fish and Wildlife Service, has
listed the bald eagle, Yuma clapper rail,
zone-tailed hawk, osprey, and peregrine
falcon as endangered species."
3-64 Errors in Figure 3-14 have been corrected
and the figure is reprinted here on p. II-8.
4-50 In the third paragraph, the fuel consumption
figure for the Mobile site should be 5,100
gallons per month rather than 8,300.
Appendix F, Table 4-1 in Appendix F is incomplete.
4-1 The table has been corrected and updated to
show data through 1981 (p. II-9).
CLARIFICATION REGARDING THE WESTERN HARQUAHALA PLAIN AND RANEGRAS
PLAIN SITES
The Draft EIS shows the Western Harquahala Plain and Ranegras
Plain sites as each consisting of two one-square-mile parcels,
while the Mobile site was shown as one one-square-mile parcel.
This is because ADHS has not identified the specific one-square-
mile parcel it would seek to purchase if the Legislature approved
either of these sites as an alternative to the Mobile site.
ADHS has identified two preferred parcels at each site. Both
parcels are used in the Draft EIS for the analysis of environ-
mental impacts at the sites. One of the two parcels would be
selected if the Legislature were to approve purchase of an alter-
native site. The Draft EIS also failed to note that Section 30,
one of the two parcels at the Western Harquahala Plain site, is
State land rather than federal land.
II-2
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TABLE 3-2. TEMPERATURE, PRECIPITATION, AND EVAPOTRANSPIRAT ION AT SELECTED LOCATIONS
I
w
Normal Temperature (*F)* Total Precipitation
Casa Gil a
Month Grande Bend
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
50.6 52.6
54.9 56.5
59.7 61.4
67.7 69.5
76.2 77.9
84.8 85.9
91.1 93.1
88.9 91.5
83.6 85.8
72.1 74.7
59.5 61.6
51.8 54.0
Annual 70.1 72.0
-*•
t
Climatological Data;
Administration, Ashev
Arizona Environmental
Casa
Phoenix Grande
51.2
55.1
59.7
67.7
76.3
84.6
91.2
89.1
83.8
72.4
59.8
52.5
70.3
Annual
ille, N
0.76
0.67
0.69
0.35
0.11
0.16
0.95
1.56
0.79
0.63
0.56
0.88
8.11
Summary [for]
.C. , pp. 2, 3
Gil a
Bend
0.62
0.44
0.65
0.30
0.10
0.04
0.76
1.08
0.50
0.33
0.35
0.59
5.76
Arizona,
, 5. [1980
Consultants. Inc. First Draft
(inches)*
Phoenix
0.71
0.60
0.76
0.32
0.14
0.12
0.75
1.22
0.69
0.46
0.46
0.82
7.05
Vol. 84, No.
data]
Potential Evapotranspiration
Casa
Grande
0.44
0.64
1.64
2.70
5.05
7.41
8.46
7.71
6.17
3.26
1.11
0.49
45.6
. 13. National
[of] Environmental Impact
Gil a
Bend
0.57
0.80
1.51
3.13
5.36
7.54
8.64
7.97
6.51
3.76
1.20
0.53
47.65
Climatic Center
Report for the
(inches )t
Phoenix
0.53
0.76
1.78
3.00
5.18
7.54
8.37
7.71
6.17
3.28
1.20
0.29
45.83
, National
Provident
Actual Evapotranspiration (inches)t
Casa
Grande
0.44
0.64
1.51
0.35
0.09
0.17
1.25
1.32
0.78
0.28
0.78
0.49
8.10
Oceanographic
Energy Company
Gila
Bend Phoenix
0.57
0.56
0.62
0.22
0.11
0.07
0.82
0.91
0.47
0.36
0.45
0.53
5.69
and Atmospheric
Oil Refinery,
0.53
0.76
1.78
0.42
0.12
0.07
1.06
1.06
0.82
0.44
0.62
0.29
7.38
Mar i c op a County, Arizona.
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'll
.-.-:•:•:< B.L.H. LANDS
STATE TRUST LANDS
3THER
Figure 3-4. Land jurisdiction at Mobile site
II-4
-------
CONLEY
RESERVOIR
Figure 3-5. Existing land use at the Mobile site
II-5
-------
LEGEND
UNPAVED IMPROVED ROAD
UNIMPROVED ROAD
(«i PROPOSED 230KV WOODPOLE TRANSMISSION LINE
NORTHWEST TANK
CONLEY RESERVOIR
BLM WILDERNESS STUDY AREA UNIT #2-164
CONLEY BLM GRAZING ALLOTMENT
ZONED RURAL - 190
PROPOSED EQUESTRIAN TRAIL
(BUTTERFIELD STAGE ROUTE)
PROPOSED SITE
Figure 3-5a0 Legend to Figure 3-5
n-6
-------
Jn <>>; ? c !/v.--» d» '^qi^S '
C--* (Vo __ n e—-\ ~ f/Z— n ^* •
Figure 3-9. Land jurisdiction at Western Harquahala Plain site.
-------
I
oo
o7o»o oo •*«'#:•.»
LEGEND
;;XX B.L.M. LANDS
STATE TRUST LANDS
M OTHER
Figure 3-14. Land jurisdiction at Ranegras Plain site.
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TABLE 4-1.
Appendix F
STREAM PLOW RECORDS FOR WATERMAN WASH NEAR BUCKEYE, USGS
STATION #09514200 (DRAINAGE AREA - 403 mi2)*
Date (month/year)
9-64
8-65
12-65
8-66
9-66
9-67
11-67
12-67
8-68
8-69
8-70
9-70
8-71
3-72
73
9-74
10-75
9-76
10-77
8-78
8-79
2-80
8-81
Peak Discharge (cfs)
2,680
1 ,200
1 ,400
600
5,560
6,300
520
560
400
400
1 ,600
700
2,080
2,000
t
100 * *
1 ,200
1 ,180
740
1 ,150
t
2,220
t
* The station is a peak flow crest stage gage.
t No flow above 400 cfs (pin height).
** Field estimate.
Source: (Field notes, U.S. Geological Survey, 1983)
II-9
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SECTION III
FACILITY DESCRIPTION
THE REPRESENTATIVE DESIGNS
The Draft EIS describes "representative™ designs for the
proposed facility (DEIS Appendix D). The designs include surface
impoundments for storage or treatment of wastes, a landfarm
unit for treatment of biodegradable organic wastes, a solvent
recovery unit, and a secure landfill for burial of wastes which
could not be further treated or recycled.
Several commenters apparently interpreted these represen-
tative design features to be an actual design proposal for the
facility. This is not the case. No facility design is available
for the EIS, since the State has not selected the contractor who
would be responsible for designing the facility. In the absence
of an actual facility design, the representative facility designs
have enabled the EIS preparers to assess the nature and likely
extent of the environmental impacts which might be associated
with a facility typical of those handling the types and amounts
of hazardous wastes generated in Arizona.
Because the representative designs consist primarily of
simple or "low level" technologies such as land disposal, some
commenters felt "high level" or advanced technologies such as
incineration were being excluded from consideration in designing
the facility. Again, this is not the case. The representative
designs are meant only to illustrate the kinds of facility
features which could be developed economically in Arizona, given
the types and amounts of wastes generated within the State.
A bid based on the use of advanced technologies could meet the
conditions set forth in ADHS's Request for Proposals and receive
full consideration by the State. The decision not to include
such technologies in the representative designs presented in the
Draft EIS was based strictly on the judgement of the EIS preparers
as to the likely nature of the facility proposals. It was not
meant to preclude any particular technology.
AN ALTERNATIVE DESIGN INCLUDING INCINERATION
Since the Draft EIS was released, a bid has been submitted
to ADHS which includes incineration as a major component. If
the bid were accepted, the proposed incinerator would handle
polychlorinated biphenyls (PCBs) from several states as well as
hazardous wastes generated within Arizona. Based on comments
submitted by the bidder (ENSCO, Inc.), a discussion of the poten-
tial impacts associated with a PCB/hazardous waste incinerator
is included in this Final EIS. Many of the environmental impacts
-------
would not differ significantly from those associated with the
representative designs described in the Draft EIS. These impacts
are described in this section. Other potential impacts, such
as air quality, require more lengthy discussion. These are
addressed in more detail in Section IV.
Under the incinerator proposal, the facility contractor
would initially operate a mobile incinerator for hazardous wastes
and liquid PCBs, and a rotary kiln for PCB-contaminated solid
wastes.* (See Figure III-1.) A permanent incinerator would be
constructed later if it were economically justified. The incin-
erator would be used primarily to destroy organic wastes,
including PCBs, pesticides and other chlorinated organics, and
unrecoverable solvents.
It is estimated that 10,000 to 12,000 tons per year of PCB
wastes would be accepted at the facility, most of it from states
other than Arizona.t (See Table C-3, Appendix C.) The ability
of the facility to handle PCB waste from a regional market would
make it economically feasible to develop an incinerator in
Arizona.** The PCB waste would be in addition to the hazardous
* The description presented here is based on preliminary concepts
provided by ENSCO Inc. (2,3). If this bidder were selected by
ADHS to be the facility contractor, an actual design would be
developed and submitted as part of the permit applications
for hazardous waste and PCB disposal.
t This figure is based on ENSCO's estimate for a 100% capacity
operation (3). "PCB waste," as used in this document, refers
to all types of Federally-regulated wastes containing or con-
taminated by PCBs. (See Section V.)
**The initial costs of developing an incinerator are high, run-
ning to several million dollars depending on size (4). It is
not likely that the hazardous waste market within Arizona would
economically support development of an incinerator at this time.
An incinerator that could attract PCB waste from a regional
market, on the other hand, could realize enough economic return
in its early years to make the incinerator a feasible investment.
There would be a strong market for the incinerator service, since
disposal options for PCB generators are very limited. Most PCB
wastes must be either incinerated or chemically treated. For
those PCB wastes which can be landfilled, the cost of land
disposal may be nearly as high as the cost of incineration (5).
There are a limited number of facilities which handle PCB
waste; the only other PCB incinerators currently in operation
are in Arkansas and Texas. Consequently, a PCB incinerator in
Arizona probably would be able to attract enough PCB waste from
the western states to support the high initial investment.
III-2
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H
H
H
I
Incinerator
Scrubber
Exhaust
Stack
Rotary
Kt In
T ruck
Tral1ers
Chemical Lab/
Control Room
Storage
Tanks
C hem 1ca1
Neutralization
Sys tern
Figure III-l. Artist's concept of mobile PCB/hazardous waste Incinerator components
-------
waste generated within the State. Out-of-state waste other
than PCBs could be accepted by the facility, though no estimate
of the amount can be made at this time. (See DEIS Appendix C.)
The incinerator exhaust gases would be "scrubbed" to remove
hydrogen chloride gas (HC1) formed in the incinerator.* Since
ash from the incinerator could contain hazardous constituents
from the burned wastes, it would be disposed of in the landfill
at the facility.
A rotary kiln would be used in conjunction with the incin-
erator to volatilize PCBs and other substances from solids such
as capacitors or contaminated dirt. The solids which remained
after the volatilized substances had been incinerated would be
sent to the landfill.
As in the "low technology" design described in the Draft
EIS, resource recovery would be practical at this type of facility.
A solvent recovery unit would likely be included. In addition,
hydrochloric acid (HC1) and calcium chloride (CaCl2) could be
recovered from the incinerator scrubber effluent. It is likely
that drums used to transport the wastes would be recovered
after use by "baking off" and incinerating the organic residues.
Other potential recovery products include water from neutralizing
acids and bases and heat from incineration.
The mobile incinerator would occupy about one acre of land
(200' x 200'). Some additional land would be used to store
wastes to be incinerated.
The incinerator would permanently destroy some hazardous
materials that otherwise would be disposed of in the landfill
and/or the landfarm. It is anticipated that development of an
incinerator would preclude development of a landfarm altogether,
since the types of wastes treated by landfarming, as described
in the Draft EIS would be incinerated. Since the amount of
wastes to be landfilled probably would be reduced, the landfill
could be smaller than that projected in the Draft EIS. The
landfill would not be eliminated, however, since incinerator
ash and non-incinerable solids would be landfilled. Organic
wastes containing heavy metals would also be landfilled.
Other operations, such as neutralization ponds, evaporation
ponds, a solvent recovery unit, and support facilities (lab,
maintenance buildings, etc.) would be similar to those described
in the Draft EIS, though the size and capacity specifications
* A "scrubber" is an air pollution control device that uses
water to contact and absorb pollutants and prevent their
emission through the stack.
III-4
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could vary according to the final operating plans of the facility
contractor. For purposes of comparison, it is assumed that
these other operations at the "high technology" facility are the
same as those described in the Draft EIS for the "low technology"
facility.
Absence of a landfarm and development of a smaller landfill
would reduce the total area of land needed for the treatment
and disposal operations, compared to the representative facility
described in the Draft EIS. However, additional storage space
would probably be needed for the PCB wastes. The net reduction
in affected area would likely be in the range of 5 to 15 acres.
Both energy and water requirements for the incinerator
facility would be greater than for the "low technology" facility.
The addition of PCB wastes would also mean an increase in traffic
to the facility of one to two trucks per day.
Potential Environmental Consequences
Physical Setting
Topography and soils. The area of altered topography could
be 5 to 15 acres smaller than that identified in the Draft EIS
(DEIS p. 4-1). Mitigation measures would be the same.
Geology. Impacts on geology and mitigation measures would
be the same as those identified in the Draft EIS. The potential
for subsidence due to ground water withdrawal is discussed in
Section IV, Physical Setting.
Water Resources
Ground water. The risk of ground water contamination
could be reduced somewhat by the absence of a landfarm as a
potential source of contamination. The incinerator itself would
not pose a risk to ground water, but storage units serving the
incinerator could pose leakage problems if not properly designed,
constructed, and maintained. Such units would be subject to
Federal and State regulations, as described in Section IV,
Ground Water, and in Section V- Mitigation measures would.be
addressed in the hazardous waste permit. (See Section V.)
Surface water. Impacts and mitigation measures could be
similar to those for the representative "low technology" facility,
although absence of the landfarm could reduce the area of
facility land subject to flooding. Since storage units for
incinerator-bound waste would likely be covered tanks, the
potential for run-on/run-off problems would be less for these
III-5
-------
units than for the surface impoundments. Mitigation measures
would be addressed during the permit process. (See Section V.)
Additional discussion of surface water impacts appears in
Section IV.
Air Quality
The following discussion summarizes a lengthier analysis of
potential air quality impacts in Section IV.
Volatile organic compounds (VOCs). A "high technology"
facility would be expected to emit fewer VOCs than the "low
technology" facility: between 3 and 70 tons per year, as opposed
to 55 to 298 tons per year.
Toxic emissions. Absence of a landfarm would eliminate one
source of potentially toxic gaseous emissions. The incinerator,
however, could emit trace amounts of such contaminants. Exper-
ience at other facilities indicate that the incinerator could
also emit dioxin and furan.* Insufficient data are available at
this time to estimate the likely amount of these emissions.
Before the facility would be issued a PCB disposal permit, emis-
sions estimates would be made and a health risk assessment
conducted.
Particulates. The incinerator could release between 1 and
91 tons per year of particulate emissions (e. g., ash, condensed
vapor, or soot) resulting in a maximum additional concentration
of about 13 ug/m3 (24-hour average). This would add to any
existing particulate problems in the area around the facility
due to blowing dust, though the amount of additional emissions
would be insignifcant compared to the large amounts of dust
which can originate in these areas. (See DEIS Tables 3-3 and
3-11.)
Mitigation measures are discussed in Section IV, Air Quality,
and in Section V.
Public Health and Safety
Spill risks. Operational spill risks are assumed to be the
same as for the representative "low technology" facility. Addi-
tional transportation spill risks would be related to the number
of PCB shipments generated by the presence of the incinerator.
PCB shipments which currently pass through Arizona from the west
en route to existing incinerators in Arkansas and Texas would
* Tetrachlorodibenzodioxin (TCDD) and Tetrachlorodibenzofuran
(TCDF).
III-6
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likely go to the facility. Additional PCB shipments not currently
passing through Arizona could also be routed to the proposed
facility. An average of one to two trucks per day carrying PCB
wastes could be expected at the facility (6). This would result
in a small increase in accident risk along access routes. This
could be offset by a reduction in accident risk along routes in
Arizona and other states which would no longer be used by the
PCB transporters. See Section IV, Public Health and Safety:
Spill Risks, for additional discussion of PCB transportation.
Mitigative measures for both operational and transportation
spills would be the same as those described in the Draft EIS.
Additional discussion of spill risks appears in Section IV,
Public Health and Safety: Spill Risks. This includes a spill
scenario that could apply to either a "low technology" or
"high technology" facility.
Valley Fever. Absence of a landfarm and development of
a smaller landfill could reduce the potential for release of
Valley Fever spores due to soil disturbance. Mitigation measures
would be the same as those presented in the Draft EIS and in the
discussion of Valley Fever in Section IV.
Odors. Odor impacts would be the same as those described
in the Draft EIS. An incinerator does not release significant
odors under normal operating conditions.
Noise. Potential noise impacts could be increased somewhat
by the addition of an average of one to two trucks per day carry-
ing PCBs. This should not, however, significantly increase the
noise problems described in the Draft EIS. Noise from the incin-
erator itself would not be heard off-site.
Visual Resources
The incinerator would have a smokestack which would likely
stand about 40 feet high. The exact height would depend on
factors such as the stack diameter and the distance between the
incinerator and other buildings at the facility (because of the
effect of buildings on air currents affecting the stack). In
any case, the stack and other portions of the incinerator could
increase the visibility of the facility. Also, a plume of steam
from the stack probably would be visible when the humidity is
high. Consequently, the visual impacts could be somewhat greater
than for the "low technology" facility.
These impacts could be minimized by placing the incinerator
in a location which would allow construction of the lowest possible
stack (taking into account topography and various engineering
factors). Mitigation measures suggested in the Draft EIS, such
as use of natural color tones, could also help reduce the contrast
III-7
-------
between the facility and the background.
Ecological Resources, Land Use, and Cultural Resources
The potential impacts in these areas would not be expected
to differ substantially from those described in the Draft EIS.
Socioeconomics
Comments made at the public hearings on the Draft EIS
indicate that some area residents are especially concerned about
the prospect of emissions from a land disposal facility. To the
extent that these comments reflect public sentiment, development
of a "high technology" facility could reduce the residents'
concerns. On the other hand, the prospect of a facility which
handles such "publicly sensitive" wastes as PCBs and which could
emit dioxins and furans could create new concerns, offsetting
any advantage of the high technology approach in terms of public
acceptability.
Unavoidable Adverse Impacts
Unavoidable adverse impacts associated with a "high tech-
nology" facility would generally be the same as those described
in the Draft EIS. As noted in the preceding discussion, absence
of a landfarm and a smaller landfill could decrease some of the
potential adverse impacts, but the decrease would not be expected
to be significant. There could be some differences in unavoidable
air quality impacts, as described in Section IV.
Irreversible and Irretrievable Commitment of Resources
The resources most affected by differences between a "low
technology" and a "high technology" facility are water and energy.
The following discussion summarizes a longer discussion in
Section IV.
Water. The "high technology" facility could require up to
150 gallons of water per minute (averaged over a 24-hour period),
whereas a "low technology" facility could use about 35 gallons
per minute. The most likely sources of this water are ground
water and water reclaimed from facility operations. The capital
costs of supplying water could be higher for the "high technology"
facility, thus consuming additional economic resources as well
as water resources.
Energy. Use of electricity would be higher at the "high
technology" facility than at the "low technology" one. The
III-8
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incinerator would draw a peak energy load of up to 450 kw (kilo-
watts). The energy needs of other facility operations could
require an additional 200 to 250 kw (3). The "low technology"
facility would draw a peak load of approximately 200 kw (7).
Co-generation of electricity using excess heat from the incin-
erator could meet some of the "high technology" facility's energy
needs.
Motor fuel consumption could decrease if the incinerator
facility were developed, since trucks carrying PCBs to the facil-
ity would travel a shorter distance than they would if they had
to continue on to existing incinerators in Arkansas and Texas.
Estimates of anticipated PCB shipments to the proposed incinerator
indicate that gas savings could range from about 138,000 to
155,000 gallons per year. (See Appendix C.)
Short-term Use Versus Long-term Productivity
The relationship between short-term use of the site and long-
term productivity of the affected environment would be similar
to that described in the Draft EIS. (See DEIS pp. 4-50 to
4-52.) Any potential long-term health risks due to emissions
from the incinerator would be assessed through a risk assessment
conducted as part of the facility permitting process.
III-9
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SECTION IV
MAJOR ENVIRONMENTAL ISSUES
ALTERNATIVES
Alternative Sites
The Draft EIS considers three alternative sites for the
proposed facility: the Mobile area (Rainbow Valley), the
Western Harquahala Plain, and the Ranegras Plain. These were
the three areas recommended by ADHS to the State Legislature
for its consideration in selecting a final site. ADHS's
recommendation was the result of its siting study, described in
"Final Report to the Arizona State Legislature Regarding Siting
of a Statewide Hazardous Waste Disposal Facility," January 1981.
Some commenters suggested alternatives other than those
considered in the Draft EIS. (See Section VI.) Specific
suggestions were:
a location that is a minimum of 30 miles from any
humans residences;
a location where there is no ground water beneath
the site;
Luke Air Force Gunnery Range.
In its evaluation of potential sites, ADHS weighed many
factors influencing selection of a site. Remoteness
from residents was one such factor. It was, however, weighed
against other factors, such as:
distance from the sources of hazardous waste (for
safety and economic considerations related to trans-
portation of the waste), and
the cost of developing the facility, including
the cost of developing roads and utilities and of
attracting the professional staff needed to operate
the facility.
Also, many extremely remote areas are game ranges, military
preserves, or reservations where the acquisition of land for a
facility would be difficult or impossible. The difficulty in
acquiring federal military land, for example, was one reason
ADHS did not recommend or study sites on Luke Air Force Range.
ADHS excluded from consideration large areas of the State
because of geologic conditions which might make construction or
IV-1
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monitoring of the facility difficult. These exclusions, in
addition to other exclusions discussed below, focused the siting
study on valleys and plains where ground water is generally
present. The key ground water criterion was its depth, 150 feet
being the minimum depth considered. The deeper the ground water,
the higher ADHS rated the siting area.
Since ADHS has already conducted a comprehensive siting
study which has been incorporated by reference into this EIS,
there is no need for further analysis of sites in this document.
To facilitate understanding of how the State arrived at its
recommended sites, however, the process and criteria used by
ADHS in evaluating potential sites are summarized here.
ADHS conducted a three-step site screening process through
which it arrived at the three sites recommended to the Legislature,
Each step involved a different level of analysis, including a
variety of environmental, economic, social, and institutional
criteria.
The Legislature set certain criteria in its bill mandating
the study (SB 1283, ARS 36-2800). The site could not be located
within:
a 100-year floodplain;
an area so close to public roads, residences, public and
private water wells and water supplies as to constitute
a threat to human health or the environment;
an area where depth to ground water is less than 150
feet within one mile of the site;
an area where the surrounding land use may impede the
long-term maintenance of the site;
an area where the hydrology and geology would be incom-
patible with a hazardous waste facility;
an area where subsidence has occurred or is likely to occur,
The Legislature also directed that transportation distances and
routings from those areas in the State which are major sources
of hazardous waste be factors in determining site location.
In addition, ADHS used other criteria obtained from state and
Federal regulations and from guidance documents and reports
prepared by other agencies.
Level One Screening
ADHS' s first step v/as to exclude areas of the state which
would not be suitable for a hazardous waste facility site. The
IV-2
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initial review excluded areas for the following reasons:
Geology is unsuitable, based on the need to be able to
predict pollutant movement beneath the site in case of
a release at the facility. This excluded areas where
fissures or faults in the subsurface might become
routes through which released contaminants could rapidly
enter ground water. It also exluded areas where shallow
bedrock or rock outcrops could make monitoring difficult
and costly.
Subsidence has occurred or is occurring.
Hydrology is unsuitable. Using existing maps, ADHS identi-
fied areas where ground water is less than 100 feet deep.
Subsequent analysis of the remaining areas identified
those meeting the Legislature's requirement that ground
water be at least 150 feet deep.
Development of a hazardous waste facility would be excluded
by law. This includes national parks, national monuments,
national recreation areas, wildlife refuges, and state parks,
Acquisition would be extremely difficult or time-consuming.
Areas such as Defense Department lands, national forests,
and Indian reservations were not considered feasible
because of the difficulty of obtaining purchase or
exchange agreements.
Level Two Screening
Land not excluded in the Level One screening was divided
into a number of specific siting areas for further analysis. In
this step, additional criteria were applied to exclude unsuitable
areas from further consideration. Areas were excluded on the
basis of the following criteria:
Existing or projected land use is inconsistent with
the operation of a hazardous waste facility.
The areas are not within a reasonable transportation
distance from hazardous waste generators (defined as
150 miles from Phoenix, source of 75% of the State's
hazardous waste).
The areas have a high potential to be affected by
subsidence.
The areas have a high potential for faulting,
fissuring , seismic activity, or other undesirable
geologic activity.
IV-3
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Level Three Analysis
Ten siting areas remained after the screening process was
completed. These were subjected to a comparative evaluation
using the following criteria:
Economic criteria
cost of land acquisition
cost of facility development, including roads, utilities,
and protection of the facility from floods and other
natural hazards
cost of operation, primarily employee salaries and
monitoring costs
Social criteria
health and safety impacts of transportation to the site,
based on distance from the sources of wastes, mileage on
limited access highways, number of communities on the
routes, and number of people living along the routes
degree to which location minimizes waste import risks
health and safety impacts from operation of the facility,
measured in terms of projected population within 5 and 10
miles of the site
potential nuisances to nearby communities from transportation
to or operation of the facility
potential scenic or aesthetic impacts of the facility
archeological or historical impacts of the facility
Institutional criteria
surrounding land use within 10 miles of the site
land ownership
surrounding water uses
Environmental criteria
depth to ground water
IV-4
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quality of ground water
annual precipitation
annual pan evaporation
annual sunshine
wind impacts
characteristics of soils underlying the site
characteristics of biological communities in the area
presence of threatened or endangered species of plants and
animals in the surrounding area
Based on the comparison of the ten sites using these criteria,
ADHS recommended selection of the Western Harquahala Plain site.
In its report to the Legislature, however, ADHS also stated that
the Rainbow Valley and Ranegras Plain sites were worthy of
consideration.
Resource Recovery and Waste Reduction
Several comments on the Draft EIS addressed the possibility
of recycling hazardous wastes or eliminating the generation of
waste that must be disposed of. In response to these comments,
the following discussion has been prepared to supplement the
section of the Draft EIS which deals with recovery/recycling
(DEIS p. 2-5).
With the implementation of stringent State and Federal
regulations, the cost of hazardous waste management has increased
substantially. The high disposal costs have forced manufacturers
to evaluate and redesign their processes in order to minimize
waste generation and disposal costs. This trend is expected to
continue with future refinement of the regulations.
One objective of the State and Federal hazardous waste
programs is to encourage resource recovery and minimize the
generation and disposal of hazardous wastes. As part of this
effort, ADHS has been working with the Arizona Chamber of Commerce
in an attempt to establish a Waste Exchange Program. Since one
person's waste may become another person's raw material, the
function of the Waste Exchange Program is simply to bring together
generators and potential users of wastes, thereby minimizing or
eliminating the need to dispose of certain wastes. The program
is presently under development, and it is not certain when or
whether the program will be implemented. If implemented, the
Waste Exchange Program could impact the proposed facility by
IV-5
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bringing about a change in the types and amounts of wastes shipped
to the facility. The extent of the impact cannot be determined
at this time.
The success of waste reduction efforts depends on the economic
feasibility of recovery or reduction and other considerations.
Certain of the wastes generated within Arizona are not recoverable,
either by law or because large-scale technologies do not exist.
These include pesticides, asbestos, and certain of the extremely
hazardous wastes. The technology for recovering metal values
from wastewater is readily available, but the economic viability
of metal recovery is a function of concentration (which is as
yet undetermined in the case of the proposed Arizona facility).
Sludges typically contain recoverable metals currently valued at
$44 per ton of received sludge.* Recovery of these metals by
electrolysis and roasting would cost over $400 per ton. While
many smelters routinely process ores worth (in terms of recoverable
metals) a quarter of the value of the sludge, their large scale
of operation justifies the exploitation of low-value ores. The
proposed hazardous waste facility would be processing only about
1.7 tons (dry weight) per day.
For those wastes which can be recovered, the proposed facility
could include resource recovery operations. The representative
design described in Appendix D of the Draft EIS includes a solvent
recovery system. Other systems could be implemented if economically
justifiable, but none appear to be economically feasible at this
time. Consequently, the need for disposal and treatment capacity
should continue to exist in the foreseeable future.
These figures are based on 1982 dollars and 1982 metal values
IV-6
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PHYSICAL SETTING
Seismology
This discussion of the recent seismic history of Maricopa
and Yuma Counties uses the Modified Mercalli scale.* Appendix E
reproduces the explanation of this scale which appears in Bulletin
193 of the Arizona Bureau of Geology and Mineral Technology (8).
In Maricopa County, in which the Mobile site lies, 23
earthquakes were recorded between 1875 and 1974 (the period for
which data are available). These earthquakes ranged in maximum
intensity from II to X on the Modified Mercalli scale (8). The
three most intense earthquakes recorded originated in California
(VII and X) and in Mexico (X). The most intense recorded earth-
quake which actually occurred (i. e., the epicenter was located)
in the County was ranked VI.
La Paz County, in which the alternative sites lie, was
created in January of 1983 from what had been the northern part
of Yuma County. Between 1872 and 1977, 112 earthquakes were
recorded in Yuma County. Of the ones which centered in Yuma
County, all but one ranged in intensity from II to VI on the
Modified Mercalli scale (8). The 1872 earthquake is estimated to
have been one which would be ranked VII on this scale, but this
kind of estimate is open to question, as it is based on historical
evidence such as letters, newspaper accounts, and local histories
(8). Sytematic earthquake reporting did not begin in the area
until 1910.
Over 70% of the earthquakes which have been recorded in both
Yuma and Maricopa Counties have been centered outside the State
of Arizona, commonly in California or Mexico (8). No earthquakes
ranked over VII have occurred in either county.
Federal regulations prohibit the siting of a hazardous waste
facility within 200 feet of a fault (See Section V). If the
facility were located at either of the two sites in La Paz County,
the operator would have to show in the hazardous waste permit
application that the facility meets this standard. This would
require geophysical and subsurface explorations during the
facility design phase. Because the seismic conditions in
* The Mercalli scale is used here for convenience in discussing
the seismic history of these two counties. EPA's seismic
location standard is based on the presence near a facility of
any fault active within recent geologic (Holocene) time
without regard to the magnitude of earthquakes experienced.
IV-7
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Maricopa County are different, the operator of a facility at the
Mobile site would not be required to demonstrate in the permit
application that the site meets the standard. For further
information on this requirement, see Section V.
Subsidence
Land subsidence in Arizona is usually associated with excessive
ground water pumpage. Subsidence, the physical depression of
the earth's crust, may result in the development of fissures
and cracks as well as changes in the slope of the ground surface.
Subsidence can result in the accelerated erosion of drainage
ways.
Some evidence exists that subsidence has occurred in parts
of Rainbow Valley near Heaton (9). These areas, however, are 13
to 14 miles from the proposed site, and are located in the eastern
side of the Valley where ground water pumpage has historically
been greater than in the area around the site (see Appendix F in
the Draft EIS).
The Mobile area is within the Phoenix Active Management
Area (AMA), designated under the provisions of the State's Water
Management Act in order to provide for better management of ground
water resources. The State Department of Water Resources (DWR)
is currently preparing a plan for the Phoenix AMA which, when
completed in early 1984, will identify issues related to ground
water management in the area. DWR will then develop guidelines
for addressing issues identified in the plan. Issues examined
will include subsidence problems. The hazardous waste facility's
ground water permit could include provisions designed to address
subsidence if a subsidence problem is identified in the Mobile
area.
If a potential subsidence problem is identified, the
facility may also be required to develop a plan for handling any
emergencies caused by subsidence at the facility (such as damage
to a landfill cell or surface impoundment liner). This would be
part of the contingency plan required in the facility's hazardous
waste permits issued by EPA and ADHS (see Section V).
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GROUND WATER
Ground water data for the specific parcels identified as
potential sites are very limited at this time. Consequently,
the EIS assesses ground water impacts using regional data from
U. S. Geological Survey studies and other available sources.
This assessment should should not be interpreted to be a conclusive
analysis of ground water conditions at the sites. Rather, it is
an overview of regional conditions which indicate possible or
likely conditions at the sites and suggest factors which should
be considered in developing and permitting a facility.
This assessment includes a discussion of the travel time
that might be required for ground water to move from each site
to the nearest existing off-site water supply wells. The Draft
EIS estimates it would take ground water 270 to 370 years to
travel from the Mobile site to the nearest existing wells, while
it would take an estimated 2,700 to 11,000 years at the Western
Harquahala Plain site, and 2,250 to 6,750 years at the Ranegras
Plain site.
Some readers interpreted these numbers to mean the time it
would take contaminants to reach ground water from the surface.
This is not the case. They indicate a range of travel times
which might be involved after contaminants had already entered
ground water. The Draft EIS states (DEIS p. 4-4) that "given the
substantial depth to ground water, it would likely take decades
for even a large release of contaminants to reach the water
table after leaking from the facility." This would be in addition
to the time it would take contaminants to travel to the nearest
existing wells. A more definite estimate of the time it would
take for contaminants to reach ground water was not made because
there is insufficient information about the subsurface at the
sites and about specific constituents of the hazardous waste and
how they would behave in the subsurface soils.
Several readers correctly commented that contaminants from
hazardous waste may travel at rates different from those presented
for ground water. Some may travel faster than ground water,
others slower. It should be clarified that the figures presented
in the Draft EIS are estimates for ground water, not for hazardous
constituents. While there is not a direct correlation between
ground water movement and the movement of hazardous constituents,
the travel times do provide a general indication of particle
movement which is useful in comparing the three sites for the
purpose of site selection.
The statement in the Draft EIS that "the concentrations of
contaminants would likely be very low by the time the contaminated
water reached the nearest wells" (DEIS p. 4-5) also generated
comments from readers. We agree this may be an overstatement
since it is couched in such general terms. However; experience
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at uncontrolled hazardous waste sites in semi-arid environments
has shown that some contaminants are removed and/or retarded in
the unsaturated zone, and that some dilution does take place for
some contaminants, when a plume of contamination travels over a
distance of several miles.
Prevention and Control of Ground Water Contamination
Several commenters expressed concern over various ways in
which ground water contamination might occur, such as the inter-
action of liquid wastes and the soils into which they are placed,
release of contaminants into wells, or contamination of shallow
ground water downstream from the facility. In this document, it
is not possible to make reasonable predictions about the chance
that ground water contamination could occur through any particular
set of circumstances. The kind of information needed to make
such assessments, such as how the facility is to be designed and
how particular wastes would be situated with regard to potential
contamination routes, would be available at the time the facility
operator applies for the permit to build and operate. Such
concerns would be addressed in the permit process.
The following discussion identifies how the permit could
address the potential ground water problems which have been
raised in comments on the Draft EIS. As the discussion of the
permitting process in Section V notes, the public would have an
opportunity to review and comment on these and other conditions
contained in the draft permit.
Release of Contaminants into the Subsurface Soil
Some readers are concerned that wastes could be released
through interaction with the soils and would move quickly
through the subsurface soils into ground water. While liquid
wastes or leachate coming into direct contact with the soil
could move downward into the ground water, the rate of movement
would depend on the particular soils and geology beneath the
facility and on the specific substances in the liquid or
leachate.*
* Leachate is a liquid which percolates through the waste and
combines with water-soluble waste constituents. Leachate will
travel down through the soil and enter ground water if it
exceeds the capacity of the soil to absorb it.
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To minimize the possiblity of such an event occurring ,
Federal and State regulations focus on keeping hazardous con-
stituents out of the subsurface soil. This is accomplished
through several provisions in the regulations, including the
following major requirements.
Use of liners and monitoring/detection systems. All new
waste piles, surface impoundments, and landfills must have
liners that are designed and installed to prevent any migration
of wastes out of the unit to the adjacent subsurface soil or to
ground water or surface water thoughout the active life of the
unit.* Since it is recognized that eventually any liner may
leak or be damaged, a detection system is required to monitor
for leaks or for the release of hazardous constituents into the
ground water. The regulations provide for two main options in
meeting this requirement: a single liner with a ground water mon-
itoring system, or a double liner with a leak detection system.
If a single liner were to be used, then a ground water
monitoring system would have to be established to determine
whether any hazardous constituents have leaked or leached out
of the facility and entered ground water. Monitoring wells
would be placed around the perimeter of the treatment, storage,
and disposal units (i.e., the boundary of the "waste management
area"). If monitoring indicated that contaminants had entered
the ground water, the facility operator would have to determine
whether contaminants were exceeding a standard set to protect
public health and the environment. If any contaminants did
exceed that standard, the facility operator would have to take
"corrective action" to clean up the ground water and prevent
further contamination.
* Federal regulations exempt a facility from this requirement if
the facility owner or operator can show that alternative design
and operating practices, together with location and waste
characteristics, will prevent the migration of any hazardous
constituents into the ground water or surface water forever.
Such a showing would involve extensive analysis of the the
subsurface geology, the nature of the ground water beneath the
site, the nature of the waste handled at the facility, and
other considerations. Given what is currently known about
ground water and the subsurface in the areas around site con-
sidered in this EIS, the expense of conducting such an analysis,
and uncertainties involved in making such predictions, this
option is not considered a viable one for the proposed Arizona
facility. Should the operator attempt to make such a showing,
however, the public would have an opportunity to review and
comment on it as part of the permit review process.
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In the double liner option, a leak detection system is placed
between two liners to determine whether the top liner is leaking.
The second liner would contain any liquid that had leaked through
the top liner. If a leak were detected, the operator would have
two choices: repair the leak in the liner, or allow the leak to
remain unrepaired but put into place a ground water monitoring
system. Under the latter option, any hazardous constituents that
continued to leak through the unrepaired liner would be detected
if they entered ground water. Corrective action would then be
required if hazardous constituents were present in amounts or
concentrations harmful to human health or the environment.
Because it provides for detection of leaks before hazardous
constituents have entered the subsurface, thus allowing time to
repair the leak, the double liner option exempts the facility
from the requirement to have ground water monitoring (unless,
as noted above, the operator opts for monitoring after a leak
has been detected in the top liner). The double lines option,
then, is considered to be as effective in protecting human health
as the single liner option with ground water monitoring.
The Draft EIS suggests that the double liner/leak detection
design might be more appropriate than the single liner/ground
water monitoring design at the particular sites considered for
the Arizona facility (DEIS p. 4-7). Because of the substantial
depth to ground water and the normally low moisture content of
the desert soils, it could be many decades before a ground water
monitoring system could detect a leak. Leak detection directly
under the liners would mean faster identification of potential
problems.
While use of the double liner/leak detection system should
be considered by the facility contractor in designing the facility,
this statement should not be construed as a requirement that the
contractor adopt this particular system. Final determination of
the liner design would be made by the contractor based on a
variety of factors considered in the overall design of the facility.
Since this would be part of the permit application, it would be
subject to agency and public review during the permit process.
Use of leachate collection/removal systems. For landfills
and piles, liners (single or double) are to be used in conjunc-
tion with a leachate collection and removal system. Such a
system would help minimize the possibility that leachate would
pass through the liners and enter the subsurface. The system
would collect any liquids draining through the treatment, storage,
or disposal unit so they can be safely removed.
Surface impoundments are not required to have a leachate
collection and removal system because of the large amounts of
liquids that are regularly placed in them. To minimize the
formation of leachate, liquid wastes in impoundments must be
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either removed or solidified before the unit may be closed. If
the waste is not removed, the impoundment must be covered (capped)
to prevent rainfall or other liquids from entering the impoundment
after it has been closed.
Controls on the placement of liquids into landfills. Two
provisions of the regulations are intended to minimize placement
into landfills of liquids would could leak or seep through the
liner. First, liquid wastes (those not in containers) may be
placed only into a landfill with a liner system that will prevent
the migration of wastes into the subsurface. That is, no liquids
may be placed into a landfill which is exempt from the liner
requirements unless the wastes have been treated or stabilized,
chemically or physically, so that free liquids are no longer
present.*
Containers holding liquids cannot be placed into a
landfill (even a lined one) unless all free-standing liquids
have been removed or absorbed or solidified, so that no free-
standing liquid can be observed. Excepted from this rule are
containers which are very small (such as an ampule) or which
are designed to hold.liquids for use other than storage (such
as a battery or capacitor).
Capping disposal units at closure. Disposal units, in
which wastes will be left permanently in place, must be covered
or "capped" when the unit is closed to prevent rainfall or
other liquids from entering the unit and forming leachate.t
The cover must be maintained for the entire "post-closure" period,
normally 30 years.** While the liner is the primary means of
keeping hazardous constituents out of the subsurface during the
active life of the facility, the cover is the main method of
protecting the subsurface after closure by minimizing the
formation of leachate within the disposal unit.
* The exemption from the liner requirement is discuss in the foot-
note on p. IV-11.
t Units used only for treatment or storage are not covered because,
at closure, all the wastes and waste residues must be removed
and disposed of in a disposal unit, leaving no wastes to leach
into the soil.
**The "post closure" period, during which the facility owner or
operator must maintain the unit covers and continue monitoring,
may differ from the normal 30 years under certain conditions.
For example, the occurrence of leaks or other problems could
cause the period to be extended.
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Placement of wastes. The regulations include restrictions
on the placement of wastes which are ignitable, reactive, or
incompatible. The purpose of these restrictions is not only
to avoid accidents (such as explosions or fires), but also to
protect the integrity of liners and other structural design
features which keep wastes from migrating out of the treatment,
storage, or disposal units.
Release of Contaminants into Wells, Holes, or Other Openings in
the Soil
Some commenters raised the possibility that contaminants
could enter ground water through wells at or near the facility.
The most likely wells to become routes of contamination would
be those nearest the units which handle the wastes, that is,
monitoring wells at the perimeter of the waste management area
and water supply wells on the facility grounds.
Ground water monitoring wells must be placed at the edge
of the waste treatment, storage, or disposal units, rather than
within the units or their structure (e. g., the dikes forming
impoundments). This is to avoid the possibility that the well
shafts would become a direct route for contamination or could
threaten the integrity of the unit (e. g., by weakening the
dikes). Wells at the perimeter must be constructed to avoid
contamination of the aquifer, through means such as sealing
the space around the well casing above the area where samples
are to be drawn (these measures also protect the samples from
contamination).
Placement of water supply wells at the facility is not
addressed in the regulations. The permit application, however,
would show the location of the supply wells in relation to the
treatment, storage, and disposal units. Any potential problems
with well placement would be addressed by the permit writer and
the applicant. Good engineering practice suggests that the
wells be placed upgradient (with respect to ground water) of the
areas where wastes are handled, that they be placed so that no
surface run-off from the active units flows toward the wells,
and that they be placed away from areas where trucks carrying
waste loads might spill wastes into them. Sealing the casings
could also help avoid contamination.
Wells, holes, fissures, or other openings in the surface on
property outside the facility could become routes for contamina-
tion of ground water if run-off from the treatment, storage, or
disposal units flowed towards them. To prevent this, facility
owners and operators are required to divert run-on (such as storm
water flowing onto the facility) away from these units, and to
contain run-off (liquids flowing out of the units) through the
use of containment dikes or other methods. The federal regulations
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require that, for waste piles and landfills, the run-off contain-
ment system be capable of containing the volume of at least a
24-hour, 25-year storm. For surface impoundments, the regulations
do not specify a storm level, but require that the impoundments
be designed, constructed, maintained, and operated to prevent
overtopping. The 24-hour, 100-year storm is recommended as a
guideline, however, since this is the most extreme (i.e., "worst
case") event for which data are readily available.
As the Draft EIS notes, the Mobile site appears to be subject
to intense storm water run-off from the surrounding watershed.
For that reason, ADHS has agreed to use the 100-year storm as
the standard for designing all run-on diversion and run-off
containment systems rather than the 25-year storm. According to
EPA estimates based on national statistics, use of the 100-year
standard rather than the 25-year standard could increase costs
to the facility operator by up to 25 percent (10).
Release of Contaminants into Shallow Ground Water
Some residents of the Rainbow Valley area have commented
that ground water can be found at very shallow depths of 10 to
40 feet at certain places in the Valley. They are concerned
that contaminants might be spread to soils in these areas
through storm water run-off from the facility or the settling
out of airborne contaminants. Their concern appears to be
that surface contamination could enter ground water through
naturally-occurring "recharge" of the aquifer in these areas
of shallow ground water.
Depth to ground water in the Waterman Wash/Rainbow Valley
area (as of spring, 1982) varies from greater than 400 feet in
the southern part of the basin (near the site) to approximately
100 feet in the extreme northwest part of the basin (11). Ground
water flow from both areas is toward a large cone of depression
just southeast of the 100-foot zone (See DEIS p. 3-8).
Twenty miles directly northwest of the proposed site is an
area within the Gila River recharge zone where the depth to water
is within several feet of the surface. This shallow depth is
due to recharge from upstream dam releases and irrigation return
flows. This basin is separate from the Waterman Wash/Rainbow
Valley ground water basis (i.e., ground water from one basin
does not flow into the other).
Storm water run-off from the facility or flood waters passing
through the facility, if uncontrolled, could carry contaminants
to natural recharge areas along Waterman Wash or the Gila River.
In that event, contamination of ground water through recharge
would be of concern if the concentration of contaminants were
significant. This can be prevented by designing and operating
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the facility to control run-off and prevent washout from floods
(see previous discussion and Section IV, Surface Water).
Settling out of airborne contaminants is not expected to
pose a problem. Winds strong enough to carry airborne particles
20 to 25 miles from the facility to the shallower wells in the
Gila River area would substantially dilute any pollutants
carried by the winds.
Contamination from Land Treatment Units
As the Draft EIS notes, land treatment or "landfarming" is
one of the methods through which the facility could treat biode-
gradable organic wastes or wastes which can be "immobilized"
within surface soils. In landfarming , wastes are tilled or
injected into top soils where microorganisms in the soil can
act upon them, degrading waste substances into non-hazardous
materials. Alternatively, the wastes may react with the soils
to remain stable or immobile.
Because of the size and nature of such operations, liners
and leachate collection systems are not practical means for
ensuring that hazardous constituents do not migrate to ground
water. Instead, operating and monitoring requirements provide
for protection of ground water. These include the following
measures:
• The operator must demonstrate that land treated wastes
will be adequately degraded or immobilized within the
"treatment zone," the top layer of soil (no deeper than
five feet) in which action on the wastes occurs. The
demonstration is made to ensure that each waste handled
in the landfarm can be treated such that hazardous
constituents are not expected to emerge from the
treatment zone.
• Ground water must be monitored unless the facility
operator can show that there is no chance that wastes
would enter ground water or pose a threat to human.health
or the environment. As with other types of treatment,
storage, and disposal units, ground water monitoring
of a land treatment unit would detect the presence of
contaminants in the ground water. If detected, the
amount of contamination would be determined and any
necessary corrective actions would be taken.
• Unsaturated zone monitoring is required to detect the
presence of hazardous constituents between the treat-
ment zone and the ground water aquifer. This type of
monitoring, which would take place directly below the
treatment zone, would provide feedback on the success
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of treatment in the treatment zone. Information obtained
would be used to adjust the operating conditions at the
unit in order to maximize degradation, transformation,
or immobilization of hazardous constituents in the
treatment zone.
It should be emphasized that unsaturated zone monitoring is
not a substitute for ground water monitoring. Both are required
at land treatment units. Ground water monitoring is designed to
determine the effect of hazardous waste leachate on the ground
water. Unsaturated zone monitoring generally cannot perform
that function. Instead, unsaturated zone monitoring simply
gives an indication of whether hazardous constituents are
migrating out of the treatment zone.
Hydrogeologic Data
Several readers commented on the insufficiency of the regional
ground water data used in preparing the Draft EIS. Some noted that
regional data could not be used to estimate adequately the time it
would take surface contamination to reach ground water and existing
wells, or to design a ground water monitoring program. Commenters
also noted that regional ground water conditions are likely to
change over time, and could be altered by water supply pumping at
the facility itself. Additional information was requested on the
types of hydrogeologic data which the facility operator (or other
parties) would be required to obtain in order to design the
ground water monitoring program.
EPA recognizes the limited nature of the ground water data
used in preparing the Draft EIS, and is not implying that such
data are sufficient to understand hydrogeologic conditions at
the sites for the purpose of designing either the facility or a
ground water monitoring program. Regional data have been used
because they are the only data available at this time and are
sufficient to provide a comparison of the range of likely ground
water conditions at the three sites in order to make a site
selection. It is also recognized that ground water conditions
may change over time, but it is not useful to speculate how they
might change without having a variety of data which are not
currently available (such as specific information about supply
wells to be located at the facility: location, pump rates,
etc.).
The additional ground water data that would be required
during the design and permitting processes depend a great deal
on features the permit applicant chooses to incorporate into the
facility design. A great deal of information would be needed
to design a ground water monitoring program. Under the Federal
regulations, however, it is possible that ground water monitoring
would not be required; e.g., where all units have a double liner
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with leak detection. To be exempt from the ground water monitor-
ing requirements, the facility owner or operator would have to
include with the facility permit application an engineering
report explaining the location of the saturated zone in relation
to the double-lined units. The information obtained for this
showing would not necessarily be as extensive as that obtained
for a ground water monitoring program.
The operator could choose the single liner option, or ADHS
could require ground water monitoring in addition to the use of
double liners and leak detection.* In this case, the operator
would have to study carefully the hydrogeologic setting in order
to place the ground water monitoring wells properly. It would
be necessary to determine parameters such as ground water depth
and the rate and direction of ground water flow. Through logs
of the well hole drillings, the geology of the subsurface could
be studied to determine soil types, indications of the presence
of faults, etc.
If ground water monitoring is implemented, the direction
and rate of ground water flow must be checked at least annually.
This is because the occurrence of a leak or a leachate problem
is determined by comparing the levels of hazardous constituents
downgradient of the treatment, storage, and disposal units with
their levels upgradient of the units. Consequently, it is vital
that the proper location of wells with respect to ground water
flow be determined. If the sampling indicates a change in the
ground water conditions (e.g., a change in ground water flow
rate or direction caused by new wells in the vicinity), the
monitoring program must be changed to meet the permit require-
ments. Consequently, if ground water monitoring is required,
regional ground water changes would be identified and taken into
account.
Another option in the regulations allows a permit applicant
to be exempt from ground water monitoring if the applicant can
show that, because of an extremely favorable hydrogeologic setting,
hazardous constituents would never enter ground water. Since
much of the data needed for such a demonstration may be subject
to scientific uncertainties, the regulations require that an
applicant for the exemption use assumptions which tend to maximize
the estimated rate of leaching, that is, the "worst case." Data
and assumptions that would likely be required in order to obtain
such an exemption include the following:
* In this case, optional use of ground water monitoring could be
subject to negotiations between ADHS and the facility contractor,
when the contractor is selected.
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The thickness or depth of soil underlying the regulated
unit should be determined. This factor can be determined
directly by soil core borings. If soil depth estimates
are used in the prediction, however, the minimum value
in the range of depth estimates should be selected.
The calculation of travel time should be based only on
natural soil properties, ignoring the effects of synthetic
or recompacted natural soil liners placed beneath the
waste.
The prediction should be based on the travel time of the
most dense and/or least viscous fluid in the regulated unit
(i.e., the fluid with the lowest kinematic viscosity). For
example, some solvents are less viscous than water and thus
are likely to move faster than water.
Since the depth of liquids or leachate in a unit can vary,
the prediction should assume that the unit is full of liquids
(i.e., the maximum possible hydraulic head).
The owner or operator should account for the effective
porosity of the soil when making a prediction. Estimates
of effective porosity are difficult to make. For this
reason, EPA believes that 10% effective porosity, a low
value, should be used to avoid the uncertainty involved
in estimating effective porosity and to ensure relatively
short travel time predictions for the soil beneath the
regulated unit.
Soil attenuation mechanisms should be ignored in travel
time predictions.
As another measure to increase confidence in a prediction
made to qualify for this exemption, EPA has required that the
owner or operator's demonstration must be certified by a qualified
geologist or geotechnical engineer.
Relationship Between Ground Water Data, Protective Measures, and
the Facility Permit
Some commenters wrote in support of specific ground water
protection measures, such as leak detection plus ground water
monitoring or monitoring below the second liner of the landfill
(in addition to leak detection between the liners). Both these
comments and those suggesting the need for additional data on
ground water conditions at the sites are valuable. EPA feels,
however, that it is not appropriate to commit the facility
contractor (who has yet to be selected) to any specific ground
water protection measures or ground water data requirements at
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this time for the following reasons:
Ground water measures must be tailored to the specific
design of the facility, which has not yet been developed.
Federal and State regulations allow the facility operator
certain flexibilities in achieving the environmental and
health-related goals of the hazardous waste management
program. For example, although the Draft EIS points out
that conditions at the site suggest that double liners
with a leak detection system would be a desirable design
feature, the facility developer would be allowed, under
these regulations, to propose the single liner/ground
water monitoring option in the permit application.
The design to be submitted with the permit application
would depend to a certain extent on the outcome of
negotiations between ADHS and the facility contractor.
Specific design, monitoring, and data requirements would
be fully addressed in the permit process. Since the permit
process is the "functional equivalent" of an EIS on the
facility design, it is not necessary to present information
or speculate about permit features at the "site selection"
phase.*
Consequently, EPA has determined that further data needs
and the commitment to specific ground water protection measures
should be left to the permit stage rather than presented in this
ElS.t The public would have an opportunity to review the permit
conditions and the pertinent ground water data during the
permitting process.
* See Appendix A, p. A-12, of the Draft EIS for a discussion of
EPA permits and the Federal EIS requirements.
t ADHS has prepared its own list of studies which Department staff
believe may be needed to adequately design the facility. This
list appears here in Appendix F.
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SURFACE WATER
Several commenters expressed concern over potential flooding
problems at the Mobile site. Several issues are raised in these
comments:
The threat to the Central Arizona Project canal and to
stock ponds.
Alternatives to the use of surface impoundments (ponds)
containing uncovered liquid wastes.
Assurance that flood protection measures would be adequate,
Consideration of the difficulties that flooding potential
poses for the design and operation of a facility at the
Mobile site.
Threat to the CAP Canal and to Stock Ponds
One commenter suggested a flood at the Mobile site could
wash contaminants into the Central Arizona Project canal and
consequently threaten the water supply of Tucson. The Mobile
site is 25 to 30 miles south of the CAP canal. The watershed
at the site drains into Waterman Wash, which empties into the
Gila River several miles south of the canal. Since floodwaters
from the site would drain into the Gila River near Buckeye, the
canal would not be affected by such flooding. The facility
would pose no hazard, then, to Tucson's drinking water supply.
(For a discussion of the impacts of a flood at the Mobile site,
see DEIS p. 4-8.)
Stock ponds currently exist at the Ranegras Plain site and
near the Mobile site. A stock pen also lies near the Western
Harquahala Plain site, although at the time of this writing its
water is contained in a metal tank rather than a pond. Nonethe-
less, surface waters could collect in low areas during a heavy
rain and would be accessible to cattle in the area.
The chance of sheet flooding washing spilled chemicals into
these ponds is small for several reasons. There is only a low
probability of a spill during either the transport of waste or
operation of the facility (e.g., during transfer of waste from
trucks to facility units). Since the annual amount of rainfall
is low in these areas, the probability of a spill during or just
before a rainstorm is significantly lower still. The permit
conditions could further minimize this possibility by requiring
special operating procedures at the facility during stormy weather
(especially during the months of heaviest rain—July, August,
and September). For example, the facility's "contingency" plan,
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required as part of its permit, could establish that under
certain weather conditions likely to produce heavy rainfall,
operations susceptible to spills should be restricted. The plan
would establish spill response procedures; prompt clean-up of
spills would reduce the possibility that sheet flow could come
into contact with contaminants.
Alternatives to Surface Impoundments
Surface impoundments (ponds) are of concern because they
would hold large amounts of liquid wastes and could overflow if
an excessive amount of rainwater fell directly into them.*
Flood waters could also potentially breach the berms forming the
impoundment and cause massive release of wastes.
Impoundments are an economical means of handling large
amounts of liquid wastes for certain purposes. In the Arizona
desert, use of evaporation ponds could be a highly effective way
to reduce the water content of some wastes to form a sludge that
could be readily landfilled or landfarmed. Acid or alkaline
wastes could also be neutralized in large quantities.
Alternatives to surface impoundments, such as covered tanks,
could be viable for some operations. However, these would likely
be much more expensive than impoundments. The facility operator
would have the option of using such an alternative in designing
the facility. Given the advantages of using impoundments to
store and treat a variety of bulk liquid wastes in an economical
manner, though, it is not likely the operator would choose to
avoid impoundments completely in favor of more costly methods.
Also, tanks would not be viable for reducing the volume of wastes
because of the large surface area required in solar evaporation
techniques. The question then becomes one of assuring that
surface impoundments, as well as other parts of the facility,
are adequately protected. This question would be addressed
through the permit, as described below and in Section V.
Adequacy of Flood Protection Measures
Two sets of standards in the federal regulations for
hazardous waste facilities deal with problems related to storms
and flood waters: a floodplain location standard, and run-on/
run-off controls.
* Surface impoundments are not normally covered because of their
size and function and the nature of the wastes placed in them.
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Floodplain Location Standard
Federal regulations require that a hazardous waste facility
located within a 100-year floodplain be designed to withstand the
100-year flood (see Section V). Floodplain maps for the Ranegras
Plain and Western Harquahala Plain sites show both sites well
outside the 100-year floodplain in that area. Consequently, a
facility located at either of these sites would not be subject to
the 100-year flood protection requirements. The facility would,
however, be subject to the run-on and run-off controls discussed
below.
Floodplains in the vicinity of the Mobile site have not
been delineated. Before a permit could be issued to build and
operate a facility at that site, the 100-year floodplain would
have to be identified. There are significant technical problems
in doing this, however, due to the nature of drainage patterns
in the area. Generally, floodplains exist around well-defined,
relatively fixed stream or river beds. When the water level
rises above the banks, the overflow follows an identifiable
flooding pattern based on the amount of overflow and the topo-
graphy of the surrounding area. In the case of the Mobile site,
however, numerous channels or washes cross the area. Stormwater
is likely to flow over a wide area, at a low depth but at a high
velocity. Under these conditions, the shallow channels may be
frequently changed by the stormwaters flowing over the alluvial
plain. (The fact that vegetation is sparse is another factor
inhibiting the formation of permanent drainage channels.)
Although some of the washes crossing the site are relatively
well-defined, the changing nature of the overall drainage pattern
makes it very difficult to identify a floodplain. EPA and ADHS
are working to determine a suitable method of analyzing the
floodplain so that the facility's compliance with the floodplain
location standard can be determined during the permitting process.
Run-on/Run-off Controls
Federal and State regulations also require that hazardous
waste facilities be designed to prevent storm waters from run-
ning onto active treatment, storage, or disposal units (run-on)
and to prevent waters which have collected in these units from
flowing out into the environment (run-off). Under the Federal
regulations, run-on controls for land treatment units, waste
piles, and landfills must protect against the peak flow of at
least a 25-year storm. Run-off controls for these units must at
least contain the run-off volume from a 24-hour, 25-year storm.
Surface impoundments must be designed to prevent "overtopping"
from rainfall, run-on, and other causes; though no storm standard
is set, EPA recommends designing to prevent overtopping from at
least a 24-hour, 100-year storm.
IV-23
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At the Mobile site, run-on from high-intensity storms,
flowing over a wide area, could pose a significant problem at
the hazardous waste facility. For this reason, ADHS has agreed
that the facility contractor should design the facility to protect
against a 100-year storm rather than a 25-year storm, if placed
at the Mobile site.
As noted in the discussion of floodplains, stormwaters at
the Mobile site would tend to flow over a wide area rather than
from an identifiable floodplain. In a sense, then, protecting
the facility against run-on from the 100-year storm would provide
substantially the same protection that would designing for a
100-year flood. Consequently, use of the 100-year storm standard
for design of the run-on control system should provide a high
level of protection at the facility.
Design Considerations
There is a certain amount of risk involved in any design
for purposes of flood protection. In general, flood risk is
composed of both hydrologic risk and structural risk. Structural
risk refers to the probability that a structure will fail during
an event (flow) of lower magnitude than the design event. This
is usually assumed to be zero, given proper engineering and
construction. Hydrologic risk, on the other hand, is based on
the uncertainty of events (flows) with magnitude greater than
the structure design event. This is usually determined by the
proposed lifetime of the facility. Table IV-1 indicates the
probability of one or more more flows equal to or exceeding
design capacity (the designed flood protection measures). For
example, if the hazardous waste facility has a proposed lifetime
of 20 years and an additional 30-year period during which it is
monitored after closure, the flood protective measures could be
designed for the 50-year design flood. If so, there would be
a 64% chance that a flood greater than or equal to the 50-year
flood would occur sometime during the 50-year period. (See
Table IV-1.) Similarly, the chance that of at least one flood
of this magnitude would occur within 50 years is 39%.
Obviously, the risk of experiencing one or more flows greater
than or equal to the flow used as the design standard depends on
which event is used as the standard. The more stringent the
design requirements, however, the higher the construction costs.*
Consequently, the additional cost of such requirements must be
* For example, EPA estimates that a run-on control system designed
for a 100-year storm could cost 7 to 25% more than a system
designed for a 25-year storm, depending on location, watershed
size, and unit size and design (10).
IV-24
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Table IV-1.
Percent probability of one or more flows greater
than or equal to the design flood in relation to
the years of facility operation.
No. of Years of
Operation
5
10
20
25
50
75
100
Return Period (Design Flood)
25 50 100 500
18
34
56
64
87
95
98
10
18
33
40
64
78
87
5
10
18
22
39
53
63
1
2
4
5
10
14
18
Source: Reference 12
weighed against the benefits provided in terms of protecting
health and the environment (and the possibility that stricter
design requirements may lower the cost of the owner's and
operator's liability insurance).
IV-2 5
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AIR QUALITY
An area of great concern among those who commented on the
Draft EIS was the potential for release of contaminants into the
air. Several questions were raised about the effects of weather
conditions on the facility, especially the effects of inversions
and "dust devils" (rotating columns of air which carry dust or
sand). Commenters also raised the issue of incineration and its
overall impact on air emissions from the facility. Finally,
some readers commented on air pollution monitoring requirements
and on dust problems related to the facility. The following
discussion addresses each of these areas of concern.
Effects Of Weather Conditions On Air Emissions
A temperature inversion (or "inversion") is a meteorological
condition in which temperature increases rather than decreases
with height through a layer of air. This creates a stable layer
of the atmosphere which suppresses vertical air movement, thereby
serving as a "lid" for gases which would otherwise rise from the
earth's surface.
In an inversion, little dispersion of air pollutants occurs.
Rather, the pollutants tend to remain at the level at which they
are emitted. Consequently, emissions from an incinerator stack
would not quickly disperse higher into the atmosphere nor mix
toward ground level.
On the other hand, emissions from a surface impoundment, a
landfarm, a landfill, or a spill would concentrate at ground
level. Under these conditions, a light wind of about 2.5 meters
per second (5 miles per hour) would create a "worst case" air
emissions situation, since the wind would increase volatilization
while providing minimal dispersion of the pollutants. Winds in
excess of 2.5 meters per second would increase volatilization
but also cause dispersal of gases in the ambient air. The assess-
ment of toxic emissions from the landfarm assumes a "worst-case"
wind speed of 2.5 meters per second. (See DEIS pp. 4-13 and
G-5.) The hazardous waste spill scenario presented here in
Section IV, Public Health and Safety: Spill Risks, also assumes
this wind speed.
Several commenters raised the possibility that high winds
(such as dust storms and dust devils) common to the desert could
transport contaminated particles from the facility to population
centers to the east. High winds are particularly common during
the summer when subtropical storms pass through Mexico and into
Arizona.
Dust devils occur sporadically, generally during the late
morning through mid-afternoon hours on days with light winds and
IV-2 6
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intense solar heating (i.e., clear skies). They are formed when
a localized parcel of air next to the surface becomes superheated,
and rises to form a swirling column of air. Wind speeds in the
larger dust devils can approach 40 mph or more, over an area up
to several hundred yards in diameter. In this localized area of
high winds dust can be suspended and transported along the path
of the dust devil. These disturbances last for only a few minutes
because their energy source (localized surface superheating)
rapidly dissipates.
More significant wind-related problems could occur during
dry summer thunderstorms or dust storms and during the springtime
when sustained strong winds are the most common. Based upon
Phoenix wind data, strong winds (>20 mph) occur nearly 1.0 percent
of the time in the area of the Mobile site. Phoenix weather
records indicate that annual and monthly average wind speeds are
in the range of 5 to 10 mph. Peak gusts of up to 86 mph have
been recorded during severe thunderstorms. High velocity winds
have been recorded from all compass directions, but extreme
winds from the west through southeast are most -common.
Information on the types and amounts of waste to be handled
at the facility and on the treatment and disposal processes to be
used is not available in sufficient detail at this time to project
the potential transport of contaminated
particulates and potentially toxic volatile organics under high
wind conditions. EPA agrees that this problem needs to be
addressed in the facility's hazardous waste permit, when more
detailed information would be available. There are two provisions
in the Federal regulations which address this problem:
• a requirement that wind dispersal of particulate matter
from piles, landfarms, and landfills be controlled
(40 CFR 264.251(f), 264.273(f), and 264.301(f)); and,
• a requirement that the facility be designed, constructed,
maintained, and operated to minimize the possibility of
an "unplanned sudden or non-sudden release of hazardous
waste or hazardous waste constituents into air" (40 CFR
264.31 ) .
In applying for the permit, the facility operator would
show how these requirements would be met. The following types
of data should be provided in the application:
• Types, concentrations, and volatility of chemical compounds
typically contained in the wastes to be handled at the
facility.
• A description of analytical techniques which will be used
to analyze incoming waste samples for volatile or toxic
content.
IV-2 7
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• Documentation of the expected volatilization from treatment
and disposal units.
• Documentation of the potential for dust storms or dust
devils at the site to cause pollution problems in
populated areas.
• A plan for monitoring meteorological parameters such as
wind speed and direction and ambient temperature.
• Documentation that adequate cover material for landfills
and adequate depth of subsurface injection for land
treatment will be employed.
• A plan for changing operations when weather conditions
could lead to elevated emissions of potentially toxic
compounds.
• A preventive maintenance and inspection plan for equipment,
to minimize the possibility of "sudden unplanned" emissions.
• A provision in the facility's emergency response contin-
gency plan for controlling unplanned emissions, focussing
on high probability or high exposure incidents.
In the permit process, a determination would be made whether
pollutant dispersion measures proposed by the facility operator
would be adequate to meet the requirements in the regulations.
Adequate control measures would then become a condition of the
permit which the operator would have to observe.
In addition, ADHS may wish to require the following informa-
tion to ensure compliance with State regulations which require
appropriate equipment devices which are adequate to monitor and
control the escape of fumes and gases into the environment
(Arizona Regulation R9-8-1821 A.2):
• Evidence that maximum removal of volatile organics from the
wastes prior to treatment will occur (i.e., through solvent
recovery distillation, steam stripping, etc.).
• Evidence that processes to remove volatile organics will
have effective emission controls, such as carbon adsorbers,
in place.
Potential Emissions from a Facility With Incineration
The representative facility design used in the Draft EIS
does not include any "high technology" treatment process, such
as high temperature incineration. After the Draft EIS had been
published, ADHS received a proposal which included an incinerator.
IV-2 8
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The bidder, ENSCO Inc., submitted comments on the Draft EIS
noting that this should be addressed in the Final EIS. (See
Section VI.) Other commenters also suggested the Final EIS
consider "high technology" alternatives.
As a result of these comments, the following analysis has
been prepared to estimate potential air emissions from a facility
with an incinerator. The analysis is in a format which allows
comparison between these estimates and the air emissions esti-
mates for the representative facility design used in the Draft
EIS. The analysis makes the following assumptions:
• The wastes handled by the facility are the same types and
quantities as the facility waste stream described in the
Draft EIS with one exception: 10,000 to 12,000 tons per
year of polychlorinated biphenyls (PCBs) would be added
for treatment in the incinerator.
• Certain wastes which, in the design used for the Draft EIS,
would have gone to the landfill (chlorinated solvents) and
the landfarm (biodegradable organics) would be incinerated.
This would eliminate the need for a landfarm, although a
reduced landfill operation would continue to handle incin-
erator residues (ash) and some other solid or stabilized
wastes.
• As in the Draft EIS, acids and alkalis, and wastewaters
with heavy metals and/or cyanide would be placed into
surface impoundments and wastes in the "various solvents"
category would be treated in a solvent recovery unit.
These assumptions have been made in order to provide a
basis for comparison of the air quality impacts of an incinerator
operation with those of the land-based treatment and disposal
operation assessed in the Draft EIS. Because actual emissions
from the facility would vary according to its specific design
and operating features, and the types and quantities of wastes,
these estimates should be viewed as an indication of possible
emissions rather than a precise projection.
Volatile Organic Compounds
Volatile organic compounds (VOC) are of concern because
excessive amounts of VOC (in combination with oxides of nitrogen)
can lead to the formation of ozone or "smog" and because some
volatile organics are documented or suspected toxic compounds.
Table IV-2 below shows estimated VOC emissions from the repre-
sentative facility design without incineration (Representative
Design #1) and a facility design with incineration (Represen-
tative Design #2). VOC emissions estimates for the incinerator
are based on EPA regulations which require that an incinerator
IV-2 9
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destroy or remove 99.9999% of the PCBs and 99.99% of other hazard-
ous waste constituents.*
At these removal rates, the anticipated 10,000 to 12,000
tons per year of PCB wastes would result in emissions of approxi-
mately 0.01 tons per year, while 238 tons of biodegradable organic
wastes would result in emissions of approximately 0.02 tons per
year.
As Table IV-2 shows, VOC emissions from a representative
"high technology" facility would be far less than emissions from
a facility which is landfills and landfarms the same wastes.
These estimates also indicate that an incinerator handling these
quantities of wastes in an enclosed manner would not likely
need a PSD air quality permit, since the VOC emissions are well
below 250 tons per year. (See DEIS pp. 4-10 and 4-13 for a
discussion of PSD permits.) It is possible, however, that if
the solvent recovery unit were operated at full capacity of 3600
tons per year, VOC emissions from the unit could exceed 250 tons
per year.t In that case, an air quality permit would be required.
On the other hand, emissions control techniques that would likely
be used on the solvent recovery unit could keep VOC emissions to
a much lower level. An estimate of VOC emissions from a specific
unit or design would have to be made to determine whether a PSD
permit would be needed.
It should also be noted that use of the incinerator at full
capacity, which would mean about a ten-fold increase in the
amount of wastes being treated, would increase VOC emissions to
an estimated 0.4 tons per year.** This increase is insignificant
relative to the amounts of VOC emitted by the representative
facility without incineration.
* Under EPA's PCB regulations (40 CFR 761), the mass air emissions
from an incinerator burning non-liquid PCBs can be no greater
than 0.001 gram PCB per kilogram of PCB introduced into the
incinerator; hence, 99.9999% of the PCBs would be removed. No
mass air emission limit is set for liquid PCBs; however, incinera-
tors generally are able to meet the 99.9999% rate. The require-
ment to remove 99.99% of the hazardous constituents in hazardous
waste is contained in a different set of regulations. (See 40
CFR 264.)
t The Draft EIS assumes 300 tons per year would be treated in the
solvent recovery unit. The full capacity estimate (900 Ib/hour)
is from ENSCO (13).
* *
The full capacity estimate is from ENSCO (3)
IV-30
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Table IV-2.
Volatile organic compound (VOC) emissions
representative facility designs.
for
Waste Type
Chlorinated Solvents
Various Solvents
Biodegradable Organics
Acids/Alkalis, Waste-
water, Cyanides
PCBs
TOTAL
Rep. De:
No Incir
Process
landfill
solvent
recovery
landf armt
surface
impound. **
none
sign #1*
leration
Emissions
( tons/year )
40-157
3-30
12-71
0-40
none
55-298
Rep. D«
with Inc
Process
inciner .
solvent
recovery
inciner.
surface
impound .
inciner.
3 s ig n #2
: inerat ion
Emissions
( tons/year)
0.02
3-30
0.02
0-40
0.01
3-70
* From the Draft EIS, pp. 4-13 and 4-14, and Appendix G.
t The Draft EIS poses two scenarios for the landfarm. The first
assumes the facility has no solvent recovery unit, so wastes in
both the "various solvents" and "biodegradable organics" cate-
gories are treated in the landfarm. The second scenario
assumes there is a solvent recovery unit which treats the
"various solvents," while biodegradable organics go to the
landfarm. Since the ENSCO proposal includes solvent recovery,
only the second scenario is included for this comparison.
**In the Draft EIS, one figure of 40 tons per year is given for
VOC emissions from the surface impoundments. This may be
somewhat misleading. No theoretical calculations were made for
the surface impoundments because the representative design does
not call for disposal of organic compounds in the surface
impoundments. Because other facilities do place such compounds
in impoundments, however, this possibility can not be ruled out
at the proposed facility. Consequently, an empirical measurement
made at another hazardous waste facility was used to estimate a
maximum emission rate of 40 tons per year. It is more accurate
to present this as a range of 0 to 40 tons per year to account
for the possibility that no organic compounds would be placed in
the impoundments.
IV-31
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Toxic Emissions
Test data from two operating incinerators show emissions of
two potentially toxic pollutants which could be emitted from the
incinerator; dioxin (tetrachlorodibenzodioxin, or TCDD) and
furan (tetrachlorodibenzofuran, or TCDF). These two substances
have been identified as by-products of PCB incineration.
The source tests detected emissions at levels ranging up to
0.039 ng/dscf for dioxin and 12.0 ng/dscf for furan.* Risk
assessments were performed by EPA to determine the impact on
public health from dioxin and furan emissions from the stationary
incinerators in Arkansas and Texas. For the Arkansas incinerator,
the additional risk of cancer was calculated to be less than
one case per 2.5 million people exposed (14).t At the Texas
facility, the additional risk was estimated at less than one
case per 50,000 exposed persons (15).
Insufficient data are available at this time to project the
potential emissions of TCDD and TCDF from the proposed Arizona
facility. Emissions estimates would have to be made before the
facility would be issued a PCB-disposal permit by EPA. Based on
the emissions estimates, EPA would conduct a risk assessment to
identify the potential risk to public health posed by the emis-
sions (see the following discussion of mitigation measures).
Particulate Emissions
While construction activities were the only significant
source of particulate emissions identified for the representative
facility addressed in the Draft EIS, inclusion of an inciner-
ator could alter the level of Total Suspended Particulates (TSP)
emissions from the facility. Particulate emissions (in the form of
ash, condensed vapors, or soot) have been measured at existing
incinerators and have ranged from 1 to 91 tons per year. Assuming
a "worst case" emission rate at the proposed facility of 91 tons
per year, the incinerator would add 13 ug/m3 particulates to
the ambient air concentrations (24-hour average).
* ng/dscf » nanograms per dry standard cubic foot (10~9 grams/dscf)
t The emissions used to calculate the risk were 0.005 ng/dscf
for TCDD, and 0.060 ng/dscf for TCDF. These were the average
emissions from the stationary incinerator. The higher numbers
which appear above (0.039 ng/dscf for TCDD; 12.0 ng/dscf for
TCDF) are from a mobile incinerator. A risk assessment has
not been conducted for the mobile incinerator.
IV-32
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Particulate emissions from the incinerator, combined with
dust emissions caused by construction activities (estimated to
be 10-11 ug/m3),* would not be expected to exceed air quality
standards. They would nonetheless add to the existing problem
of naturally-occuring particulate problems at each of the sites
caused by dust storms, etc.
Mitigation Measures
In the case of construction activities, surface impound-
ments, and solvent recovery, measures to mitigate air pollution
problems would be the same as those identified in the Draft EIS.
Toxic emissions. If the selected contractor includes a PCS
incinerator in the final design submitted to the State, EPA
would conduct a quantitative risk assessment, such as those
conducted for other PCB facilities, to determine any potential
health risks posed by incinerator emissions. This would be
used in the permit process to guide permit writers on necessary
design or operating conditions to mitigate significant potential
health risks.
A risk assessment estimates the probability of occurrence
of some adverse consequence per unit of specified time and per
unit of specified population. In other words, using the same
approach as the risk assessments for the other two PCB inciner-
ators, the assessment could identify the probability that one
additional cancer case would occur over a 70 year period per
X number of exposed persons (e. g., one cancer case per 50,000
exposed persons; one per million, etc.).
Additional sampling of air emissions from the existing
mobile incinerator may be needed to conduct the assessment (at
a cost of roughly $50,000). That data would be modeled to show
the maximum concentration of the compounds in the atmosphere.
A cancer risk factor would be applied to that maximum concen-
tration to arrive at the potential cancer risk. In determining
an acceptable level of risk, decision-makers would need to
consider the number of persons who could be exposed to that
concentration.
Particulates. The amount of particulate emissions from the
incinerator would be a function of the amount and types of wastes
burned and the efficiency of the burn. Operating conditions
established in the facility's hazardous waste and PCB disposal
permits would minimize particulate emissions.
* See Draft EIS pp. 4-12 and 4-15.
IV-3 3
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Monitoring of Facility Emissions
Facility emissions subject to monitoring would be monitored
on-site by the facility operator. The specific requirements would
depend on the source and type of emission.
Solvent Recovery
The State could require monitoring of the solvent recovery
unit under the State hazardous waste regulations. Depending on
the amount of wastes handled in the recovery unit and the
anticipated emissions of VOC, an air quality permit (PSD) might
also be required in addition to the hazardous waste permit (see
DEIS pp. 4-10 to 4-13). This is not expected to be the case, but
a final determination would depend on the specific design and
operating plans of the facility contractor.
Incinerator
If an incinerator were located at the facility, EPA would
require that the exhaust emissions be sampled and analyzed to
verify that the operating requirements established in the permit
achieve the required performance standards. These standards
require destruction and removal of 99.99% of each principal
organic hazardous constituent (POHC) identified in the permit.
When an incinerator is first used to dispose of PCBs, the
operator must sample stack emissions for several substances,
including PCBs and Total Particulate Matter (see 40 CFR 761.70).
The operator must also monitor certain combustion parameters
whenever PCBs are incinerated to indicate that the operating
requirements are being met.
Other Toxic Pollutant Emission Sources
Federal regulations contain no specific requirements for
monitoring toxic pollutants from surface impoundments, waste
piles, landfills, or land treatment units. As noted earlier,
however, there is a prohibition against the "unplanned release
of hazardous wastes or hazardous waste constituents into air"
(40 CFR 264.31). In order to show compliance with this standard,
the facility operator would have to demonstrate what emissions
were expected to occur normally during operations, then monitor
to see whether these normal conditions were exceeded.
IV-34
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In addition, the State hazardous waste regulations require
appropriate equipment adequate to monitor and control the escape
of fumes and gases into the environment. These monitoring
requirements would be established as part of the facility permit.
Dust Control
Some comments on the Draft EIS addressed the potential dust
problem due to construction activities and truck traffic on
unpaved roads. The Draft EIS states that "ADHS would ensure
that the contractor minimizes the impacts of fugitive dust" and
suggests several measures that could be taken to accomplish this
(DEIS p. 4-14). The measures address both the temporary problems
caused by construction activities and additional potential
problems during operation of the facility.
ADHS is committed to working with the contractor to implement
dust control measures at the sites. To control dust generated by
truck traffic on the access road, ADHS would require the use of
some form of dust suppressant until the roads are paved.
Under the conditions of the contract with ADHS, the facility
contractor would pave six miles of road leading into the facility.
At the Western Harquahala Plain and Ranegras Plain sites, that
would cover the entire distance between the sites and 1-10. At
the Mobile site, however, some 15 miles of dirt road between
Mobile and Maricopa would remain. It is possible that Provident
Energy Company would pave that segment of the road to provide
access to its proposed refinery at Mobile. At this time, however,
it is not certain whether this project will proceed, or, if it
does proceed, whether the company would pave all or only part of
the road segment. (This is more fully discussed in the following
section, Public Health and Safety: Spill Risks.)
An average of one to two trucks per hour would be expected
to travel to the hazardous waste facility. If the road were
unpaved, dust generated by these passing trucks could affect
other travelers on the road as well as adjacent lands, including
the Gila River and the Ak Chin Indian Reservations, which lie
adjacent to the road at,certain points.
It should be noted that dust problems are common in the
desert areas of Arizona. As the Draft EIS notes, violations of
the "particulates1" air quality standard in the vicinity of the
proposed sites have been attributed to natural causes such as
dust storms rather than man-made causes.
While air quality monitoring does not take place in the
Mobile or Maricopa areas at this time, ADHS has the ability
IV-3 5
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to monitor if needed.* ADHS would respond to complaints about
excessive dust problems from truck traffic on the unpaved road
by monitoring along the road and working with the facility con-
tractor to mitigate any problems identified. While paving the
road would be the best mitigation measure, periodic use of dust
supressants along the road could help to control the problem.
* An air monitoring station northwest of Maricopa, from which
data were drawn for the Draft EIS, was closed in 1982.
IV-3 6
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PUBLIC HEALTH AND SAFETY: SPILL RISKS
Risks from Transporting Hazardous Waste
A number of comments on the Draft EIS concern issues related
to transportation of hazardous waste to the proposed facility.
These concerns relate primariliy to:
the risk from transport of hazardous waste compared to
the risk posed by transport of hazardous materials; and,
specific safety problems on the access routes to the
Mobile site, including the use of two-lane roads, the
condition of those roads, and the proximity to schools
in Maricopa and Mobile.
Background: The Draft EIS
The Draft EIS presents a risk assessment based on the
shipment of wastes from Phoenix and Tucson to each of the three
proposed sites. This- represents nearly 90 per cent of total
wastes generated in Arizona expected to be transported to the
hazardous waste facility. Using the total volume of wastes
generated in each city and the average volume or weight of wastes
transported per vehicle, a determination was made on the number
of trips that would originate annually from Tucson and Phoenix.
Possible routes from the two metropolitan areas to the three
proposed sites are identified. Descriptions of the alternative
routes are described in Tables 4-4, 4-5, and 4-7 (DEIS pp. 4-19,
4-20, and 4-23, respectively). Using accident statistics from
the Arizona State Department of Transportation for each route,
accident rates were estimated. An accident rate for a particular
route would show the number of accidents that had occurred for
every 1,000 vehicle miles. For example, Route A (DEIS Table 4-4)
from Tucson to the Mobile site has an accident rate of 0.0006
accidents per 1,000 vehicle miles. The accident probability is
an estimate of the expected accidents per year of motor vehicles
carrying hazardous waste. The accident probability is determined
by first estimating the total distance traveled yearly by motor
vehicles carrying hazardous waste between Phoenix and Tucson and
the three proposed sites. The accident rate along a designated
route is applied to this distance to determine the accident
probability—the number of accidents expected yearly by hazardous
waste carriers.
Tables 4-4, 4-5, and 4-7 in the Draft EIS show that expected
accidents by motor vehicles carrying hazardous waste would be
extremely low, less than one per year. The analysis does not
consider the probability of a release of waste material into the
environment as a consequence of an accident. Not all accidents
IV-3 7
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would result in the release of hazardous material. Thus, the
risk estimates in the analysis may be somewhat overestimated.
The route with the highest accident probability and highest
population risk factor* is the route from Phoenix to the Western
Harquahala Plain and Ranegras Plain sites, along Interstate 10.
Because 1-10 is not completed between Phoenix and Avondale,
travel on surface streets (primarily Buckeye Road) is required
on that portion of the route. A relatively high accident rate
on this segment increases the overall accident rate along the
entire route.
As noted in comments on the Draft EIS, completion of this
segment of 1-10 would be expected to lower the accident rate and
the population risk factor on this route. One commenter felt
the use of the higher accident rate overstates the actual risk
of transport to the alternative sites compared to the risk of
transporting wastes to the Mobile site.
We agree that the accident rate is likely to be reduced
upon completion of 1-10. This does not guarantee, however, that
the risk factor of this route would necessarily be significantly
lower than that of other routes. Even if completion of 1-10 meant
the current accident rate were cut in half, the population risk
factor would be approximately 9,300. This compares with factors
of 9,312, 17,212, and 2,088 for the alternative routes from
Phoenix to the Mobile site.t
Transportation of PCB Wastes
If a PCB incinerator were included at the proposed Arizona
facility, it is estimated that approximately 360 shipments of
PCB waste would be delivered to the facility annually (6). This
would average to one to two trucks per day in addition to the
estimated 8 trucks per day delivering hazardous wastes generated
within Arizona.
This estimate is based on projected shipments from major
cities in Western states, as shown in Table C-1, Appendix C.
The majority of these shipments, about 270 per year, would be
expected to enter Arizona from California on Highway 1-10.
Most of the other shipments would likely enter Northern Arizona
on U.S. 89 or 1-40, then take 1-17 from Flagstaff to the Phoenix
* See Appendix N of the Draft EIS for an explanation of the steps
involved in arriving at the population risk factor.
t It should be noted that the figure of 2,088 is for the Mobile
access route preferred by ADHS.
IV-3 8
-------
area and tollow the previously identified access routes to the
facility (see Figure IV-1). About a dozen PCB shipments would
be generated each year in the Phoenix area.*
Appendix D presents an analysis of the additional risk
that PCB shipments would present along likely site access routes.
Routing an additional 89 trucks per year through or from the
Phoenix area to the Western Harquahala Plain or Ranegras Plain
sites via 1-10 would increase the population risk factor along
that access route by about four percent over the risk presented
by hazardous waste shipments generated within Arizona (as analyzed
in the Draft EIS; see DEIS p. 4-25). Routing the PCB shipments
to the Mobile site would increase the population risk factor
along the preferred access route from Phoenix to the site,
Route C, by almost 140%. t It should be noted, however, that
even with this large a percentage increase, the population
risk factor along this route would remain the lowest of all
access routes. The population risk factors for alternative
routes to the Mobile site, routes A and B, would increase by
about 44% and 32%, respectively.
Existence of a PCB incinerator in Arizona would be expected
to shift PCB waste transport patterns through the western states,
since much of the waste currently shipped to incinerators in
Arkansas and Texas could be sent instead to the Arizona facility.
It is estimated that, at present, nearly 175 trucks per year
pass through northern Arizona on 1-40 en route to the incinerator
in Arkansas. Another 13 or so shipments per year leave Phoenix
for the same facility, presumably travelling 1-17 to Flagstaff,
then 1-40 eastward. PCB shipments currently travelling from
California and other far western states to the incinerator in
Deer Park, Texas (near Houston), are presumed to pass through
Phoenix and Tucson on 1-10- Records maintained by the Texas
Department of Water Resources show, that during 1982, four PCB
shipments were sent from California to the Deer Park incinerator
(16). Another 37 shipments originating outside Texas were
recorded that year, but the points of origin are not identified.
Consequently, up to 40 shipments of PCBs per year may be passing
* It should be emphasized that these are rough estimates. Periodic
shipments from different points of origin, following different
routes, could be expected. For example, 1982 manifest data from
the Arkansas Department of Pollution Control show PCB shipments
to the existing PCB incinerator in El Dorado originating in other
Arizona towns, such as Kingman, Bagdad, Benson, and in the Tucson
area.
t As shown in Appendix D, this includes the segment between the
Western Harquahala Plain/Ranegras Plain sites and Phoenix,
which would be travelled by approximately 272 trucks per year
carrying PCBs from California,
IV-3 9
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"Across Jaw . .
CANA cf A
NORTH DAKOTA
Williston De
Minot
fYcrme North Pi^tt*
WESTERN
HARQUAHALA
PLAIN/RANEGRAS
PLAIN SITE
Figure IV-1. Major transit routes for PCB shipments to proposed
Arizona Hazardous Waste Management Facility.
IV-40
-------
through Arizona en route to Texas, although the actual number is
probably less since it is unlikely that all of those shipments
originated in western states.
With a PCB facility in Arizona, the number of PCB shipments
travelling 1-10 between California and the facility would be
expected to increase significantly, as shipments currently travel-
ling 1-40 to the Arkansas facility are routed instead to the
Arizona site. Similarly, PCB traffic on 1-17 between Flagstaff
and Phoenix would increase due to shipments from states such as
Idaho, Utah, and Colorado. The increase in accident risk along
the access routes to the Arizona facility, however, could be
offset by a reduction in current PCB traffic on 1-40 through
Northern Arizona (shipments currently sent to Arkansas from the
West Coast). PCB waste traffic, and the accident risks associated
with it, could similarly be changed in other states. As Table
C-1 shows, shipping the projected amount of PCB wastes to a
facility at the Western Harquahala Plain/Ranegras Plain sites
could save over 380,000 total travel miles over trucking the
same number of PCB shipments to the existing Arkansas facility.
Over 340,000 travel miles could be saved by shipping the wastes
to a facility at the -Mobile site. Since the Texas facility is
approximately the same distance from these cities as the Arkansas
facility, additional savings in travel mileage would be realized
if shipments to that facility went instead to an Arizona facility.
The overall safety impacts of shifting the routes of one to
two PCB trucks per day are difficult to assess. Since a reduction
in PCB traffic could be expected along some routes from western
states to the Arkansas facility, such cities as Albuquerque,
Amarillo, Oklahoma City, Little Rock, San Antonio, and Houston
could experience a small decrease in the risk of PCB spills. On
the other hand, the Los Angeles area could experience an increase
in PCB traffic because trucks from Northern California, Oregon,
and Washington which currently travel 1-40 through northern
Arizona could instead connect with 1-10 in Los Angeles in order
to reach the Arizona facility on a more direct route. Within
Arizona, PCB traffic on 1-40 through Kingman and Flagstaff would
likely be reduced due to greater use of 1-10 from points of
origin on the West Coast.
At least two companies have indicated in interest in develop-
ing a PCB incinerator in California. Although EPA has not been
formally advised of any firm plans to proceed at this time, the
possibility that such a facility could be developed cannot be
dismissed. In that case, much of the PCB waste currently generated
in California and other nearby states could go to the California
facility rather than the Arizona facility (depending largely on
economic factors such as transport costs and disposal fees charged
by the facilities). This could substantially reduce the amount
of PCB traffic passing through Arizona.
IV-41
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Potential for Rail Transport of Hazardous Wastes
The closeness of the Southern Pacific Railroad (SP) line to
the Mobile site raises the possibility of rail transport of
hazardous wastes. SP representatives have indicated they would
consider the development of a spur line to a hazardous waste
facility if it were economically feasible (17).
Several factors, however, cast doubt on the feasibility of
rail transport of wastes. For one thing , railroads emphasize bulk
shipments of hazardous materials in tank cars; hazardous wastes
are usually transported in drums which incur greater handling
costs. Also, transport of waste within Arizona would primarily
involve the shipment of small volumes over relatively short
distances from the State's two major metropolitan areas. It
would probably not be economical to make such shipments by rail.
Consequently, the feasibility of rail transport to the
facility would likely depend on bulk shipment of wastes over
long distances from out-of-state. This is most likely to occur
if a PCB incinerator is included at the facility. Approximately
5% of the wastes going to one existing incinerator are transported
by rail ( 18 ) .
Whether transport of hazardous waste by rail would reduce
or increase the risk of transportation accidents involving
hazardous waste en route to the facility would depend on the
number of shipments made by rail and the accident rate on the
rail lines travelled. Nation-wide, the accident rate for trains
has been decreasing in recent years. In 1981, the rate was 8.55
accidents per million train miles (or 0.0085 accidents per
thousand train miles). This is 5% below the 1978 accident rate
(19). This compares, however, to an average accident rate for
commercial motor vehicles in Arizona of 0.005 accidents per
thousand vehicle miles (20).
Transportation of Hazardous Materials
Some commenters felt the Draft EIS overemphasizes the health
risk due to transport of hazardous waste, especially when compared
to the existing risk from the transport of hazardous materials
(that is, hazardous substances which are still in commercial
use). Two factors have been cited as contributing to the lower
relative risk from the transport of hazardous waste:
The amount of hazardous waste being transported is very
small compared to the amount of hazardous material being
transported.
Hazardous waste is generally much more dilute than
hazardous materials, which may be nearly pure compounds.
IV-42
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That is, the higher volume and concentration of a typical
hazardous material shipment is likely to pose a much
greater hazard if spilled than a typical shipment of
hazardous waste.
The Arizona Department of Health Services estimates that,
in 1981, approximately 21,500 tons of hazardous wastes generated
in Arizona were shipped by the generator to a treatment or
disposal facility. in contrast, it has been estimated that an
average 180,000 trucks pass through Arizona's ports of entry
every month, and of these, six percent carry hazardous materials
(21). It has also been estimated that only one-half of these
carriers have full cargos. Thus, if only three percent of carriers
carry full cargos of 45,000 pound payloads, the amount of hazardous
material transported in Arizona by truck per year would be about
1-46 million tons. The ratio of hazardous material transported
in Arizona to hazardous waste shipments is about 68:1.
Table IV-3 shows the type and amounts of hazardous material
transported in Arizona and is based on a sampling of 4,438 commer-
cial motor vehicles in 1981. Hazardous waste carriers were not
found in this 1981 survey.
Although a large amount of hazardous material is transported
by motor vehicle, railroads carry the bulk of hazardous material.
Railroads move approximately 70% of all hazardous material;
this amounts to about 5% of total rail carloads (22). In 1982,
1.2 million cars of hazardous material (80 million tons) was
transported. About 80 percent of the material is carried in tank
cars, is concentrated, and poses extreme risk when accidentally
released (22).
Table IV-4 shows the type and volume (by number of tank cars)
of hazardous material carried by the Southern Pacific Railroad
(SP) in Arizona. Much of this material is carried on the SP line
which runs past the proposed Mobile site and the access road
between Mobile and Maricopa. The data show that traffic of
hazardous waste to the Mobile facility would be much smaller
than the amount of hazardous material currently transported on
the nearby railroad.
Serious accidents involving hazardous material have occurred
in Arizona. The State Department of Public Safety estimates that
in the 1980-81 period, 80 accidents involving hazardous materials
transported by truck and rail were reported. According to the
U. S. Department of Transportation railroad accident statistics
for Arizona for 1981, 79 carloads of hazardous material were
involved in accidents, and of these, 27 were damaged. In three
railcars, hazardous material was released. In 1981, 2,500 people
were evacuated in Arizona because of rail accidents involving
hazardous material. In 1983, a carload of phosphorus was released
near Casa Grande, resulting in a serious hazard (19).
IV-4 3
-------
Table IV-3. Hazardous materials hazard class
Total H/M count in pounds
This form
is Part #2
of Table #1
Carrier's
Code
as listed
Table #1
1 . Yuma
2. Ehrenberg
3. Kingman
4. Williams
5.
6. TOTAL
7.
Non/
Class Class Class Flam- Combus- Flam- Flam- Flam- Poison Poison Corro- Oxi- Organic Radio- Hazar-
A B C mable tible mable mable mable A B sive dizer active dous
Explo-
sive
150
0
50788
50938
Explo-
sive
6507
46
890
7443
Explo-
sive
798
248
3524
4570
Liquid
440236
195993
10533
143828
790680
Liquid
15233
23847
2079
41159
Gas
285171
13294
40274
338739
Solid
165
700
42136
92591
135592
Gas
48910
95476
216
68606
213208
4009
41190
45199
Mat'l
106062
227121
64540
79592
477315
101820
60048
95020
1019
257907
Perox-
ide
10000
10000
Mat'l
114
114
Waste
H
I
Hazardous Materials Transportation sampling conducted May 17 to 19, 1981 at Yuma (1-8), Ehrenberg (1-10),
Kingman (U.S. 93), and Williams (1-40). Crews worked 4 hours on duty and 6 hours off duty beginning
at 11:00 p.m. May 17, 1981.
During hours of inspection, 4,438 heavy commercial motor vehicles passed the inspection points.
There were 263 motor vehicles transporting hazardous materials. (Percent of total vehicles transporting
hazardous materials - 5.92%)
Inspection crews included personnel from the following agencies: Arizona Corporation Commission
Arizona Dept. of Public Safety
Motor Vehicle Division, ADOT
Federal Highway Administration, U.S. DOT
Interstate Commerce Commission
Source: Arizona Department of Transportation, Charles Kapuscak, Hazardous Materials Specialist.
-------
Table IV-4. Hazardous material carried by the Southern
Pacific Railroad in Arizona, 1982
Railroad Truck
Hazardous Material Car Loads Trailers
Chlorine 372
Flammable Gases 12,942 743
Hydrofluoric Acid 205
Poison Gas 8 56
Radioactive Material — 14
Sulphur Dioxide 133
Class A Explosives 384 boxcars 21
All Other Material
(e.g., sulphuric Acid, Gasoline) 87,357 —
TOTAL 101,401 834
Source : Reference 17
Compared to hazardous waste, hazardous material may pose a
greater risk to populations along transport routes because it is
routinely transported in large volumes and because it generally
consists of concentrated materials. Hazardous waste shipments,
on the other hand, usually involve smaller shipments, and the
hazardous constituents in the waste are generally diluted (mixed
with wastewater sludges, or non-hazardous solid materials, etc.).
It should be noted, however, that the mixed nature of hazardous
waste can make a waste spill more difficult to handle than a
hazardous materials spill, since a number of different hazardous
substances in varying concentrations may be involved.
In sum, the data show:
Hazardous material transportation in Arizona far exceeds
the volume and weight of hazardous waste shipments.
Accidents involving hazardous material have exceeded
incidents involving the shipment of hazardous waste.
The risk of spills of hazardous waste in transit has
been determined to be low. Hazardous waste is generally
less dangerous than hazardous material because it is
less concentrated. However, it may be difficult to deal
with a mix of hazardous wastes.
IV-4 5
-------
The Mobile area is at risk from hazardous material
transported by the Southern Pacific Railroad, which runs
south of Mobile and within 1 ,000 yards of the community.
In 1981, over 100,000 carloads of hazardous materials
were transported by the SP in Arizona, much of it over
the line near Mobile.
It should be noted that the Western Harquahala Plain and
Ranegras Plain sites are close to a major route for transporting
hazardous materials: Interstate 10. Table IV-3 shows, for example,
that over 300 tons of hazardous materials passed through Ehrenberg
on 1-10 during a three-day sampling period. At that rate, the
amount of hazardous materials shipped on 1-10 would approximately
equal the amount of hazardous waste shipped to the waste facility,
although this probably underestimates the amount of hazardous
material because the sampling on which Table IV-3 is based was
not conducted over full 24-hour days.
At both the Mobile site and the alternative sites, then,
the transport of hazardous wastes would represent an increase in
risk over the risk currently posed by the transport of hazardous
materials. Estimated accident probabilities for hazardous waste
shipments, however, show the risk to be low.
Additional Transportation Risks at the Mobile Site
The safety of access routes into the Mobile site compared
to routes into the alternative sites was raised by several
persons commenting on the Draft EIS. Specific concerns are:
• the number of miles of two-lane roads that must be
travelled to reach the Mobile site (30 to 50 miles
compared to approximately 6 miles for the alternative
sites).
• the condition of the two-lane roads leading to the Mobile
site.
• co-use of or crossings over the El Paso Natural Gas pipeline
roads.
• the existence of schools alongside the access roads in
Maricopa and Mobile.
Two-lane roads. The Draft EIS assumes hazardous waste
will be transported to the Mobile site via 1-10 from Phoenix
and Tucson. There are several routes the transporters could
take between 1-10 and the site (see DEIS Tables 4-4 and 4-5,
pp. 4-19 and 4-20, respectively). Each of these routes would
involve travel on two-lane roads for distances ranging from
IV-46
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approximately 30 to 50 miles. It is likely that most of the
shipments would come from or through the Phoenix area,* exit
1-10 at Chandler and travel down the Maricopa Road to Maricopa,
then take the Maricopa-Gila Bend Road to the site. This route
would involve about 33 miles travel on two-lane roads.
Since limited access highways are generally considered safer
than unlimited access roads, the need to route traffic over these
two-lane roads was identified as a drawback to the Mobile site in
ADHS's siting report (1). Highway safety, however, is affected
by many different factors. The analysis of transportation risks
presented in the Draft EIS shows the Phoenix-Chandler-Maricopa-
site route to have overall a relatively low accident rate of
0.0003 accidents per 1,000 vehicle miles (see DEIS Table 4-5,
page 4-20). This is the lowest accident rate of all the routes
considered to either the Mobile site or the alternative sites.
Based on accident rate statistics and total mileages for the
various routes, the projected probability of total commercial
vehicle accidents and hazardous waste transport accidents for
this route compares favorably with those of the other routes to
the Mobile site and to the alternative sites, even those which
are almost totally on four-lane limited-access highways. While
firm conclusions about the absolute safety of a particular
route cannot be drawn from such statistics alone, the projections
suggest that there is no reason to believe that this particular
route is less safe than routes to the other two sites.
The road between 1-10 and Maricopa currently handles a
number of heavy trucks daily, principally trucks carrying agri-
cultural products and supplies. The additional truck traffic
to the facility would be expected to add an average of only
one to two trucks per hour. Also, the additional traffic
is expected only during daylight hours, which would tend to
minimize the risk of accidents.
The data presented In Tables 4-4 through 4-8 in the Draft
EIS (DEIS pp. 4-19 to 4-25) show that other possible routes to
the Mobile site from Phoenix and Tucson have higher recorded
accident rates and accident probabilities than the Phoenix-
Chandler-Maricopa-site route. The statistics for some of these
routes are comparable to those for routes to the two alternative
sites, while others are not. The statistical data, then, suggest
that routing traffic along some of these other possible routes
could pose a higher risk of transportation accidents.
* This is because 75% of Arizona's hazardous waste is generated
in the Phoenix area; also, most wastes coming from California
(if any) would likely use 1-10 through Phoenix.
IV-4 7
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In the comments on the Draft EIS, the possibility was raised
that trucks transporting hazardous waste to the site might enter
Rainbow Valley from the north across Tuthill Bridge and drive
south through the Valley to Mobile. Presumably the trucks would
enter the Maricopa-Gila Bend road at Mobile and travel six miles
on that road to the site.
This route was not considered an alternative in the Draft EIS
because of the tremendous cost of upgrading existing dirt roads
over the distance involved. After the Draft EIS was published,
the Arizona State Legislature amended ARS 36-2800 to require that
access into the Mobile site be from the east or west on existing
public roads. This would preclude use of this route because
Tuthill Bridge and the Maricopa-Gila Bend road are not connected
by "existing public roads."
Based on the costs of upgrading existing roads and the
Legislature's action, ADHS prefers access from the east via the
Maricopa-Gila Bend Road. It is expected that ADHS's preferred
route would be specified in regulations ADHS will establish to
govern transport to the facility.
Condition of the Roads. At present, the road between
Maricopa and the site is an unpaved dirt road. Several comments
indicate a concern over use of such a road for truck transport
of hazardous waste.
Use of this road in its current condition could pose safety
problems. Dust could cause visibility problems, and rain could
make passage difficult or wash out portions of the road.
According to ADHS, it would cost some $11 million to provide an
all-weather surface over the 21 miles of unpaved road.
The Request for Proposals which ADHS issued for selection
of a facility contractor contains a bid specification that
requires the facility contractor to improve six miles of unpaved
road along Maricopa Road. This improvement would provide an
all-weather road from Mobile to the site.
At least part of the remaining portion of the road between
Maricopa and Mobile would be paved by Provident Energy Company
(PEC) if the company carries out its plans to build an oil
refinery at Mobile. As a condition of PEC's air quality permit,
ADHS has required that all regularly-used access roads be paved
within 10 miles of the proposed refinery. The Maricopa County
Planning and Zoning Commission also placed a requirement on PEC
that the company establish the Maricopa-Gila Bend road as its
access route and pave it to the nearest paved road. Since the
nearest paved road is in Pinal County, however, it is not clear
that Maricopa County's requirement could be enforced. Nine
miles of the unpaved road lie within Pinal County.
IV-48
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At this time, there is no assurance that PEC would pave
the entire road between Mobile and Maricopa. A final decision
on whether the company will proceed with the proposed refinery
is not expected until the first quarter of 1984. Even if the
project does proceed, however, ADHS and Maricopa County require-
ments would provide for paving at most ten miles of the road.
This would leave part of the road in Final County unpaved. The
cooperation of Final County would be required to ensure this
portion were paved.
Because of the uncertainties involved in the PEC project,
ADHS is working with the Arizona Department of Transportation to
determine options for improving the road. The final solution
may require some legislative action. The following options are
being discussed:
• DESIGNATE THE ROAD AS A STATE HIGHWAY. This option would
require new legislation. ADHS would have to approach the
State Legislature in an attempt to have the road designated
as a State Highway. If approved, monies would be appro-
priated for the road improvement or the Arizona Department
of Transportation would be instructed to utilize the State
Highway Trust Fund or other appropriate fiscal mechanism
to improve approximately 21 miles of road. The cost may
be offset by establishing the road as a State Toll Highway.
• SHARE FISCAL RESPONSIBILITY AMONG MARICOPA COUNTY, THE
STATE OF ARIZONA, AND PROVIDENT ENERGY COMPANY (PEC).
Under this option, many funding schemes may be considered.
Negotiation and inter-agency agreements would be required.
ADHS would also have to approach the State Legislature for
amended legislation and appropriations for funding the
State's share of the road improvement costs. A firm
committment by PEC on construction of the oil refinery
would also be required.
• LET PRIVATE INDUSTRY HANDLE ROAD IMPROVEMENT. Under this
option, the six miles of road between the Mobile site and
the unincorporated Town of Mobile would be improved by the
facility contractor and PEC would improve the road from
Mobile to the boundary between Maricopa and Pinal Counties.
Even if PEC improved this ten-mile section of the road (as
discussed earlier), this would still leave several miles
of unpaved road in Pinal County.
ADHS intends to resolve this problem before final contract
negotiations with the selected facility contractor are completed.
Pipeline Road. El Paso Natural Gas Company (EPNG) submitted
comments noting that co-use of patrol roads and right-of-way along
its buried pipeline could not be permitted for safety reasons and
to protect the pipeline. This comment apparently refers to the
IV-4 9
-------
pipeline road that crosses Rainbow Valley, connecting Mobile
with roads at the northern end of the Valley. Use of this road
for hazardous waste transport, however, has been effectively
precluded by the State Legislature's recent amendments to ARS
36-2800. The amendments limit access routes to the Mobile site
to existing public roads approaching from the east or west. The
pipeline road does not meet these criteria.
It should be noted that the likely access route (Maricopa-
Gila Bend Road) crosses the pipeline near Mobile. EPNG has
commented that the company will have to review and approve plans
for crossing its pipeline to determine the need for additional
pipeline protection. ADHS has agreed to work with the facility
contractor and other government agencies to ensure that EPNG is
provided the information it needs to conduct such a review.
Risk to Schools. The Draft EIS points out that two schools
are on potential access routes to the Mobile site. One is the
Mobile Elementary School, located on the Maricopa-Gila Bend Road
6 miles east of the site. The other school is located in Maricopa,
It should be noted that the school in Maricopa is situated
along one of the possible routes for waste shipments from the
south or west. Trucks coming through Stanfield and approaching
Maricopa from the south would be expected to pass this school.
This would represent only a small percentage of the waste ship-
ments going to the facility. Also, traffic could be routed
onto an alternative access route to avoid this school. This
is a factor which ADHS should address in its transportation
regulations.
The Mobile School, on the other hand, is located such that
all traffic approaching the site through Maricopa (the preferred
route) would pass by. Consequently, the school should be con-
sidered a "special population at risk" as stated in the Draft
EIS. It is difficult to estimate the precise risk to this
population, however. As noted earlier and in the Draft EIS,
the probability of an accident involving a hazardous waste truck
is very low. Also, the number of trucks would be small (an
average of one to two per hour).
The chance of an accident involving a spill of hazardous
waste near the school is even smaller, given that not all
hazardous waste truck accidents involve a release of wastes.
It should also be noted that the school is already at some risk
from the SP Railroad, which passes within approximately 500 feet
of the school and carries several thousand carloads of hazardous
materials each year.
While the transport of hazardous materials on the railroad
presently places the school at risk from a spill, it is clear that
IV-50
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the addition of hazardous waste transport traffic would increase
that risk to some extent. Consequently, measures would need to
be taken to minimize that additional risk. Possible measures are
discussed at the end of this section.
Risk of a Spill at the Facility
The Draft EIS estimates that 0.5 spills per year could take
place at the facility in the course of its operations (DEIS page
4-17). This estimate is derived from the operating experience of
a California facility at which it was estimated that one on-site
spill occurred for each 10 million gallons of waste delivered to
the facility. This figure is used only to present a general
indication of the likelihood of spills. Actual experience at the
proposed facility would depend on a variety of factors.
One comment on the Draft EIS asks for information on the
spill experience at "a similarly designed plant currently in
operation." In general, events such as leaks, spills, emissions,
and their effect on public health and the environment are more
likely to be functions of the operator, and the care taken during
site construction and operations, than functions of the site
design. Some similar facilities have exemplary safety records,
while others have been plagued with problems. There is no way
to generalize from the experience at other facilities.
On the other hand, it is possible to imagine a spill scenario
from which a projection of impacts could be made. A discussion of
such a scenario follows.
Hazardous Waste Spill Scenario
In response to comments on the Draft EIS, an effort has been
made to characterize the emissions and associated ambient levels
of two volatile organic compounds spilled in an accident. In
this scenario, a truck carrying 5,000 gallons of hazardous waste
overturns.
In order to create a "worst-case" scenario in terms of an
immediate danger to exposed persons, the following assumptions
and considerations are used:
• Two very volatile compounds, benzene and methylene
chloride, have been selected. These compounds could
be released rapidly into the atmosphere under the
conditions selected.
• The entire amount of each compound is assumed to spill
immediately, and to be distributed in a "puddle" that
is only 1 inch deep.
IV-51
-------
• A very high concentration (90% by volume) of these two
compounds has been assumed. In reality, hazardous waste
shipments are not likely to contain this high a concen-
tration of the hazardous constituent. The emissions
calculated in this scenario, then, are likely to be
higher than those experienced in an actual waste spill.
The ambient levels of the two substances at given distances
from the spill are given in Table IV-5 below. The calculations
are presented in Appendix B.
These levels may be compared to two different exposure limits.
The EEL (Emergency Exposure Limit) is defined as:
...a short term exposure limit which is used in an
accidental release of a toxic chemical... [EELs] were
established by the National Academy of Sciences-National
Research Council Committee on Toxicology. Concentrations
are such that reversible toxic effects and discomfort,
short of actual incapacitation, may well occur (23).
An EEL for benzene could not be found at the time of this
writing, so IDLH (Immediately Dangerous to Life and Health)
concentrations for both compounds are also presented (24). The
IDLH concentration represents a "maximum level from which one
could escape within 30 minutes without any escape-impairing
symptoms or any irreversible health effects" (24).
The EEL for methylene chloride is 7.08 grams per cubic meter
(g/m3) or 2000 parts per million (ppm). The IDLH for benzene is
6.5 g/m3 (2000 ppm); for methylene chloride, 17.8 g/m3 (5000 ppm).
Table IV-5 shows that a 5,000 gallon spill of either benzene
or methyl chloride (at a 90 percent concentration) would pose
an immediate health hazard to exposed persons within 100 meters
(328 feet) of the spill. Levels of these toxic chemicals would
fall well below the exposure limits at a distance of 500 meters
(1640 feet). Based on these data, it is reasonable to assume
that the exposure limits would be exceeded, thus posing a sig-
nificant immediate hazard, within about 1,000 feet of the spill.
Emergency Response
Some commenters raised concerns about the ability of the
State and local governments to respond to hazardous waste spills.
In discussing emergency response capabilities, the Draft EIS
notes a number of areas in which lack of resources could prevent
prompt, adequate response (see DEIS pp. 4-28 and 4-29). It should
be clarified, though, that Arizona does have an operating
state emergency response system. This system was set up to
handle the current problem of hazardous material spills. Spills
IV-52
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Table IV-5. Impacts of spills involving benzene
and raethylene chloride*
Ambient Level (g/m3)
Distance from Spill Benzene Methylene Chloride
100 meters
(328 feet) 8.0 27.0
500 meters
(1640 feet) 0.90 3.05
1 kilometer
(3280 feet) 0.33 1.17
5 kilometers
(approx. 3 miles) 0.033 0.01
10 kilometers
(approx. 6 miles) 0.013 0.005
* See text and Appendix B for a discussion of the assumptions
used in making these calculations.
in the State have prompted use of the system in the past. It is
expected that hazardous waste spills would be handled under
the same system.
The State's emergency response system uses existing
personnel at the State and local levels. These personnel are
publicly funded to respond to a variety of incidents including
fire control, transportation accidents, crime, natural disasters,
and the like. The State system supplements existing response
capability by coordinating statewide communications, acquiring
or providing access to equipment, and training personnel.
The response system is designed to function as follows:
Local emergency response personnel respond first on the
scene and take protective actions.
IV-5 3
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If the incident exceeds the capability of the local
emergency personnel, the Arizona Department of Public
Safety (DPS) is called in to coordinate the State response.
In either case, DPS, ADHS, and other pertinent agencies
provide the expertise in containment and clean up.
It should be noted that in the case of a transportation
accident involving a spill of hazardous waste or material, the
clean-up costs are paid by the shipper and/or generators of the
material. In the case of an on-site spill at the facility, the
facility operator would be responsible for the clean-up costs.
Mitigation Measures
Mitigation of the potential environmental impacts of hazardous
waste spills involves:
• measures to minimize the possibility of a spill occurring;
and,
• measures to ensure that emergency response personnel
promptly and effectively respond to and clean up spills
that do occur.
The Draft EIS discusses a number of measures which would be
taken to meet these two goals (see DEIS pp. 4-24, 4-27, 4-29,
and 4-30). Because this is an area of significant concern, the
following discussion is included to add to the discussion in the
Draft EIS regarding transportation spills. On-site spill preven-
tion and response measures would be addressed in the facility
permit. (See Section V.)
Measures to Minimize Spill Occurrences
The primary means of avoiding problems in the transport of
hazardous materials or hazardous waste are safe packaging and
transport practices mandated through Federal and State regulations.
The Federal regulations, which have been adopted by Arizona to be
its own State regulations, are briefly summarized in the Draft
EIS (DEIS Appendix A, p. A-12).
In addition to the operating practices required by these
regulations, transport safety is affected by the routes used.
ADHS is required by law (ARS 36-2800) to develop rules and
regulations governing the travel routes hazardous waste trans-
porters would use within the State. Information contained in
this EIS concerning accident rates and population risk factors
would be used in developing these regulations.
IV-5 4
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The regulations would also take into consideration special
populations at risk, such as the Mobile School. There are
several safety measures that could be required near the school,
including stop signs, low speed limits, and warning signs.
ADHS's transportation regulations would be subject to public
review and input. Further information on the plans for these
regulations and ADHS's timeframe for developing them is presented
in Section VI of this document.
Use of surfaced (all-weather) roads leading into the facility
is another measure that would minimize the possiblity of spills.
Under the terms of the Request for Proposals issued by ADHS, the
facility contractor would be required to pave six miles of road
from Mobile to the site. Since 5 to 6 miles of unpaved roads
connect the two alternative sites with 1-10, the same condition
would apply at these sites.
As noted earlier, paving six miles of road at the Mobile site
would still leave some 15 miles of dirt road between Mobile and
Maricopa. ADHS is working with Provident Energy Company, Maricopa
County, and the State Department of Transportation, to develop a
workable plan to pave that portion of the road. There is no
assurance, though, that this would be accomplished without legis-
lative action.
Spill Response Measures
Plans for upgrading the State's emergency response system
are briefly discussed in the Draft EIS (DEIS pages 4-27 and 4-28).
Experience with hazardous materials spills suggests that, in
spite of a need for more resources, the system is working and
adequate response to spills is taking place. Some of these
spills have taken place along the hazardous materials transport
routes near the proposed sites, indicating that hazardous waste
spills could also be responded to.
At present, State personnel are working to improve the
emergency response system. Their attention is focused on coordi-
nating specialized emergency response services out of Phoenix,
and on training personnel at the local level.
Pipeline Protection Measures
ADHS has noted EPNG's comments regarding the need for EPNG
to review plans for crossing its pipeline to determine whether
additional protection is needed. ADHS would work with the
Maricopa County Highway Department, the Arizona Department of
Transportation, and the facility contractor to ensure that road
improvement plans are reviewed by EPNG. ADHS would ensure that
IV- 5 5
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the facility contractor provides specific information on vehicle
weights and axle loads.
PCB Transportation Outside Arizona
Development of a PCB incinerator in Arizona could alter the
current pattern of PCB shipments in other western states. To
ensure that state and local emergency response authorities are
aware of potential changes and take them into account in their
emergency response planning , EPA would notify the lead agency
for emergency response in each affected state if the facility
is issued a PCB disposal permit.
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PUBLIC HEALTH AND SAFETY: VALLEY FEVER
Testimony at the public hearings on the Draft EIS returns to
the continuing concern of Rainbow Valley residents over the
potential for spreading Valley Fever (See DEIS pp. 4-30 and
4-31, and DEIS Appendix H). Some comments indicate the DEIS may
give an erroneous impression of the risks of Valley Fever in the
area of the proposed Mobile site.
While it is true that Valley Fever spores may be trans-
mitted over long distances by high winds, the appropriate
question at this point is one of significant impacts. The
Arizona Lung Association estimates that two-thirds of all adults
who have lived in the Valley Fever areas of the southwestern
U.S. have been infected with the fungus which causes the disease
and have thereby acquired an immunity to further infection (25).
Very few cases progress beyond the so-called primary stage of
the disease and most people who are infected are not aware of
the infection, unless they have skin tests, as they have no
symptoms (25, 26). A small percentage of cases may progress to
the secondary (or disseminated) stage and result in serious
illness (25, 26, 27).
It is not known precisely how far spores may be carried by
the wind. In one incident, infectious spores to travelled as far
as 500 km (310 miles) in a major dust storm (27). (This event
is discussed in the Draft EIS, Appendix H, pp. H-3 and H-4.) The
disease spores are endemic to large areas of the southwestern
U.S., including the areas surrounding the proposed site and both
alternative sites (25, 26). Under certain weather conditions,
construction or operational activities at the sites could cause
the spores to be spread to the Phoenix area unless mitigative
measures were in effect. (See DEIS Appendix H.)
Opinion differs on the significance of the health risk that
would be posed by release of the spores. Available data reviewed
during this study suggest that the combination of previous exposure
of local residents and the limited probability of serious compli-
cations limits the significance of the potential spore releases.
On the other hand, one Valley Fever expert who has commented on
the Draft EIS, Dr. Chester Leathers of Arizona State University,
has expressed a great concern for the health and safety of facility
construction workers, nearby school children, and residents
living "within a radius of approximately 50 miles of the proposed
site" (Section VI, Written Comments, Comment #W-56).
EPA believes that ADHS should strive to produce a margin of
safety in implementing the mitigation measures described below.
Dr. Leathers' expert opinion should be sought on whether measures
taken by ADHS or the facility contractor are appropriate.
IV-5 7
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Mitigation Measures
As indicated on p. 4-31 of the Draft EIS, ADHS is committed
to working with the facility contractor to minimize the disturbance
and dispersal of Valley Fever spores which may be present at the
Mobile site. Mitigation measures may include:
• minimizing the area of soil disruption during facility
and road construction.
• sampling soils to identify areas of especially high
spore density. Appropriate mitigation or avoidance would
be taken in such areas.
• confining soil-disturbing activities to periods of low wind
velocity. This would reduce the potential for distributing
airborne arthrospores.
• landscaping and periodically watering the soil (or using
chemical dust suppressants) to reduce dust.
• requiring the contractor to consult with experts on the best
practical control measures.
• monitoring health records for the area for indications of
Valley Fever problems.
• where appropriate, using face mask respirators to safeguard
occupationally exposed individuals.
• disseminating information on exposure risks to the
construction workers, especially regarding the practice
of carrying contaminated clothes to their residences.
The facility contractor would be responsible for
implementing most of these control measures. ADHS would be
responsible for some soil sampling and monitoring of health
records, in coordination with the facility contractor. ADHS
plans to undertake a a study to determine the impact of the
hazardous waste facility on disease development in the area.
This study is part of ADHS's commitment to monitoring the health
of residents in the Mobile area.
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SOCIOECONOMICS: "QUALITY OF LIFE" CONCERNS
In considering "quality of life" effects, the Draft EIS
notes that residents in the vicinity of the proposed facility may
experience anxiety over potential harm to public health or other
potential impacts of the facility. A recent survey of Rainbow
Valley and Mobile area residents has identified a high level of
concern among survey participants. The survey report, prepared
by Mr. Kenneth Bachrach, was entered into the public records at
the hearing on the Draft EIS. Because of the level of concern
expressed by Mobile and Rainbow Valley area residents, the Bachrach
study has been reprinted here.
Mitigation Measures
As this EIS has noted, the facility's hazardous waste permit
(and the PCB permit, if applicable) would include provisions to
protect against contamination of ground water, surface water,
and air. It would also include requirements that the permit be
amended if the operator were to plan significant changes in
facility operations or in the types and amounts of wastes handled.
Survey participants, as well as other interested citizens, would
have an opportunity to review and comment on the permit provisions.
Partly in response to Mr. Bachrach's study, the Director of
ADHS has committed the Department to gathering baseline health
information in the Mobile area and to monitoring the health of
area residents throughout construction and operation of the
facility. This health monitoring program, together with the
permit conditions, may help to address the concerns expressed
by survey participants regarding the potential health risks
associated with the facility.
IV-5 9
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REPORT ON THE CONCERNS OF RAINBOW VALLEY AND MOBILE RESIDENTS
REGARDING THE PROPOSED HAZARDOUS WASTE DISPOSAL FACILITY
Kenneth M. Bachrach
Arizona State University
Introduction
The purpose of this report is to communicate the concerns of local
residents about the proposed hazardous waste disposal facility. It is based
on the August 1982 survey of the Rainbow Valley and Mobile communities.
This is not meant to be a technical report. Detailed information on
sampling procedures, measurement reliability, and data analyses have been
purposely omitted in the hope that this report will be readable and thus
used. I will be happy to supply more technical information to interested
readers.
The format I chose in which to present the results was to ask an
important question and to then provide survey information which answers
it. I have attempted to stick to the facts in answering these questions and
to provide my personal viewpoints only at the end.
Summary and Overview
Residents were most concerned about water contamination, health
hazards, and accidents arising from transporting waste. They v/ere ^ngry
about the decision to locate the facility in their community, believed that
there were better available sites, and viewed the decision as unfair. Resi-
dents perceived the facility as a threat to their well-being, anticipated few
community benefits, and did not believe that tha facility management would
be responsive to community needs. Even though residents did not want the
facility, most people thought it would be built. Should tnis occur, they
viewed as most important the monitoring of their health and the establish-
ment of better medical facilities and emergency systems. A strong adver-
sarial relationship exists between the local community and the state govern-
ment, which will likely create problems for both residents and governmental
officials. It is recommended that representatives of the state and local
community begin a dialogue to improve relations.
How was the survey conducted?
People who participated in the August 1982 survey about the proposed
hazardous waste facility were selected one of two ways. Seventy people
were chosen at random from a specially developed map of Rainbow Valley
and Mobile. This map was quite accurate, with the exception of some homes
in Deep Rainbow Valley not being included. Interviewers alternated speak-
ing to the male and female head of household. Twenty-nine residents were
selected at random from a list of people who had attended meetings or
voiced their opinion on public record about the hazardous waste facility.
Thus, a total of 99 people were interviewed in their homes, with only 7% of
those contacted refusing to be interviewed. The median time per interview
was 35 minutes.
1/83
IV-60
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What were the charactenstics_of_the people surveyed?
Most of the people surveyed were Caucasian (82%), married (84%),
and high school graduates (73%). They had lived an average of 8 years in
the area, and slightly more than half were female (52%). The average age
was 41 years, but there was a fairly equal distributon across age groups.
For example, 36% were under 35 years and 37% were 45 years or older. The
median family income was $21,000, with one-quarter of the families earning
under $13,000 annually and one-quarter earning over $28,000. Sixty-three
percent were employed full- or part-time, 7% were retired, 19% were home-
makers, arid 8% were unemployed.
How do people feel about the facility being built?
Eighty-five percent of the sample reported they v/ere either concerned
(34%) or upset (51%) when they learned that a hazardous waste facility might
be built. Most people believed the decision to locate the facility near Mobile
was either unfair (33%) or very unfair (49%), and viewed Governor Babbitt,
the State Legislature, and certain politicians as responsible for the decision.
Half of those interviewed were either angry (20%) or very -angry (30%)
about the decision and generally did not see themselves becoming less angry
over time. Still, over half of those interviewed (54%) see themselves ac-
cepting the fact that the facility may be built, and two-thirds of the sample
believe that it is either likely (18%) or very likely (44%) that the facility will
be built.
What are, the major concerns of residents?
Near the start of the interview people were asked the question,
"Specifically, what are your feelings and opinions about the proposed
facility?", and up to four responses per individual were recorded. Many
responses fell into similar categories and are presented below.
43% Water contamination
33 Better/other sites/in more isolated areas/away from people
24 Health hazards
23 Transportation hazards/accidents
13 General safety concerns
12 Waste/chemical leakage
11 Don't like it/against it/here
10 Air pollution
8 Lower property value
7 Site selection a political decision
6 Need a site
6 Good/ideal site/if built right
Do residents expect future problems with the proposed facility?
Residents view the facility as a threat, are distrustful of those who may
manaqe the facility, and believe few community benefits will come from it.
Examples follow to support each of these statements.
IV-61
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Agree or
Agree
Strongly
Disagree or
Disagree Don't
Strongly Know
(1) FACILITY VIEWED AS A THREAT
The likelihood of an accident
occurring is extremely slight 16%
There will be a high potential for
ground or surface water contamination... 81%
People will face a greater risk of
becoming sick 69%
The facility represents a threat
to my well-being 70%
(2) DISTRUST OF FACILITY MANAGEMENT
Public complaints on the facility's
operation will be investigated
promptly 25%
The public and 'local community will
be advised of changes in operations
and types of waste handled at the
facility. 15%
A good working relationship will
develop between local residents
and the facility operator 15%
(3) FEW COMMUNITY BENEFITS EXPECTED
Fire and emergency systems in the
community will be improved... 25%
Better medical facilities will be
provided for the community 15%
The facility will generate tax
dollars for the community. 26%
73%
6%
18%
22%
65%
78%
72%
55%
69%
52%
11%
12%
13%
10%
7%
13%
19%
16%
22%
What compensation or community benefits do residents feel would be most
important, should the facility be built?
Residents were asked to rank order seven statements, with "1" being most
important and "7" being least important. As can be seen below, the state-
ments relating to health and health care were most important in the minds
of most people.
IV-62
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Average
Ranking
1. The health of residents should be regularly monitored. 2.51
2. Better medical facilities should be provided for the
community. 3.09
3. Fire and emergency systems in the community should
be improved. 3.20
4. Some type of compensation should be provided to
residents affected by the facility. 3.66
5. Access roads should be improved (e.g., paved) and
widened. 4.61
6. Employment opportunities for local residents should
be provided. 5.43
7. The facility should generate tax dollars for the
community. 5.44
Did people selected from the list of residents attending meetings differ from
those selected at random from the community?
The two groups differed in some respects but not in other ways. The
"actively involved" group tended to be older (5V years vs. 37 years) and to
have lived longer in the community (12 years vs. 7 years). They had a
stronger sense of community, were more likely to believe they couid do
something about the facility being built, and had known that the facility
might be built for a longer period of time (2 years vs. 1 year).
While most residents of both groups were opposed to the building of
the facility, the actively involved group's opposition was more intense.
They tended to be "upset" when they learned the facility might be built,
while the rest of those interviewed were more likely to respond "concerned."
They believed the decision to build the facility near Mobile was "very
unfair" while others viewed it as "unfair." Similarly, those actively in-
volved were generally "angry" over the decision to build the facility com-
pared to "somewhat angry" for the rest of the sample.
There were no_ significant differences between the two groups on many
measures. Similar~proportions of each group owned their homes and be-
lieved that property values would decrease. Both groups equally believed
that the facility will probably be built and that good relations are not likely
to develop between the local community and facility operator. A very
important finding was that both groups ranked the seven community benefit
or compensation items in a similar fashion, viewing the monitoring of health
and better health care facilities as most important.
Discussion
The results paint a strong adversaria! relationship betwen the com-
munity and governmental institutions. The community does not trust the
state government as evidenced by perceptions that (1) politicians were
responsible for the decision to locate the facility near Mobile; (2) the de-
cision was unfair; and (3) facility management cannot be trusted. Further-
more, residents viewed the facility as a threat to their well-being and
expect few community benefits. In a nutshell, the community is saying that
it has little to gain and potentially much to lose as a result of this facility.
IV-63
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Even though local residents do not want the facility, the majority of
them believe that it will be built in their community. This suggests that
residents do not believe that they can do much about the present situation,
which could produce cynicism, anger, and a sense of powerlessness among
many people.
A continuation of this adversarial relationship does not appear bene-
ficial to any of the parties involved. If the community does not feel it can
trust the State or the facility operator, this will undoubtedly increase
distress among local residents once the building of the hazardous waste
facility begins; for if they cannot trust the party monitoring the safety of
the facility, to whom can they turn? The state government has little to
gain by having its credibility questioned continuously by local residents.
Furthermore, such criticism does not remain a local issue but spreads via
the media. Similarly, the facility operator will likely be backed into a
corner, having to frequently defend its actions to people looking for mis-
takes.
A reconciliation among the parties will not be easily achieved. The
local community has fought hard to stop the building of the facility and 46%
of the residents still do not see themselves accepting the fact that the
hazardous waste facility will be built. Hazardous waste disposal is not a
popular subject among politicians. Since few communites want hazardous
waste facilities, discussion usually centers on where not to place them
rather than on how to deal with the problems of hazardous waste. State
agencies, such as the Department of Health Services, are often caught in
the middle, because they are influenced by legislative decisions which tell
them what to do and limit their resources.
There is no simple solution, but a dialogue between representatives of
the State and the local community would be a step in the right direction.
Many issues must be sincerely dealt with and resolved if relationships are
to improve. The overriding issue may be one of justice and fairness. Few
people want a hazardous waste facility located near them. Should those who
must assume more than their fair share of the social cost of hazardous
waste production receive something in return? It is interesting to note that
local residents viewed as most important the monitoring of their health and
better medica! facilities, not monetary compensation or employment op-
portunities. These seem to be reasonable requests and are worthy of
lengthy discussion.
IV-6 4
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IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
Water and energy resources are addressed briefly in the
Draft EIS's discussion of the "irreversible and irretrievable
commitment of resources" associated with the proposed facility
(DEIS p. 4-50). Both resources were the subject of comments
on the Draft EIS. The following additional information has been
provided in response to these comments.
Water Use
Potable water would be needed primarily for drinking, showers,
eye-washes, and laboratory facilities. Non-potable water could
be used for purposes such as vehicle washing facilities, irriga-
tion, dust control, and fire protection. Typical potable water
requirements are on the order of 35 gallons per shift. Total
water needs are estimated to be 35 gallons per minute (averaged
over a 24-hour period) for a "low technology" facility such as
the one described in the Draft EIS (DEIS Appendix D). Water
needs for a facility with a high-temperature incinerator would
be higher, in the range of 100 to 150 gallons per minute (gpm) .
Although water could be delivered to the site from off-site
water sources, the most likely source is ground water beneath
the site. Some non-potable water needs could be met through use
of neutralized waste waters, but the amount is not known at this
time. Given the high cost of obtaining either ground water or
water from off-site sources, it is likely that the facility
operator would make every effort to conserve water and reuse
suitable waste waters.
Available ground water in the Rainbow Valley area is limited.
However, the water needs of the proposed facility are reasonable
compared with other water users. At a maximum rate of 150 gpm,
the facility would require about 200 acre-feet per year. Based
on ground water data from the eastern and northern parts of
Rainbow Valley, where ground water use is highest, it is estimated
that the 210-square mile Waterman Wash area contains approximately
10.3 million acre feet of ground water. Current irrigatioa
requires about 72,000 acre feet (28). It is not known whether
ground water lies beneath the proposed site or, if it is present,
whether it is recoverable. The facility contractor would have
to do exploratory drilling to determine the level and sufficiency
of ground water at the site. Should ground water not be found,
the facility operator probably would have to pipe water in from a
well off-site. Unless an existing well could be used, the
operator would have to develop the well (or wells) in addition
to the pipeline, and would have to obtain right-of-way agreements
with BLM and other property owners along the pipeline route.
IV-6 5
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Information on ground water availability in the Western
Harquahala Plain and Ranegras Plain areas is very limited.
Stock wells near the Western Harquahala Plain site pump ground
water at a rate of 25 to 30 gpm. An irrigation well about 13
miles east of the site draws 3,000 gpm. A stock well on the
Ranegras Plain site draws about 20 gpm, while a well a few miles
to the south pumps about 35 gpm. Irrigation wells roughly 10
miles north of the Ranegras Plain site draw 2600 to 3500 gpm.
While accurate judgements about the quantity of ground
water available over the life of the facility cannot be drawn
from these data, they do indicate that wells near the two
alternative sites can pump water at a rate that would meet the
facility's maximum estimated water needs. Clearly, wells of a
larger diameter than the stock wells in the area would be needed.*
As with the Mobile site, further site investigation would
be needed to determine the sufficiency of the ground water
supplies beneath these sites. The presence of a stock well at
the Ranegras Plain site confirms the presence of recoverable
water (at least in one part of the two-section area considered
for the proposed site). There is no information confirming the
presence of ground water at the Western Harquahala Plain site at
this time. There are, however, operating stockwells within 2
to 3 miles of the site in three directions.
ADHS has asked the Department of Water Resources to consider
the proposed waste facility's water needs in allowing other
ground water permits in the basin. This should help ensure that
adequate water is available to meet the needs of the facility
and of others planning to use water in the area.
Energy Consumption
Electrical Power Requirements
The Draft EIS notes that "energy consumption at the facility
would be minimal" (DEIS p. 4-50). This statement is based on
the "low technology" representative design used as the basis for
preparing the Draft EIS. Since the Draft was issued, additional
information has become available on expected energy requirements
of both a "low technology" and a "high technology" facility.
The peak energy load for a facility without incineration is
expected to be around 200 kilowatts (kw) (7). The needs of a
* These stock wells would have a diameter of 5 to 6 inches, while
the irrigation wells would have a diameter of about 20 inches.
IV-66
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facility with an incinerator would be higher: a peak load of
approximately 450 kw for the incinerator, and probably an
additional 50 percent for the other facility operations (3).
At the Mobile site, existing power lines would have to be
extended for approximately seven miles. While the exact cost of
extending the line and providing the needed circuits at the site
cannot be determined until the facility is designed, a rough
estimate from the Arizona Public Service Company indicates a
minimum cost figure of about $30,000 per mile (total minimum
cost of $210 ,000) (29).
The costs per mile of extending a line to the Western
Harquahala Plain or Ranegras Plain sites would be similar, about
$30,000 per mile at a minimum. A line crosses the corner of one
of the sections at the Western Harquahala Plain site; consequently,
the extension could be less than one mile, depending on which section
was selected and where the facility was located within the section
(29). An extension to the Ranegras Plain site would have to
cover some 14 miles. Such an extension could cost at least
$400,000 (29).
A facility which includes an incinerator might require more
power than existing lines in remote rural areas could provide.
Consequently, while the Western Harquahala Plain site appears to
have the lowest potential cost for extending the existing power
lines, the cost would be significantly higher if the line needed
to be reconductored to increase its load capacity. Additional
information on the facility's design and specific energy require-
ments would be needed to determine whether reconductoring were
needed and to estimate the costs involved (29).
Because the cost of extending the transmission lines could
be quite high, the facility operator may choose to develop a
power source on-site. At the "high technology" facility, excess
energy from the incinerator could be used to meet part of the
facility's power needs through co-generation of electricity. The
amount of energy which could be generated this way has not been
determined by the bidder (30).
Motor Fuel Consumption
The Draft EIS notes that transporting hazardous wastes to
the site could result in a net savings in terms of fuel consumed,
over transporting the same amount of waste to existing out-of-state
facilities. The Draft EIS estimates that over 8,300 gallons of
gasoline would be consumed monthly in transporting waste to the
Mobile site, while nearly 10,000 gallons would be consumed monthly
in transporting waste to the Western Harquahala or Ranegras
Plain sites.
IV-6 7
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An error was made in calculating fuel consumption to the
Mobile site, overestimating fuel consumption by over 3,000 gallons
per month. (See DEIS p. 4-50.) Based on transportation estimates
used in the Draft EIS, the correct figures would be about 5,100
gallons per month, or nearly 66,000 gallons per year. Table C-2
(Appendix C) shows the calculations for annual fuel consumption.
This table also shows fuel consumption estimates for transporting
the same waste to the nearest out-of-state waste site.
For wastes generated within Arizona, the greatest savings
would come from using the Mobile site — approximately 280,000
gallons per year. The savings from using the Western Harquahala
Plain or Ranegras Plain sites — 230,000 gallons annually —
would also be significant.
As noted earlier, a PCB incinerator located in Arizona would
be expected to attract PCB wastes from a number of western states.
Table C-3 (Appendix C) compares the total one-way mileage involved
in shipping PCB wastes to an existing incinerator in El Dorado,
Arkansas, and to the proposed Arizona facility sites.* The table
is based on estimates of the number of shipments from major
western cities which are likely to be attracted to an Arizona
facility.
Table C-4 (Appendix C) shows the fuel that would be consumed
in shipping wastes to the proposed Arizona facility and to the
existing facility in Arkansas.* About 138,000 gallons would be
saved annually by shipping to the Mobile site, while 154,000
gallons would be saved by using a facility at the Western
Harquahala Plain or Ranegras Plain sites.
Considering both hazardous waste and PCB shipments, locating
the proposed facility at the Mobile site would likely result in
a slightly greater overall fuel savings than would locating the
facility at either of the other two sites.
* Only the incinerator in Arkansas is considered in Tables C-3
and C-4, since there is not sufficient information available
on current shipments to the Texas facility to estimate total
mileages. Both facilities are about the same distance from
Arizona. The tables assume that no other PCB incinerators
are developed closer than these two facilities which would
reduce the number of PCB shipments going to Arizona.
IV-6 8
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SECTION V
MITIGATION MEASURES
The Draft EIS explains that the proposed hazardous waste
facility would be required to have a State or Federal permit,
or both, in order to operate. The permit (or permits) would
establish the design and operating requirements the facility
must meet to ensure adequate protection of human health and the
environment. As noted in the Draft EIS, many of the potential
environmental impacts associated with the facility would be
addressed in the permit.
A number of impacts have been .identified, however, which
are outside the scope of the hazardous waste facility permits.
One major area of concern is transportation of waste to the
facility. Many of the transportation-related impacts could be
addressed through regulations which ADHS is required to issue
by State law (ARS 36-2800). For other impacts, appropriate
mitigation measures have been identified.
A summary table showing the impacts and the measures which
would mitigate them appears at the end of this section. Preceding
the table are discussions of the facility permit requirements
and of the procedures ADHS will follow in developing its
transportation regulations.
THE FACILITY PERMIT REQUIREMENTS
Appendices A and B of the Draft EIS summarize the Federal
and State hazardous waste regulations and facility permit
requirements. The Appendices do not cover all of the regulatory
requirements, but highlight many of the major ones. Their
purpose is to illustrate ways in which the regulations and permit
conditions would address environmental concerns related to the
design and operation of the facility.
In response to comments on the Draft EIS and to clarify por-
tions of DEIS Appendices A and B, we have included the following
discussion of facility permits and regulations.
State and Federal Permits
The proposed facility would have to meet the same permit
requirements as other facilities which treat, store, and dispose
of hazardous wastes. Currently, a new hazardous waste facility
in Arizona must obtain both a Federal permit from EPA and a
State permit from ADHS before it will be allowed to operate.
V-1
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As described in Appendix B of the Draft EIS, an agreement
betweeen EPA and ADHS allows the two agencies to work together
in processing the State and Federal permits. Since a facility
must have both permits, a decision by either ADHS or EPA to deny
its permit would prevent the facility from operating.
Federal law allows EPA to transfer full responsibility for
the hazardous waste management program to individual states.
Under this provision, a state may be authorized to issue hazardous
waste facility permits in place of an EPA-issued Federal permit.
If Arizona were to become authorized, the State's own permit
would be the only approval needed in order for the facility to
operate as a hazardous waste disposal facility.* EPA may review
and comment on draft permits, but the State would retain
responsibility for issuing the final permit.
Arizona is presently developing regulations needed to obtain
"authorization" from EPA to run the Federal program in the State.
Its current schedule calls for the State to complete the author-
ization process and become authorized in 1985. Since the schedule
for developing the proposed facility calls for completion of the
permitting process during 1984, it is expected that the facility
would have to follow current procedures and obtain both a State
and a Federal permit.
If, however, permitting of the proposed facility were not
to take place until after the State is authorized, ADHS would
have sole responsiblity for issuing its hazardous waste facility
permit. As the Draft EIS notes (p. B-3), this places ADHS in
the dual role of regulator of the facility and co-applicant for
the permit (as owner of the land leased to the operator). The
Draft EIS states that ADHS intends to resolve the potential
conflict presented by its dual role by entering into an agreement
with EPA to have EPA issue this particular permit. Further
review of the Federal legal requirements since the Draft EIS was
issued, however, indicates that such an arrangement could not be
made. Once the State is authorized, EPA will not have authority
to issue a permit to the proposed facility.
This situation is not likely to occur, given the State's
current schedules for authorization and for developing the proposed
facility. If it did occur, EPA would retain the right to review
the permit conditions and comment on them (but not to issue the
permit in place of ADHS). ADHS would agree to accept, or justify
its rejection of, EPA comments and recommendations, including a
recommendation to deny the permit if this were recommended.
* Other approvals, such as air or water pollution control permits
or local zoning or construction approvals, might be needed in
addition to the hazardous waste permit.
V-2
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If the proposal to develop a PCB incinerator were accepted,
the facility would need an EPA permit to dispose of PCBs.
This woudl be in addition to its hazardous waste permit. Permit-
ting of PCB facilities cannot be delegated to a state. The PCB
permit is briefly discussed later in this section.
Mitigative Effects of Permit Conditions
Conditions established in the facility permit may address
some of the potential impacts identified in the EIS. These
conditions would be based on the Federal regulations (40 CFR
Part 264). While much of this information is covered in Appendix
A of the Draft EIS, it is presented here in a format that ties
permit conditions to specific types of impacts. Since ADHS uses
the Federal regulations as guidance in preparing State permits,
the conditions applied in the State permit would be similar to
those described here. (One difference between the State and
Federal permit requirements is discussed under Air Quality in
this Section and in Section IV, Air Quality.) Additional mitiga-
tion may be provided depending on the potential environmental
impacts of the actual facility design and the specific conditions
imposed by the permit.
Physical Setting
Earthquakes. The EPA regulations contain a seismic standard
which prohibits placement of hazardous waste treatment, storage,
and disposal units within 200 feet (61 meters) of a fault which
has had displacement in recent geologic time (Holocene time).
In certain designated areas which are known to contain such
faults, the facility owner or operator must demonstrate that the
facility meets this requirement. Facilities in areas without
known Holocene faults are presumed to meet this standard
because of their geographic location.
Maricopa County is not one of the designated areas;
consequently, a facility at the Mobile site would be presumed to
meet the earthquake standard and would not have to demonstrate
compliance. Yuma County, however, is a designated area.
Recently, the new County of La Paz has been formed out of the
northern part of Yuma County. Although La Paz County is not
listed, EPA officials believe that facilities located within the
county would have to demonstrate compliance with the standard
because that area was part of Yuma County at the time the list
was developed. Consequently, a facility located at either the
Western Harquahala Plain site or the Ranegras Plain site would
have to demonstrate compliance.
V-3
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To demonstrate compliance with the standard, the operator
would have to show either:
that no faults which have had displacement in Holocene
time are present, or no lineations which suggest the
presence of such a fault within 3,000 feet of the facility
are present; or,
if faults (or lineations) which have had displacement
in Holocene time are present within 3,000 feet of the
facility, that no faults pass within 200 feet of the
portions of the facility where treatment, storage, or
disposal of hazardous waste will be conducted.
The presence of faults or lineations within 3,000 feet of
the facility must be determined using published geological studies,
plus aerial reconnaissance within a five-mile radius of the
facility, analysis of aerial photos covering a 3,000 foot-radius
of the facility and, if needed for clarification, a walking
reconnaissance of the area within 3,000 feet of the facility.
Lack of published data on faults at the two sites indicates that
on-site studies would be needed to determine whether faults are
present.
The presence or absence of faults within 200 feet of the
facility units must be determined through subsurface exploration
(trenching) within that area, unless a site analysis is otherwise
conclusive. (See 40 CFR 122.25(a)(11).)
Geologic Conditions. The Draft EIS notes that limited
available information indicates that the proposed and alternative
sites' "general geologic conditions are generally suitable for
development of the proposed hazardous waste management facility,
provided the facility is designed to minimize contact between
the wastes and the subsurface environment" (DEIS p. 4-2). EPA's
ground water protection requirements are intended to minimize
contact between the wastes and the subsurface. These requirements
would be the basis for permit conditions. (See the discussion of
ground water below.)
If there were a potential for subsidence at or near the
site, the facility's contingency plan would have to include pro-
visions for handling any emergencies caused by subsidence. (See
the discussion of contingency plans on pp. V-9 and V-10.)
Water Resources
Ground water. The permit would establish conditions for
the protection of ground water resources based on two sets of
standards. The first set is preventive, aimed at minimizing the
release of contaminants into the subsurface through facility
V-4
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design and operating standards. The second set of standards is
corrective, providing that ground water be monitored to detect
the presence of contaminants and that any potentially harmful
levels of contamination which are detected be cleaned up.
The ground water protection provisions of the regulations
and the options for meeting the requirements are discussed at
length in Section IV of this document. Additional background
information on the regulations is presented in the Preamble to
EPA's Land Disposal Regulations, in the Federal Register of
July 26, 1982 (47 FR 32274).
Surface water. EPA's facility regulations contain
provisions to keep waters or other liquids flowing into the
facility ("run-on") from entering the treatment, storage, or
disposal units and to prevent the release of liquids from the
units ("run-off"). Other requirements are intended to minimize
the potential for washout of the facility due to flooding.
Surface impoundments (ponds) must be designed, constructed,
maintained, and operated to prevent overtopping (the flow of
liquids over the top of the containment structures). There are
a variety of potential causes of overtopping of impoundments
which would be addressed in the permit, such as overfilling by
the operator, wind and wave action, rainfall, and run-on (e.g.,
stormwater flowing into the impoundments).
The regulations leave it to the permit applicant to show
how the facility would meet this standard. One means is to
construct dikes which provide a large amount of freeboard (space
between the the top of the dike and the level of liquid in the
impoundment). Operating practices, such as adjusting inflows
and outflows to regulate the level of liquids in the impoundment
or using automatic level controllers or alarms, would also help
prevent overtopping when potential problems (such as unusually
large storms) occur.
To reduce the possiblity that storm waters would enter
waste piles, land treatment units, and landfills and cause
contaminants to leach into the subsurface, each unit must have a
run-on control system capable of preventing flow onto the active
portion from the peak discharge of at least a 25-year storm.*
To minimize hazards from run-off of contaminated liquids from a
* It should be noted that this is a minimum standard. As the Draft
EIS notes (DEIS p. A-9), ADHS believes the 100-year storm standard
is more appropriate for conditions at the Mobile site and would
require the facility contractor to meet that standard rather than
the 25-year storm standard.
V-5
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unit, there must be a run-off management system capable of
collecting and controlling the volume of run-off resulting from
at least a 24-hour, 25-year storm. The collection and holding
facilities of both run-on and run-off control systems must be
emptied or otherwise managed expeditiously after storms to
maintain capacity of the system.
EPA recognizes the magnitude of the environmental consequences
of a flood at a hazardous waste facility, the 100-year floodplain
has been set as a standard for facility location and design.
While the regulations do not prohibit a facility from locating
in a 100-year floodplain, any facility situated in one must be
designed, constructed, operated, and maintained to prevent washout
of any hazardous waste by a 100-year flood. For a new facility,
this standard must be met unless the facility operator sets
procedures which will cause the wastes to be removed safely,
before the flood waters can reach the facility, to a location
where the wastes will not be vulnerable to floodwaters. This
latter option, however, probably would not be a viable one for a
comprehensive treatment, storage, and disposal facility located
in a desert environment which is subject to intense flash
flooding.
The permit applicant must document whether the facility site
is located in a 100-year floodplain. This documentation already
exists for the Western Harquahala Plain and Ranegras Plain sites,
in the form of Federal Insurance Agency (FIA) maps. As the Draft
EIS notes (DEIS pp. 3-38 and 3-59), these maps show both sites
well outside the 100-year flooplain in these areas (at Bouse
Wash). For the Mobile site, no FIA maps yet exist. Consequently,
the applicant must calculate the floodplain. The discussion of
the floodplain location standard in Section IV addresses the
difficulty in identifying a floodplain in the Mobile area.
EPA and ADHS would have to determine an appropriate methodology
for assessing the floodplain.
If the facility is in a 100-year floodplain at the Mobile
site, the permit applicant must provide:
an engineering analysis to indicate the various hydro-
dynamic and hydrostatic forces expected to occur at
the site as a consequence of a 100-year flood; and,
structural or other engineering studies showing the
design of operation units (e. g., tanks, incinerators)
and flood protection devices (e. g., floodwalls, dikes)
at the facility and how these will prevent washout.
Air Quality
Wind dispersal of wastes. EPA's regulations require that
V-6
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operators of waste piles, land treatment units, and landfills
control the dispersal of wastes by wind. The practices used
to control wind dispersal, such as covers or wetting, must be
described in the permit application.
Toxic emissions. Because information on air emissions
from hazardous waste land disposal units is very limited and
the problem appears to depend greatly on the type of wastes
handled, EPA's regulations do not set standard controls on
toxic air emissions. At the proposed facility, such emissions
may be addressed through State regulations, which require that a
hazardous waste facility have appropriate equipment and devices
"adequate to monitor and control the escape of ... fumes and
gases into the environment". (R9-8-1821) This is discussed
further in Section IV, Air Quality.
Incinerator standards. While no federal regulations have
been established to control emissions from waste piles, impound-
ments, land treatment units, or landfills (except wind dispersal
controls), standards have been set for incinerators. These
standards require that, where specified hazardous constituents
listed in 40 CFR Part 261, Appendix VIII are present in the
waste, an incinerator must achieve a destruction and removal
efficiency of 99.99% for each of the principal organic hazardous
constituents (POHC) designated in its permit. POHCs are specified
from the list of hazardous constituents. They generally are
those which are most difficult to incinerate and are present in
large quantities or high concentrations in the waste.
The regulations also specify limits on the amount of hydrogen
chloride and participates which may be emitted. These two sub-
stances are by-products of the incineration process.
The permit specifies the wastes which may be burned and the
operating conditions for those wastes. To indicate that the
incinerator will meet the standards, the permit applicant must
either:
. conduct a trial burn under conditions set by EPA for that
purpose, or
. submit extensive data on the wastes to be burned (heat
value, viscosity, hazardous constituents), a detailed
engineering description of the incinerator, and
information comparing the wastes and the facility s
design/operating conditions with those at units for
which burn data are already available. Other data
may also be required.
These standards do not apply to incinerators which burn
wastes which are hazardous only because they are corrosive,
7Sni7*hlP or reactive. The facility may also be exempted if
materials'included on the hazardous constituents list are present
V-7
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in insignificant concentrations and would not pose a threat to
human health and the environment when burned in the incinerator.
Since listed hazardous constituents such as PCBs would be
included in the waste stream of the incinerator proposed for
Arizona, that facility would not be expected to qualify for
these exemptions. Permit conditions for the treatment and disposal
of PCB wastes are discussed at the end of this section.
Public Health and Safety: Operational Spills and Emergencies
The facility permit would contain several requirements
designed to prevent spills, explosions, fires, and other
emergencies. The requirements also are intended to minimize
the impacts of any emergencies that might occur.
Proper Handling of Wastes. The permit would describe
procedures designed to ensure the proper handling of wastes at
the facility. The permit applicant must obtain chemical and
physical analyses of the hazardous wastes to be handled. The
analyses must contain all the information needed to treat,
store, or dispose of the wastes properly in accordance with
EPA's regulations. The permittee must develop and follow a
written waste analysis plan to carry out this requirement.
The plan must include the parameters for which each waste
will be tested, testing and sampling methods, and frequency of
the analyses. For an off-site facility, such as the proposed
facility addressed here, the plan must identify waste analyses
that waste generators have agreed to provide to the facility,
and must specify procedures to be used to ensure each hazardous
waste received at the facility matches the waste identified on
the shipping manifest accompanying the shipment.
The permit would describe precautions the facility operator
would take to prevent accidental ignition or reaction of ignitable,
reactive, or incompatible wastes. Such wastes must be separated
and protected from sources of ignition. The facility operator
must also take precautions to prevent reactions which:
generate extreme heat or pressure, fire, explosions,
or violent reactions;
produce uncontrolled toxic mists, fumes, dusts, or
gases in sufficient quantities to threaten human
health or the environment;
produce uncontrolled flammable fumes or gases in
sufficient quantities to pose a risk of fire or
explosions;
damage the structural integrity of the device or
facility; or
V-8
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• through other like means threaten human health or
the environment.
Spills. The permit would include measures to prevent and
respond to on-site spills or hazardous wastes. Measures to
control run-off and flooding described earlier in this section
would also serve as spill prevention measures. In order to
minimize the chance for a transportation-related accident, the
permit applicant must also describe measures to prevent hazards
in unloading areas and identify traffic patterns, estimated
number and types of vehicles, traffic lanes, access road surfacing
and load bearing requirements, and traffic control signals on
access routes into the facility. The facility must be designed,
constructed, maintained, and operated to minimize the possibility
of a fire, explosion, or any unplanned release of hazardous
waste or hazardous waste constituents to air, soil, or surface
water which could threaten human health or the environment.
To ensure quick response to emergencies, the facility must
have the following equipment (unless it can be demonstrated in
the permit application that none of the hazards posed by the
wastes handled at the facility could require a particular type
of equipment):
an internal communications or alarm system capable of
providing immediate emergency instruction to facility
personnel;
a device such as a telephone or two-way radio capable
of summoning emergency assistance from local police
departments, fire departments, or state or local
emergency response teams;
portable fire extinguishers, fire control equipment
(including special extinguishing equipment, such as
that using foam, inert gas, or dry chemicals), spill
control equipment, and decontamination equipment; and
water at adequate volume and pressure to supply water
hose streams, foam producing equipment, automatic
sprinklers, or water spray systems.
The facility must have adequate aisle space to allow the
unobstructed movement of personnel, fire protection equipment,
spill control equipment, and decontamination equipment to any
area of the facility (unless the permit applicant demonstrates
that aisle space is not needed for any of these purposes).
The permit applicant must include as part of the application
a contingency plan designed to minimize hazards to human health
or the environment from fires, explosions, or unplanned releases
V-9
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of hazardous wastes or hazardous constituents to air, soil, or
surface water. The plan, which must be implemented in the event
of such an emergency, must:
describe the actions facility personnel must take to
respond to the emergency;
describe arrangements made with state and local
emergency response teams and contractors, local police
and fire departments, and hospitals to coordinate
emergency services;
list all required emergency response equipment; and
include an evacuation plan for personnel.
Ecological and Cultural Resources
EPA permits must be issued in a manner consistent with other
Federal laws, including the Endangered Species Act, the National
Historic Preservation Act, and the Indian Religious Freedom Act.
While the findings of this EIS indicate that no protected species,
historic sites, or Indian religious sites would be adversely
affected at any of the three sites, the permit would provide an
additional opportunity for review of these findings by appropriate
agencies and the public. In addition, the permit would include
a provision that the facility owner or operator must consult the
State Historic Preservation Officer and take appropriate mitiga-
tion measures if any discoveries are made during construction
and operation which would be protected under of these laws.
PCB Disposal Permit
EPA has developed regulations specifically controlling the
disposal of PCBs (40 CFR Part 761).* These regulations require
"approval" from the EPA Regional Administrator before any facility
may dispose of regulated PCB wastes. EPA approval takes the form
of permits issued to disposal facilities, which may either be
incinerators or landfills. Liquids containing PCBs in concentra-
tions greater than 500 parts per million, as well as capacitors
containing 3 pounds or more of dielectric fluid, may only be
incinerated or chemically treated. Other wastes containing PCBs
* Oils and other liquids containing a PCB concentration of 50 parts
per million or more are regulated under the Federal regulations.
Other articles containing or contaminated by PCBs, such as capa-
citors, transformers, clothing, and soils, are also covered. See
40 CFR 761 .60
V-10
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are commonly incinerated, although they could be landfilled
under conditions set in the regulations.
Incinerators must meet certain combustion criteria to ensure
adequate incineration of the waste materials. To obtain EPA
approval, the facility owner or operator must submit a report
which includes a facility description and design drawings, engi-
neering reports or other information on the anticipated perfor-
mance of the incinerator, information on sampling and monitoring
equipment and facilities, and waste volumes expected to be incin-
erated. A trial burn may be required to confirm the ability of
the incinerator to meet the requirements. A waiver from these
requirements may be obtained if the owner or operator can document
that operation of the incinerator will not present an unreasonable
risk of injury to health or the environment from PCBs. Additional
discussion of PCB incinerator requirements appears in Section IV,
Air Quality.
A landfill which handles PCB wastes must meet several specific
design and operating requirements, including the following:
• The site must either be located where the soils are rela-
tively impermeable (such as areas with thick clay layers)
or else the operator must install natural or synthetic liners.
• The site must have at least three ground water monitoring
wells, samples from which must be analyzed for the presence
of PCBs, and for other parameters.
• A leachate collection system must be installed and moni-
tored monthly for quantity and physicochemical character-
istics of the leachate.
• If the facility is located below the 100-year floodwater
elevation, diversion dikes must be placed around the
perimeter of the landfill with a minimum height equal to
two feet above the 100-year floodwater elevation.
For a complete discussion of these and other landfill design and
operating requirements, see 40 CFR 761.75.
The PCB facility permitting process would involve a public
review process similar to that for a RCRA permit (see DEIS
Appendix A, p. A-ll). Generally, PCB permits involve a shorter
public review period than RCRA permits (30 days rather than
45 days) and more limited public notice requirements. The
proposed Arizona facility, however, would be both a hazardous
waste facility and a PCB facility (if the incinerator proposal
is selected by the State). In such a case, the RCRA hazard-
ous waste permit and the PCB permit would be issued simulta-
neously, and the RCRA public review provisions would be
followed for both permits.
V-ll
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ADHS TRANSPORTATION REGULATIONS
ADHS is required by State law (ARS 36-2800) to develop trans-
portation regulations for the hazardous waste facility. These
regulations will specifically address the routing of hazardous
waste shipments to the facility and safety considerations for
special populations at risk. At the present time, the Mobile
Elementary School is perceived as requiring special consideration.
Safety measures being considered include low speed limits and
warning signs. ADHS will solicit public input on the regulations
during the regulation adoption process.
ADHS expects to promulgate the regulations by mid-1984.
In adopting the regulations, the Department will follow the
procedures and time frames outlined below.
Activity
Prepare Regulatory Needs Statement;
Hold workshop to discuss statement
and to receive input on regulatory issues
Prepare draft regulations
Give notice of public meetings on
draft regulations
Hold public meetings
Prepare responsiveness summary and final
draft of regulations; obtain Attorney
General's approval
Prepare submittal for Governor's
Regulatory Review Council (GRRC);
begin notice of public hearings;
appear before GRRC
Hold public hearings; prepare responsiveness
summary and final regulations
Submit regulations to Attorney General
for certification (allow 90 days)
Attorney General certification and
filing with the Secretary of State
step
Filing regulations with the Secretary of State
in the State's regulatory development process.
Date
June-July,
1983
August
August-
September
September
October-
November
November-
January , 1984
January-
March
March
May-June
is the last
The Bureau
of Waste Control intends to combine development of the transpor-
tation regulations with the revision of the State's Hazardous
V-12
-------
Waste Regulations, which is required by House Bill 2326, enacted
by the State Legislature in the 1983 session. Promulgation of
the transportation regulations may be delayed if revision of the
hazardous waste regulations takes longer than the schedule
outlined above, as may be the case. Nevertheless, the transpor-
tation regulations will be adopted before the State hazardous
waste facility becomes operational.
SUMMARY OF IMPACTS AND MITIGATION MEASURES
Table V-1 summarizes the potential environmental impacts of
the proposed hazardous waste facility, and the measures which
would be taken to mitigate them. Impacts would be similar at
all three sites unless otherwise noted. For more detailed
information, see Section 4 of the Draft EIS and Sections III
and IV of this Final EIS.
V-1 3
-------
Table V-l. Mitigation of potential impacts
IMPACTS
MITIGATION
Physical Setting
Topography over an area of
approximately 58 acres would
be altered locally by the
construction of the facility
and access roads. Soils would
be disturbed or removed. If
erosion is not prevented, this
could result in increased wind
and water erosion due to the
considerable disturbance of
the site's natural vegetation.
Following the construction phase,
some of the disturbed land
would likely revert to the pre-
construction conditions over a
period of years.
If the land transfer is made
and the facility is built,
ADHS would ensure that the
contractor would:
minimize disturbance of
soils and vegetation in
adjacent areas;
minimize erosion
embankments;
of
minimize
soils or
piles to
stockpiling of
stablize stock-
avoid erosion;
rehabilitate borrow areas;
provide adequate drainage.
Water Resources: Ground Water
Because the estimated depth to
ground water is 320 ft (Ranegras
Plain) to 500 ft or more
(Mobile), the possibility of
contaminants from the facility
leaching or leaking into ground
water is remote. Should ground
water become contaminated at
Except in special cases,
Federal regulations require
that hazardous waste facility
units have either: (a) a
single impermeable liner
with a ground water moni-
toring system, or (b) a double
liner with a leak detection
V-l 4
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TABLE V-1, cont'd
IMPACT
MITIGATION
Water Resources; Ground Water, cont'd
the Mobile site, regional
hydrogeologic data indicate
that it would take an estimated
270 to 370 years for the
contaminated ground water to
move from the site to the
nearest existing water supply
wells. At the Western Harqua-
hala Plain site, it would take
some 2,700 to 11,000 years for
the ground water to move to
the nearest downgradient wells,
while at the Ranegras Plain
site it would take in the
range of 2,250 to 6,750 years.
system between the liners.
Specific ground water protec-
tion requirements would be
established in the facility's
hazardous waste permit, and
would depend on the character-
istics of the site and the
design of the facility.
Methods which could be used
to detect leaks from the
facility include:
leak detection and col-
lection system between
the double liners in a
landfill or impoundment;
liquid mass balance calcu-
lations;
unsaturated zone monitoring;
ground water monitoring.
Water Resources: Surface Water
If a facility constructed at the
Mobile site were not adequately
designed to withstand flooding
from intense storms, run-on
from the surrounding watershed
could flood the facility and
carry contaminants into
Waterman Wash. A public health
problem could result, although
contaminant levels downstream
would be reduced by dilution.
Diversion of storm waters
around the facility as a flood
protection measure could affect
drainage patterns near the site;
the flow of storm water into
Northwest Tank could increase.
ADHS would require that the
facility be designed to protect
against a 100-year storm rather
than a 25-year storm, using
berms, ditches, dikes, or other
hydraulic structures. ADHS
would work with the contractor
to minimize or avoid adverse
impacts on the Northwest Tank
or on other areas affected by
drainage patterns on and
around the site.
V-1 5
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Water Resources: Surface Water, cont'd
Since the Western Harquahala
Plain and the Ranegras Plain
areas are subject to sheet
flow rather than concentrated
flooding, the potential for
flooding of the facility is
lower at these sites than at
the Mobile site. Overflow
from a nearby portion of the
CAP canal due to an intense
storm however could flood a
facility at the WHP site and
carry contaminants into Bouse
Wash. A public health problem
could result, although contami-
nant levels downstream would be
reduced by dilution. Because
the CAP canal is designed to
avoid or control overflow
problems, such an event is
unlikely.
ADHS would require evaluation of
the potential for flooding posed
by overflow from the CAP Canal.
Based on this analysis, appro-
priate protective measures such
as berms, dikes, etc., would be
incorporated into the facility
design.
Air Quality
Emission of TSP (e.g., dust,
dirt) from construction
activity would be expected
to add an estimated 10 ug/m3
to the ambient concentrations,
exacerbating occasional TSP
problems from natural sources
(e.g., dust storms). Smaller
amounts of dust could be
emitted from operational
activities.
ADHS would ensure that the con-
tractor minimize dust problems
during construction. Control
measures may include:
watering disturbed areas;
ceasing construction during
high winds;
using dust suppressants.
To control dust during facility
operation, ADHS would ensure
that the contractor:
revegetate disturbed areas;
V-1 6
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Air Quality, cont'd
Particulates from an incinerator
could add up to about 13 ug/m3 to
the ambient TSP concentrations.
Volatile organic compound
emissions from facility opera-
tions could exceed 300 tons
per year, making the facility
subject to Prevention of
Significant Deterioration
(PSD) review if the emissions
were determined to be "non-
fugitive." Additional infor-
mation would be needed to
determine the potential for
hazardous or toxic emissions.
A PCB incinerator could
emit dioxin (TCDD) and
furan (TCDF), as well as
trace amounts of other
hazardous compounds. The
TCDD and TCDF emissions
could pose a risk to public
health and the environment
if emitted in significant
quantities.
pave access roads and main
areas of vehicle traffic;
water or use dust suppres-
sants on overburden storage
piles
water the landfarm area;
cap and revegetate closed
landfill areas.
The facility's permit condi-
tions should minimize the
emission of particulates from
the incinerator.
ADHS and the facility con-
tractor should carefully
evaluate the potential for
hazardous emissions from
the facility. Proper
operation should minimize
impacts.
As part of the process of
issuing a permit for the
disposal of PCBs in the incin-
erator, EPA would conduct a
risk assessment for inciner-
ator emissions to determine
the potential health risk.
During the permit process,
this assessment would be sub-
ject to review by State and
Federal decision-makers as
well as the public.
V-1 7
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Public Health and Safety; On-Site Spill Risks
Experience at an existing
hazardous waste facility
suggests that 0.5 operational
spills per year could be
expected at the proposed
facility. Impacts of a spill
would depend on the type of
waste, weather conditions, etc.
A spill of hazardous waste
could emit toxic or hazar-
dous constituents into
the air. A "worst case" spill
scenario indicates that ambient
concentrations of highly
volatile substances could
pose an immediate hazard
within about 1,000 ft of the
spill.
ADHS would work closely with the
facility contractor in develop-
ing emergency preparedness and
and contingency plans required
for the hazardous waste permit.
Measures that may be included are:
grading of waste handling
areas to a central collec-
tion point;
incorporation of an emergency
spill handling system as part
of the overall engineering
design;
careful monitoring;
protection of employee health
through training, health
monitoring, use of appro-
priate equipment, and
limitations on the handling
of certain wastes.
Public Health and Safety; Transportation Spill Risks
A transportation risk assessment
shows that the potential for
accidents is low (0.01 to 0.02
accident per year) along three
alternative routes from Tucson
to the Mobile site. Accident
probabilities for routes from
Phoenix to the Mobile site may
range from 0.02 to 0.13
accidents per year.
About 0.05 accidents per year
could be expected from shipping
wastes from Tucson to either
the Harquahala Plain site or
to the Ranegras Plain site.
The following actions would
minimize the frequency of
transit-related accidents and
reduce the population at risk:
Arizona's Law (ARS 36-2800)
requires transportation
routing regulations to be
promulgated. In designat-
ing transit routes, ADHS
would take into considera-
tion the frequency of
accidents and the number
of people at risk.
ADHS would work with the
V-1 8
-------
TABLE v-1, cont'd
IMPACTS
MITIGATION
Public Health and Safety; Transportation Spill Risks, cont'd
Accident probabilities from
Phoenix to these sites (via
1-10) are 0.16 to 0.18
accidents per year.
Shipment of wastes from
Phoenix and Tucson to the
Mobile site poses risks to
the population along
potential routes and near
the proposed facility.
The population at risk from
Tucson to the site would
range from 55,000 to 56,000
(depending on the route) while
the Phoenix-site route would
place from 104,000 to 133,000
at risk. Schools located in
the Maricopa and Mobile areas
may be considered as special
cases of population at risk.
For the alternative sites, the
population at risk is estimated
to be 60,000 to 225,000 on two
alternative routes from Tucson
to the sites, and 103,000 from
Phoenix to the sites. The
potential for spills into the
CAP Canal presents a special
hazard. However, the probability
of such spills is extremely
low, since the trucks would be
near the Canal for only a short
time.
The addition of trucks carrying
PCB wastes to an incinerator at
the facility could increase the
population risk factors along
the access routes to the Western
Harquahala Plain and Ranegras
Plain sites by about 4% and
to the Mobile site by 32 to
140% (depending on the route).
Arizona Division of
Emergency Services (DES)
to make any necessary
revisions to the State
Emergency Response Plan,
the document which outlines
the roles of Federal,
State, and local agencies
in the event of transit
emergencies.
The facility contractor
would work with the county
highway departments to
ensure that improvements
made in access roads
consider safety concerns
raised in this EIS.
ADHS would encourage waste
haulers to limit particu-
larly hazardous loads to
those times of the day
and weather that are
likely to minimize the
risk of a transit accident.
V-1 9
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Public Health and Safety; Off-site Emergency Response
For the Mobile site, 14
communities, 3 of which
are near the site, could be
exposed to hazardous material
emergencies; 13 communities
could be affected by a transit
emergency. Phoenix and Casa
Grande are more likely to
experience transit emer-
gencies than other cities.
For the alternative sites,
20 communities, 7 of which are
near the site, could be exposed
to hazardous materials emergen-
cies; 20 communities could be
affected by a transit emergency.
None of these nearby communities
and virtually none of the non-
metropolitan communities have
adequate emergency personnel,
equipment, and communication
equipment to respond to such
emergencies. Emergency response
personnel based in Phoenix could
become overburdened if called
upon to serve the facility in
addition to their present
responsibilities.
Mitigation of the effects of
hazardous waste incidents
depends on response prepared-
ness. ADHS would work with
the Division of Emergency
Services to ensure prepared-
ness of safety agencies
through:
upgrading the state
emergency response
system to ensure that
agencies are adequately
equipped;
training personnel to
recognize hazardous
materials incidents;
training hazardous mater-
ials specialists in
hazardous chemical
management;
ensuring that the Emer-
gency Response Plan is
distributed, understood,
and tested.
Public Health and Safety; Valley Fever
Soil disturbance at the Mobile
site may pose a risk of Valley
Fever to those construction
workers who have not previously
been exposed. The probability
of significant impacts on persons
outside the site appears to be
low. Occasional high winds
could disperse spores to nearby
populated areas.
Valley Fever spores cannot be
eradicated, but ADHS would
work with the contractor to
minimize the severity of any
spore releases. Precautions
may include:
minimizing soil disturb-
ance;
V-20
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Public Health and Safety: Valley Fever, cont'd
It is assumed that the Valley
Fever spore population at the
alternative sites is similar to
that at the Mobile site. The
population subject to possible
exposure is lower than at the
Mobile site.
soil sampling;
confining soil-disturb-
ing activities to periods
of low wind velocities;
using dust suppressants;
monitoring health
records;
having workers use face
mask respirators;
informing workers of risks,
Public Health and Safety; Odors
Since the proposed sites are
located in rural areas with
low population density, odors
are not expected to be a
major problem.
ADHS would: (a) establish a
system to respond to any
citizen complaints, (b) work
with the contractor to alle-
viate any problems that did
arise, and (c) ensure prompt
cleanup of any spills.
Public Health and Safety; Noise
Operational noise levels at
the facility would be con-
siderably above background
levels, but the general
noise level would not be
expected to exceed OSHA
standards. Facility
operational noise would
not be expected to affect
nearby communities.
The operator would be respon-
sible for complying with all
OSHA Noise requirements"to
protect employees.
V-21
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Public Health and Safety; Noisef cont'd
Noise from truck traffic
through or near Mobile and
Maricopa may be a nuisance,
No transportation noise
impacts would be expected
at the alternative sites,
as there are no permanent
residences along the main
access roads. Facility
truck traffic would be an
insignificant addition to
traffic on 1-10.
ADHS would:
work with the contractor
to limit traffic-generat-
ing activities to daylight
hours;
establish a system for
responding to citizen
complaints; and
monitor and mitigate noise
impacts on schools, if
requested by school
officials.
Ecological Resources
Construction would result in
some loss of vegetation and
disturbance of land.
ADHS would require that the
contractor:
minimize the disturb-
ance of vegetation;
limit clearing to areas
needed for construction
or disposal operations;
minimize the size of
construction and
maintenance roads;
revegetate cleared areas
with "appropriate" native
seed or mature plants (in
consultation with the
Arizona Commission on
Agriculture and Horticul-
ture and the Arizona Game
and Fish Department).
The contractor would be required
to confirm whether any Federally
V-22
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Ecological Resources, cont'd
Food, shelter, and nesting
habitats for local wildlife
may also be disturbed or
removed. Some direct animal
kills might occur. The
operation of evaporation
ponds may pose a threat to
the avian population attracted
to the ponds as a source of
water.
protected species would be
affected (none are currently
known to exist at the sites).
Certain State-protected species
at the sites would be relocated,
Mitigation would consist of:
(a) minimizing disturbance
of land, (b) revegetating as
soon as possible, and (c)
informing the contractor and
their employees of wildlife
protection regulations.
Rodent and bird controls,
if necessary, would be
implemented in consultation
with the Arizona Game and
Fish Department.
Land Use
No significant impacts on land
use would be expected to result
from the removal of 58 to 640
acres from the existing BLM
livestock grazing allotment.
Only a minor impact on the
recreational resources could
result. Some of the uses,
such as grazing, may reoccur
after facility has been fully
closed, depending on the
conditions of the permit.
Owners or permitees would be
reimbursed for range improve-
ments adversely impacted.
V-23
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Visual Resources
At the Mobile site, the
facility would stand in
significant contrast to the
existing visual environment.
The impact would be low
because of the relatively
small number of recreational
users of the areas, and its
distance from populated
centers.
At the Western Harquahala
Plain, the facility would
be visible from 1-10, but
the existing topography and
presence of other currently
visible structures (CAP
canal, pipeline pumping
station, transmission line,
1-10) would reduce the
visual impact of the
proposed facility.
At the Ranegras Plain site,
the visual contrasts of the
facility could be significant
to users of the Kofa Game Range
and a Wilderness Study area.
However, existing visual dis-
turbances (transmission line,
windmill pump and water tank,
and 1-10) would lessen the
overall impact of the facility
on visual experiences.
Development of an incinerator
at the facility would increase
the visibility of the facility
due to the presence of a smoke
stack. The stack would likely
be about 40 feet high.
ADHS would ensure that visual
disturbances were minimized
as much as possible. Guidelines
will include the following:
Protective dikes should
appear as natural as
possible (e.g., approximat-
ing natural grades).
Native vegetation should
be used to reduce visual
contrast.
Facility structures should
appear as natural as possible
and be earth tone in color.
Height of facility struc-
tures should be limited,
if possible.
The incinerator smokestack
should be placed in a
location which would allow
construction of the
lowest possible stack,
taking into account the
topography and various
engineering requirements.
V-24
-------
TABLE V-1, cont'd
IMPACTS
MITIGATION
Cultural Resources
No recorded archeological,
historical, or significant
Native American resources
have been identified at the
sites; therefore no impact
is anticipated. The facility
would be expected to eliminate
the gathering of subsistence
plants by Native Americans
on the Mobile site. Given the
small area of affected land,
this impact would not likely be
significant.
The facility contractor, as
part of the permit process,
must identify any cultural
resources at the site or
confirm that no such resources
exist. If any such resources
are identified, appropriate
mitigation measures would be
taken in consultation with
the State Historic Preserva-
tion Officer.
Socioeconomics
Economic/demographic effects
would be minimal. There could
be increased revenue flow to
regional and local jurisdictions,
generation of sales tax
revenue during the construc-
tion period from purchase of
construction materials locally,
and tax revenue from out-of-
state purchases. Because of
conflicting impacts on land
values, it is not possible
to project the net impacts
on land values. Odors,
traffic noise, and anxiety
with respect to other possible
public health and safety
effects could cause deteriora-
tion in the quality of life for
a small number of people.
Mitigation measures are
identical to those described
for impacts on land use and
on public health and safety.
V-25
-------
'T*ie good tile is one inspired by love and ftuided by knowledge"
THE BEKTRAND RUSSELL SOCIETY, INC.
Robe>-; K. dv is
3D
^
Peter G. Cranford
Donald W. Jackanicz
Secretary
Dennis J. Darland
Treasurer
w~3
W-4
Phys
Alex Dely, Chairman, Science Committee
ics Department University of Arizona Tucsor
VI-5
-------
VT-6
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L, I It
^^w^jTu^fifi.vi fck&.
4jL-AflJftJlJte
-------
"The good /i'e is one inspired by love and guided by knowledge"
HE BERTRAND RUSSELL SOCIETY, INC.
Robe*-: K. Davis
Peter G. Cranford
Cha i rman of the Board
Harry Ruja
Vice--resident
Donald W. Jackanicz
Secretary
Denni s J. Darland
Treasu rer
^ c^gfkeft- Z-g^JL^
AŁj±S5i±jL-ra SLJ r^j^Lsj^
UuJs-
<*-^ W-8
i^n- 4- ' p^cU*U*. kj t^-^_
^ 8 ' / ^S^b_^ŁS2SŁ^:
^ ct WO-A b<
Alex Dely, Chairman, Science Committee
Physics Department University of Ari zona Tucson, Anzona
W-9
VI-7
-------
7_ -i i
VI-8
-------
'The good life is one inspired by love and Ruided by know/edge"
THE BERTRAND RUSSELL SOCIETY, INC.
Robert K. Davis
President
Harry Ruja
Vice-President
Peter G. Cranford
Chairman of the Board
C&*C&. E&JlfO, C^'fil.
Donald W. Jackanicz
Secretary
Dennis 0. Darland
Treasurer
CC.5
fitt-
»
Alex Dely, Chairman, Science CoiTiniittee
Physics Department University of Arizona Tucson, Arizona 8b/.
VI-9
-------
W-l The Request for Proposals which ADHS issued to potential
facility contract bidders states that the selected con-
tractor must meet the financial liability requirements
of the State and Federal hazardous waste regulations.
The State of Arizona would be named as an insured party in
all insurance policies that the contractor must obtain.
The coverage must be retained for the lifetime of the
facility. In addition, the contractor must meet the
closure and post-closure financial requirements specified
in the Federal regulations (40 CFR Part 264, Subpart H).
In effect, the contractor would provide adequate financial
responsibility protection for the operational, closure,
and post-closure phases of the facility. The State of
Arizona would take over the perpetual care of the site
after the closure and post-closure phases. The trust
fund provided for by ARS 36-2800 would be used in part
to pay for the perpetual care and any necessary liability
costs.
Being the land owner, the State would incur ultimate
legal liability for the site. The State is self-insured
up to $500,000 and maintains liability insurance for
$100 million. A citizen or organization could seek
redress from the State through appropriate administrative
and legal channels. This would normally take place only
after the contractor's financial responsibility mechanisms
were exhausted.
W-2 In the event of a contamination problem, the facility
contractor would be responsible for identifying the
severity and extent of the contamination. State involve-
ment in an investigation of contamination would be to
assess data provided by the facility contractor and to
provide for independent sampling and analysis, if required.
The State would also be responsible for evaluating and
approving any remedial action plans to correct the problem,
and for taking enforcement action if necessary. Resources
for the State's monitoring activity would come from the
trust fund established by ARS 36-2800. The fund will be
used for monitoring, perpetual care, and liability costs.
W-3 See the discussion of subsidence in Section IV, Physical
Se 11 i ng .
W-4 Specific ground water protection requirements for the
facility would be established in the permit process.
This comment is more appropriately addressed at that
stage. See the discussion of liner and monitoring/
detection systems in Section IV, Ground Water.
W-5 The CAP canal would not be affected. See Section IV,
Surface Water.
VI-10
-------
W-6 There are no regulations precluding the use of innovative
technologies at the Arizona facility. Whether such tech-
nology is developed depends on its economic feasibility.
This Final EIS includes an analysis of a high-temperature
incinerator as an alternative to land disposal of certain
types of wastes.
W-7 Data does not exist which would show a relationship between
the level of user fees charged and the amount of illegal
dumping. While many people would agree that the existence
of reasonably-priced disposal options tends to encourage
compliance with the hazardous waste control laws, the
limited experience with user fees and the difficulty in
obtaining statistics on illegal dumping make it hard to
assess the real impact of user fees on compliance. One
EPA study of state hazardous waste fee systems states the
following:
Officials in one state expressed concern that the use
of a fee mechanism might work counter to a program's
regulatory enforcement goals by encouraging operators
to find ways (both legal and illegal) to get out of
the regulatory system to avoid the fees. Fees are
accordingly seen as an additional incentive for "mid-
night dumping." The only response to these concerns
is that the states with fees in place did not mention
this result to be actually occurring. (30)
The fees to be charged by the facility would be set by
ADHS in consultation with the facility contractor. Both
the need to generate a profit for the contractor and the
need to avoid unreasonably high charges would have to be
considered by the Department in setting these fees.
W-8 Additional discussion of resource recovery and waste
reduction appears in Section IV, Alternatives.
W-9 DEIS Table C-2 is based on the most complete information
available on hazardous waste generated in Arizona, and
includes data from some "small quantity generators" who
voluntarily submitted reports. The exact amount and types
of wastes the facility would be able to handle depend on
the specific design and operating plans of the operator.
That information would be included in the operator's
permit application.
W-10 See the discussion of the Waste Exchange Program in
Section IV, Alternatives.
W-11 The State's emergency response 'capabilities are discussed
in Section IV, Public Health and Safety: Spill Risks.
The facility operator would be responsible for identifying
VI-11
-------
and providing emergency response equipment and personnel
training to ensure quick response to on-site emergencies.
Only when the facility design and operating plans are
available will it be practical to determine an adequate
emergency response system at the facility. This would
be done as part of the permitting process.
VI-12
-------
ARIZONA DEPARTMENT OF HEALTH SERVICES
Division of Environmental Health Services
REF: HWS 082
r '. "," Feb<
Acting Director
BRUCE BABMTT. c^ February 16, 1383
Donald B. Mathis ' ' ' •
Mr. Chuck Flippo
U. S. Environmental Protection Agency
Region IX (T-2-1)
215 Fremont Street
San Francisco, California 94105
Dear Chuck:
This letter is to transmit comments from the Bureau of Air Quality
Control (BAQC) on the Draft Environmental Impact Statement for the
proposed State Hazardous Waste Management Facility. Mr. Lloyd Rowe,
Acting Chief of the BAQC indicated that:
o -Most of the BAQC concerns expressed on a previous draft of the
EIS were addressed and that reasonable steps have been identi-
fied to minimize particulate emissions.
o A commitment should be made to minimize the tracking of dirt
onto paved roads during construction and subsequent operation
of the facility.
If you have any questions, please call me at 602-255-1162.
Sincerely,
Tibaldo Canez, Manager
State Hazardous Waste Site
TC:ph Bureau of Waste Control
The Department ?f Health Services 19 An Equal Opportunity Affirmative Action Errployer All qualified men and
women, including the handicapped, are encouraged 10 participate.
State Health Building 1740 West Adams Street Phoenix, Arizona 85007
VI-13
-------
W-12 Use of dust suppressants during construction and
paving of main vehicle routes within the facility are
among mitigation measures identified in the Draft EIS
(DEIS pp. 4-14 and 4-16). ADHS's Bureau of Air Quality
Control should work with the Bureau of Waste Control to
ensure sufficient dust control measures are identified
and implemented.
VI-14
-------
ARIZONA I PARTMENT OF HEALTH RVICES
Inter-Office Memorandum PDU 10.3
TO. Tibaldo Canez, Manager DATE' February 2, 1983
State Hazardous Waste Site, BWC_
"\ y--.
THRU. J. B. Bale, Manager ~" v. ^< J^^
Water Quality Management,Section
Bureau of Water QualityCoritrol
FROM: V. C. Danos, P. E.,cM&rfajEr
Program Development Unit
RE Draft EIS for the State Hazardous Waste Management Facility
Overall, this version is far superior to the previous review drafts. Our
review has been confined to the discussions pertaining to water resources.
The following minor comments are offered:
1. On page 3-8, it is stated that moist sand was detected in an
abandoned well. This statement should be clarified to indicate T'J—13
the source of this sand (backfill material, ruptured casing, etc.).
2. On page 3-36, fourth paragraph, it is stated that the average
annual groundwater flow velocity is between 1.8 and 7.4 feet V—14
each year. From the discussion, it is not apparent how the
figure "1.8" was derived.
3. On page 4-5, the EIS notes that in the event of a major undetected
leak to groundwater, concentrations of materials in existing wells
would be low as a result of subsurface attenuation and dilution. W-1 5
The first reason, implying attenuation in the subsurface, is
grossly misstated. This kind of reasoning has historically led to
the after-the-fact discovery that chemicals were not removed in
the unsaturated zone. With no data to the contrary, this statement
is misleading. Secondly, there would be minimal dilution within
the saturated zone. Groundwater flow is laminar; dilution would
occur only from dispersion
J JB: VCD :AJG: dink
VI-15
-------
W-13 According to the Arizona Department of Water Resources,
the abandoned well was still equipped with a submersible
pump when the moist sand was detected. Since the pump
was still in the well, it is reasonable to assume that
the pump had been used within the past few years and that
the moist sand in the well is bottom hole material rather
than backfill.
W-14 The flow velocity was calculated from regional ground
water data using a modified form of the Darcy equation.
This method is outlined in EPA's draft Ground Water
Monitoring Guidance for Owners and Operators of Interim
Status Facilities, 1982. See also comment W-21.
W-15 See Section IV, Ground Water.
VI-16
-------
Sta of Arizona
DEPARTMENT OF WATER RESOURCES
99 E Virginia Avenue, Phoenix, Arizona 85004
BRUCE BABBITT, Governor
WESLEY E STEINER, Direc'or
February 10, 1983
U. S. Environmental Protection Agency o
Region 9 c~ ^ fn
ATTN: Chuck Flippo (T-2-1) - o <
215 Fremont Street ^ 5 f
San Francisco, California 94105 —: 5 C
c
-------
Mr. Chuck Flippo
February 10, 1983
Page Two
not sufficient to design a groundwater monitoring
program. This entire section is based on the
assumption that site conditions are the same as
regional conditions. There is no proof of this. It
is also assumed that conditions will remain the same
throughout the proposed facility's useful life. This W—18
may not be the case, in fact, it probably will not be
the case. Groundwater will most likely be the source
for the water needed to run the plant. This means a
well must be completed near or on the site, which will
alter both local and perhaps regional conditions. In
addition, there is at least one large proposed industrial
project in the Mobile area that will utilize groundwater
and will no doubt alter regional conditions. Of course,
all future changes cannot be considered; however, without
understanding current site conditions, the potential
effects of changing regional conditions on the site cannot
even be attempted.
-Same Page, Same Section and Subsection, Paragraph 3
This treatment of groundwater protection is not sufficient.
The purpose of an EIS is to evaluate potential impacts and
provide a plan to eliminate or reduce the impacts. This
cannot be done properly at this time for groundwater because
of a lack of site specific groundwater data. However,
simply saying it will be taken care of later by the permitting
system is insufficient. This EIS should provide specific
minimum requirements for data collection, analyses and W—19
consideration of these in the monitoring program design as
part of the accepted EIS. This is really the only way the
federal government, and the public relying on the federal
government, can be assured that the environment will be
protected. Approving an EIS prior to defining the site
environmental conditions without providing for adequate
study of the environmental factors appears to be side-
stepping the purpose of doing an EIS.
Affected Environment
-Page 3-8, Water Resources Section, Groundwater Subsection,
Paragraph 3
The use of average particle velocity in the formula
v = -kdh/dl/6 to calculate the travel time of a
pollutant introduced into groundwater is suspect.
Average particle velocity as calculated may not
VI-18
-------
Mr. Chuck Flippo
February 10, 1983
Page Three
represent fluid or contaminant velocity. In fact,
many researchers suggest that average particle velocity
is inadequate for such use (see Lohman, S. W., Ground- W—20
Water Hydraulics, U.S. Geological Survey Professional
Paper 708, 1972, p. 10 and 11).
Also, this use of average particle velocity assumes the
pollutant travels at the same velocity as the water
particle. This is not necessarily so. Pollutant velocity
may be higher due to dispersion effects. Thus, travel
times calculated using this method are suspect.
-Page 3-36, Paragraph 4
The first "flow rate" (14.6 ft/year) is wrong; the value
used in the last sentence (1.8 ft/year) is correct. This W—21
is also particle velocity, not flow rate. I am not sure
how the first value was calculated, but if the calculation
technique used is the same as all of the others in this
section, there is an error.
Thank you for the opportunity to comment on this document. If I
may be of any further assistance or can clarify any of the above comments,
please call.
Sincerely, /
I,
EdVarS A. Nemecek
Chief Hydrologist
nh
VI-19
-------
W-16
W-17
W-18
W-19
W-20
These comments are addressed in Section IV/ Ground Water.
See in particular the discussion of hydrogeologic data
and the subsequent discussion of the permit.
W-21 This observation is correct; the "flow rate" is 1.8 feet
per year, as calculated using a modified form of the
Darcy equation (see comment W-14). All other figures
that appear in this discussion are correct.
"Flow rate" or "flow velocity" is more accurately described
as the "average linear velocity of a particle of water."
VI-20
-------
JIM HARTDEGEN
CAS.0R.,DE .R.ZeNA.,222 ^xL—T,,, COMMiTTEES
636- I 1O? IHOHCp
25S-5549 lOFFICEi
of 3ReprŁaentatt&cs
ix, ArtHnna 85007
February 17, 1983
Mr. Chuck Flippo
Environmental Protection Agency
Region 9
215 Fremont Street San Francisco, CA 94105
Dear Mr. Flippo:
I am writing in regard to the Environmental Impact Statement on the Arizona
Hazardous Waste Facility. I would like to aim my remarks to the road system
leading into the proposed Rainbow Valley site.
The route would be over Maricopa Highway, which lies between Interstate 10
and Arizona Highway 84, and passes through the little community of Maricopa.
From Maricopa westward, travel is via a dirt road called the Maricopa/Gila
Bend Road. At the present time, the Maricopa Road is a county highway that
is in both Maricopa and Pinal Counties. This road has an unbridged crossing
at the Gil a River.
This road is in terrible condition and, in my opinion, is not adequate to
haul large amounts of hazardous waste. I am sure the dirt road from Maricopa TT_O')
to the dump site would be dangerous under rainy conditions for vehicles haul- W"^^
ing waste material. I do not believe the Department of Health Services has
addressed the subject of transportation safety and considered the condition
of these roads.
I would like these comments submitted into the report for the purpose of
calling attention to the fact that the major way into this dump site is, in
my opinion, very dangerous. The road system should also be addressed by
the Environmental Protection Agency.
If I can be of any further assistance to you, please contact me.
x^incerely,
^.-r
(JIM HflRTDEGEN
St-ate.-'Representati ve
District 6
JHrba
VI-21
-------
W-22 See the discussion of access routes to the Mobile site
in Section IV, Public Health and Safety: Spill Risks.
VI-22
-------
•2 A o-'
BRUCE BABBITT, Gonernor •«./•>-O
CHARLFS e ROBERTS OD Bisb*e Ctif
FRANK FERGUSON JR Vg-flB
FRANCES A1 WERNER Tucson
CURTIS A JENNINGS ScotlsOale
JOHN j GiSi Fia&siaf
LhrfcKf
7
ARIZONA GAME & FISH DEPARTMENT
3222 Wof gut^xy 6?*^ (fa**;*. ^fup** 85023 942-3000
February 23, 1983
Sonia F. Crow, Regional Administrator
Environmental Protection Agency, Region 9
215 Fremont Street
San Francisco, California 94105
RE: Draft E.I.S. - Arizona
Hazardous Waste Facility
Dear Ms. Crow:
Our Department has reviewed the draft environmental impact
statement for the Arizona Hazardous Waste Facility and we submit
the following comments.
Specific Comments by Page;
Page 3-17 "Amphibians and Reptiles".
The desert tortoise and the Gila monster are not listed as
endangered by the Arizona Game and Fish Department, as stated in
the text. The desert tortoise is listed under Group 3 in "Threat- r*y_23
ened Native Wildlife in Arizona, approved by Arizona Game and
Fish Commission 10 December 1982". By definition, Group 3 includes
animals "... whose continued presence in Arizona could be in
jeopardy in the foreseeable future." The Gila monster is protected
from killing under Commission Order 43, (R12-4-443), but is not
otherwise listed.
Page 3-18, 1st paragraph.
The spotted bat is no longer listed in "Threatened Native _ .
Wildlife in Arizona" and Arizona Department of Game and Fish V\—z4
should read Arizona Game and Fish Department.
Page 4-8, Surface Waters, Mobile Site.
We agree with the statement that "Under these circumstances,
the requirement to protect the facility from a 25 - year storm W-25
could be inadequate", especially since, as stated on page 3-10,
"Northwest Tank, ... could be affected by surface water draining
through or near the site."
AN EQUAL OPPORTUNITY AGENCY
VI-23
-------
Page 2
The deserts of Arizona are noted for torrential rains of short
duration, which result in substantial runoff on even the smallest
of watersheds. This runoff causes much natural erosion and could
severly damage the proposed facility and result in significant
adverse impact to the downstream environments.
Adequate protection from surface flooding must be provided
and the 25-year standard is not adequate. We believe that at
least protection from a "100-year" storm is needed to ensure a
reasonable level of safety, as stated on page 4-9 under "Mitigative
Measures"-
Page 4-36, Mitigative Measures, Bird Control.
In reference to the protection of birds from poisoning in
evaporation ponds, we believe that bird-proof screening is the ...
minimum control measure that is acceptable. Noise makers are VI-
generally effective for only short periods of time,, as birds be-
come tolerant of- them.
General Comments;
Other than the specific problems noted above, the draft E.I.S.
appears generally to be adequate and accurate.
Our Department believes that the Mobi]*. site is the most
appropriate site for the hazardous waste facility. r.—
We appreciate the opportunity to review this document and
we anticipate close coordination between our Department and the
Department of Health Services on this matter in the future.
Sincerely,
Bud Bristow, Director
William E. Werner
Habitat Specialist
Region IV - Yuma
CC: Don Metz, U.S.F.W.S., Phoenix
Planning and Evaluation Branch, Phoenix
State Clearinghouse, AZ 83-80-0007
WEW/cr
VI-24
-------
W-23 These two errors have been corrected. See Section II.
W-24
W-25 Comment noted. See Section IV, Surface Water.
W-26 Based on knowledge of similar existing facilities,
bird control should not be a problem. If a problem
did arise, ADHS would seek guidance and assistance from
the Arizona Game and Fish Department to evaluate and
implement appropriate bird control measures.
W-27 Comment noted. No response needed.
VI-25
-------
February 18, 1933
U. S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, California 94105
ATTN: Mr. Chuck Flippo (T-2-1)
RE: Draft Environmental Impact Statement for Proposed Arizona Hazardous
Waste Management Facility, January 1983.
Dear Mr. Flippo:
I have followed with great interest the work performed by the Arizona
Department of Health Services in developing an acceptable hazardous waste
facility site.
There were objections to the Harquahala and Ronegras sites that are not
present with the Mobile site; primarily, location. Transportation of TA — 2 8
hazardous waste would be much more expensive to the more remote sites.
One aspect of the mobile site that should add to its desirability is the
Southern Pacific Railroad that runs almost adjacent to the Mobile property W~29
as well as less road distance from the two largest population areas (Phoen-
ix and Tucson).
The primary concern of Arizona is protection of the groundwater. Since a
large majority of the people in Arizona depend upon the water source almost W—30
entirely, it must be guarded carefully from contamination. Your Draft
E. I.S. addresses this concern carefully and I find no fault there.
In establishing a hazardous waste treatment and reclamation facility, the
lack of use of railroad facilities under present prohibition does present
certain transportation problems. This presents problems in western states
where the distances between generators of waste and the facilities for T'T—31
proper disposal are great.
I, therefore, feel that E.P.A. should take immediate steps to alleviate
this situation. Most hazardous wastes are considerably less dangerous to
the population than railroad tank cars full of 98% sulfuric acid, anhydrous
ammonia, chlorine, military ordinance, ethylene oxide, and many other
chemicals the list is quite long.
electric power Cooperative inc. po Dox670 oenson. arizona e5o02 pnone602-586-363!
VI-26
-------
Page 2
U.S. Environmental Protection Agency
February 18, 1983
It is my conclusion that the site is well isolated and insulated from private W—3 2
encroachment and, therefore, an excellent site for the purpose intended.
Sincerely,
11\
Robert L. Maurice, Jr. /-
Environmental Engineer
RLM:hb
cc: Tibaldo Canez, Chief
Hazardous Waste Division
Arizona Department of Health Services
Phoenix, AZ 85007
Frank Flanders
Jim Carper
Jim Guinane
VI-27
-------
W-28 Transportation costs would likely be lower for the Mobile
site than for the other two sites. Shipment of hazardous
waste in this area generally costs between $2.50 to $3.50
per loaded mile. Using an average cost of $3.00 per
mile and mileage estimates from Tables C-1 and C-3
(Appendix C), the costs of shipping wastes to the Western
Harquahala Plain and Ranegras Plain sites are estimated
to be about 20 percent higher than the costs of shipping
waste to the Mobile site. The difference in costs for
shipping just hazardous wastes generated within Arizona
is considerably greater (about 45%).
Mobile Site WHP/RP Sites
Hazardous waste shipments
(from Phoenix, Tucson) $ 493,000 $ 892,000
PCB shipments 877,000 752,000
TOTAL $1,370,000 $1,644,000
W-29 See the discussion of railroad transport in Section IV,
Public Health and Safety: Spill Risks.
W-30 Comment noted. See Section IV, Ground Water.
W-31 EPA does not know of the prohibition referred to in this
comment. Under Federal regulations, hazardous waste can
be shipped by rail (see Section IV, Public Health and
Safety: Spill Risks). The main consideration in deciding
whether to ship by rail or by other means is cost.
The danger of hazardous materials compared to that of
hazardous waste is discussed in Section IV, Public
Health and Safety: Spill Risks.
W-32 Comment noted. No response needed.
VI-28
-------
March 1, 1983
Mr. Chuck Fllppo
EPA Region IX
215 Fremont Street
San Francisco, California 94105
Dear Mr. Flippo:
The Phoenix Area Indian Health Service has reviewed the "Draft EIS for the
Arizona Hazardous Waste Facility."
Our comments'will be limited to those items which could possibly effect the
health conditions of the Indian people living on or near the Gila River and
Ale-Chin Indian Reservations in the vicinity of the Mobile, Arizona site.
The Indian Communities have already expressed their concerns at previous
hearings and Mr. Ed Dunn, Director, Tribal Environmental Health Department,
Gila River Tribe will be submitting his written comments to your office in the
near future.
The Indian Health Service is primarily concerned about the following items:
1. Transportation routes on or near the Reservations will result in
increased heavy truck traffic. Heavy traffic on the narrow two-lane T7_'}o
Reservation roads will make it considerably more dangerous for the V.— jJ
residents who must travel these routes, thereby increasing the
possibility of accidents and hazardous waste spills.
2. Increased traffic, will cause Reservation roads to deteriorate and I'7—34
will require a greater maintenance effort. Who will be responsible?
3. Site preparation and increased traffic will create airborne pollution
from dust.
Will the roads leading to the site be paved? Can the Reservation T,7_ o C
residents be assured that proper dust control methods will be used on
the site? Who will be responsible for monitoring airborne pollution
on the Reservation lands, in the vicinity of the site?
4. Although the Mobile site is closer to Phoenix and Tucson than the
Harquahala Plain site, actual travel time saved may not be that great W—36
when comparing traveling on a two-lane road versus an Interstate
Highway.
VI-29
-------
PAGE 2 - MR. CHUCK FLIPPO
5. In comparing the sites, it appears that the Mobile site has a greater
possibility of flooding than the Harquahala Plains site. Can the T'V 3 7
Indian people be assured that the Mobile site can be adequately
protected in event of a 100 year flood?
6. Tests indicate that leakage would take 200-300 years to reach the
groundwater table. This may be true at the sites tested, but if W "? R
leakage or flooding should reach abandoned wells, holes or other soil
conditions in the area, the groundwater could be contaminated.
7. Where is the site going to get its water? If a well is drilled on TAT_"3Q
the site, can it be adequately protected to prevent contamination of
the groundwater?
The draft EIS has addressed most of our concerns as related to the environ-
mental impact on the Gila River and Ak-Chin Reservations.
We realize that specific site development information will not be available
until a Permit Application and design proposal is submitted to EPA and the
state.
IBS would appreciate receiving a copy of the final EIS, Permit Application
site, design proposal for review and final comment.
Sincerely,
George Oslind, P.E.
NEPA Officer
Phoenix Area IHS
VI-30
-------
W-33 See the discussion of two-lane roads in Section IV,
Public Health and Safety: Spill Risks, under "Risks of
Transporting Hazardous Waste."
W-34 Maricopa County and Final County have jurisdiction and
responsibility for monitoring and maintaining those
sections of access roads from 1-10 to the Mobile area.
Once the Maricopa to Mobile site road is improved, the
Counties would likely take over the maintenance of those
sections of the road in their jurisdiction.
W-35 Paving of the roads and other dust control issues are
addressed in Section IV, Air Quality.
W-36 It is not likely that differences in travel times to the
sites would be significant. Even if they were, however,
travel time is more related to costs of transport than
to environmental impacts. In its siting study, ADHS con-
sidered the travel time issue. The criterion the
Department used in its evaluation was whether a truck
could travel from Phoenix or Tucson to the site, unload,
and travel back within a day, so as to avoid expensive
overnight travel) (1). Environmental issues related
to the use of two-lane roads are addressed in Section IV,
Public Health and Safety: Spill Risks.
W-37 This comment is addressed in Section IV, Surface Water.
W-38 The adequacy of flood protection measures is addressed
in Section IV, Ground water.
W-39 The facility would be expected to meet most of its water
needs through pumping of ground water at the site (see
Section IV, Irreversible and Irretrievable Commitment
of Resources). Protection of wells is addressed in
Section IV, Ground Water.
VI-31
-------
Unted Stales Soil
Department of Conservation Room 3008 Federal Building
Agriculture Service 230 North First Ave. , Phoenix, AZ 85025
March 3, 1983
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, California 94105
Attention: Chuck Flippo (T-2-1)
Dear Mr. Flippo:
We have reviewed the Arizona Hazardous Waste Facility EIS and offer
the following comments:
1. Pages 3-3 and 3-4 - The correct name for the sixth (last) soil . -
association is "Chirioni - Gachado Rock outcrop." l.~4tU
2. Page 3-4 - In the first soil association the Avondale soil should be T/ij_ 4 1
corrected to read Avondale clay loam.
3. Page 3-32, third paragraph Correct the second sentence to read W—42
"These soils have moderately rapid infiltration rates, possess moderate
available water capacity..."
4. Page 4-2, mitigation measures Additional investigations should establish
(a) the suitability of the soils for ease of establishing vegetative W—4T
ground cover and (b) suitability of the soils for retaining heavy
metals and hazardous wastes.
5. The wind direction over evaporation ponds could be a problem, especially T«T_44
when blowing toward Phoenix.
6. You should conduct engineering borings on the Harquahala Plain and T'J—45
Ranegras Plain sites. I recommend that this be done.
Thanks for the opportunity to review this EIS.
Sincerely,
Verne M. Bathurst
State Conservationist
Tne Soil Conservation Service
15 an agency o( Ihe
VI-32
-------
W-40
W-41
W-42
W-43
W-44
W-45
These three corrections have been noted (see Section II)
Additional studies which would need to be completed
prior to and during operation of the hazardous waste
facility have been identified by ADHS (see Appendix F).
Site-specific soil investigations relating to soil
attenuation (or retention) abilities for specific wastes
as well as soil engineering characteristics would be
conducted prior to facility construction.
Effects of high winds on the facility are addressed in
Section IV, Air Quality.
Engineering borings would be done as part of the design
process if one of these sites were transferred instead
of the Mobile site.
VI-33
-------
It *-*-i S/'/'V." '-
Corporate Offices (501) 375-8444
March 11, 1983
ensco
incorporated
member, en»co group
Mr. Chuck Flippo
EPA Region 9 1015 Louisiana St.
215 Fremont Street Little Rock, AR 72202
San Francisco, CA 94105
Dear Mr. Flippo:
Thank you for the opportunity to comment on the DRAFT ENVIRONMENTAL
IMPACT Statement for PROPOSED ARIZONA HAZARDOUS WASTE MANAGEMENT
FACILITY (the "Draft").
ENSCO, Inc. has submitted ^ proposal to the Arizona Department of Health
Services in response to that Department's REQUEST FOR PROPOSAL FOR A
STATEWIDE HAZARDOUS WASTE MANAGEMENT FACILITY. ENSCO'n proposal contem-
plates the installation of an incinerator, a solvent recovery unit, a
residue treatment facility, and a landfill.
The operation of the various units would be conducted in a manner that
would maximize the recovery of waste which can be recovered, the
destruction of waste which cannot be recovered, and the treatment of
waste which can neither be adequately recovered nor destroyed. In that
manner, the amount of materials to be landfilled, as well as their
hazardous properties, can be substantially reduced.
Although the Draft treats the subject of a hazardous waste management
facility in a rather comprehensive manner, additional information would
improve the Draft's utility. Accordingly, the following is respectfully
submitted for your consideration:
1. INCINERATION:
The Draft fails to address the incineration of hazardous waste. Incin- W—46
eration constitutes an increasingly important facet of waste management.
Although certain waste materials are not amenable to incineration, an
incineration unit would materially reduce the environmental impacts
associated with waste management in Arizona. Incineration technology
has advanced to the point where a very significant portion of the water
and energy required to operate thermal destruction units can be derived
from waste materials being incinerated.
The destruction efficiency has also been significantly increased in the
past several years. For example, ENSCO's thermal oxidation unit (TOU)
at El Dorado was tested in 1981 while incinerating approximately 3700
pounds per hour of PCB's. The concentration of PCB's in the stack gases
during that test period was found to be approximately equal to ambient
concentration in the area prior to ENSCO's initiation of its PCB opera-
tion. In fact, a detailed analysis of the test data indicates that the
PCB's which were found in the stack actually came frorr, ambient air which
leaked into the stack. (See enclosed copy of a letter from Dr. George
Combs to Mr. R. Stan Jorgenson, Chief, Solid Waste Branch, EPA Region
VI.)
VI-34
-------
Little Rock
March 11, 1983
Page Two
ENSCO has proposed a two-phase approach to the State of Arizona.
Initially, ENSCO would install a mobil unit which has been tested by
Battelle and has been found to exceed federal requirements. The second
installation would be a larger and permanently mounted facility which
would incorporate all of the advances which had been developed at El
Dorado. The timing of the installation of the second unit would be
dependent upon market conditions.
The energy and water required to support these units would be consid-
erably different and would depend upon the mix of waste materials
available for incineration and the extent of resource conservation
technology incorporated into the units. To give an outside range of the T'J— 4 J
energy and water required to operate the proposed units ENSCO's incin-
eration complex at El Dorado is served by a 750 KW transformer and uses
approximately 100 gallons per minute of water. It should be noted that
the complex does not generate electricity from its excess heat. Addi-
tionally, the complex does not incorporate conservation technologies
which could be indicated in Arizona. You may also wish to note that the
El Dorado facility has more than ten times the heat release capacity of
the mobile unit.
With regard to environmental impacts, you may wish to review the methods
and findings of EPA Region VI relative to that Region's PCB approval of
Rollins located at Deer Park, Texas and ENSCO located at El Dorado. Of r.j_ A o
particular interest would be the risk analysis techniques associated
with dioxins. You will note the extremely conservative assumptions
employed in that analysis. ENSCO, of course, will provide whatever
additional information you may require.
2. EVALUATION OF ALTERNATIVE TECHNIQUES
The Draft does not evaluate the relative advantages and disadvantages of
incineration vs. recovery vs. landfill. This is an important point
because incineration and recovery offer significant environmental
advantages over evaporation ponds and landfills. Of course, each \'J— 4 9
technique also presents a different set of utility needs which may
affect siting.
3. UTILITIES AND SATELLITE GROWTH
The Draft does not adequately address the utilities needed to support a
high-tech waste management facility. As mentioned previously, specific
utility needs must be determined on a facility-specific basis. However,
inadequate treatment of those needs in the Draft may effectively "lock- W-5 0
out" high-tech management facilities. While utilities may impose a
siting constraint to high-tech management facilities, the reduced
VI-35
-------
Little Rock
March 11, 1983
Page Three
environmental impacts associated with such facilities introduce signif-
icant siting flexibilities. For the long term, the constraints and
flexibilities should be balanced against each other and against the
prospect of significant industrial development in the area of a. high-
tech management facility. Such associated development is very likely
giver, the fact that the public is becoming increasingly insistent upon
prompt and proper treatment of generated waste.
4. MARKETS TO SUPPORT ADVANCED TECHNOLOGIES
The Draft makes a basic assumption that Arizona cannot afford a high-
tech waste management facility. It ignores the substantial benefits of
a regional market and the fact that all indications point to Arizona as
being one of the highest growth states over the next decade or so. W~51
ENSCO's marketing strategy is basically to utilize the regional market
to support the high-tech management facility needed to accommodate
Arizona's current and future needs.
5. TRANSPORTATION CONSIDERATIONS
Although the Draft addresses the probability of transportation accidents
associated with hazardous waste traffic to a proposed to site, it fails
to put the probabilities into perspective of total transportation. For
example, the Draft fails to compare the amount of traffic to the facil- _„
ity with the amount of hazardous materials and hazardous waste now being V,~3Ł
transported in Arizona. Here it should be noted that hazardous mate-
rials (not waste) are routinely transported in large volumes on rail and
on the highways. For the most part, these materials are more hazardous
than waste materials because they are much more concentrated. Most
hazardous waste, in contrast, is so dilute with inert materials that it
has no direct economic use.
The increase in hazardous waste traffic associated with a management
facility should be compared with the (a) increase in hazardous materials
(not waste) transportation which can reasonably be projected and (b)
increase in hazardous waste traffic which would occur if there were no
management facility in Arizona. With regard to the latter comparison, V7—bo
it should be noted that hazardous waste passes completely through
Arizona from one state to another. A management facility in Arizona
would reduce the total traffic miles. Furthermore, it would reduce the
amount of traffic which would otherwise occur in Arizona from the
transportation of wastes which is generated in Arizona but which is
transported to other states.
VI-36
-------
Little Rock
March 11, 1983
Page Four
6. IMPACTS OF TRANSPORTATION-RELATED ACCIDENTS
The Draft seriously over-estimates the impacts associated with transpor-
tation-related accidents involving hazardous waste while completely
ignoring the impacts associated with hazardous materials. It should be T'7—5 4
again noted that hazardous waste is generally less dangerous than
commercial hazardous materials because it is less concentrated. Fur-
thermore, the safety and container integrity requirements associated
with the transportation of hazardous waste are similar to, if not
identical with, the requirements associated with the transportation of
commercial hazardous materials.
7. SITE MANAGEMENT PROBLEMS
From information contained in the Draft, one would assume that manage-
ment of a facility at the Mobile site would be more difficult than the
other alternative sites. Specifically, the other sites appear to be on
the periphery of watersheds where sheet flow is the predominate form of ^_ c c
surface water. On the other hand, the Mobile site appears to receive
flow from a rather large watershed and the site has pronounced channels
which must be addressed in the design of the facility. If the foregoing
assessment is correct, the Draft should give more consideration to the
relative site management advantages and disadvantages in order to avoid
misunderstandings by the public.
I hope that the foregoing has provided some assistance to your very
important efforts in developing an EIS which will serve the needs of
Arizona. If ENSCO can be of further assistance, please feel free to
call on us.
Sincerely, ,
Melvyn Bell
President
MB/at
Enclosure
VI-37
-------
W-46 Incineration is addressed in Section III.
W-47 Energy and water needs of the facility are addressed
in Section IV, Irreversible and Irretrievable Commitment
of Resources.
W-48 See Section IV, Air Quality.
W-49 The potential environmental impacts of incineration are
summarized in Section III. Recovery operations which
appear to be feasible for the Arizona facility have been
considered in both the representative "low technology"
and "high technology" designs. Utility needs are
addressed in Section IV, Irreversible and Irretrievable
Commitment of Resources.
W-50 See previous comment.
W-51 This comment has been addressed in the analysis of
incineration included in this document.
W-52 See the discussion of hazardous materials transportation
in Section IV, Public Health and Safety: Spill Risks,
under "Risks from Transporting Hazardous Waste."
W-53 Travel patterns of hazardous waste and PCB shipments
are analyzed in Section IV, Public Health and Safety:
Spill Risks, and in Appendix C. Increases in hazardous
materials traffic are difficult to project, due to the
lack of available data. An analysis of current hazardous
materials transportation appears in Section IV, Public
Health and Safety: Spill Risks, under "Risks from Trans-
porting Hazardous Waste."
As the analyses in Section IV and Appendix C show,
development of a hazardous waste facility in Arizona
would reduce total travel miles of hazardous waste
shipments. Development of a PCB incinerator would also
reduce total travel miles of PCB shipments. If no
facility were developed in Arizona, the number of PCB
shipments through Arizona en route to incinerators in
Arkansas and Texas could increase. This is because many
generators of PCB waste in the West appear to be storing
their wastes at present to see whether less expensive
disposal options develop. Without a facility in Arizona,
these generators may eventually opt to ship their waste
to the existing incinerators rather than continue to
store the waste.
VI-38
-------
On the other hand, failure to develop a facility in
Arizona could encourage development of a PCB facility
in California or some other western state. This could
significantly reduce the number of PCB shipments
travelling through Arizona.
W-54 See the discussion of hazardous materials transportation
in Section IV, Public Health and Safety: Spill risks.
W-55 See Section IV, Surface Water.
VI-39
-------
IT-.
-.;-'. EIVED
ARIZONA STATE ' S = GION !:•
UNIVERSIT Y !• If ' TEMPE ARIZONA ss:sr
• 1 ; - U Li .-" i u -
DEPARTMENT OF BOTANY AND MICROBIOLOGY (602) 965-3414
March 7, 1983
U.S. Environmental Protection Agency, Region 9
Attn: Chuck F I i ppo
215 Fremont Street
San Francisco, CA 94105
Dear Mr. FIi ppo:
As you will recall, I have been one of the contributors to the Draft
Environmental Inpact Statement regarding the Arizona Hazardous Waste
Facility and the'site selection process with which it is concerned.
As you may also recall, I spoke regarding my concerns with Valley Fever
(Coccidiodomycosis) at the public hearing held at the Mobile Elementary
School in Arizona on February 17, 1983. As pointed out at that meeting, I
am not opposed to the selection of the Mobile site for the facility but I
am greatly concerned for the health and safety of the construction workers
to be involved in the project, as well as for the school children nearby
and for residents living within a radius of approximately 50 miles of the
proposed site. Such concern stems from the fact, as I pointed out in
previous correspondence with you, that I have found the proposed site at
Mobile to be a "hot spot" for the fungus producing Valley Fever. With
this knowledge at cur disposal we would be remiss in not emphasizing the
importance of this information to the health of all concerned with the
soil disturbing activities resulting from the project.
It is for this reason that I must express to you my feeling that certain
comments appearing in the DEIS dated January 1983 are misleading and give
an erroneous impression of the risks of getting Val ley Fever and of its W~56
significance to those within the range of its infectious spores once these
become airborne. I shall direct my comments on each point in the DEIS as
follows: In line 12 from the bottom of pg. S-6, we read "the probability
of significant impacts on persons outside the site would be low". This
statement is not in keeping with the published observations of the Kern
County, California experience of Dec. 20, 1977 in which several hundred
cases of Valley Fever occurred following a dust storm 310 miles to the
south. This epidemic cost residents far to the north over $1 Million in-
medical costs and the loss of several lives. Thus we see that once soils
are disturbed, nature may disperse the pathogen over great distances and
it may not require 99 mph wihds to accomplish it. Science simply does not
know how far the spores may be airborne under various conditions and still
remain highly infectious. To include the present statement that
"probability of infection would be low", is completely presumptuous.
VI-40
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EPA
Page 2
Feb. 25, 1983
Page S-6, line 9 from bottom of page 19 Current wording reads, "Evidence
suggests, however, that the spread of Valley Fever, even under these
conditions, would be low, since immunity is presumed to have been built up
over time in most area residents". First of all, there is no evidence
whatever to "suggest" "that the spread of the disease would be low". We
simply do not know what the spead would be from an area of high fungal
concentration but certainly there is a much higher than normal risk as
compared to areas where the fungus is rarer or non-existent. Further, the
statement "since immunity is presumed to have been built up -" is not
compatible with such non-existent evidence, nor is it compatible with the
facts that all of the area residents have undoubtedly not had the disease
and that many construction workers themselves may be from non-endemic
areas where they have never been exposed to it. The statement simply
attempts to brush off the probab i I ity of infection by refer ing to
non-existant "evidence" and by "presumptions" which are dangerous when
applied to those who have not been exposed to the pathogen. Also, the
reference to "most area residents" is mis-leading in that it implies the
rest of the population can be "sacrificed" to the potentially deadly
di sease.
Similar mis-leading and unsubstantiated remarks can be found on pages 2-11
bottom paragraphs and 2-12 top paragraphs.
In short, the impression is given that the project is worth the sacrifice
and that Valley Fever is really not such a risk after all. To permit such
an erroneous impression to exist in the DEIS is to render a disservice to
our citizens and to lead them into a false sense of security. I can only
imagine what negligence this impression could lead to by contractors of
the project and others engaged in its construction.
The steps which I believe should be taken to measure the impact of
construction at the Mobile site are those I described in my letter to you
dated February 25, 1982. Only in these ways will adequate date be
obtained to enable us to learn how important such activities are in
causing increased incidence of Valley Fever in local area residents and in
evaluating the effectiveness of the prevention measures recommended.
Sincerely,
Chester R. Leathers, Ph.D.
Associate Professor of Microbiology
VT-41
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W-56 These comments are addressed in the discussion of Valley
Fever in Section IV. Dr. Leathers' letter of February 25,
1982, which was submitted during the EIS scoping process,
has been reprinted here for the benefit of reviewers.
VI-42
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ARIZONA STATE
UNIVERSITY.
. TEMPE. ARIZONA S52S-
DEPABTMENT OF BOTANY AND MICROBIOLOGY (602) 96S--j.na
25 February 1982
Mr. Chuck Flippo
Environmental Protection Agency
Toxics and Waste Management Division
215 Fremont Street
San Francisco, CA 94105
Dear Mr. Flippo:
As indicated during the evening of February 18, 1982 at the Environ-
mental Impact Scoping Meeting held at the Mobile Elementary School
near Maricopa, Arizona I am contacting you in regard to concerns
regarding construction of an Arizona Hazardous Waste Management
Facility near that community. Due to the more technical aspects of
my comments regarding the hazards to human health relating to the
construction phase and early operation of the proposed project, I
was asked to send you a letter outlining my comments.
As background information, I should point out that I have been con-
ducting research on Arizona soils for the past few years with special
attention being given to the distribution of medically important or
human disease fungi present in the soil in various areas of the state.
I have also conducted similar tests for the Bureau of Land Management
in southern California during 1977-79 under grants provided by them
to survey the soils of off road vehicle-use sites. It has been during
these studies that I have found the fungus causing Valley Fever (also
called Desert Fever and San Joaquin Fever) to be especially prevalent
in the area of the proposed hazardous waste site approximately twenty
miles west of Maricopa, Arizona. I have isolated the fungus,
Coccidioides immitis, many times from this area and I consider it to
be a "hot spot" for the pathogen, primarily because I have been able
to isolate it more often from the soils of this area than from most
others I have tested. Because of this experience, I am concerned
that adequate precautions be taken to protect the life and health of
those who may be working on the proposed project (equipment operators,
surveyors, etc. etc.) as well as the residents of nearby communities
such as Rainbow Valley, the students attending Mobile Elementary School,
the village of Maricopa, Estrella Dells sub-division, Grand View Ranches
and possibly the residents of southwest Phoenix, among others. In
other words, I am not opposed to the selection of the Mobile site for
the hazardous waste disposal project, but I am justifiably concerned
about the impact that soil disturbances in the area may have on the
subsequent health of residents and workers.
VI-43
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Although Norm Weiss of the Arizona Department of Health Servicejwas
quoted in the Arizona Republic newspaper recently as saying, "The
fungus has been here for many years" and "I disagree (with Dr.
Leathers) that present methods of dust control are inadequate", such
statements do not properly reflect the actual situation nor do they
connote the concern for the disease felt by the residents of Arizona.
Certainly, the fungus has been known in Arizona soils for many years
but it has also been known that it is dispersed in dust from previously
un-disturbed native soils and that it is via the air from such dis-
turbances that the potentially deadly inoculum is borne to man. Our
studies to date, indicate that the fungus becomes airborne chiefly
during and after men-caused disturbances of the native soil in the
endemic areas. It is also well known that severe disease development
by most micro-organisms often results from greater than average expo-
sure to a given pathogen, thus we can expect not only an increase in
disease incidence near the site but also the likelihood of more
debilitating and life-threatening cases, unless adequate dust-control
practices are rigidly adhered to. No studies have been conducted to
date, before such projects occurred, to determine the impact of such
activities on the disease incidence and this is especially appropriate
in the Mobile area in light of our learning that the area is a "'hot
spot" for the pathogen.
What I feel is needed in this instance is the following:
1. Specific information on Valley Fever should be provided to workers
and nearby residents regarding the symptoms of the disease and to
seek medical attention if symptoms develop during the construction
phase of the project. This can be done as simply information
sessions without creating undue concern among residents. It should
be noted however, that courts have previously ruled the public is
entitled to be informed of any risks to their health beforehand.
The same rights belong to unsuspecting workers on the project.
(See newspaper clippings enclosed.)
2. Specific instructions should be given to the construction workers,
prior to land-clearing activities, in regard to proper methods of
dust control to insure maximum effectiveness in keeping the
pathogen from becoming airborne.
3. Soil tests should be conducted on earth piles, surface soil etc.
at the site to determine how long after the initial land-clearing
operation, the fungus remains viable and capable of becoming
airborne in significant quantity.
4. A study should be initiated before construction begins, to deter-
mine the impact of the project upon subsequent disease develop-
ment in the area. Such a study should involve at least the
following:
VI-44
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a. Skin tests of local residents, project workers, and school
children to determine those who are "positive" beforehand.
b. A survey of area residents, workers, and school children
during and after the construction phase to determine any
changes in disease incidence.
c. Skin tests should be given after each phase of construction
to all previously negative persons to determine how many have
converted to positive during each phase of construction.
d. Some serological tests may also be desirable to correlate
with skin tests.
e. Special soil treatments should be evaluated for their effec-
tiveness in dis-infacting soils and soil piles, to better
control disease risk.
My concerns are not limited to soil disturbances only at the construc-
tion site, but also include new road construction or enlargement of
existing roads, to be used for access as well as land clearing for
railroad spurs, etc.
You should also be informed that although farmers are frequently
blamed for generating the valley-fever laden dust, our tests do not
indicate this to be the case, probably due to the fact that most farm
fields have been under cultivation long enough to eradicate the fungus
from them. Instead, it is the disturbance of native desert soils,
previously undisturbed, or those which have lain fallow for several
years, which are the source of the infectious agent. Thus, it is even
more urgent to give attention to the proposed site and its accompany-
ing access and service roads.
To further provide your office with helpful information on the sig-
nificance of this disease, I am listing several points below, most of
which you will find borne out in the reprints, clippings and copies
of other published information I am enclosing:
1. The known death rate (i.e. diagnosed and reported cases) due to
Vallev Fever in Arizona annually is 25 persons. The true figures
are probably between 75-100/year due to:
a. Difficulty in diagnosis and incorrect diagnoses.
b. Required reporting of deaths by Arizona physicians was not
initiated until Jan. 1981, thus inadequate figures have been
used to measure the death rate.
2. Several hundred people are debilitated annually in Arizona due
to Valley Fever and considerable loss of job time and income
results.
VI-45
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3. An estimated loss of $325 million annually occurs in the south-
western U.S. due to Valley Fever. (See pp. 203-204 of Leathers'
"Plant components of desert dust in Arizona —", Geol. Soc. of
Amer. - 1981, enclosed).
4. Courts have established liability of sponsoring organizations for
providing adequate prior information dispersal, adequate dust
control practices etc. and have awarded medical costs and damages
to patients who have acquired valley fever on projects where
proper precautions have not been taken beforehand. CSee enclosed
clippings involving Int'l Harvester Co. and its Phoenix, AZ test
facility.)
Additional information relating to this disease can be found in other
materials enclosed.
In conclusion, I believe the Environmental Impact Statement relating
to the proposed Arizona Hazardous Waste Management Facility for the
Mobile-Maricop, AZ area should reflect the above concerns for the
health and safety of nearby residents and workers and that specific
recommendations are being made to adequately determine the impact of
the project for all concerned.
Should there be additional information you might need or should I be
able to provide assistance in regard to any of the above matters,
please do not hesitate to contact me.
Sincerely,
Chester R. Leathers, Ph.D.
Assoc. Professor of Microbiology
CRL:rd
VI-46
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Mar i a Abdi n • -. - , j~, .
P.O.Box 2641 ""r :'Jl'' '•'•-
Tucson, Arizona 85702 '.- •.,• •- _ . ,fl.
i: _
11 March ig«3
U.S. Environmental Protection Agency,
Region IX
215 Fremont Street
San Francisco, California 94105
Re: Draft Environmental Impact Statement
Attention: Chuck Flippo (T-2-1) Arizona Hazardous Waste Facility
Gentlemen:
I have just read the above-referenced Draft Environmental Impact
Statement. The preparers appear to have done a conscientious job with the
information available.
For some time I have been concerned about inadequate and/or improper
hazardous waste disposal in Arizona--such as dumping wastes in sewers or in
the desert. My comments and questions on the proposed sites follow.
A. HYDROLOGY
1. Community dependence on groundwater. It is noted that communities near I>7_ R 7
all three sites are dependent on groundwater (Mobile--DEIS p. 3-8; Western
Harquahala 3-36; Ranegas Plain 3-57).
2. More data on groundwater needed. It is fairly clear from the DEIS that
estimates of impact on groundwater from such a hazardous waste facility have
been based on insufficient data. Specifically, more information on aquifer W— b o
characteristics is needed:
Mob!1e: "The presence or absence of faults in the alluvium and in the
bedrock adjacent to and beneath the site cannot be determined on
the basis of the available data" (3-5).
Depth to groundwater is estimated...no groundwater measurements have
been made at the site (3-5).
Western Harquahala: "Available data are inadequate to assess fully the
faults in the area or at the Western Harquahala Plain site" (3-34).
It is not known what aquifer the groundwater under the site belongs
to (3-36).
Ranegas Plain: "Available information is inadequate to permit an
assessment of faults...in either the general ares or at the Ranegas
Plain site" (3-57).
VI-47
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Mr. Chuck Flippo, EP 2 11 March 1983
3. Possibility of aquifer contamination. The DEIS estimates it would take from
270 to 11,000 years for surface contamination to reach the nearest existing
wells, depending on the site. It would seem to me, however, that one cannot
adequately estimate how long it would take for surface contamination to reach
groundwater and existing wells without knowing the characteristics of the aquifer I'. —59
and the ground above it:
...Irrespective of the source of contamination, what is important is the
solubility and transport of contaminants in relation to the properties of
soil and aquifer rock (Hall 96).
For the prediction of the solubility of inorganic substances in the
ground, it is necessary to assume the formation of well-defined insoluble
compounds. Whereas the adsorption of ions onto minerals is bound to
occur, this cannot be confidently taken into account because of the many
uncertainties involved. Furthermore, for the removal of unnatural
contaminants from groundwater, it is probably improper to depend upon adsorption
by rock particles since this is essentially only a temporary effect (Hall 103).
Polluted water may enter an aquifer by seepage through the substance of
an aquifer or by flowing rapidly through comparatively wide channels in
granuVar media and through fissures.... If abstracted groundwater is affected
by pollution through rapid-transit channels, the effects on the aquifer are
equally rapidly overcome by the flushing out of the channels by clean water.
However, there is cause for concern in systems which are not fissured
and which are apparently unaffected by obvious sources of pollution. The
concern is that an aquifer rock removes pollution from the water and that the
rock itself becomes contaminated. The question which should be answered is
whether a pollution front can slowly move through an aquifer, eventually to
fill it and with little chance of the pollution being removable (Hall 108, 109).
Flow_rate_of contaminants is an important factor. The flow rate in the aquifers
have been estimated, but increased pumping could increase that rate. Also, can
we assume that under all conditions flow rate of an aquifer is the same as the
rate of dispersion of a contaminant through the aquifer? (One is reminded of
how fast a drop of ink can disperse in a cup of standing water.) In Tucson,
surface chemicals contaminated wells in less than 50 years.
't. Water for the facility. A question which seems not to have been addressed
in the DElS--the facility itself will presumably need a source of water. How
much water will it be using, and where will it be drawing the water from? If !'7—60
a well is dug on-site (there is presently a well on the Ranegas Plain site (3-59),
or near the site, how will it affect rate and direction of aquifer flow?
Could such a well, in case of a spill (with or without rain or sheet flooding)
become a channel for contaminants to reach groundwater?
5. Effect on stock ponds (Mobile). What is the possibility of sheet flooding W— 61
at the Mob ile si te (F5-2)be ing able to wash spilled chemicals into the stock
ponds nearby? (3-lŁ)
Hall, E.S., "Some Chemical Principles of Groundwater Pollution" in Groundwater
Pol Iut ion in Europe Proceedings of a Conference Organized by the Water Research
Association in Reading, England, September 1972, editor John A. Cole (Port
Washington, New York Water Information Center, Inc.)
VI-48
-------
Mr. Chuck Flippo, EP, 3 ,, March ,g83
6- C-roundwater monitoring. Monitoring of groundwater for contamination would
necessarily be monitoring for unknowns. What is the expense of such monitoring, W-6 2
and does the State have the capability of doing such monitoring on a routine
basis?
7- Other possible site locations. Are there any places in Arizona where the
local residents are not primarily dependent on groundwater? If so, might any W-6 3
of them serve as a hazardous waste site instead?
B. AIR QUALITY
It is clear that under some conditions, facility emissions might create serious
problems:
Given the distance from the facility to the nearest residence...odors are
not expected to be a problem off-site. This would depend, however, on the
frequency, amount, and type of spills, treatment techniques, wind
conditions, and odor-reducing techniques used at the proposed facility Ct-32).
...other landfills with organic wastes show high emission rates of organics,
many of which are potentially hazardous compounds.... While the experience
at other facilities may not be applicable to the proposed Arizona facility,
it does suggest a potential for organic and/or toxic emissions from the
landfill (It-lit).
Data on air movement patterns at the proposed sites seem to be scanty (3-7,
3-24). Do inversions occur in these areas, and if so, how would they affect T'7—6 4
concentrations of toxic and/or malodorous emissions in nearby areas? Would
emissions in an inversion adversely affect humans, animals, and landscape or other
plants in the area?
C. PLANT DESIGN AND OPERATION
1. Treatment ponds. Would the treatment ponds be covered during rain and W—6 5
flooding?
2. Verification of chemical identity. Both the adequate, safe treatment of
chemicals, and the handling of spills and accidents, depend upon knowinn what
the chemicals are.
Most organizations that provide technical information on chemical hazards
handling measures require the names of pure chemicals. Information
concerning wastes and/or spills is not as readily available. Ct-29)
I have been informed that at one hazardous waste landfill the operator simply
accepted the shipper's description (such as "solvents," "sulfuric acid," "nitrates") W-6 6
with no attempt at verification. Would there be any means of verification at
the proposed facility? It should be noted that most waste chemicals are not
pure substances, but are dirtied by other chemicals.
3. Other technologies. Do other suitable technologies exist (such as high- I*7-6 7
temperature incineration) for disposing of these hazardous wastes? How do they
compare with the proposed design in terms of effectiveness, cost, and safety?
VI-49
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Mr. Chuck Flippo, EP, 4 " riarch 1983
D. HAZARDOUS WASTE EMERGENCIES
1. On-s ite accidents .
The uncontrolled release [explosion, leaks?] of hazardous constituents
from the faci1ity...could pose a potential long-term health hazard to
nearby residents Ct-51).
The impacts of an on-site spill or emergency would depend on such factors
as the specific hazardous substances involved, the nature of the incident,
weather conditions (4-17).
Is there presently in existence a similarly designed plant in operation? Where?
How long has it been operating? What has been the experience with this facility TAT_CQ
in terms of leaks, spills, emissions, and their effect on public health and
environment? For any of the proposed Arizona sites, what would a "worst-case"
emergency scenario entail?
2. Transportation accidents.
Based on the experience of a California facility, approximately one
on-site spill occurs for every 10 million gallons of waste delivered
to the facility. Based on these data, a probability of 0.5 spills per
year could be expected from facility operation (4-17).
According to the Arizona Department of Public Safety, hazardous waste delivery
trucks contain about 7,000 gallons of wastes each. If a site handled 5 million
gallons of waste per year, an average of 2 trucks a day would be expected if it
were open 365 days a year, and 3 trucks a day if only open Monday through Friday.
The idea of hazardous waste trucks passing schools makes me very nervous.
Although statistically the risk of accident is low, one 7,000-gallon hazardous
waste truck crashing beside a school could be a terrible thing. I would like W—69
to see at least 1,000 feet between any passing truck and the boundary of a
school yard.
3. Emergency response. At present none of the proposed areas appear to have
the capability of handling a major hazardous wastes emergency of any kind (3'12,
3-^1, 3-62). It seems unfair that loca-1 communities should have to provide and
pay for emergency services for accidents related to a State hazardous waste site W—70
run for the benefit of profit-making businesses. I feel the State should pay
for clean-up and be reimbursed by the shipper and/or facility operator, as
applicable. I also feel the emergency services should be funded and operated
by the State, and that emergency personnel from local communities (police, fire,
ambulance, etc.) should receive some training in emergency response at State
expense, and a communications network including the local communities should be
• stabl i shed.
E. LIABILITY
1. Emergency handling plans in permit. "Specific spill prevention, counter- W—71
measures, and contingency plans would be prepared as part of the facility permit."
This is very good! (S-5)
VI-50
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Mr. Chuck Flippo, EPA 5 It March 1983
bond
2. Performance bond. I feel a performance/must be submitted by the contractor y,y_ "J 2
to ADHS (E-l).
3. What redress does a citizen have under the State's "self-insurance coverage"? Vf— 7 3
(E-l)
A final note; I would hope that Arizona can encourage industries to
design products and manufacturing methods so as to use less toxic and hazardous T"7— 7 4
materials; and to encourage industries committed to non-hazardous products and
processes to settle in Arizona.
Thank you for the opportunity to comment.
S i ncerely ,
Ma r fa Ab d i n
Larry Hawke, Chairman, House Natural
Resources and Energy Committee
John Hays, Chairman, Senate Natural Resource
and Agricultural Committee
James E. Sarn, M.D., Director, ADHS
Tibaldo Caflez, Chief, ADHS Bureau of Waste
Con t ro 1
Southwest Environmental Services, Tucson
VI-51
-------
W-57 Comment noted. No response needed.
W-58 See Section IV, Ground Water, in particular the section
W-59 on hydrogeologic data.
W-60
j. —i ~f
The facility would presumably draw most of its water from
the ground water aquifer beneath the site (see Section IV,
Irreversible and Irretrievable Commitment of Resources).
The potential for ground water contamination via the
well and the effect on regional ground water movement
are discussed in Section IV, Ground Water.
W-61 This comment is addressed in Section IV, Surface Water.
W-62 The cost of ground water monitoring cannot be determined
until the exact monitoring requirements for the facility
are established in the permit (see Section V). The highest
cost is the initial expense of putting in monitoring wells,
which according to one estimate, could cost up to $85,000
per well at the Mobile site. Normally, a minimum of
four wells are installed (one upgradient, three down-
gradient), but this can vary. Continuing costs for
maintaining the wells and analyzing samples could run to
a few thousand dollars per year (depending on the number
of wells and the number of samples). These costs would
be covered by the facility operator rather than the
State. ADHS would make periodic inspections and monitor
reports from the facility. Under State law (ARS 36-2800),
costs to the Department of monitoring the operation and
environmental impacts of the facility may be covered by
the State trust fund, which would be derived from a
portion of the disposal fees charged at the facility.
W-63 See the discussion of alternative sites in Section IV,
Alternatives.
W-64 Data on air movement patterns at the proposed sites are
limited. The need for additional site-specific data is
addressed in Section IV, Air Quality. Inversions are
also discussed in that Section.
W-65 See the discussion of alternatives to surface impoundments
in Section IV, Surface Water.
W-66 Analysis of incoming wastes is now required under the
Federal regulations (see the discussion of proper
handling of wastes in Section V).
W-67 High-temperature incineration is addressed in Sections
III and IV,
VI-52
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W-68 See the discussions of ori-site spills and the hazardous
waste spill scenario in Section IV, Public Health and
Safety: Spill Risks.
W-69 See the discussion of risk to schools in Section IV,
Public Health and Safety: Spill Risks, under "Risks
from Transporting Hazardous Waste."
W-70 See the discussion of emergency response in Section IV,
Public Health and Safety: Spill Risks.
W-71 Comment noted. No response needed.
W-72 The Request for Proposals that ADHS issued for the
construction and operation of the proposed facility
contains a provision that requires the contractor to
submit to ADHS a performance bond. The bond would be
used to reimburse ADHS for any operational, legal, or
incidental damages incurred in the event of default by
the contractor.
W-73 See the response to comment W-l.
W-74 The responsibility of ADHS in the hazardous waste
program is to ensure that the waste is properly managed
within the State and that adequate public health and
environmental protection is provided. The encouragement
of industries committed to non-hazardous products and
processes to settle in the State is an economic develop-
ment issue and not under the jurisdiction of ADHS. A
copy of this EIS is being forwarded to the Office of
Economic Planning and Development for their consideration.
ADHS is working to encourage the recovery and reuse of
hazardous wastes through the Chamber of Commerce's planned
Waste Exchange Program, described in Section IV,
Alternatives, under "Resource Recovery and Waste Reduction."
If successful, this program could help eliminate the need
to treat or dispose of some types of hazardous wastes.
VI-53
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March 1,
To:
Environmental Protection Agency, Region 9
1:15 Fremont St..
Sail Francisco. Ch. :-4iO_'<
Attention: Chuct Flippo
Fr oin:
League of Wcjfne-i'i Voters cjt A
The League of Women Voters' involvement and participation in
the scoping process relating to the proposed HW facilitv was
based on =.. fervent belief that public: participation should be an
integral part of this siting process. Our committment, as yours,
to protect the environment, and accomplish a t^aste treatment
faci]:> (. y in Arizona, prompts us to support your efforts'
Our c o n c: e r n st ] ] ] e" ] sts o^er si'rf ace? water problems, ] n ':he
ever'it of f 1 oodi no , The pr'ecaut i o^is oi.itlined in the ET5 are
adequate but because there is always present in Arizona, snci
especially at the Mobile site, the real possibility of fJoodinq
and consequently contamination we suggest further informat \ on
into alternative treatment methods- to the mentioned surface
impoundments. 6round water protection measures are applauded if
in fact lest detection method? can be implemented in addition tn " 'D
water mon j tr-r i nc;.
Transportation =ti!J seems to be an area in which more
information is need&d,, E'meraency n ..-ai 1 sbi 1 i t v a~c r i si f;-ctnr= T«T_77
ere totaJiv CK-jpenoeril on basic transportation issues.
VI-54
-------
The accident pr obab.t 1 i *_ . t-iqures are not clear to ins
h::ii'jS"--='r. != the- "/. at accidents pe1- truct- load of waste, or per W—7 R
mile travelled and how was; that data calculated? Our concern
still remains over the transportation route by grade schools in
Lhe communities o-f Maricopa and Mobile. That seems ] i ke an W~79
LinneceEsar i 1 v dangerous prospect^
Uie tharit. vou. Chuch, for rr,al:inq the DEIS available to us so
t.l,al_ we ma>' comment.
Tina Morgan
Hazardous Waste Chair.
League of Women Voters of
VI-55
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W-75 See the discussion of alternatives to surface impoundments
in Section IV, Surface Water.
W-76 Specific ground water protection requirements for the
facility would be established in the permit process.
This comment is more appropriately addressed at that
stage. See the discussion of liner and monitoring/
detection systems in Section IV, Ground Water.
W-77 Transportation issues are discussed in Section IV, Public
Health and Safety: Spill Risks.
W-78 Calculation of the accident probability figures is
explained in Appendix N of the Draft EIS and summarized
here in Section IV, Public Health and Safety: Spill
Risks.
W-79 See the discussion of risk to schools in Section IV,
Public Health and Safety: Spill Risks, under "Risks from
Transporting Hazardous Waste."
VI-56
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major
SIGNOFF
OMB Approval No. 29-R0218
FEDERAL ASSISTANCE
1. Type Of QPreapplicatlon
Mfe?f'°n Q Application
appropriate Q Notification Of Intent (Opt.)
/ D Report Of Federal Action
Numbei
.2 83-80-0007
Year month dav
83 01 26
4. Legal Applicant/Recipient
a. Applicant Name
b Organization Una
c. Street/P.O. Box
d City
f State
h. Contact Person :
(Name Ł Telephone no.j
U.S. Environmental Protection Agcy.
Region 9
215 Fremont Street
San Francisco e- county
California g. ZIP code : 94105
Chuck Flippo (T-2-1)
(415)974-8128
5. Federal Employer Identification No.
6. Program
(From
Federal
Catalog!
b. Title
Environmental Protec-
tion Agency
7. Title and description of applicant's project Arizona Hazardous Waste
Facility - Draft Environmental Impact Statement
The State of Arizona proposes to purchase a one-
square-mile parcel of federal land from the U.S.
Bureau of Land Management (HEM) for the purpose
of siting a hazardous waste management facility.
The proposed facility would be designed to treat,
store, and dispose of hazardous wastes that are
generated in Arizona but are not disposed of on
the generator's property.
8. Type of applicanl/recioient
C-Submit Dm
ty Action A««ncv
Federal Agency
Enter appropriate letter |
9. Type of assistance
A—Basic Grant D—Insurance
B—Supplemental Grant E—Other r—r—i
C—Loan Enier appropriate letter(s) [__|e|
10. Area of project impact (Namesofcitiesrcounfies,states,etc.)
(There are 2 other alternate sites)
near Mobile, Arizona (J"laricopa Co.)
11, Estimated number
of persons
benefiting
12. Type of application
A—New C— Revision E— Augmentation
B—Renewal D-Continuation
Enter apptopriate letter [a.I
13. Proposed Funding
14. Congressional Districts Of:
15. Type of change For 12c or 12e
a. Applicant
.00 16. Project Start
i Date Year month day
b. Project
17. Project
Duration
A—Increase Dollars
B—Decrease Dollars
C—Increase Duration
D — Decrease Duration
E—Cancellation
F— Other Specify
Months
Enter appro-
priate letterfsj
Total Ł
.0018. Estimated date
to be submitted
to federal agency 19
Year month date
19. Existing federal identification number
20. Federal agency to receive request f.\!ams, city, state, zip code)
2l. Remarks added
QYes []N
| 22.
!The
I Applicant
Certifies
That
a. To the best of my knowledge and
belief, data in this preapplication/
application are true and correct, the
document has been duly authorized
b/ the governing body of the appli-
cant and the applicant will comply
wuh the attached assurances if the
b. If required by OMB Circular A-95 this application was submitted,
pursuant to instructions therein, to appropriate clearinghouses and
all responses are attached.
d)Arizona State Clearinghouse
J\'o
Response
) Region I Clearinghouse (?1AG)
response attached
D
D
D
23.
Certify ing
represen-
tative
a. Typed name and title
c. Date signed
Year month day
I 24. Agency name
Application
received T9
f 26. Organizational Unit
27. Administrative office
28. Federal application
identification
30. Federal grant
identification
31. Action taken
Qa Awaraed
Qb. Rejected
C~]c. Returned for
amendment
Qd Deferred
O Withdrawn
38.
Federal agency
A-95 action
32. Funding
a. Federal
b Applicant
c State
d Local
c Other
* Tola:
s .00
.00
.00
.00
.00
s .00
Year month day
33. Action date 19
35. Contact for additional information
(Name and teleph&ue number}
34. Year month
Starting
date 19
36, I ear month
Ending
date 19
day
day
37. Remarks added
DYCS DNO
s In taxing aoove action, any comments received trom clearing- D. rederal Agency A-ab umcial
houses were considered If agency response is due under provisions (Same and telephone number/
of Part 1 , OMB Circular A-95, it has been or is being made.
Prescribed by GSA. Federal Management Circular 7-1-7
VI-57
-------
Comment Form To Be Completed by Reviewing Ag«ncy
TO:
State Applicant,., .dennfier (SAD
Stan AZ No.
JAN 2 6 1963
Department of Water Resources
Mr. Frank Barrios
99 E. Virginia
Phoenix, AZ 85004
F ROM: Arizona State Clearinghouse
1700 West Washington Street, Room 505
Phoenix, Arizona 85007
Indian Affairs
Game & Fish
Transportation
Ag. & Hort.
Arid Lands Studies
Environmental Studies {<$
Public Safety
Emergency Services
Arizona Natural Heritage
Health
Waterx
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
j |No comment on this project | j Proposal is supported as written F^^-Comments as indicated below
1 Is project consistent with your agency goals and objectives^! I Yes I I No |_J Not Relative to this agency
2. Does project contribute to statewide and/or areswide goals and objectives of which you are famniar?L_j Yes I I
No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals ana CDjectives'LjYes [_ J No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?! ] Yes I I No
5. Does project violate any rules or regulations of your agency' I I Yes I I No
6. Does project adequately address the intended effects on target population' II Yes I I No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' 11 Yes ll
No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature
Title
Date
Telephone
W-80
VI-58
-------
W 80 The Department of Water Resources submitted comments in
a separate letter. See comments W-16 through W-21.
VI-59
-------
Comment Form To Be Completed by Reviewing Agency
r°:
Siaie Applicant ;ntifier (SAU
n7
Ql State AZ No.
JAN 2 6 1963
Agrncu°ture& Horticulture Dept
421 Capitol Annex West
Phoenix, A2 85007
FROM: Arizona State Clearinghouse
1700 West Washington Street, Room 505
Phoenix, Arizona 85007
Indian Affairs
Game 6. Fish
Transportation
Ag. & Hort.X
Arid Lands Studies
Environmental Studies
Public Safety
Emergency Services
Arizona Natural Heritage
Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate .as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
^] No comment o'n this project (~~1 Proposal is supported as written | /[Comments as indicated below
1 Is project consistent with your agency goals and oojectives?|_| Yes I J Mo l_J Not Relative :c this agency
2. Does project contribute to state-wide ano/or areawide goals and oojectives of which you are familiar'! _ | Yes LJ No
3 Is the
re overlap or duplication with oir.er state agency or local responsibilities and/or goals ana objectives?! _ I Yes LJ
4. Will project have an adverse effect on existing programs with your agency or within project impact area'l I Yes 1 I No
5. Does project violate any rules or regulations of your agency' | _ ( Yes I I
No
6. Does project adequately address the intended effects on target population' I ] Yes 1 I No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' 1 I Yes 1 I No
Additional Comments (Use back of sheet, ,f necessary):
Reviewers Signatu
Title
sfrl.. A**-" *-'
/
Date o*~ l "
Telephone
VJ-81
VI-60
-------
W-81 ADHS would seek guidance from and work with the Arizona
Department of Agriculture and Horticulture to ensure that
protected native plants within construction areas are
properly salvaged or relocated.
VI-61
-------
Comment form To Be Completed by R« viewin
State Applicai Identifier ISAI)
9?-an-nOQ7
Indian Affairs Center for Public Affai
Dt. Jam.. Becker Game & Fish *SU Library-Rebecca
Center for Public Affairs Transportation ouine
Arizone State University &Hort
T««-.AZBW1 Arid Lands'studies
Environmental Studies *
FROM: Arizona State Clearinghouse Emereencv Services
1700 West Washington Street, Room 505 ŁŁona NaJurS Heritage
Phoenix, Arizona 85007 Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
| | No comment on this project | | Proposal is supported as written Xfc [Comments as indicated below
1 Is project consistent with your agency goels ana objectives^ I Yes II No II Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of whicn you are familiar'LJ Yes I I No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and cbjectives?[_J Yes LI No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?(_J Yes t) Np
5. Does project violate any rules or regulations of your agency? 11 Yes Pj No
6 Does project aaequately address the intended effects on target population' I I Yes I I No
7. Is projec; in accord with existing applicable laws, rules or regulations with which you are familiar? Q Yes Pi No
The proposition thrt "the ir.onct
Additional Comments (Use back of sheet.if necessary): *°uld be insignificant" (p.S-8, W-82
Ecological Resources) is not factual.
The sun of such imcpcts is the present ecoior,ic - j^^- c- /-«— 'a ___ _ Date *.-_0-fiO
Title Prof. Center for Publir- Affairs Telephone 955-1073
VI-62
-------
W-82
We disagree with the comment. While it may be true that
the sum of numerous small changes may create a signifi-
cant impact on a community or on a specific environment,
construction of the proposed facility would be a single
action affecting a small parcel of land (one square
mile). The desert populations which might be affected
are wide-ranging, and the animals generally shun human
contact. Only a small percentage of such populations
would be affected, resulting in a small overall impact
on the wildlife resources in the area.
W-83 The statement on p. 4-47 of the Draft EIS is: "It is
likely any private siting effort would meet strong public
opposition from residents of any siting area" (emphasis
added). This statement is based on experience with
other siting efforts, public and private, around the
country, as documented in an EPA study (see DEIS refer-
ence 87). Also, ADHS encountered public opposition to
all the sites analyzed in detail in its siting study.
There is no reason to believe that a private company
would have any different results.
VI-63
-------
BRUCE BABBITT, (.'ui
I '."twin-i'in- r.
CHARLES F ROBERTS 00 Bunw Cf>».m. •"
f-RANK fEHGUSON Jfl Yum*
f SANCtS W WERNER 1ur«e'
CUHTlS * JENNINGS ScolHOB*
JOHN J QlSl Fl«g»M»
f ARIZONA GAME & FISH DEPARTMENT
BUD BRISTOL
February 23, 1983
Sonia F. Crow, Regional Administrator
Environmental Protection Agency, Region 9
215 Fremont Street
San Francisco, California 94105
ATTN: Chuck Flippo (T-2-1)
Dear,Ms. Crow:
-RE: Draft E.I.S. - Arizona
Hazardous Waste Facility
. Our Department has reviewed the draft environmental impact
statement for the Arizona Hazardous Waste Facility and we submit W-84
the following comments.
Specific Comments by Page:
Page 3-17 "Amphibians and Reptiles".
The desert tortoise and the Gila monster are not listed as
endangered by the Arizona Game and Fish Department, as stated in
the text. The desert tortoise is listed under Group 3 in"Threat-
ened Native Wildlife in Arizona, approved by Arizona Game and
Fish Commission 10 December 1982"- By definition, Group 3 includes
animals "... whose continued presence in Arizona could be in
jeopardy in the foreseeable future." The Gila monster is protected
from killing under Commission Order 43, (R12-4-443), but is not
otherwise listed.
Page 3-18, 1st paragraph.
The spotted bat is no longer listed in "Threatened Native
Wildlife in Arizona" and Arizona Department of Game and Fish
should read Arizona Game and Fish Department.
Page 4-8, Surface Waters, Mobile Site.
We agree with the statement that "Under these circumstances,
the requirement to protect the facility from a 25 - year storm
could be inadequate", especially since, as stated on page 3-10,
"Northwest Tank, ... could be affected by surface water draining
through or near the site."
AN EQUAL OPPOPTUN1TY AGENCY
VI-64
-------
The deserts of Arizona are noted for torrential rains of short
duration, which result in substantial runoff on even the smallest
of watersheds. This runoff causes much natural erosion and could
severly damage the proposed facility and result in significant
adverse impact to the downstream environments.
Adequate protection from surface flooding must be provided
and the 25-year standard is not adequate. We believe that at
least protection from a "100-year" storm is needed to ensure a
reasonable level of safety, as stated on page 4-9 under "Kitigative
Measures".
Page 4-36, J4itigative Measures, Bird Control.
In reference to the protection of birds from poisoning in
evaporation ponds, we believe that bird-proof screening is the
minimum control measure that is acceptable. Noise makers are
generally effective for only short periods of time, as birds be-
come tolerant of them.
General Comments:
Other than the specific problems noted above, the draft E.I.S.
appears generally to be adequate and accurate.
Our Department believes that the Mobile site is the most
appropriate site for the hazardous waste facility.
We appreciate the opportunity to review this document and
we' anticipate close coordination between our Department and the
Department of Health Services on this matter in the future.
Sincerely,
Bud Bristow, Director
William E. Werner
Habitat Specialist
Region IV Yuma
CC: Don Metz, U.S.F.W.S., Phoenix
Planning and Evaluation Branch, Phoenix
Clearinghouse, AZ 83-80-0007
WEW/cr
VI-65
-------
W-84 Arizona Game and Fish Department comments were submitted
separately. See comments W-23 through W-27.
VI-66
-------
Comment Form To Be Completed by Reviewing Agency " i
state Application .uentifief (SAD
Ms. Terrie L. Krieg Indian Affairs
a. -an -00 07 s.,..AZNo, JAN 2 6 MM
a TH
& Fl
Administrative Services Officer
Director's Office
Dept. of Public Safety Transportation
P.O. Box 6638 Ag. & Hort.
Phoenix, AZ 85005 Arid Lands Stu-dies
Environmental Studies
FROM: Arizona State Clearinghouse Public "Safety"; ' .....
1700 West Washington Street Room 505 Emergency Services
Phoenix, Arizona 85007 ' Arizona Natural Heritage
' ' - " - _ Health "
/\ Water
\ AORCC
\ Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
^J No comment on this project || Proposal is supported as written [>q Comments as indicated b«low
1 Is project consistent with your agency goals and objectivesTf&J Yes 1— J No LJ Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are fam:liar'[_] Yes II No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and cbiectives?[_J Yes )ŁJ No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?[jY«i ylNo
5. Does project violate any rules or regulations of your agency? |_l Yes Ł3 No
6 Does proiect adequately address the intended effects on target population? Ł3 Yes [_J No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' I I Yes Ij No
,
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature tv, /JL-^L,<-L / • /^t^-&4^ _ Date •2-0L-Q 3
Title stf^t . ^U^- • Ul . _ Telephone
w-85
VI-67
-------
W-85 Comment noted. The commenter does not give specific
reasons why the Mobile site does not appear to be the
most appropriate. Consequently, a specific response
cannot be given. The analyses presented in this Final
EIS may respond to the commenter's concerns.
VI-68
-------
Comment Form To Be Completed by Review Agency
JQ. State Application identifier (SAD
JAN 2 6 1963
: NO.
Mr. David Landrith Indian Affairs
Executive Director, SEAGO Game & Fish
118 Arizona St. Transportation
B,sbee,AZ 85603 P
Arid Lands Studies . . ,
Environmental Studies^ V jj
FROM: Arizona State Clearinghouse Public Safety '
1700 West Washington Street, Room 505 Emergency Services
Phoenix, Arizona 85007 Arizona Natural Heritage r, o .
Health OCiJU,~-i.
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no laterthan 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional tine for review.
t^ I No comment on this project || Proposal is supported as written Q Comments as indicated below T"T— 8 6
1 . Is project consistent with your agency goals and objectives?! I Yes | _ j No I I Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?! I Yes [ I No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and cbjectiveŁ?l__] Yes L J No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?LjYes IT] No
5. Does project violate any rules or regulation', of your agency? |_J Yes [_J No
6. Does project adequately address the intended effects on target population' l_J Yes |_J No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' I I Yes I I No
Additional Comments (Use back of sheet, if necessary):
^>0l
VI-69
-------
Comment Form To B» Completed by Reviewing Agency
^ State Application ititier (SAD
T0: * .on? JAN 2 6 1963
3^-ftn-flOO' State A2 No
Christopher J. Bavasi, Ex. DIr. Indian Affairs
NACOG, Region III Game 5, Fish
119 E. Aspen St. Transportation
Flagstaff, Arizona 86001 Ag. & Hort.
Arid Lands Studies
Environmental Studies
„, . ,_ Public Safety
FROM: Arizona State Clearinghouse Emergency Services
1700 West Washington Street, Room 505 * Natural.Heritage
Phoenix, Arizona 85007 Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
[ XI No comment on this project j | Proposal is supported as written [ |Comments as indicated below
1 Is project consistent with your agency goals and oojectivesrLJ Yes [ j No I I Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and oojectives of which you are familiar7! J Yes I I Mo
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals ana cbjectives'LJ Yes LJ No
4 Will project have an adverse effect on existing programs with your agency or within project impact area'^J Yes I I No
5 Does project violate any rules or regulations of your agency' I I Yes I I No
6 Does project adequately address the intended effects on target population' I I Yes I I No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' 1 j Yes 1 I No
Additional Comments (Use back of sheel, if necessary)
Reviewers Signature \^~? ,*.«/v•___<. s {. .- < \! (/ • ' - ' < y -s^ Date
Christopher >j:'Bavasi, Executive Director, rlACUG
Title Ł/ Telephone
2-23-83 774-1894
VI-70
-------
Commem Form To Ba Completed by Reviewmo Aqency
TO:
State Application identifier I SAO
Robert K. Lane Acting Commissioner
State Lsnd Department
1624 W. Adams, 4th Floor
Phoenix, AZ 85C07
Attn: Robert Yount
FROM: Arizona State Clearinghouse
1700 West Washington Street, Room 505
Phoenix, Arizona 85007
State A2 No
JAN 2 6 1963
Indian Affairs
Game & Fish
Transportation
Ag. 6, Hort.
Arid Lands Studies
Environmental Studies
Public Safety
Emergency Services
Arizona Natural Heritage
Health
Water
AORCC
Land
Parks'
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
| | No comment on this project | XI Proposal is supported as written |] Comments as indicated below
1. Is proiect consistent with your agency goals and objectives^] Yes I I No I I Not Relative to this agency
2 Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?) X I Yes I I No
W-88
3. Is there overlap or duplication with other state agency or local responsibilities ano/or goals and cbjectives?l_J Yes UU No
4. Will project have an adverse effect on existing programs with your agency or within project impact area'LjYes I I No
5, Does project violate any rules or regulations of your agency' 1 I Yes IX 1 No
6 Does project adequately address the intended effects on target population' |_J Yes |_J No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar' IXI Yes 1 I No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature_
Title
Date 2/16/83
I and Manager
Telephone 255-4625
VI-71
-------
Comment Form To Be Completed by Reviewing Agency
State Application .jentiher (SAI)
T°: 00 07 State AZ NO JAN 2 6 1983
Dale Busldrk Indian Affairs
Advanced Planning Secticn Game & Fish
Dspt. of Transprtaticn Transportation/^
206 So. 17th Ave., Rn 310 B Ag. & Hort.
Pnosiix, AZ 85007 Arid Lands Studies
Environmental Studies
Public Safety
FROM: Arizona State Clearinghouse Emergency Services
1700 West Washington Street, Room 505 Arizona Natural Heritage
Phoenix, Arizona 85007 „ , ^
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please .contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
K?f No comment on this project Ł] Proposal is supported as written ^^Comments as indicated below VJ~89
1 Is project consistent with your agency goals and objectives?! I Yes I I No |_J Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?|_J Yes |_l Mo
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and cbjectivesFLJ^es I I No
4. Will project have an adverse effect on existing programs with your agency or within project impact area'^JYes I I No
5. Does project violate any rules or regulations of your agency'[_J Yes I I No
6. Does project adequately address the intended effects on target population' I I Yes I I No
7. Is proiect in accord with existing applicable laws, rules or regulations with which you are familiar? I I Yes I I No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature C?
-------
Comment Form To Be Completed by Hevi< -\ Agency
State Apphcanon Identifier ISA!)
JAN 2 6 1963
-OOP? Sia»AZNo
Mr. John Blackburn, Exec. Dir. Indian Affairs
Central Arizona Association Game & Fish
of Governments Transportation
P.O. Box JJ (1810 Main St.) Ag. 4 Hort.
Florence, AZ 8S232 Arid Lands Studies
Environmental Studies
FROM: Arizona State Clearinghouse Public Safety
1700 West Washington Street, Room 505 Emergency Services
Phoenix, Arizona 85007 Arizona Natural Heritage
Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
[vj] No comment on this project . Qj Proposal is supported as written ^Comments as indicated below W— 9 0
1 Is project consistent with your agency goals and objectives?! I Yes I I No 1_J Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?Lj Yes I I No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and cbjectives?|_J Yes LJ No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?l lYes 1 I No
5. Does project violate any rules or regulations of your agency? I I Yes I I No
6. Does project adequately address the intended effects on target population? |_J Yes I I No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar? I I Yes I I No
Additional Comments (Use back of sheet, if necessary):
" " A0-3 3
Reviewers Signature V{. V J-A~-r?LxvJ V5^J_A-^-/^>J^O\(SiJ Date
s .A V> >~^~ •> ':*• ™~- 'U^- Telephone Y\ W is ~ ;T ''
Title
VI-73
-------
Comment Form To 8« Completed by Review1 - Agancy
TO:
State Application Identifier (SAD
JAN 2 6 1963
Dr. James Sarn, M.D., Director
Department of Health Services
1740 West Adams Street
Phoenix, AZ 85007
FROM: Arizona State Clearinghouse
1700 West Washington Street, Room 505
Phoenix, Arizona 85007
Indian Affairs
Game & Fish
Transportation
Ag. Ł. Hort.
Arid Lands Studies
Environmental Studies
Public Safety
Emergency Services
Arizona Natural Heritage*.^
Healthx
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
| | No comment on this project |V1 Proposal is supported as written [ | Comments as indicated below
1 Is project consistent with your agency goals and objectives?! I Yes I I No [_J Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?!.
Mo
3 Is there overlap or duplication with other state agency or local responsibilities and/or goals and obiectives?l_) Yes LJ
No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?f I Yes I i No
5. Does project violate any rules or regulations of your agency? L_j Yes I i
No
6. Does project adequately address the intended effects on target population' 1 I Yes It
No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar? 1 I Yes I i No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature
Title
Date
Telephone
/
VI-74
-------
Commeni Form To Ba Completeo by Reviewing Agencv
70:
Stare Application entitier [SAD
Diw--K. E. Foster, Assoc. Dir.
Office of Arid Land Studies
University of Arizona
845 N. Park Avenue
Tucson, Arizona 85719
3?-an-no 07 Sa-
ne AZ No
JAN 2 6 1983
: ArizonTState Clearinghouse
1700 West Washington Street, Room 505
Etioenix,_Aj#ona 85007
r
Indian Affairs
Game & Fish
Transportation
Ag. & Hort.
Arid Lands Studies (/
Environmental Studies
Public Safety
Emergency Services
Arizona Natural Heritage
Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
JNo comment on this project || Proposal is supported as written Q Comments as indicated below \fj— 9 2
Is project consistent with your agency goals and objectives^ ] Yes I I No 1_J Not Relative to this agi
>ency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?LJ Yes I I No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and objectives?l_J Yes LJ
No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?! I Yes I I No
5. Does project violate any rules or regulations of your agency? I I Yes LJ No
6. Does project adequately address the intended effects on target population' |_J Yes LJ No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar? [_J Yes I I No
Additional Comments (Use back of sheet, if necessary):
Dat
Telephone
VI-75
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Comment Form To Be Completed by Ravie-- ->g Agency
Stare Application Identifier (SAD
T0; « nnn7 JAN 2 6 1963
SUM
Mr. Clinton M. Pattea Indian Affairs
Executive Secretary Game
Indian Affairs Commission Transportation
1645 West Jefferson St. Ag> & Hort.
Phoenix, AZ 85007 Ar^d Lands Studies
Environmental Studies
Public Safety
FROM: Arizona State Clearinghouse Emergency Services
1700 West Washington Street, Room 505 Arizona Natural Heritage
Phoenix, Arizona 85007 Health
Water <-•'-'/•'.
AORCC '''•'.;
Land 0,> '.-Ł., - '
Parks ^ " /'\'Ł,,
'"ii j ''-6, Regions
,
This project is referred to you for review and comment. Please evaluate as '- _v.
to the following questions. After completion, return THIS FORM AND ONE ^
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
fV|No comment on this project ^J Proposal is supported as written [^Comments as indicated below W~93
/
1. Is project consistent with your agency goals and obiectiuesj I Yes I I No l_J Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar'|_J Yes |_J No
3. Is there overlap or duplication with other state agency or local responsibilities and/or goals and objectives?t_J Yes l_J No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?[ JYes LJ No
5. Does project violate any rules or regulations of your agency? I I Yes I I No
6. Does project adequately address the intended effects on target population? I I Yes I I No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar? I I Yes I I No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature
<ŁSLs • xO^f-~7^Ł^- - _ Date / "5" '/ Q 'c'
Title __ _____^_ _ Telephone
VI-76
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Comment Form To Be Completed by Reviewing Agency
State Applicaito. ntifier ISA!)
JAN 2 6 1963
93-an-POO? S..»AZNO.
Mr. Terry B. Johnson Indian Affairs
Arizona Natural Heritage Progran Game & Fish
30 North Tucson Boulevard Transportation
Tucson, Arizona 85716 Ag> & Hort.
Arid Lands Studies
Environmental Studies
FROM: Arizona State Clearinghouse Public Safety
1700 West Washington Street, Room 505 Emergency Services
Phoenix, Arizona 85007 Arizona Natural Heritages
Health
Water
AORCC
Land
Parks
6 Regions
This project is referred to you for review and comment. Please evaluate as
to the following questions. After completion, return THIS FORM AND ONE
XEROX COPY to the Clearinghouse no later than 17 WORKING DAYS from
the date noted above. Please contact the Clearinghouse at 255-5004 if you
need further information or additional time for review.
M I No comment on this project Q] Proposal is supported as written ^Comments as indicated below T'T—94
1. Is project consistent with your agency goals and objectives?) I Yes I I No I I Not Relative to this agency
2. Does project contribute to statewide and/or areawide goals and objectives of which you are familiar?[_J Yes I I Mo
3. Is there overlap or duplication with other state agency or local responsibilities and/or goafs and cbjectives'L—I Yes L_ I No
4. Will project have an adverse effect on existing programs with your agency or within project impact area?Lj Yes I I No
5. Does project violate any rules or regulations of your agency' |_J Yes |_J No
6. Does project adequately address the intended effects on target population' |_J Yes LJ No
7. Is project in accord with existing applicable laws, rules or regulations with which you are familiar? I I Yes I I No
Additional Comments (Use back of sheet, if necessary):
Reviewers Signature <"T _^_^A \_\ f.
Date
T
Title f-2*r*-!'.-2S5ii7't-«Ł-X/*f- s.S) SI/^r/^ Telephone i333~&&*Ł /
VI-77
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W-86 through W-94. No response needed,
VI-78
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El Paso
P O BOX 1492
_ EL PASO, TEXAS 79978
Natural Gas Company PHONE 915-541-2600
March 8, 1983
U.S. Environmental Protection Agency, Region 9
215 Fremont Street
San Francisco, CA 94105
Attention: Chuck Flippo (T-2-1)
Reference: Draft Environmental Impact Statement,
Arizona Hazardous Waste Facility
Dear Mr. Flippo:
El Paso Natural Gas Company (El Paso) operates one of this nation's
largest natural gas transmission systems, primarily in the southwestern
states, including Arizona. As a member of the industrial community in
Arizona, we have followed with interest the planning for a state-owned,
contractor-operated hazardous waste facility. In general, we are pleased
to see Arizona acting to develop such a facility. We feel it will W—9 5
benefit the citizens of the state, the Arizona environment, and the
state's hazardous-waste generators.
We have reviewed the draft environmental impact statement concerning
sale of public land to the state for this facility. Since El Paso pipe-
lines are near each of the three sites being considered, we believe the
Environmental Protection Agency and Bureau of Land Management should be
aware of these points when authorizing a site for the facility and when
evaluating the subsequent application for an operating permit:
o For safety reasons and to protect the buried pipeline, co-use of
El Paso's patrol roads and parallel co-use of El Paso's right-of-
way cannot be permitted.
VI-9 6
o El Paso will have to review and approve any plans for road crossings
over its pipelines to determine need for additional pipeline protec-
tion. We will need specific information as to vehicular weights
and axle loads.
VI-79
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U. S. Environmental Protection Agency, Region 9
March 8, 1983
Page 2
We hope this information is helpful. Thank you for the opportunity to
participate in the environmental review for the proposed Arizona hazardous
waste facility.
Very truly yours,
Howard Reiquafy Ph.D.
Director
Environmental Affairs Department
VI-80
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W-95 Comment noted. NO response needed.
These issues are addressed in the d _„,.
SpilinRiskSS ^ SeCti°n IV' Public Health and Safety
W—96 These issnoo =»>-o aH/^v^o^^j • 1.1. j-
addressed in the discussion of transpoi
•»«.*.j_j ^-», _.-. _ L
VI-81
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iV\ United States
f/l Department of
y Agriculture
Forest
Service
Region 3 517 Gold Avenue, SW
Albuquerque, NM 87102
R.0,,,0 1950
(FPM)
FEB 2 3 1983
Mr. Chuck Flippo
U.S. Environmental Protection Agency
215 Fremont Street
San Francisco, CA 9A105
Dear Mr. Flippo: "-"- '
We have reviewed your Draft Environmental Impact Statement for an Arizona
Hazardous Waste Facility, and concur with the proposed alternative to
purchase the Mobile site from the Bureau of Land Management for the facility.
We support the need for a hazardous waste facility of this type that would
allow controlled disposal or recycling of hazardous materials and remove
many of the problems associated with indiscriminate storing and dumping.
Sincerely,
THOMAS G. SCHMECKPEPER
Deputy Regional Forester
W-97
FS-620D-11(8-801
VI-82
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W-97 Comment noted. No response needed.
VI-83
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UNITED STATES
DEPARTMENT OF THE INTERIOR
OFFICE OF THE SECRETARY '''M
: CHIVED
REGION !;<
lu ^i «n u-
PACIFIC SOUTHWEST REGION
BOX 36OB8 . 45O GOLDEN GATE AVENUE
SAN FRANCISCO. CALIFORNIA 941O2
(419) 556.8200
EK 83/117
Referred To T-'l-
CC:
File:
MAR t 7 1983
Ms. Sonia F. Crow
Regional Admlnistr.ator
Environmental Protection Agency
Region 9-
215 Fremont Street
San Francisco, California 9^105
Dear Ms. Crow:
The Department of the Interior has reviewed the draft environmental impact
statement for the Arizona Hazardous Waste Facility.
In the main body of the environmental statement, evaluations of impacts on
topograp^ soils, and geology are largely qualitative and hypothetical. For
example, little or no indication has been given of the probable dimensions or
depths of excavation, heights or designs of embankments, thicknesses or designs
of liners, volumes of earthwork, or sources of fill. The first mention of
specific designs is in an Appendix (pp.D-6 to D-16). It would be useful to
incorporate probable design features into the evaluations of environmental impacts
in order to make such evaluations more quantitative. Information available
indicates that no major mineral resources would be affected on the Mobile site.
The alternate Western Harquahala Plain and Rangeras Plain sites may be in an
area of low temperature-geothermal resources. Small occurrences of iron also
are reported near the alternate sites.
Specific Comments
W-98
W-99
Page
paragraph 2: It appears that a leak detection system with a double
liner would be the best method of protecting against the release of contamination
from the facility.
Page 4-8, Surface Waters: Providing protection from a 25-year storm would be
inadequate at the Mobile site. Protection should be provided for a least the
100-year storm because of high Intensity thunderstorms that often hit the area.
Page ^-36, Mitigative Measures: To facilitate revegetation in those areas to be
cleared for construction activities we recommend that the vegetation be crushed
and not cleared. A high percentage of the crushed vegetation will resprout.
W-100
W-101
w-102
VI-84
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Page H-36, Bird Control: All possible control measures should be investigated
as migratory birds will be attracted to open water in desert areas.
We appreciate the opportunity to review and comment on this document. If you
have any questions regarding these comments, please contact me.
Sincere ly;,
Patricia Sanderson Port
Regional Environmental Officer
cc:
Director, OEPR
State Director, BLH
Director, GS
Regional Director, FWS
Regional Director, BM
Regional Director, Bft
VI-85
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W-98 The reasons more specific design features are not
presented in the EIS are explained in Section I.
w-99 Comment noted. Should one of these sites be transferred,
the value of mineral resources would have to be appraised
and included in the sale price of the land.
W-100 Specific design requirements would be addressed in the
facility permit. See Section IV, Ground Water.
W-101 ADHS would to require protection from a 100-year storm.
See Section IV, Surface Water.
W-102 Comment noted. The Draft EIS states that the contractor
would be instructed to take care not to destroy the
roots of shrubs located in those areas which need only
temporary clearing for construction activities (DEIS
p. 4-36). Crushing, rather than clearing, could be
one way of accomplishing this. ADHS would seek guidance
from and work with the Arizona Department of Agriculture
and Horticulture to ensure that the commitments to
protect vegetation are met.
W-103 Experience at similar existing facilities suggests that
bird control should not be a problem. If a problem did
arise, ADHS would seek guidance and assistance from the
Arizona Game and Fish Department to evaluate and imple-
ment appropriate bird control measures.
VI-86
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UNITED STATES
DEPARTMENT OF THE INTERIOR
OFFICE OF THE SECRETARY
PACIFIC SOUTHWEST REGION
BOX 36098 . 450 GOLDEN GATE AVENUE
SAN FRANCISCO. CALIFORNIA 841O2
(415) 5S6-82OO
ER 83/117
Ms. Sonia F. Crow WAR 1 ' 1983
Regional Administrator
Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, California 94105
Dear Ms. Crow:
The following comments were inadvertently omitted from our earlier letter.
On page S-2, Affected Environment, first paragraph, there appears to be a
difference la the number of people within 5 miles of the Mobile site. Here ^T
you say 25 people live within 5 miles of the site, and on page 3-29, second
paragraph, you state that 80 persons live within a 5 mile radius of Mobile.
Which figure is correct and does this figure include an Indian population?
On page 2-3, Figure 2-1, you show Interstate 10 leaving Phoenix connecting - n _
with Highway 80 south to the Mobile site. Isn't this Highway 85? V/-1UD
On page 3-^5, Land Use, first paragraph, the second from last sentence states
"Private and other lands are located along the CAP canal . . .". What is the W-106
amount of ''other lands" and who are the land owners?
On page 3-62, parapraph 6, it states "The U.S. Department of the Interior has
listed the bald eagle, Yuma clapper rail, . . .". We feel this should read, W—107
the U.S. Department of the Interior, Fish and Wildlife Service has listed the
bald eagle . . .
One page k-kO, mitigative measures, "... appropriate mitigation measures
.". The responsible person handling the Archaeology section could explain
what is meant by appropriate mitigation measures. Will the cultural resources
be avoided, tested for determining significance, subjected a data recovery pro- W—108
gram or a mixture of the aforementioned measures? It would be more meaningful
if the public is made aware of how the appropriate mitigation measures operate.
The use of professional jargon in a public publication should be limited as
much as possible.
In Appendix K (K-l), again, the EIS is for public review and such usage as Class ™_
I and II should be explained, thus avoiding unnecessary confusion for the layman. w
VI-87
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Additional Comments:
1. The EIS section concerning archaeology, prehistory, history, and socio-
history does not mention the effect of the Project on sacred and religious W-110
area as mandated under the American Indian Religious Freedom Act. The EIS
should address this area of concern with the Indian Tribes being impacted.
2. The archaeology section of the EIS does not mention whether the
National Register of Historic Places was consulted, or if the SHPO was contacted W—111
to see if potential resources were listed.
3. The EIS does discuss the availability of access to the proposed areas
but it does not consider or mention if these secondary access routes will be W—112
upgraded for the X amount of traffic. If the access routes will be improved,
then, the right-of-way needs to be mentioned, as it can cause considerable
damage to cultural resources.
We appreciate the opportunity to comment on this DEIS.
Sincerely, ~^
/ Patricia Sanderson Port
^ Regional Environmental Officer
cc:
Director, OEPR
State Director, BLM
Regional Director, FWS
Regional Director, BM
Regional Director, BR
VI-88
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W-104 Two different areas are being addressed: a 5-mile radius
around the site, and a 5-mile radius around the community
of Mobile (which is 6 miles from the site). Twenty-five
people live within a five-mile radius of the site itself.
Most of the 80 persons who live within a five-mile radius
of the community of Mobile would be further than five miles
from the site.
The number of Indians in these figures is not known,
since census data used to arrive at these figures do
not distinguish between Indians and non-Indians. The
nearest reservations are outside both five-mile radii.
W-105 At the time the map used in DEIS Figure 2-3 was made,
the road segment referred to was U. S. 80. It is now
Arizona State Highway 85. The highway connects with the
Maricopa-Gila Bend Road, but would not necessarily be
an access route to the Mobile site. The likely access
route to that site is from the east through Maricopa.
W-106 The sentence referred to should have read "Lands in the
jurisdiction category of 'private and other1 ..." rather
than "Private and other lands ...". The lands referred
to in the sentence are right-of-way for the Bureau of
Reclamation's Central Arizona Project. The size of
this land is shown in DEIS Figure 3-9 (reprinted with
corrections in Section II).
W-107 This correction has been noted. See Section II.
W-108 No significant cultural resources have been identified
at the sites. It is difficult to specify in advance the
measures that would be taken if cultural artifacts were
discovered in the future. Depending on the resources
identified, mitigation may include mapping of the site,
surface collection of artifacts, subsurface testing,
and/or excavation. The State Historic Preservation
Officer would be consulted to determine appropriate
measures if such resources were discovered during con-
struction or operation of the facility.
W-109 Class I is a BLM designation for a cultural resources
overview of an area conducted through literature reviews
and record searches. As stated in DEIS Appendix K,
p. K-2, a BLM Class II Cultural Resources survey is
a sample on-the-ground survey. A Class III Cultural
Resources survey is an intensive on-the-ground survey
covering 100 percent of the study area.
W-110 The Draft EIS identifies sacred and religious areas as
well as other Native American cultural resources in the
vicinity of the proposed sites. These are presented in
VI-89
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Table 3-6 (DEIS p. 3-26), Table 3-14 (DEIS p. 3-54), and
Table 3-18 (DEIS p. 3-71). None of the sacred areas is
expected to be adversely impacted by the proposed facility.
No comments have been received identifying potential
impacts which were missed in the analyses done for the
Draft EIS. (See also the response to comment W-112.)
In order to identify and document concerns for cultural
resources that have historical or contemporary significance
to Native Americans, mail and telephone contacts were
made with the Inter-Tribal Council of Arizona, represen-
tatives of the Native American tribes of Arizona, and
appropriate Federal and State agencies. A summary
list of the contact program conducted is provided in
Appendix M of the Draft EIS; see DEIS pp. M-3 to M-5.
A summary of the concerns raised in these discussions
was prepared but omitted from the Draft EIS. It is
reprinted below for the benefit of reviewers. Most of
these concerns relate to ground water contamination and
transportation-related accidents. There was some concern
that the gathering of cholla, greasewood, mesquite beans,
and saguaro in the Rainbow Valley area could be impacted.
Site visits to the proposed Mobile site indicate that
some subsistence plants do grow there (e.g., mesquite
beans). Since only a small area of land would be affected
by the facility (one square mile), the impact on the
ability of Native Americans to gather these plants would
not be expected to be significant.
Native American Concerns:
The president of the Inter-Tribal Council of Arizona (ITCA)
recommended that contacts be made with all tribal leaders
in Arizona since "the process of selection and the impli-
cations for use of natural resources and population growth
have a potential impact on all tribes." The ITCA also
noted that the issue of ground water protection was of
particular concern. Contacts were made with the represen-
tatives of the Fort McDowell (Yavapai), Papago (Papago),
Gila Bend (Papago), Gila River (Pima-Maricopa), and Ak Chin
(Papago-Pima) Indian reservations (see DEIS Appendix M).
The chairman of the Papago Tribe forwarded a copy of a
Tribal resolution passed on August 6, 1982, objecting to
location of a hazardous waste facility site in Rainbow
Valley and requesting the Federal government to "refuse
the transfer and use of Federal lands within the Valley
for such a purpose." The chairman of the Gila Bend Papago
did not feel that the proposed facility near Mobile would
impact historic or cultural resources, but expressed strong
concerns for the possiblity of contaminating the water
basins in Vekol and Vasco Washes. Similarly, a represen-
VI-90
-------
tative for the chairperson at Fort McDowell expressed
concern over the potential adverse effect of hazardous
waste disposal on ground water sources for Arizona in
general, and Yavapai ancestral lands in particular. At
Ak Chin, the chairperson noted that a number of reserva-
tion families continue to gather cholla, greasewood,
mesquite beans, and saguaro in the Rainbow Valley. The
concern was expressed that the proposed facility would
contribute to the depletion of these resources in the
area. The governor of the Gila River reservation
expressed strong concerns over the transportation of
hazardous waste across reservation land because of the
potential for accidents, resulting in contamination.
He stated that the tribe objected strongly to such
action on their traditional homeland.
W-lll As part of the record searches done for the EIS, the
Arizona State Historic Preservation Office was contacted
(32). No known sites recorded within the project area are
currently listed on or nominated to the National Register
of Historic Places. The Gila Trail or Butterfield Stage
Route has unofficial distinction; the route is marked
with interpretive signs and is used by Boy Scout groups
as a hiking trail.
W-112 Access is anticipated along existing roads, some of which
would need to be upgraded (see Section IV, Public Health
and Safety: Spill Risks, under "Risks from Transporting
Hazardous Waste".) Since the roads already exist, the
impacts on cultural resources due to upgrading of the
roads would be expected to be minimal. Paved roads
could be seen as making some of the resources near the
sites more accessible than the current dirt roads (e.g.,
the Butterfield Stage Trail, which can be reached via
the Maricopa-Gila Bend Road). Improved access could
benefit users or potential users, but could also increase
vandalism of these resources. Since road improvements
would be made only as far as the facility, it is difficult
to say whether this limited increase in accessibility
would in fact result in greater use of these resources
or in increased vandalism.
Where the roads cross BLM lands, an environmental analysis
was conducted as part of the process of granting right-of-
way. If the right-of-way needed to be extended to provide
for the necessary road improvements, further environmental
review would take place as part of BLM's process of amend-
ing the existing right-of-way agreement. (Similarly,
extension of utility lines across BLM lands would require
an environmental review as part of the process of granting
right-of-way.) The State Department of Transportation
would conduct an environmental review for expansion or
reconfiguration of State or county roads.
VI-91
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ORAL COMMENTS
A public hearing was held to receive comments on the
Draft EIS on Tuesday, March 1, 1983. The first part of the
hearing was held in Phoenix at 9:30 a.m.; the second part
was held in Buckeye at 7:30 p.m. Court reporters recorded
the testimony presented at the hearing. The transcribed
record (with corrections) is reprinted here.
Substantive hearing comments are numbered H-l through
H-40. The response to each numbered comment appears beside
that comment on the same page.
VI-92
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1
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3 !
4 j
5 i
6
7
A Public Hearing to Consider:
DRAFT OF ENVIRONMENTAL IMPACT STATEMENT
For the Arizona Hazardous Waste Facility
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Conducted by: The U.S. Environmental
Protection Agency, Region IX,
San Francisco, California
Phoen i x, Arizona
March 1, 1983
9:30 o'clock a.m..
MR. MATTHEW S. WALKER, Hearing Officer
Volume I
ANDREA WEAVER- CERTIFIED COURT REPORTER
M. L. SPICER & ASSOCIATES
700 West Campbell
Sui te 10
Phoenix, Arizona 85013
602-277-5664
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2 5
SPEAKERS :
RICHARD WRUBLIK
RAYMOND ADAMS
EXHIBITS
No . 1 (Environ
NO . 2 (N
No . 3
No . 4 (
No . 5 (
No . 6 (
No . 7
N o . 8 (
INDEX
PAGE
31
PAGE
(Environmental Impact Statement) 4
(Notice of Hearing)
(Map)
(Let. 9-20-82)
(Let. 2-8-83)
(Let . 1-29-81)
(Article)
(Let. 1-20-83)
4
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March 1, 1983
9:10 o'clock a.m..
The Public Hearing on the matter of a
Draft of Environmental Impact Statement, Arizona
i
Hazardous Waste Facility, conducted by the U.S.
Environmental Protection Agency, Region IX, San
4
Francisco. California, commenced at 9 : O'O o'clock
a.m., on March 1, 1983, at The Arizona Department
of Health Services, Conference Rooms A and B,
Fourth Floor, 1740 West Adams Street, Phoenix,
Arizona, before ANDREA WEAVER, a Certified Court
Reporter and Notary Public in and for the County
of Maricopa, State of Arizona.
The Hearing was conducted by the Hearing
Officer:
Mr. Matthew S. Walker
EPA, Region IX, San Francisco, California
The proceedings follow:
MR. MATTHEW WALKER: Good morning.
We will start this Public Hearing.
My name is Matthew Walker, and I've been
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designated by the Environmental Protection Agency
to preside at this Public Hearing.
This is a Public Hearing to consider a
Draft Environmental -- excuse me, Impact Statement
on the Arizona Hazardous Waste Facility.
The Environmental Impact Statement has
been prepared and notice of this Hearing has been
published in the Arizona Republic and the Phoenix
Gazette on the 14th of January of this year.
In addition to that a mailing was made of
a large number of copies to a mailing list that
I'm informed consists of some 2,000 people.
We will not introduce the entire mailing
list into the record. I will, however, mark the
Environmental impact Statement itself as Exhibit
No. 1 for the purposes of this record and a copy
of the notice of the Hearing as Exhibit No. 2.
(Thereupon, documents were marked by Mr.
Matthew Walker, Hearing Officer as Exhibit Nos. 1
and 2.)
MR. MATTHEW WALKER: This Hearing today
is being record by a Stenographic Shorthand
Reporter, Miss Andrea Weaver, of the firm of M.L.
Spicer and Associates.
The stenographic record will be
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transcribed and a complete record will be
submitted as a part of the formal record of this
proceed ing .
If you wish to address the record, you
must have signed one of these registration cards
that was made available at the desk as you entered.
There are two boxes at the bottom. One
of them says, "I wish to make a statement.". The
other says, "Please put my name on the mailing
list.".
If you do wish to make a statement, you
should check the box saying, "I wish to make a
statement." and that card will be handed up to the
front table and you will be called upon in order.
It is necessary that we have everyone
come to the microphone and speak. For one thing,
because we are making a record of it, we need to
know who you are, if you're here in a
representative capacity, who you're representing,
and we need to be able to hear and understand what
it is that you have to say.
It's almost impossible to make an
adequate record of people speaking from the
aud i ence .
Now, the procedure that will be followed
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on this, is this; we'll hear all of those who wish
to speak this morning, we will continue as long as
necessary. If the speaking takes considerable
length of time, which I do not anticipate, we- may
need to take a mid-morning recess for the sake of
the Repor ter .
At the close of the formal part of the
Hearing, certain members from the Environmental
Protection Agency will be available here for a
question and answer period. However, that
question and answer period will not be a part of
the formal official record of this proceeding.
Those questions and the answers you may
receive are for your information and use, but
cannot be considered as part of the administrative
record of the Hearing, and cannot be relied upon
for either support or attack of the Environmental
Impact Statement.
Any statements, questions, or other
interrogatories that ar
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made will be addressed in the final Environmental
Statement that will be prepared, and notice of
that will be published in the Federal Register,
and elsewhere, for your knowledge and information.
If you have signed one of the cards and
put on the bottom, "I wish my name to be placed on
the mailing list." you will be advised of the
final Environmental Impact Statement, by mail, so
that you will then have an opportunity to know
what is the result of this proceeding and the
result of this Hearing.
The method by which the final
Environmental Impact Statement is arrived at is
somewhat complex since many people are involved
and several agencies are involved.
Reports are prepared, briefings,
documents are prepared, and submitted, and
considered, and the only way I can adequately
describe that is that it is a comraunity-type
decision, there is no one single person who makes
the entire decision. It may be that the Regional
Administrator will sign off on it, but obviously,
many people participate in the proceedings up
until then.
Now, I have one of these registration
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cards where someone has asked to speak to the
Panel. At the present time I have only one, so
that makes my problem of protocol quite simple.
Normally we take elected officials first,
and thereafter hear people in the order in which
they have signed up.
If there is anybody here who does wish to
address us, and to speak to the Panel, please let
us know and your card will be checked and handed
up here.
At the present time I only have the one
card and I will therefore now call on Mr. Richard
w r u b 1 i k .
MR. RICHARD WROBLIK: I guess I'm sorry
to disappoint a bunch of the people here. They
were all hoping that nobody would show up and ask
to speak, so that they could adjourn the meeting
immed ia te1y .
MR. MATTHEW WALKER: Quite the contrary,
we were hoping somebody would show up in order to
make our trip valid.
MR. RICHARD WRUBLIK: I heard the
opposite in there, so maybe the official statement
is one way, the unofficial is another.
I have, some of the stuff has been
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not recorded, and I do want some of this stuff
recorded on the official record.
I have several objections to the
information contained in the Hazardous Waste
Report that was made by the EPA.
I feel that there have been soma very
wrong statements made and we need to get some of
them corrected.
The that was
-&•Ł• *-h-e first s ta temen t/mad e in the
Environmental Impact Statement on the very first
page, which tends to make me wonder if the EPA
knows what they are doing, the first statement on
the first page says that the site is sixty-five
miles from Phoenix.
That absolutely is false. It is not
sixty-five miles from Phoenix, it is not fifty
miles from Phoenix, it is not forty miles from
Phoenix, it's not thirty miles from Phoenix, it's
not twenty-five miles from Phoenix. It's between
twenty and twenty-five miles from Phoenix.
Now, there is 'a big difference between
twenty and twenty-five, and sixty-five miles.
When you start off with the wrong
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25 assumptions, a lot of other things happen that ar<
The Draft EIS does not clarify that
the 65-mile distance is road miles
from central Phoenix. The commenter
is correct in that the direct dis-
tance ("as the crow flies") between
the site and the western suburbs
of Phoenix is 25 to 30 miles.
Where a mileage figure is used in
this EIS, the mileage figure most
appropriate for the particular
impact being analyzed is given
(e.g. , road miles are used in
assessing transportation-related
spill risks).
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wro ng also.
And I am submitting into evidence, and I
have it here if anybody wants to look at it, I
have a map that is from the official State of
Arizona that clearly shows exactly where the
hazardous waste site is, and if you don't believe
it, check it yourself, and you will see that we
are less than thirty miles from the site today.
Right where you're sitting is less than thirty
miles. This is a fact.
MR. MATTHEW WALKER: Did you want to make
that map a part of the record?
MR. RICHARD WROBLIK: Yes, I will.
MR. MATTHEW WALKER: I'll mark that as
Exhibit 3 for the Record.
Thank you .
MR. RICHARD WRUBLIK: I have a bunch more
I have to get from my —
MR. MATTHEW WALKER: Just a minute, let
me identify this for the record.
This appears to be a Xeroxed copy of a
general highway map, Maricopa County, Arizona,
prepared by the Arizona Department of
Transportation, 1980, and it has on it some radii
which are marked in numbers, and I presume those
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1 are in miles.
2 It will be marked Exhibit No. 3 for this
3 r ecord .
4 Go ahead , sir.
5 (Thereupon, a document was marked by Mr.
6 Matthew Walker, Hearing Officer as Exhibit No. 3.)
7 MR. RICHARD WRUBLIK: When you look at
8 this map then, and you know how close it really is
9 to Phoenix, well then, I think that the people (H-2)
a
10 that are being Affected weren't properly notified.
11 We're having a meeting tonight in Buckeye,
12 for the Buckeye area. They say, well, that they
13 are so close they have to be notified.
14 Believe it or not, you are sitting almost
15 as close as they are, probably the same distance.
16 Most of the people in Buckeye live farther away
17 from it than what you're sitting right here today.
18 There has been no notification telling
19 the people of Tempe. Why weren't the people
20 notified in Tempe, they're only about thirty miles
21 away?
22 Chandler is only about thirty-six.
23 And one of the high-risk people that are
24 involved are Sun City, they are only thirty-five
25 miles away. There is a tremendous hazard to them.
Efforts to notify the public of
the public hearings are documented
in Appendix G.
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1 which we brought out very clearly at Mobile, which
i that even wrote
2 I is backed by the specialist/ the report for this
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that Valley Fever is a dangerous situation.
The people in Sun City have not lived
here a long time and the wind that comes from this
hazardous site carrying Valley Fever can come on
them very easily.
There are documented stories, reports now
in California where tremendous amounts of Valley
Fever was moved this length of distance through
the air by a bad storm.
I think they are negligent when they are
not notifying the people that have definitely a
chance of being involved.
I think I know why, they don't want the
people of Sun City to know how dangerous it is
because they are a very strong, vocal, organized
group. But, that doesn't mean they shouldn't be
noti fied.
The whole metropolitan area, one million
six, I guess it runs one million six, is supposed
to be the population of the metropolitan area, all
live within forty-two miles of the place, not
sixty-five miles, as is in the report.
This gets down to the very nuts and bolts
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of the whole report. How much value is it?
I think the best example of what, for
what I think it's worth, is one of my teachers in
college taught me what the rule of averages was.
He told me, "How do you, what temperature
do you people like; seventy, seventy-five, is that
a good temperature for everybody?". " Seventy-five,
r ight. "
He said, "All right, take that example of
seventy-five, that's a reasonable temperature.-'
All right now, he'd give you another
example; "150 degrees, and zero, that's an average
of seventy-five , but who wants to be in zero
14 temperature, and who wants to be in 150?'
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Well, what happens out here is this; why
am I using this example? The report that is in
EPA
the gnu i r
Report is primarily made
of those types of averages. The people who wrote
those reports did not go on-site, they never
investigated within the area. There's a few that
went on-site, but most of that report is made from
a broad area, taking these types of averages.
It was not done looking at the site, and
the proximity to it.
you
Now, y say, do I know that to be true?
The use of data from broad areas
(regional data) rather than site-
specific data is addressed in
Section I. Where regional data
are used, as in the ground water
discussion, the "worst case"
values for that region are
presented as well as the "average"
values.
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I've been told this by the people that
wrote the report. Both the Department of Health
and by the EPA, I'm quoting them. If you don't
believe them, I can't help you.
They did not have, the Department of
Health here did not have any money when they were
assigned the job, and the money that they did get
they spent to impress the Legislature.
And what they did there was a crime
because the report that they give them showed them
I
' all these new electronic things that can take
waste and do away with it, which is a good idea, I
really think that is a good system.
But, what is actually happening out there
is that we got a storage dump. That's all we're
going to get. There is no electronics, there is
no electronic -- this new processing, at all.
They had no money to do their job.
They took and went to books of record and
wrote the report on that. Whatever those people
said in the report was based on broad areas, cause
they only had time to go out to some of the sites
and just walk around for fifteen minutes and got
in the car and left, so they could say they were
on the site.
Use of a "low technology" facility
as the basis for analyzing impacts
in the Draft EIS is discussed in
Sections I and III. The impacts of
a representative "high technology"
facility, using a high-temperature
incinerator, are analyzed in this
document (see Sections III and IV).
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So, this is the type of report that we
have.
Now then comes along the EPA and they
copy the Department of Health's report.
Then you begin to wonder what real value
there is in the report. I'm not questioning the
capabilities of the people, especially the
Department of Health Services, I have nothing
against the EPA even, because I know you guys were
10 ! not given the money and that's the best you can do
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12 couple of reports and write it up.
13 i The total sum budget was less than
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$10,000. Am I right? I was told it was less than
S10,000.
Okay, the next point that I want to bring
up is why was the Mobile site chosen when the
people knew, really, the involved people knew that
it was only twenty-five miles from Phoenix? There
has to be a reason, nothing is done without a
reason .
And the reason, one of the reasons, very
obvious, I was told this by one of the
representatives of -- I got it secondhand, you
might say, it was from a very reliable person, why
The Draft EIS incorporates ADHS's (H-S)
siting study by reference (1).
Such use of previously published
material is required by Federal EIS
regulations to avoid unnecessary
duplication (see 40 CFR 1502.21).
While the siting study included
environmental considerations in
its analysis of potential sites,
this EIS goes into much greater
detail on the potential environ-
mental impacts than did the
ADHS study.
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was the Mobile site being pushed so hard?
The answer is very simple, that Provident
Energy will save one million dollars in
construction costs, that's what they are quoted as
saying.
MR. MATTHEW WALKER: I'm sorry, what
energy company?
MR. RICHARD WRUBLIK: Provident Energy
Company .
MR. MATTHEW WALKER: Provident?
MR. RICHARD WRUBLIK: They are talking
about putting a refinery in there. If they don't
have to have a retaining place for the waste, they
can save one million on the construction site, and
with the hazardous waste down the road six miles
they wouldn't have to do that, and only have to
haul it a few miles, instead of 150 miles to the
other site that the Department of Health actually
recommended .
So, this would cost a couple of hundred
thousand dollars a year, so there is a good
economical reason why this happened.
The question gets down to why, why wasn't (H ~ 6
the site recommended by the Department of Health,
actually accepted?
ADHS's study recommended the
Western Harquahala Plain site,
but also informed the State
Legislature that the Mobile
(Rainbow Valley) site and the
Ranegiras Plain site would be
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They raised some very good issues in
saying why they wanted it: It's remote, it's easy
access to the freeway, you can get there in three
to six miles from the freeway.
Now, we get down to Mobile, I don't think
this was addressed properly in there; in the EPA
study. What is it going to cost to put twenty
miles of road, twenty miles of, there's dirt road
for twenty miles out there and there are people
living on it, and in order to bring hazardous
waste down you're going to have to bring in a good
road, at least twenty million dollars. I
Now, in our report we were led to believe
when they went to the Legislature that the
hazardous waste site was going to pay for the
roads, there would be no cost to you, the public.
Well, we're having troubles, they are
having troubles getting anybody to bid on the site.
Am I right? People from the Department of Health
are having trouble getting bids on this.
MR. MATTHEW WALKER: Just tell us your
problems and then we'll address those.
MR. RICHARD WRUBLIK: Okay, okay, okay.
What is happening is that the cost of the
roads is so high that they are new trying to come
acceptable alternatives. The
decision to select the Rainbow
Valley site was made by the
Legislature. The EIS addresses
all three sites.
The estimated cost of improving
the road is discussed under
"Risks of Transporting Hazardous
Waste" in Section IV, Public
Health and Safety: Spill Risks.
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1 I out with another program to handle it. They are
2 1 now suggesting that the hazardous waste site, tha
i e
3 refina'ry, Final County and Maricopa County will
4 share the cost.
5 Now, what that simply means is that half
6 of that road cost would be subsidized if this goes
7 thr ough .
8 We're talking about ten million dollars,
9 probably, that will have to be subsidized.
10 | This has not been addressed in this
11 report, whatsoever. Why not?
12 The next point, the other point that is
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13 i raised in this report which is, I think is in
14 | error or very misleading, maybe not in error,
15 misleading. The biggest hazard •*:«- that we have
is not
16 3 emeo n e hauling hazardous waste, and this
17 Department of Health knows this very well because
18 i they do not know of hardly any accidents carrying
19 | hazardous waste, but there's hardly a week that
20 goes by that we don't have trouble with hazardous
21 material. One of the reasons given for not going
22 to the Harquahala site, by one of the key people
23 in the Senate was he said that the hazardous waste
24 truck would have to go over the canal. One of the
25 I main reasons for not choosing the other site.
Sharing the cost of paving the
road between Maricopa and Mobile
is one option currently under
consideration. The options are
listed in the discussion of "Risks
of Transporting Hazardous Waste"
in Section IV, Public Health and
Safety: Spill Risks.
The transportation of hazardous
material is addressed in
Section IV, Public Health and
Safety: Spill Risks.
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1 1 Well, the truth of the matter is that
2 i hazardous material will go over that canal
3 j thousands of times a day and the material in that
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4 ! hazardous material is sometimes more dangerous
5 I than the hazardous waste.
6 The hazardous waste does not represent
7 one percent of the total problem. And the
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8 question is, what are we doing to protect the
9 i public right today from those hazardous materials
10 ! going across those rivers and potential rivers?
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11 ! Nothing, hardly. It's a real problem.
12 I also want to put in a document on the
13 record, and I'll give you another copy here just
14 to show you why we're concerned out there, I have
15 a report here from the Buckeye area — I'll find
16 j it here in a minute and give it to you, by the
17 Buckeye Rural Fire Department.
18 j MR. MATTHEW WALKER: Thank you.
i
19 i Now wait just a minute until I identify
20 this.
21 This is on the letterhead of the Buckeye
22 Valley Rural Fire Department, dated September 20,
23 1982, "Subject: Hazardous Waste Materials
24 incident of 8-27-82, at the Rainbow Valley
25 Landfill.". And there are three pages for the
See previous comment,
See Section IV, Public Health
and Safety: Spill Risks, for a
discussion of transportation
safety regulations and the
State's Emergency Response
program.
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1 report, and one, two, three, four pages attached
2 to i t .
3 This will be marked Exhibit 4 for the
4 purposes of this record.
5 (Thereupon, a document was marked by Mr.
6 Walker, Hearing Officer, as Exhibit No. 4.)
7 MR. RICHARD WRUBLIK: This report happens
8 to be on the law that you're not supposed to dump
9 certain things in the landfill out in Rainbow
10 Valley .
11 Well, it was dumped there -- stuff
12 against it, restrictions -- it just was lucky that
13 the driver pulled over on the side of the bridge
14 there, and it wasn't on the bridge, it was just
15 near the bridge.
16 ! But, the people in Rainbow Valley, anytime
17 anybody pulls off the road people will check it
18 out, they care about their fellow neighbor out
19 there .
20 And it was just lucky that they did stop
21 because that man was in serious condition from
22 taking, breathing the fumes from this hazardous
they were
23 material, and/able to call the emergency units and
24 get him in the hospital so he didn't die.
25 Now, the point I'm after here is that
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this is the stuff that's on the books, but it's
not being enforced.
We're very much concerned out in that
area because there's very serious dangers out
there in the soil that we have. The soil that
they're going to put this stuff at does not absorb
hazardous waste very well. It is very loose and
will flow through very quickly.
There is nothing in this environmental
report -- and we know there is a danger in it --
is that when you store cans under the ground, that
soil has got a lot of chemicals in it and can
react very violently to certain containers. Those
containers also have liquid, and when you get
underneath there you're going to have a lot of
heat in the summer after awhile and they will
activate that dirt.
Nothing has been done, and over a period
of years we're not saying if it's going to break
through, we know it's going to break through.
With the work that's being done we're very much
concerned it's going to-break through and won't go
down, and with the lack of money the Health
Department has, we're very much scared that that
will go down into our water.
Release of contaminants into the
subsurface soil is discussed in
Section IV, Ground Water.
See previous comment.
If potentially harmful levels of
contaminants are detected in
ground water beneath the facility,
the facility owner or operator
must take corrective action as
discussed in Section IV, Ground
Water. The facility contractor,
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Now the people in this report said that
the, it's about 400 feet of water there, but
twenty miles away it's ten feet, on a direct line
to Waterman's Wash (phonetic), comes straight on
through there into Rainbow Valley, and it gets
down to ten feet. I don't know if the Department
of Health knew that. Ten feet is all the water is,
not 500.
It is very easy to contaminate our water
in different ways, and that's why we're so scared
about it.
Right now the next one I want to raise is
a
-t-h-e- very important one, I think, to the public.
What was the purpose of the hazardous waste site?
Why do we even want one in the State of Arizona?
The purpose of it was, is to help the
companies that produce it so they'd have a place
of disposing of it cheaply, so that they will
attract more people to Arizona. I think that was
the purpose of the hazardous waste site, and also
stop the dumping of it out in the desert, cause we
didn't have a place.
Well, the truth of the matter is this;
the way they were approaching it with this Mobile
site, we are not going to solve the problem.
as operator of the facility,
would be responsible for
corrective actions at the
proposed Arizona facility.
Ground water depths in the Rainbow
Valley area are discussed in
Section IV, Ground Water.
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because if that hazardous site has to pay for
those roads at twenty miles and they have to put
up $20,000,000 just for that alone, the companies
know that if their price is too high that they are
bidding on this thing, that's why they are having
trouble bidding on it, if they know it's too high
the company that produces the waste has two
choices. No. 1 choice; he has a choice of hauling
it out of the state, like he's been doing, and the
second thing is; he can find it, put it on -- find
a way of handling it on location.
So, what happens here in this hazardous
waste site if they did chose Harquahala, or
g
Ranefras Plains, they wouldn't have to pay the
cost of the roads over there. You can almost put
in a private road, cause it's only three to six
miles.
New, that's iirportant to the customer.
/ And I am a customer for hazardous waste
because I'm a farmer
sites/and we have certain things that we are
supposed to take to the hazardous waste site; the
cans that have pesticide, and things in there that
need to be disposed of.
Now, what happens then is this; if we had
to pay for those roads, an-d we do not have,
according to their own report, there does not
The cost of paving the access
roads is discussed in Section IV,
Public Health and Safety: Spill
Risks, under "Risks from Trans-
porting Hazardous Waste." The
road improvement costs to the
facility contractor would be
similar, since the Western Har-
quahala Plain site would require
that approximately five miles of
a gravel road be improved and
the Ranegras Plain site would
require that approximately six
miles of existing road be
improved. Use of public funds
would not be anticipated at
these two sites.
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appear to be enough hazardous waste in the state,
the cost is going to be prohibitive. Therefore,
it would be a lot better and a lot cheaper to go
and put the hazardous site by Ranegras Plains and
Harquahala, which
for
?he Department of Health recommended/two
reasons; the cost is less to get the site on line.
No. 2; we are close to the biggest market in the
United States, and that's California. If we can
get part of the California waste to come in, the
company that's putting up the site can make money
and also charge the customers in Arizona a lower
rate at the same time, which is the purpose of the
whole thing .
The purpose of this thing was not to
provide this oil refinery with a big tax savings
and a dollar savings. That is what we're really
dealing with.
Another problem I want to talk about is --
let's see, I got one more document I wanted to put
into evidence here, make sure it gets in.
MR. MATTHEW WALKER: Thank you.
This is on the letterhead of the Arizona
State University Department of psychology, dated
February 8th, 1983. It is addressed; "Dear
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Resident". It is signed; "Kenneth M. Bachrach,
M.A.", and the letter is one page and there is a
one, two, three, four, five-page attachment to it.
It will be marked Exhibit No. 5 for the
purposes of this idcord.
(Thereupon, a document was marked by Mr.
Walker, Hearing Officer, as Exhibit No. 5.)
MR. MATTHEW: WALKER: Go ahead, sir.
MR. RICHARD WRUBLIK: Okay. This report
lays out the way that people feel in Rainbow
Valley, where the site is going. They feel that
the site was chosen politically, they feel it was
refinery's benefit
chosen for the -r-e-Ł i noe iea, it was not taken at all
into consideration for their benefit or the people
of Phoenix, or the State of Arizona, and I think
this report will lay it out.
I don't want to spend all the time going
over that report.
Another exhibit I'd like to put in is —
MR. MATTHEW WALKER: Thank you, sir.
This is on the letterhead of the Maricopa
County Democrats, Jennie P. Cox, Chairman. It is
dated January 29th, 1981.
Is that the right date?
MR. RICHARD RUBLIK: Yes.
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1 I MR. MATTHEW WALKER: Signed; " J e n n i e -Go*-,
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2 ! -f-o-* Jennie P. Cox, Chairman" and there is a one-oage
3 at tachment.
4 That will be marked Exhibit No. 6 for the
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6 (Thereupon, a document was marked by Mr.
7 Matthew Walker, Hearing Officer, as -Oepoa i t ion
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8 Exhibit No. t.)
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9 I MR. RICHARD WRUBLIK: I'm not a Democrat
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10 j or a Republican, I'm an I ndependant, and I think
11 you can see why I'm standing here. I believe in
12 I saying what I believe in, and I don't want to go
13 with one party or the other, but I think the
14 purpose of this report is that the people that
15 know the facts know that the hazardous waste site
16 in Mobile is wrong.
17 The answer is so simple that it's hard to
18 believe that we're here talking about it. I can
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19 j take a ten-year-old child, a ten-year-old child,
20 and he would make a decision in ten seconds as to
21 where to put it.
22 If you have a choice of putting a
23 hazardous waste site twenty-five miles from a
24 metropolitan area, or seventy-five miles from a
25 metropolitan area, which would you do?
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We know that this material is dangerous,
they don't know a lot of things about what is
going to happen out there. Why make the decision
at twenty-five miles when you've got a choice of
seventy-five miles, at all?
He doesn't even have to, he would know
that you'd rather build three to six miles of road,
rather than twenty. I don't see where it takes
any big brains to see that the Mobile site is
wrong .
I also want to put in evidence this
d ocument.
MR. MATTHEW WALKER: Thank you.
Excuse me. Just wait a minute, until I
identify this.
This is a three-page document and it
seems to be a collection of several clippings and
this headline; "Do you live in Arizona, do you
know what is going on?" And then there's one
hazardous waste -- there is a clipping from the
Associated Press; "Senate Panel clears Usdane of
wrongdoing in taking fee." And then there is
another clipping I can't identify, Columbus
D i spa tch Sun?
MR. RICHARD WRUBLIK: It's in Ohio, I
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2 | MR. MATTHEW WALKER: Three pages, and it
3 will be marked as Exhibit 7 for the purposes of
4 this record.
5 (Thereupon, a document was marked by Mr.
6 Matthew Walker, Hearing Officer, as Exhibit No. 7.)
7 MR. MATTHEW WALKER: Go ahead, sir.
8 ! MR. RICHARD WROBLIK: Okay. The whole
9 point I'm trying to make here is that I'm not
10 j against the hazardous waste site. I do believe,
11 ! though, that the health of the people in the
12 Metropolitan area should be considered, I do
13 believe that the economics should be considered, I
14 do believe that in order to have a cheap waste,
15 have a good waste site we're going to have to get
16 more hazardous waste, whether we like it or not.
17 If we move to the Harquahala site it
18 saves 150 miles coming in from California, almost
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19 200 miles, it's that much closer, almost 200 miles
20 if you go to the Harquahala/Ranegras Plains site.
21 I'm hoping, and I know the Department of
22 Health shares this feeling with me, they have said
23 unofficially, which I'm not going to quote any of
not
24 them who have said it, they would n-o-t- r a t her/ ha ve
25 the hazardous waste site go in with the storage
Differences in the cost of
transporting hazardous wastes
and PCBs are discussed in the
response to written comment
no. W-28. Shipping costs for
waste generated within Arizona
would be considerably lower
for the Mobile site than the
other two sites. Total
shipping costs for PCB waste
shipments would be somewhat
lower for the alternative
sites than for the Mobile site.
The overall shipping costs
considering both within-state
shipments and PCB shipments
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stuff fledged facility
and pond *-i_t-e-, they want a fu 11 —«ve-r-g»e-d—s-t-t-e- that
handles the waste properly and disposes of it, so
that we don't worry -- using the electrical system
of breaking breaking
-a-iv4--bj;«i-)e-nig- it down, and really Ja-r.fr It i-ivg- it down
and recycli ng it.
This is the feelings of your own Health
Department, unofficial feeling.
This type of hazardous waste site that
they are proposing is a joke, they don't like it,
they will have to eat it, and they will do the
best job they can with no money, like they have
been doing all along.
But, I do believe that from an economic
standpoint and from a health standpoint that
Valley Fever out in Rainbow Valley, Mobile and
Rainbow Valley, is one of the most dangerous parts
in the United States, it's a hot spot. When you
go out and dig up the soil and do different things
with it, it activates the spores, and when the
heavy winds come in, they do come down and go
across Phoenix, they come in on the south,
northeast, come in that way, and come up and go
northeast, which means that people in Sun City --
the people in Avondale and Goodyear were not
notified either, and they are right in the path.
would be lower for the Mobile
site. The costs of shipping
hazardous waste (other than
PCBs) from out-of-state
sources cannot be estimated
for reasons discussed in
Appendix C of the Draft EIS
(DEIS p. C-5). Of course,
shipping costs are only one
factor that could affect whether
the facility has enough business
from waste generators to remain
economically viable. Differences
in the disposal fees charged by
facilities in the region, for
example, could also be an
important factor. Other aspects
of the economics involved in
siting a facility at the various
potential sites were addressed
in the ADHS siting study (1).
A discussion of Valley Fever
appears in Section IV.
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twenty-five miles away, too. They were not
notified. Why don't they have a special meeting
for them?
So, I don't believe that the people's
health has been really addressed in this whole
situation, nor have the economics of it.
Now, you think I'm kidding you, you think
that -- I've heard words from both Provident
Energy, and from, you know, some of the people
that know some of the bidders, and they say they
can't afford to put that twenty miles of road in.
That costs a lot of money.
The only way it's going to happen is if
you and I go and stick our money in our pockets,
and through Pinal and Maricopa, and bail them out.
They don't need that, we don't need
Provident Evergy that bad to bail them out for
that kind of money. We ought to face the reality
and let the people of Phoenix know the truth, the.
health hazard, and let them know how close it is.
If you ask their if it was twenty-five or
thirty-five, they would yell, and they said
sixty-five, and they go clear around the mountain
and they come up with sixty-five miles, but I tell
you, spores coming in from Valley Fever don't go
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around the sixty-five miles, they go the
twenty-five and thirty miles.
That's all I have to say.
MR. MATTHEW WALKER: Thank you, sir.
I have one more thing to do.
I have now a copy of the Notice of this
Meeting that was sent out in the mail, which was a
little different than the one that was published,
and I'll add this to the record and mark this as
Exhibit 8.
(Thereupon, a document was marked by Mr.
Matthew Walker, Hearing Officer, as Exhibit No. 8.)
MR. MATTHEW WALKER: Yes, sir?
MR. RAYMOND ADAMS: I did not speak, but
I could say one more thing, if I may.
MR. MATTHEW WALKER: Did you fill out a
card?
name ?
MR. RAYMOND ADAMS: I filled out a card.
MR. MATTHEW WALKER: So, we have your
MR. RAYMOND ADAMS: Yes, sir.
MR. MATTHEW WALKER: Yes, sir. Do you
want to come up to the microphone?
MR. RAYMOND ADAMS: My name is Raymond
Adams .
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MR. MATTHEW WALKER: Oo we have Mr.
Adams' card?
Thank you. Go ahead, Mr. Adams.
MR. RAYMOND ADAMS : Thank you, sir.
I live west of Maricopa, just a little
bit south of the Maricopa -- they call it here the
Maricopa County/Gila Bend Highway, if you want to
call that dirt road that's half-time underwater,
highway -- but anyway, he made a very good speech;
the other gentleman did. I think he brought up
many many good points.
I would like to say one thing about the
Harquahala. I've been noticing on the maps that's
in the book here, the site is less than just a
very few miles from the Arizona CAP canal, the
canal is going to carry water into Phoenix.
MR. MATTHEW WALKER: I just want to point
the microphone near you.
MR. RAYMOND ADAMS: Thank you.
The CAP Arizona Canal is just going to be
a few miles from the Harquahala site.
I've been to the, two of the meetings in
Mobile, and to this one here. I've never heard
yet anybody, any of them spoke of the hundred-year
floods, and they had the hundred-year tornados.
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We also might say we have hundred-year earthquakes,
which probably come sometime in the next fifty,
maybe 100 years.
But, these things do happen. We never
know when^ whan this short distance from here to
there, even though the map shows that the water
flows the opposite way, fissures do come into the
earth from earthquakes and stuff.
At that point if that should be decided,
and not down to the Ranegras Plain, which I agree
would be a good site for it, those fissures or
whatever could possibly in years to come maybe
crack the earth or some way dump this waste site
that's just stored, not reprocessed but just
stored, into and seep into the Arizona Canal,
which is going to be the water supply for Phoenix
in the coming years. And they may have to depend
upon a lot of that water if the groundwater gets
bad and they have a water problem in Phoenix, and
Scottsdale, and Glendale, and all. And it could
be the Western Harquahala site so close to the CAP
Canal, under some freakish nature thing, could
become dangerous and hazardous.
I think the other site should be
considered more than the Harquahala site, even
A discussion of seismicity appears
in Section IV, Physical Setting.
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because of that one reason.
And I'd like for just to bring it up as a
suggestion in the final consideration for where
they're going to put a hazardous waste site.
Thank you .
MR. MATTHEW WALKER: Thank you, sir.
I do not now have before me any cards of
people who checked off that they wish to make a
statement.
Is anybody here who did check the box
saying they wish to make a statement and for some
reason that card has not reached us?
I see no one ar i se .
Has anyone changed his mind and is now
inspired and wishes to talk to the Panel?
I see no one arise.
Very well then, I guess we've come to
that part of this Hearing, and we will recess this
Public Hearing to 7:30 p.m. today, where it will
be reconvened in the Buckeye Elementary School
cafeteria, 210 South Sixth Street, in Buckeye.
That will be a continuation of this
Hearing, not a separate Hearing. It is not
necessary to go to Buckeye and repeat what has
been said here this afternoon, at this morning.
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It will all be part -of one record, and will be
reviewed and acted upon as a unit.
And with those comments, unless somebody
else wishes to address the record, or the Panel, I
thank you all for coming, and please have a good
day .
If there's anybody here who wishes to
engage in an informal question and answer session,
there are members of the Environmental Protection
Agency here who will be available for that purpose,
As I mentioned, however, that will not be a part
of the formal record.
(Whereupon, the proceedings were recessed
at 10:35 o'clock a.m..)
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STATE OF ARIZONA )
COUNTY OF MARICOPA ) SS.
BE IT KNOWN that the foregoing Hearing
was taken before me, ANDREA HEAVER, a Notary
Public in and for the County of Maricopa, State of
Arizona; that the proceedings thereto were taken
down by me in shorthand and thereafter reduced to
typewriting under ray direction; that the foregoing
35 pages are a true and correct transcript of all
proceedings had upon the taking of said Hearing,
all done to the best of my skill and ability.
I FURTHER CERTIFY that I am in no way
related to any of the parties hereto nor am I in
any way interested in the outcome hereof.
DATED at Phoenix, Arizona, this JJj_^. daM
of March, 1983.
ATn cfr'e a Weaver
My commission expires:
August 31, 1984.
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A Public Hearing to Consider:
DRAFT OF AN ENVIRONMENTAL IMPACT STATEMENT
For the Arizona Hazardous Waste Facility
Conducted by: The D.S. Environmental Protection
Agency, Region IX, San Francisco,
California
Buckeye, Arizona
March 1, 1933
7:30 p.ra.
MR. MATTHEW S. WALKER, Donna Robars, RPR
Hearing Officer Court Recorter
COPY
M. L. SPICER ft ASSOCIATES
377-5634
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Pago
Opening Statement by Mr. Matthew S. Walker 3
PRESENTATIONS:
Mr. Richard Wrublik 3
Mr. Bill Gillard 21
Ms. Ruth Kephart 26
Mr. Harry Larison 28
Mr. Frank Thornton 32
EXHI_3_I_T_S_
Number 9 - Document 21
Number 10 - Article, Phoenix Gazette, 2-14-83 . . 24
number 11 - flap and Document 33
1_. SP1CER a ASSOCIATES
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1 : The Public Hearing en the matter of a Drift of
2 j liKvircnmental Impact Statanent, Arizona Hazardous Waste
3 ! Facility, conducted by the U.S. Environmental Protection
j
* | Agency, Region IX, San Francisco, California, commenced at
i
7:30 o'clock p.m. on March 1, 1983, at the Buckeye Elementary
School Cafeteria, 210 South 6th Street, Buckeye, Arizona,
before Donna Pobare, RPR, a Court Reporter and Notary Public
in and for the County of Maricopa, State of Arizona.
The hearing was conducted by the Hearing Officer:
Mr. Matthew S. Walker
EPA, Region IX, San Francisco, California
The proceedings follow:
MR. WALKER: Good evening, ladies and gentlemen. >7e
will convene this public hearing. This is a continuation
of the first part of this public hearing that was convened
first in the offices of the Department of Health Services
this afternoon. At that time we had the initial session,
and this is a continuation of it. It is part of the =air.e
hearing.
My name is Matthew -'alker, and I have been
designated to act as presiding officer for this hearing bv
Administrator
the Regional -ftatnirtiu'fc«ti«R- of the Environmental crotection
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23 ' Agency. This is 3. public hearing convened to consider the
M. L. SPICER Sc ASSOCIATES
PHOeNIX ARIZONA
277 S66U
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Draft Znvircnr.entai Ii?.-??.ct Sr:at=r=:it for Arirc.-ia ::a = ardouo
Waste facility,
You have a copy of it here. There ara son« copies
of it in the back of the room. This cooy has been marked
in this afternoon's session for purposes of this record.
Some other exhibits were also marked and introduced at the
session this afternoon. I won't go into then this evening.
If you have a need to know about there, come up during a
recess later on, and you may examine them. They are part
of a public record.
With me this evening, too, from tha Environmental
Bobel
Protection Agency is Mr. Phil Bofeii, who is Chief of the
Toxic and Waste Management Section, Toxic and Waste
Management Branch of the Air and Hazardous Materials
Division of EPA, Region IX. Also here, is ?lr. Chuck Flipoo,
who is the Environmental Impact Project Officer for the
Arizona Hazardous Waste Facility. There are also in this
room representatives of the Arizona Department of Health
Services.
We are making a record of this hearing. A steno-
graphic record was made of the hearing this afternoon. It
is being continued this evening.
It is necessary if you are going to address us that
you register on one of these little cards, available st tha
door, and checX the little box that says "I wish to pake a
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I • ata-cemeni:. 15 ycu :io, cli.-ic oarc wj.ll be brcuaht for./.j-'i co
2 j the front of the room and people vill be called upon in the
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3 i order in which the cards are received. We also require that
•* ! you come UD and use the nicrophone. Tell us your name. If
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5 j you are here in a representative capacity, tell us about
6 ! that. We are not able to make a proper record if people are
7 j speaking fron the> wdienca.
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8 . Notices of this -public hearing were published in the
9 Arizona Republic and in the Phoenix Gazette on the 14th of
'0 January of this year, and colic's of those notices are in
" ' the record.
12
The orocsdure that vill bo followed is this. We
13 ! will hear from the people who have registered. After that
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there will be a very short recess and there will be a
question-and-answer session in an informal manner. Members
of the staff are hera for that purpose. The question-anc-
I answer session will not be a part of the official formal
18 i and administrative record. This is for your information.
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19 j If you wish to have any specific rar.arXs nade a part of the
20 | record, it is necessary that you should core forward, use
21 the microphone and get them on the record in that way.
22 ! written statements nay be received, and they will be given
23 ! exactly the sane weight ar.d the same attention as oral
.. j
i statements made at the mi'croohone.
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25 I A VOICH: How long are we going to keep the record open?
M. L. SPICER a ASSOCIATES
PHOENIX. ARIZONA
277 5664
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MR. WALKER: The 14th of March.
So if you have second thoughts, third thoughts — if
you wish to make any written comments and you are 3hy about
getting up in public or for whatever reasons or if you want
to make additional comments on this project, you may send
them in writing to the Environmental Protection Agency Region
9, 215 Fremont Street, San Francisco California 94105. They
should be marked to the attention of Mr. Chuck Flippo, and
his mail code is T-2. That isn't essential, but it will
help get it to the right desk if you put that on the
envelope.
After the comment period is closed and after the
record of this hearing has been prepared, the process for
decision is this. A number of people will write briefing
documents, summaries of the records, and eventually a final
environmental impact statement will be prepared. That
environmental statement, as it is finally prepared, is the
work of many people. It is possibly sic.ied by the regional
administrator, but she is not the one that does all of the
work, and all the decision-making issues under her name.
Public notice will be given of the issuance of the final
draft of the environmental statement.
And these who have registered a check on the box
"I wish to be placed on the mailing list," they will be
notified by mail of that event. And you will have an
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opportunity to see what the rasulto cf this process nay be.
It is not a foregone conclusion t.nat the final statement
will be exactly the same as the draft statement. I know
there is a popular idea to that effact, that these hearings
accomplish no purpose except to get people out in the
country, but it has been my personal observation on quite a
number of occasions the comments received at public hearings
do, indeed, have an effect and do sometimes change the final
project.
Now that is all of the original comments, or
preliminary comments, that I wish to make. The remarks here
are being taken down in shorthand by a certified shorthand
reporter, Ms. Donna Robare of the firm of M.L. Spicer and
Associates. Ultimately, a copy of the transcript will be
in the regional office for public inspection if you wish to
see what was said. If you have need of a copy for your own
use in something less than several weeks, you should make
individual arrangements with the reporter who is an
independent contractor.
And now I will call on the first person to speak,
j Mr. Harry Larison.
! MR. LARISON: Sir, I have been out of touch with the
latest goings-on. If Mr. Gillard and Mr. Krublik would like
j to speak before me, I'd appreciate it.
MR. WALKER: Mr. Wrublik.
M. L. SPICER 3r ASSOCIATES
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277 3664
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Mr. Carlson, aii I pronounce your nam.e ritiht?
MR. IARISOII: Y9S.
MR. WALKER: All right. Mr. Wrublik, the microphone
is yours .
MR. WRUBLIK: Well, last time in Mobile we talked to
you about the fact that you don't put good notices out. It
had no reaction on you whatsoever, we should have done it
ourselves, but I was busy on another project and couldn't
do it. And I take this as a crime. You put out a notice
on January 14th of a meeting on March 1st. What are you
talking about? What kind of idiocy calls that proper notice?
KR. WALKER: Let ce interject here we are bound by
certain regulations and we are required to give that notice
that far ahead of time.
MR. WRUBLIK: We asked at the last neeting in Mobile —
we asked and were led to believe by your representative (jo)
that additional notice would take place before this meeting .
It was not done. I don't like that. I'm not talking about
your legal — we were led to believe that you were going to
try and improve your nctif ication. Why didn't you tell us
you were not going to do it? Has the cat got your tongues?
Are you babies?
MR. WALKER: Why don't you just tall us your problem.
MR. WRUBLIK: I'm telling you rny problems, I'm trying
to get across a point of why apathy takes place. There
Additional notice appeared in the (
Buckeye Valley News of February 24,
1983, as a result of press releases
sent out by EPA (see Appendix G).
The press releases were the addi-
tional notice EPA's representative
was referring to at the Mobile
meeting.
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•ir-in1 i a lot of -2cr:l2 h:;r^ because of the way you guys
operate. Someone asked me to raake soir.e comments that can't
be here. You go through this very nice formal approach.
You set up a citizens' advisory committee, you set it up
and they went through and recommended a particular point of
that be
view -04- the EIS -teha-t-prepared for both the land transfer
and the facility involved. Everybody agreed. What happens?
They are never called back together again; never called back
to tell them "Drop dead. Thank you.' or nothing. No
transfer, no carry-through. What do you think people think?
They are being usad. That's what they think. And that's
Follow the law, ves.
what you're doing is using them. ,/I can't blame you. You
probably can't do a thing about it. Ts it right? Mo, it's
not. It's a farce, and that's what the whole thing is about.
And we have a report in here. These people want to
know. There was a specialist from the university come down
and did an emotional impact study on the people of Sainfcow
Valley- The people of Rainbow Valley have had so many
fignts, trying to get a break, trying to stop the annexation
of Avondale, so it gets tiresome fic-hting that political
crap, following the rules that you make and doing what you
want with us.
So I do want to make i point. I don't think when
you set up a citizens' advisory committee — when their
recommendation is put through, they should have been called
M. L. SPICER * ASSOCIATES
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u?cr. for further consultation. Khy was the recommendation
of tha citizens' advisory coranittee dona? The simple fact
is this: The E??i they have a quote from the particular
section where your people recommended an environmental
study be done on site transfer and facility. They
recommended it themselves. It wasn't done. Why? The
Department of Health Services in Arizona for the same
reason they had trouble with the original thing, nobody —
they do not have a recommended site. How can you make an
EIS on something that doesn't exist? It's a complete hoax.
The leoislators made made
-feefeJ-6— gjjct mako-a recommendation and «»J%e-a decision
on site location based on the assumption that they
represented a false one. How close it vas to Phoenix was
false. And what type of facility was going to be there.
I haven't found anybody yet that would object to the
but
hazardous waste site that was not promised,/indicated in
their presentation, not promised. I'm clarifying that they
didn't lie, but it was misleading as heck.
What did they show us? They show us pictures of
beautiful incinerators to take all this hazardous waste and
put it in a little can. That's what they showed the
but
legislature, ->»M?ei* when they ask you what do you recommend;
not a darn thing was presented, not a facility at all. Why?
We have a right to know why that wasn't done.
The BLM recommended,they were involved with this,
The focus of the EIS is the site
transfer rather than the specific
design of the facility, for
reasons presented in Section I.
To the extent that we are able
to discuss typical facility
designs and the potential impacts
that may be associated with such
"representative designs," we have
done so in this EIS.
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2 insisting that thay do an environmental ir.pact 'study for both
3 : the facility and the transfer. The guy involved got
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transferred. Raised too much hell; kicked him out of the
way, because he didn't want to do it. He said according —
they had a right to have this pushed aside. I think that
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8 | citizens' advisory committee kicked aside? Why does EPA
9 I themselves get kicked aside for their own recommendation?
Tno has that kind of power to take all three of the
ccTiittees and tell them, to go to hell? Who has that right?
Mow that's ar. environnental impact study on people's
feelings, and I think that we have a right to kr.ov. It
affects our thinking about our government and our people.
It does affect us, and I think we have a darn good right to
know who pulls those type of strings.
And if you don't believe it, we have people that
have bf»en at those meetings where this has been said and
j and
19 | what; has hap?ened,/chey wanted this brought out very clearly,
20 1 that tr.ere has been a violation in this area. Then you
21 I wonder why there's aoathy. Notification six weeks ahead.
22 j My C-od. If you were told something six weeks ahead so you
had to be some place and they buried it in the paper to
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start with, what chance in the world do you have of
remembering it. Even if they wanted to be here, they could
BLM is a "cooperating agency"
and has been a party to all major
decisions concerning the EIS.
As noted in the previous comment,
the reasons the EIS addresses
site transfer are stated in
Section I.
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t?-*3\' forget that. I chi.ik you'd havs 1:0 agroe wi^h chat
yourself, and what makes ne mad, people were there -it
X.obile on the 14th. We were led to believe they were
-oing to give additional notification -- maybe r.ot
promised, maybe I can't take you to court and sue you, but
we were definitely indicated that they would try to do
this.
Now they also want to go on record because they
want to be able to sue the devil out of you people, not
the EPA, bat they want to be able to sue the State. They
want to be able to sue the person running that facility.
What do they want to sue you for now? They want to let you
know, and they want this very clearly on notice, that there
are farms nearby and they are producing, and they will be
producing more,vegetables and other crops. If that residue
gets on there and anybody is affected, they want to be able
to sue you to kingdom come, because they feel you are
ignoring the situation. They say, and we have experts that
have said at the last meeting in Mobile that contaminants
will at certain times come off and be blown into the dssert
and blown long distances. Now what happens? They say
that they did the research. This is somebody's — they say
the prevailing winds are from the south to the east, which
means that within 30 miles you can hit Tempe, nest of
Phoenix, Chandler, Mesa, and all the resr. r,ov the-2
M. L. SPtCER a ASSOCIATES
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1 i sronns come up and they take these contaminants. And they
2 i want it on racord that one of the people is an expert from
3 i your own field, and he says this can haopen. I c wasn't
4 recorded that day, and if they have any question, we want
5 to make that person — that record. I don't know if he
back
6 had the record here to p4«k- it up, but they have said, from
7 I an expert in their own field, that a contamination can and
8 I will be picked up to some degree and be thrown into the air.
9 When that contamination comes down and causes damages, we
10 want to be able to sue you because we are aware of your
11 carelessness — and I'm not talking about the EPA. I'm
12 talking about the State. I'm talking about Babbitt. I'm
13 talking about the legislators. And I'm talking about the
14 person that's going to operate this facility. And I want
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15 it on the record very clear that we're putting them on
14 notice, and we want to be able to sue them. And they better
17 have a lot of coverage.
18 NOW that is important. Mow that contamination —
" I think you think it's very funny — that contamination, if
20 it goes over, is croing to land on crops, in schoolyards,/!
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21 in pools. Mow maybe in some cases it will do no damage or
22 you can't tell, but I want to put you on notice that this
23 is going to happen. How much damage we don't know, but we
24 ]' want the people to know that are in the government what is
going on.
H. L. SPICER a ASSOCIATES
277-3664
The potential for contamination
of lands on and around a hazardous
waste facility is addressed
through the permit process, as
discussed in Sections IV and V
of this document. See Section IV,
Air Quality, for a discussion
of the spread of airborne
contaminants.
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one to every legislator, both in the Senate and the House.
I dor.' t want to co~e around to election time. If something
happens, I want to be able to go out to each one of those
let the oeoole en is in the city of
?ho»r.ix down at 51st Avenue and Van Buren. That's how
close C5 miles is, teliave it or nob. "euld you believe
thar the caoitol is almost as close =3 right hers. rho
people down there Jon't knew they're sitting on the thing
tco.
Oh, I knov one thing I wanted -- it was not
addressed to the environmental inpact statement — if you
look =t the lavci.it of the city of Phoenix, you •••ill see
^^3-t -here are reservations stcori.ng the crrowth to the
south, and rhera is a mountain -here and a reservation 3nc
sone laid-out ground -- not it id out in th? s?nse the
Also there
.:=mers use in, but it's owned by the covernnent /in
the
Scottsdala/ -Ą•«•,»-reservation sroos you there out to the
north to the mountains almost, so 355 soon as that freeway
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1 > is done, you are going to see a tremendous raovener.t out to
2 j the west whether the people in Buckeye or Rainbow Valley/If
3 j like it or not. They are going to cone that way. We have"
4 a beautiful bridge going across Rainbow Vallev. which we
5 appreciate, and I guess they're going to release water
6 again, so we do appreciate that bridge, but with that
7 bridge, we also knew we're going to get additional people
8 | moving down the road as soon as that highway's finished,
9 and you're going to find that Rainbow Valley can't afford
10 to farm because the water cost is tco high. There's
orice of the
11 10,000 acres out there. The/land is going to be reasonable ;
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12 How what's going to happen? we start a community
13 out there in Rainbow Valley. You're going to have a lot of
14 people out there in Rainbow Valley five miles maximum from
15 this site. If those people get contaminated, they want to
16 be able to sue you. Now, if it's wrong, we want to sue
17 the State and the contractor on the site. Again, I think
1* we have the right to put you on notice of that. Isn't that
19 the purpose of this meeting? To put you on notice that
20 the thing can be dangerous? So the people involved rr.ake
21 the decision and they make them against statements like this,
H they have to pay the damages. Of course, that's ir. a court
23 of law. No telling what would happen there. I hope it's
in this envircnirental impact study
24 not as bad as what's happening to -th-i-a-cnviir-gftaeiMi—tn-
in relation
25 jrr-ir-nr-A^ co this hazardous waste deal.
The Draft EIS estimates projected
population within 5, 10, and 15
miles of the proposed Mobile site
(see DEIS pp. 3-27 and 3-28).
The 1-10 corridor, along which
westward expansion of suburban
Phoenix is concentrated, is about
25 miles north of the Mobile
site. The project which would
likely have the most direct
impact on development near Mobile
is the proposed Provident Energy
Company oil refinery; this
is addressed in the Draft EIS
(DEIS p. 3-27).
L. SPrCER & ASSOCIATES
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I tr.irA that tha ir.fcrr.aticn contained in the SIS,
I think, is wrong. In the sense in regard to the roads
?clng out to Mobile there is going to be at least — I ,
think it's around 45 r.iles of narrow two-lane road to get
that to that site. Marrow two-lane roads are dangerous
with big trucks on them. The report there — they said
they thought it was more dangerous to go through the city
of Phoenix. It exposes more people. That's a conedy.
hazardous materials
Because ftjriaonn dust travel^ through there i thousand
times as often, and they Ł.re exposed to things r.cre
dangerous than hazardous waste all the time.
So the point I am getting at, within a few years
the freeway will be brought into -- it's alrost to 99th
now — within a. few years when this thing's operational —
within a few years — then you would have access to the
freeway all the way to the other sites, all the way four-
lane highways all the way to the site. You don't have to
get on a narrow road; don't have to go through the city
of Phoenix on a direct basis; much safer than the two-lane
road proposed here on this 45 miles.
This person wanted this answered. T-,"hy was che
selection done before the EI3 was done? >Thy do you choose
the site and then
decide to do the environmental impact study, have
it already finalized, put in the law. You can't change it.
You said I rrade a decision. Now you find a reason -o
See Section IV, Public Health
and Safety: Spill Risks, for a
discussion of two-lane roads.
Hazardous material transportation (J|f)
is addressed under "Risks of
Transporting Hazardous Waste" in
Section IV, Public Health and
Safety: Spill Risks.
The difference that completion of
1-10 would make on the transporta-
tion risk analysis is discussed
under "Risks of Transporting
Hazardous Waste," in Section IV,
Public Health and Safety:
Spill Risks.
See Section IV, Alternatives, for
an explanation of the how the
EIS process relates to the State's
site selection process.
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justify it. Whac fcyoe of — how ara t.eopla supposed to
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'nave respect for legislators when they do stuff like that?
Isn't the normal process tc find the facts. Then .-r.akc the
decision based on the facts? Here they make a decision and
T^sv
say now find me the facts. How can they justify that? X •
want that answered, which I probably won't get anyway.
Anyway, they asked for it.
They also want to put in here, which I think we've
done other times, why was the site chosen 25 miles from
Phoenix when they should have knovn the danger to Phoenix.
And the dust from the Valley Fever. '«e had a — at
the last nesting we had an expert in Valley Fever, and he
brought out very clearly it's very dangerous, and this
person wanted to know why. Why would they expose the
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entire Valley to Valley Fever at this location when the \1§.
other site wouldn't do it?
Why would they choose a site that in case an
accident happens, it's only one-twentieth as safa as the
site in the other — the other two sites. One takes -- was
it 10,000 years or 6,000 years for it to leak down and
cause any trouble; in one a couple hundred years, based on
their
= cts. And what are their facts worth? J. con t ,
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vhat tha vhcla region vac. Thay didn't tell what was in
this particular area at all. They've got things just
rp.ixad together chat may have no relationship to the site
at all, so they felt this is a horribls injustice. VThy
do people get discouraged with you people, and I'm talking
about people in the government.
You do represent Babbitt, don't you?
A VOICE: Yes, sir, I do.
MR. WROBLIX: I don't dislike the person, really, but I
do feel there is a problem here right now, and I think he
should have dona something about it. I really think that
Eabbitt should have done something about it. Ke was put on
notice by the people that elected hin, and the people that
are his lieutenants sent him a very clear message saying
what he was doing was wrong, and they didn't have the
courtesy to answer back to them.
to I right, Gillard?
MR. WALKER: Please, just address us in the record.
We'll get into trouble if we have this colloquy.
MR. WRUBLIK: I'd like to get you in a little bit of
trouble.
M?.. WALKER: You might have a —
MR. HRUELIK: I'm always in trouble. I got 13 kids,
and I'm always in trouble.
MR. WALKER: I believe that.
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>"?.. -vKL'BijI:'* They al^o vant^u co knov — I thiiil* •'*.
addressed this, but they want an jnsver to it, so I'll
put it in the record for them. Why //as the site 25 niles
from Phoenix selected instead of 30 miles a^ay? Why
didn't you put it in the Luke Air Force base where the \3y
which
gunnery range is, =aaa=nobody can get near, and it would be
We pushed that verv strong.
isolated and safs? /And we didn't get a good answer. We
really didn't get a good answer. Vie cushed that real hard.
Members — representatives of the committee really pushed
that facility.
We also know there was two sites in Yur.a, well-
recomraended, but some political null vas done to get it
out of that district. This whole thing smells. The vhcle
thing smells from one end to the other end. That's why
people get discouraged. It's a political maneuver, nothing
based on facts. Emotion.
I am going to have a hard time getting this into
the record. I'll try and do it. I can't hardly read their
writing.
"R. V7ALXER: ?ut the document itself in.
f!R. WRDBLIK: I don't know if they expected that to
happen. I think it covers primarily — I think I've
summarized it already. Maybe I can put it into the record,
but the point they are really trying to make in here, vhich
is one I think I've made to a degree, is that they felt the
M. L. SPICER 8c ASSOCIATES
277-566J
See Section IV, Alternatives,
for a discussion of additional
alternative sites.
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31^1 '.-.ad the capability of dcir.g 3 earn aood impact study
It is their own land. They would be interested in what
happens to it, and they have the interest to do a
thorough job. They wanted to do the job, but for political
reasons, the site selection was made before on a political
basis, and everybody knows that that's been around here.
After the political base was done, they did try — and I
will clear up what kind of a study they wanted, which was
a prooer facility and transfer statement. Then it went
over to the department of SIS, and they recommended that
the sane thing be dene.
And they got a different section here, 10 —
1501.2 3., so they've done their homework. The thing
they're trying to get at why does everybody reco:rmend,
frctn the citizens' committee to the scoping meetings to the
3LM to EPA themselves, they all recommend one thing, and it
doesn't get done. It's completely overpassed. Just com-
pletely ignored. Who is this almighty power? Is there a
god here doing this? We want to know who the cod is, so we
can bow down to him, I guess. So I guess I can't -- I
think it would be best to put it in there.
MS. WALKER: Let's put it in. We'll do the best we
can with it.
:m. "P.UBLIK: Okay. I think I've raised enough Cain
for tonight. I'll let somebody else have it.
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MR. WAiXEE: All right. Well, this is a handwritten
document, two sides, one piece of paper. And I will put
on the slicker that says this is Zxhibit 9 on the one side
of it, and we'll try to figure out later on what it's
supposed to communicate to us. And this will be Exhibit 9
for purposes of this record.
This will be your exhibit. I see no other names
on it.
MR. WRUBLIK: I know who gave it to me. Perry
(phonetic) gave it to me, but somebody else gave it to her.
MR. WALKER: Well, we can take it on that basis. I
just want to know who to identify it with. Okay, I'll
identify it with you.
Thank you, sir.
Mr. Bill Gillard.
MR. GILLARD: My name is Bill Gillard, and I'-3 like to
— the reason I'rr, here tonight is the same reason you guys
are here. You got a job to do. You are hoping we'll
hurry up and get it over with so we can all go home. This
is one of them things that's cut and dried, just like every
other meeting that goes on public notice. They covered it
pretty good.
I personally asked how come there wasn't really a
notice, a public notice from you people, from any agency,
that wasn't given to the Buckeye Valley News. The only
M. U. SPICER 3c ASSOCIATES
PHOENIX ARIZONA
277-3664
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1 ir. lorration we get -t-~ out ci th3 gccdr.cs
2 , editor, who did put an article abcut si:-: weeks ago in the
3 ; paper because he learned it fron people in the ''alley.
4 I And he had also run an article last week in the paper,
5 : which I called about, and he informed me he had already
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6 I written an article.
7 i And I will tell you the reason I'm here is trying
8 | to fight for the peoole out there in the Valley. I've been
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9 | fighting for a long time. And at that meeting out in
10 I Mobile. I can't believe how untrue sore of these statements
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11 are in this impact — in your draft here. Hooefully, that's
12 not the final one.
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13 Sir, what is your name again?
14 MR. V.'ALKE": Please talk to the panel. We're here,
!5 all of us, in a representative capacity.
16 MR. GILLARD: I brought up a fact that we do have
17 dust devils out there, and, believe it or not, the man
13 didn't even know what the dust devil was. I've seen these
19 dust devils as wide as two, three hundred feet travel four
20 i or five miles at a time. IThan I talked to him about them,
t
21 he couldn't believe that these dust devils could actually
22 j pick up liquids and transfer them over the area. He's
23 talking, well, sone 20 acres within a square nile, which
24 ] you people have been trying to recoirmend that the Bureau
25 of Land Management release to the State or sell to the
I
Dust devils are addressed in
Section IV, Air Quality.
M. l_. SPiCER & ASSOCIATES
RHOEM1X, ARIZONA
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1 Stat.2. Twenty acres is nothing. Vhat the hell you going
2 j to do when you start bringing this stuff in from other f\(-
,33,
states? like California? They are aoing to travel these
4 same routes that they say aren't safe to travel if they
5 put it out there in the Ranegras Plain or Harquahala
6 Valley.
"I I'm concerned because I don't think our people in
8 government really know what the heck's going on. I
9 personally, as Dick mentioned there, did ask the governor
10 through a resolution through the Maricopa County Democrats
11 that he veto this hazardous waste site after the legislature
12 had passed it, which was strictly political. Mr. Chris —
13 can't think of his last name — the representative of the
14 governor — was there at the last meeting and agreed with
'5 me. Sixteen out of the eighteen people on the committee
16 agreed with me that he should veto this, yet all I got from
17 the governor was a form letter saying I would give it some
'8 consideration. And I feel when you are giving consideration
19 you're getting something in return. I dcn't know what he
2" got in return.
21 i'm concerned because of the fact that even after
22 this goes in, there will be no monitoring or policing —
23 maybe monitoring, but no policing.
24 Dick mentioned going to court. I've set at the
25 governor's office, and he says, you know, who governs is
A discussion of transportation
risks appears in Section IV,
Public Health and Safety:
Spill Risks.
a. L. SPICER & ASSOCIATES
PHOENIX. ARIZONA
277-S664
ADHS would have primary responsi- (
bility for enforcing conditions of ^
the permit at the facility. ADHS
staff would regularly inspect the
facility, and report their findings
to EPA. EPA staff would accompany
the State's inspectors or do inde-
pendent inspections, as needed,
to ensure compliance with the
Federal requirements.
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1 : the judge;;, you /;ncr,,. You know. This is cut and driad
2 ! stuff.
3 i The City of Phoenix wants the restrictions eased.
4 I give this — hand you a copy of the newspaper
5 here. It shows where about a week ago they wanted to dump
6 more cyanide, cadmium, chromium, and copper — they want
I not but
7 ' to increase/the percentaae =«Ł the amount. I can understand
8 if there is a larger volume of people and they —
9 MR. WALKER: This document you have given me could you
10 identify it.
11 MR. GILLARD: It's out of the Phoenix Gazette, the
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12 I r.orning paper — I believe it's morning — that we had the
13 hearing out in Mobile on.
14 MR. WALKER: And what date would that be?
15 MR. GILLARD: Was that the 14th of February? I
16 | believe the 14th of February in the morning paper maybe.
17 i MR. WALKER: All right. And I will mark this, then,
18 as Exhibit 10 for the purposes of this record.
19 | MR. GILLARD: And so what they ended up saying is if
1
20 their lawyers feel that this is all right — not that's
21 right and what's wrong, but what is legal — they will
22 probably increase the percentage of stuff, poison, they car.
23 damp into the river. My God.
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24 ! I understand today something passed in the
25 legislature where it's going to help us, where they're only
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•:'oi/ij -o allow transoortation^
to be comma from Mobile.
I talked to Mr. Scott (phonetic)
3 | He was surprised. He said: "There's only one road into
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4 i here?" I said, "Hey, I came over the back road, and I
5 I Xnow of one ether one." And as this whole population
6 increases out here, there is going to be more roads. This
7 55 million bridge we got, they're not going to ?^v that
that's for you guys up there at Rainbow Valley. This is
thouch
9 going to be a legal route, and even/the legislature said (,]
10 they're only going to brina it throuah Maricopa Count-/.
11 That's wrong. Sonebcdy is going r~ tack another SDpnur.^nt
12 on another bill that nobody over sees iovTi th_-n5. Iz -.'ill
13 be cut and. dried again.
14 You gentlemen, I hope each dnd every one of you
15 when you go back use your common sense that God aave you
16 to not be persuaded by politics and not go on the inforria-
17 tion you got from somebody sitting »t a de = k and calling
18 somebody else and say this is what hardened five years ago.
19 The original amount I tnink that was set aside --
20 again, it's economics. !7hat can ---s sffcrd? 7ha first r,art I
21 they done, they went out there -- I t.-.ink the legislature
22 | allowed 310,000, which — what can y,-u buy for ?i:,003?
23 You can't ^ret a ria to go out thara *o drill core holes frr
24 that. And that's the only thing that's been done on that
I Senator
25 ! site, except maybe for/Usdane, who r.ay have flown across
Access routes to the Mobile site
are addressed under "Risks of
Transporting Hazardous Waste"
in Section IV, Public Health
and Safety: Spill Risks. The
Legislature's recent amendments
to the siting law effectively
preclude use of a north-south
access route over Tuthill bridge.
If the Legislature wished, it
could change this law to allow
or require use of a different
access route. Given the cost
of providing access to the site
via Tuthill bridge, however,
such a reversal of its recent
decision is unlikely.
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•z.-.ara and locked it ever. Mr. Burton ?arr rock a r?~l
fast trip. Made it in 30 minutes to travel 65 miles
And they're cut and dried.
I hope you guys do it -ind not be afraid of vcur
job and say this is what the hell it is, and let's face
facts. That's pretty much it. Thank you.
MR. WALKER: Thank you, Mr. Gillard.
Ruth Kephart.
MS. KEPHART: I'm Ruth Kephart.
First of all, I'd like to say this, that I thought
I had so much to say, but our Richard Wrublik pretty well
covered a lot of how so rrany of us out in Rainbow '/alloy
fael. He covered most areas.
I came in a few minutes late and I might have
nissed something, but I would just like to say that I feel
this is just another political maneuver as far as our
hazardous waste dump goes. Just like so many other things.
A good example would be our Perryville prison.
Now our federal government plus our state lec'isla-
tura they make a lot of really, really strict rules, jrd
they sound pretty good, but when it comes down to then
it's fine
deciding they want to do something, then -Ł'r.ey fin*?, a—idv- to
break their rules. I can't see any one of us going and
doing the things they do and get awav with it. I think it1-
We 11, go
really pathetic/out there and take a ride and see how clor.e
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tl'f> Triton is <-."! -h-» schools. There's a strict rule against
r_h?it.
Ajyyvay, I just wanted to say with the thousands of
acres of land that your federal government has and our ($(J
State owns, and there were, I believe it was ten sites
that were considered for this hazardous waste dump, why
bring it over here close to people, cattle, schools, our
crops. And there are a lot of hazards there.
And it seems our legislators could care less. I
mean it's a political thing. And they're going to do just
33 they doggone well olease like they always do, no matter
hew hard we fight.
I've talked to a lot of people cut in the Valley
there, ar.d cuite a fev had planned on coming tonight, but
they felt why bother, they're going to stick it on us.
This is it.
I really think you people ought to seriously think
of what you're doing to all of us out here. See, the
people cut in Sccttsdale like good old Usdane and a few
other people who have said on 'TV: Oh, it's rerfsctly safe.
The hell it's safe. It's so safe Usdane doesn't put it in
his backyard. He sticks it somewhere else, "hy out here?
Ke've got to live too. It's not like you have to put it
our here in the middle of everything. I'd really apcreciate
it if you oeople would just do some serious thinking,
M. L. SPICER a ASSOCIATES
J77-S664
The State siting report (1)
discusses the relative advantages
and disadvantages of the ten
sites studied in the "level
three" analysis (see the discus-
sion of alternative sites in
Section IV, Alternatives).
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1 i because we sure as heck don't want it out there. Thank you.
2 MR. WALKER: Thank you.
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3 I Harry Larison.
4 MR. LARISON: My name is Earry Larison, and I live at
5 20492 West Rainbow Trail, Little Rainbow. I've lived there
6 for over ten years now.
7 i &nd as has been mentioned before, many trials and
8 tribulations have encompassed our area, but none can match
9 the magnitude of what we are about to receive. I came here
10 tonight to learn a little about something, because I have
11 been lax in attending other functions. I thought there may
12 be something new, and I find we are rehashing the same old
13 story.
14 I am exceptionally displeased with the total lack
IS of community involvement tonight. But I am just over-
16 whelmed that no one in government, other than EPA is
17 represented here today — or tonight. Certainly I would
'8 have expected BLM or the Department of Health Services,
" at the very least.
20 7he issue that I would like to reiterate is one
2' that I brought up at the Senate Committee hearing at the
22 Capitol, chaired by Senator Usdane. And it is simply that
23 the committee sat there listening to the peoole that sooke
24 with absolute, total inconsideration. We in the audience
25 i were not permitted to smoke — and I am very uncomfortable
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there and chey srsoked and they jawed back and forth with
one another. Occasionally Senator Usdane vould pay
attention to a word hare or there that was being said by
the concerned citizanry. Senator Hal Runyan was so totally
inconsiderate and he was so totally lacking in etiquette
that he left the meeting — that he could not even say as
he left the meeting: Would you people axcuse me. I have
someplace else to go. He just plain got up and left. I
had the feeling before I came here tonight that this was
another ena of those situations, and I honestly believe I
was right. I do not feel that thars is a government agency
that is interested in the welfare of tha citizenry on any
topic — let alone the hazardous v.-aste dur?.
Sow having read Mark Shechard, when I regard quite
highly, in his final paragraph he said that hearings of
this nature are required by law. He said the past hearings
conducted for various purposes hereabouts have meant little
or nothing as far as local corr.ent^have been concerned. In
other words, the elected and appointed officials couldn't
care less. The campaign promises the ~ocn. When it cones
vou
time to deliver,/don't even listen to us. Public aoathy.
It's terrible.
I haven't covered anything here that night be of
a concern to the Environmental Protection Agency, but I
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277-3664
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"--3- '-rir.r -j~ ?, 7"->ir.t that I brought up to Senator Usdar.e.
'••^ich I think is quite; valid. "avinq lived in P-ainbow
Valley for ten years, I have been privileged to witness
exceptional 3torms in the south end of Sig Rainbow.
Whenever we have severe disturbances over the Baja
Peninsula and they come roaring over in lower portions of ('
the ^
Central Arizona, they come in over/Mar icooa/? come in over
Mobile right where that site is proposed. They will
whistle to the southeast and they encompass the areas of
Terape, Mesa, Phoenix proper, et cetera. I can s^st in my
yard and drink a cold beer and be in total sunshine and
vatch the damndest storms you ever saw in that particular
area.
I mentioned this to Senator Uscane. It was
brought up by Mr. Gillard, the ferocity of the dust devils.
Those of you that have not seen them I can absolutely tell
you they are fierce. In some cases, I have had their, pick
my chickens up and throw them out of the chicken yard. And
I came vary close to becoming hit with a child's wading
?.ool from the neighbor' s; after another one, I found a brand
new washtub in my yard. I don't know where it came from,
but it certainly cane through the air. Dust devils are
miniature tornadoes, and they do suck up dirt and debris.
They take up moisture, and they will deposit it wherever
the winds will take it.
M. i_. SPICER a ASSOCIATES
See Section IV, Air Quality, for
a discussion of high-wind storms.
Dust devils are addressed in
Section IV, Air Quality.
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With these points in rr.ind, it would certainly
appear to ma that persons of responsible positions would
look into this. At the present time — I hate to bring
this up since you're the only representative here, but we
are all vitally aware of the nasty mess Ann Gorsuch
is in. We are aware of the terrible situation of hazardous
waste dumps, and we are aware of the billions of dollars
it's going to coat us to clean up that mess. And we are
going to build a new one right here. This has to be a
laughable situation, ire— I- roasoa-.-
Acid rain . . .
/ We have TV documentaries out of Canada they don't
subversive or something
say it's/ — acid rain is
even want shown because they sa
real thing.
And I guess in closing I would like to make an
suggestion. Since I do live in Little Rainbow and I do
not have city facilities, I am required by law to care for
my own personal waste, so at ny expense I install a
septic system and care for my personal wastes. Had I not
done this, the law would have refused to permit me to Live
on the land. In other words, the law said to ire as a
private citizen, you create a waste so you take cars of it.
Is it too difficult to ask that if you manufacture and if
you produce as a byproduct of your manufacturing a
hazardous waste, that you should also have to neutralize it.
Why out the oroblera on us. Thank you.
See Section IV, Alternatives, for
a discussion of waste reduction.
M. L. SPICER 8. ASSOCIATES
277-3664
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VR. WALKS?: Thank you, Mr. Larison.
I have now come to that part of the evening where
I have no further cards before me requestina an opportunity
to address the panel. Is there anyone who has filled out
a card and checked the little box saying they wanted to
make a statement and for some reason the card has not
reached us.
A VOICE: I believe I did. Maybe I forgot to check
the box.
MS. WALKER: What is your nane, sir?
MR. THORNTON: Frank Thornton.
MR. WALKER: Do you wish to cor.e up here and use the
microphone? There should be a card there. We'll get your
card.
MR. THORNTON: My name is Frank — did I mark it?
MR. WALKER: Yes, you did, sir. We apologize.
MR. THORNTON: My name is Frank Thornton, and I live
y
souteest of Maricopa only seven or eight niles as the crow
would fly from the proposed dump site. This is not
important — this particular thing where I live is nor
important.
What I wish to bring before you peoole many of
these men have brought this subject up. I will touch on it
briefly in the things that I have to say.
I believe in the human race. I am interested in the
M. i_. SPICER 8c ASSOCIATES
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1 ' h'jrsar. race. The survival of the human race is very
2 ! important to me. I am part of that race.
3 ; We have been working with chemicals for a long
4 time that we should never have. These chemicals are much
5 too hazardous for the workers or anyone to work with, but
6 that is beside the point. We are working with them.
7 Now when a person has a very highly communicable
8 disease, what do they do? They put that person in
9 quarantine, separate that person so they will not cause a
10 disease to pass to other people. Now let's use that
11 reasoning in our dump sites. I think this would be a very
12 valid point.
13 Maricopa is a small rown; Mobile is a small town.
There's oecple living there. I would like to see a site
'5 selected somewhere in the state of Arizona. I know there's
16 sites that would meet this bill. Isolation is of the
17 ! utmost importance in this. I would like to see a location
18 somewhere in the state where a minimum of 30 miles to any
19 living humans. And the next criteria that is VST/ impor-
20 tant is rhe water underneath this location.
21 j Would like to find a place where it was as deep
22 as possible. If you could find a place where there wasn't
23 any water underneath the land, that would be a better
24 i place to put a dump. Water, as I understand it, travels
25 roughly three feet a year — and I'm not an expert in none
A. L. SPICER 8. ASSOCIATES
PHOENIX ARIZONA
277-5664
See Section IV, Alternatives,
for a discussion of additional
alternative sites and the siting
criteria used by ADHS in its
siting study (1).
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j i o^ cn^so C~e.i_d3, bu*o nhio Is vhtiT: I've been t.old. If tha
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in
4 that hazardous ?saterial will be undor our water supply.
5 The human race on this planet we all share this
6 planet together. We all live on it. Our air, our water
7 and our food is already contaminated. We don't need any
8 more contamination in these three categories. The human
9 race must have these three things to live. The water
10 supply has already got many contaminants in it. When have
1] any of you got a breath of good clean fresh air? >rhen
12 did you get that last breath? We are miserably failing.
\3 Technology has failed. It can put a man on the moon, but
14 it is not cleaning up our air. It is not cleaning up our
15 water. It is not giving us food that we should have to
16 eat.
17 This is what I'm interested in. The human race.
18 The s-urvival of — many of these men and women here have
19 children. Their children and their children's children
20 will not live long enough to get out of this dump site
21 that we are proposing.
22 The location of it is very important. I would love
23 to sit down with the senators, with the governor, with any
24 Of those responsible for it. These sites, all of then, I
25 I would like to set in and explain to them that their
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1 i faniily's health depends on it. All the human race dec=;nd=i
2 i on this. We have been working with too many chenicals -co
3 i long.
4 I was raised up in the Midwest, St. Louis, Missouri,
5 I to be exact. I have seen all the hazardous waste
6 material that a man needs to see in a lifetime dumped in
7 the Mississippi River. The manufacturers have no regard
8 for the human race. Anything to get rich and anything to
9 get rid of their highly toxic wastes. Dump it in the
10 river. And the next guy down the river, he has to
11 tolerate it. This I have seen. Manufacturers — the
12 chairman of the board, they don't care. These giant
13 corporations they don't care what happens as long as they
14 produce a product that will sell. Money is the name of the
15 game. They don't care what happens to the hazardous waste.
16 if a truck driver takes it out and dumps it on the
17 desert or takes it to the city dump and dumps it, they
18 could care less. They have no respect for human life.
" Their very children and their families are going to suffer
20 as all of us will. *!one of us are exempt.
21 I believe your name is Mr. Walker. True?
22 When did you breathe a good clean fresh breath of
23 air?
24 jjp^ WALKER: Well, just give us your comments. -ie
25 don't want to get into that. I'm here in a representative
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capacity so my personal views are not important.
.'I?.. THOPHTOS: Cfcay.
I live out in the desert by choice. I coulc1 live
most anywhere that I wish to, but I live there by choice.
I like it for its quiet. The air still is fairly good, and
at tiroes the pollution out of Phoenix comes out our way
and it is something else. Our eyes burn. You don't have
to guess whether we're being polluted or not. This
hazardous dump will only add to it unless all people work
together.
It's going to take patience, lots of patience with
the governor and with the senators, representatives, all
men in the government. It's going to take lots of patience,
but I don't think anything is cut and dried. When it
comes t.o the human line, it can always be altered. It can
be. It should be.
A site can be selected if all the people — I'm
disappointed. I was in hopes this evening this building
would be filled to overflowing with people concerned.
Evidently, they don't care for their health. I care for
mine, and I an interested in your health.
Isolation is the point that I would love to make.
Isolate this dump site to where it will not harm anyone,
any human life.
I thank you, Mr. Walker.
M. i_. SP1CER 8« ASSOCIATES
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MR. WALKER: Thank you, Mr. Thornton.
13 there anyone else who checkad the box on the
card saying they wished to make a statement and for some
reason we have not received the card?
I see no one arise.
Has anyone been inspired by the previous speakers
and has changed his or her mind and wishes to address the
panel who didn't check the box?
I see no one arise.
Very well, then. I think we have come to that part
of this hearing where the public part of the session will
be closed. As I stated earlier, the record will be kept:
open for written comments until the close of business on
the 14th of March, 1983. What day is the 14th of March?
That's Monday. Now this must be received in the regional
office at 215 Fremont Street, San Francisco, California
94105 by the close of business on that day. It will not
be sufficient to simply mail them on that day. They may
not then be included in the record. In order to do so, we
might have to reopen the whole subject, and it would result
in consequences that you might not care for. So if you
wish to have your remarks included in the written record,
be sure you get them to the regional office by the close
of business Monday the 14th of March, 1983.
After the record is closed, we have received the
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ccnTTEnts,
transcript, and we have reviewed all of the/briefina
documents will be prepared and submitted to the regional
administrator and to others for review, study, and final
decision. For those people who have check/the box saying
they wish to have their name placed on the mailing list
a notice will be sent to them of the final environmental
statement, impact statement, and at that time this
procedure will have been concluded. And with those remarks
I think we will conclude our public session here.
I have just received from Mr. Wrublik a second
copy of the map that he introduced this afternoon and which
was then marked as Exhibit 3. This one will be marked as
Exhibit 11 for the purposes of this record. And attached
to it is a four-page statement that appears to be xeroxed.
I wish to add my personal statement here. Although
the speakers were not numerous, they were eloquent, and
your comments have been considered and will be considered
further. I don't know what the final decision is going to
be. Some of you say that you do. I don't. I do know from
past experience that quite frequently these oublic hearings
do affect the final decision. This nay be the case this
time. If it is not, it is not because of any lack of
eloquence on your part. And it is not necessary that you
fill the hall in order to be eloquent. We appreciate your
statements. We appreciate your courtesy and the comments
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you have made to us.
Thank you very much and have a good evening.
(Thereupon, the proceedings were concluded at
8:50 p.m.)
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I, DONNA ROBARE, RPR, hereby certify that the
proceedings taken in the foregoing entitled matter are
contained fully and accurately in the shorthand record
nade by rae thereof, and that the foreooing 39 typewritten
paces constitute a full, true, and accurate transcript of
said shorthand record, all done to th2 bft = t of ny skill
and abilitv.
OATED this
cay of March, 19 S3.
Tcr.r.a Hob are
Court Reporter
SPICER a ASSOCIATES
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HEARING EXHIBITS
The following documents were submitted as exhibits at the
public hearing on the Draft EIS.
VI-169
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*l **><*•" REGION IX
215 Framont Street
14 JAN 1983 San Francisco, Ca. 94105
TO ALL CONCERNED PERSONS:
The Environmental Protection Agency (EPA), Region 9,
has prepared an Environmental Impact Statement (EIS) on the
proposed sale of federal land to the State of Arizona for
the purpose of developing a hazardous waste management facility.
The Arizona Department of Health Services (ADHS) proposes to
purchase a 1-square mile parcel of land near the community
or Mobile, Arizona, for the facility.
AVAILABILITY OF THE DEIS
The Draft Environmental Impact Statement (DEIS) has been
prepared in compliance with Section 102(2)(c) of the National
Environmental Policy Act. The DEIS will be available for
distribution to the public and other government agencies on
or about January 20, 1983. A summary of the DEIS will also
be available upon request. Persons wishing to review the
draft EIS or the summary should request a copy from:
0. S. Environmental Protection Agency
Region 9
ATTN: Chuck Flippo (T-2-1)
215 Fremont Street
San Francisco, CA 94105
You may also phone your request to EPA at (415) 974-8128 or
ADHS in Phoenix at (602) 255-1162. A limited number of
copies will also be available at a public meeting to be held
in Mobile (see below).
Copies of the DEIS will be available for public review
at EPA offices in San Francisco and Washington, D. C., as
well as at depository libraries and government agencies in
Arizona. A list of these libraries and agencies is attached.
POBLIC MEETING
EPA, in cooperation with the CJ. S. Bureau of Land
Management and ADHS, will hold a public meeting on Thursday,
February 17, 1983, so that interested persons may meet with
agency representatives to discuss the contents of the SIS
VI-170
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and answer questions about the document. The purpose of the
meeting is to present information rather than to receive
formal comments on the DEIS. Two public hearings have been
scheduled to receive oral and written public comments at a
later date (see below).
The public meeting will be held in the Mobile Elementary
School, 14 miles west of Maricopa on the Maricopa-Mobile
Road, between 7:30 and 9:30 p. m. The meeting will be in an
"open house" format. A short opening statement will be made
to summarize the contents of the EIS. Afterwards, persons
with specific concerns or questions will be able discuss them
individually with agency representatives.
PDBLIC HEARINGS
Public hearings on the Draft EIS will be held on Tuesday,
March 1, 1983, at these times and places:
9:30 a. m. Arizona Department of Health Services
Conference Rooms A and B, 4th Floor
1740 West Adams Street
Phoenix, Arizona
7:30 p. m. Buckeye Elementary School
Cafeteria
210 South 6th Street
Buckeye, Arizona
All persons are invited to express their views at these hearings
either orally or in writing. Oral statements should summarize
extensive written materials so that there will be time for
all interested persons to be heard.
Written comments may also be sent to EPA Region 9 at the
address given below. The Agency will receive written comments
for a period of 45 days after notice of the DEIS appears in
the Federal Register on or about January 28, 1983.
FOR FURTHER INFORMATION, CONTACT:
Chuck Flippo, Environmental Protection Agency, Region 9,
215 Fremont Street, San Francisco, CA 94105; (415) 974-8128
(Commercial); 454-8128 (FTS).
Attachment
VI-171
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DRAFT EIS
ARIZONA HAZARDOUS WASTE FACILITY
List of Depositories
0. S. Environmental Protection Agency
Region 9
Library/Information Center
San Francisco, CA 94105
0. S. Environmental Protection Agency
Public Reference Unit, Library
401 M Street SW, Room 2922
Washington, DC 20460
U. S. Bureau of Land Management
Phoenix District Office
2929 West Clarendon
Phoenix, AZ 85017
Arizona Department of Health Services
Library
1740 West Adams
Phoenix, AZ 85007
Arizona Department of Health Services, Northern Regional
Office
2501 North Fourth Street
Flagstaff, AZ 86001
Arizona Department of Health Services, Southern Regional
Office
403 West Congress
Tucson, AZ 85701
Arizona Department of Library, Archives, and Public Records
State Capitol Building
Phoenix, AZ 85007
Central Arizona Association of Governments
1810 Main Street
Florence, AZ 85232
District IV Council of Governments
1020 Fourth Avenue
Yuma, AZ 85364
VI-172
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Maricopa Association of Governments
111 South Third Avenue
Phoenix, AZ 85004
Northern Arizona Council of Governments
119 East Aspen Street
Flagstaff, AZ 36001
Pima Association of Governments
405 Trans-America Building
Tucson, AZ 85701
Southeastern Arizona Governments Organization
118 Arizona Street
Bisbee, AZ 85603
Clifton City-Greenlee County Library
Riverside Drive
Clifton, A2 35533
Cochise County Library
6 Main Street
Bisbee, AZ 85603
Flagstaff City-Coconino County Library
11 West Cherry
Flagstaff, AZ 86001
Maricopa County Library
3375 West Durango
Phoenix, AZ 85009
Miami Memorial-Gila County Library
1052 Adonis Avenue
Miami, AZ 85539
Mohave County Library
219 North Fourth Street
Kingman, AZ 86401
Nogales City-Santa Cruz County Library
548 Grand Avenue
Nogales, AZ 85621
Pinal County Free Library
1301 Pinal
Florence, AZ 85232
Prescott Public-Yavapai County Library
215 East Goodwin Street
Prescott, AZ 86301
VI-173
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Roxanne Whipple Memorial-Navajo County Library
420 West Gilmore
Winslow, AZ 86047
Safford City-Graham County Library
808 Eighth Avenue
Safford, AZ 85546
St. Johns-Apache County Library
75 West Cleveland
St. Johns, AZ 85936
Tucson Public-Pima County Library System
200 South Sixth Avenue
Tucson, AZ 85729
Yuaa City-County Library
350 Third Avenue
Yuraa, AZ 85364
Arizona State University
Documents Service
Rayden Library
Tempe, AZ 85281
Northern Arizona University
Library
Flagstaff, AZ 86001
Health Sciences Center Library
University of Arizona
Tucson, AZ 85724
VI-174
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Exhibi
Valley, AŁ
1 "tor, 83
VI-175
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^p... A
-------
Exhibit 4
BUCKEYE VALLEY RURAL VOL. FIRE DIST. ^
j
P. O. Box 75 Buckeye, Arizona 85326
Chief Darrel McCarty SecAreas Robbie Sorrel I e
386-2005 932-7150 386-2617
September 20, 1982
Subject: Hazardous Materials incident of 8-27-82 at the
Rainbow Valley Landfill
I would like to bring to your attention the fact that
on August 2?th an incident developed concerning Hazardous
Materials at the Maricopa County Landfill in Rainbow Valley,
that could have easily cost a Waste Management truck driver
his life.
It is presumed that the driver, Mr Rod Gates in truck
#290, at some place along his route, picked up some materials
which developed into a potentially deadly situation. Upon
arrival at the landfill and while preparing to dump his load,
the driver was met by smoke coming from the rear portion of
the load. The driver apparently inhaled some of the smoke
and began feeling the adverse effects of it. The load was
dumped and the waste management truck driven away by the
driver. Upon reaching a point approximatly six miles North-
west of the landfill, Mr. Gates was too overcome by the inhaled
smoke and fumes to continue further and chose to stop and
abandon his vehicle.
A passerby (Mr. Clarence Hovland) of Rainbow Valley stopped
to inquire if help was needed at about 10s20 AM. Mr. Gates
mentioned "Hazardous Materials" to Mr. Hovland and appeared
to be in severe discomfort, but declined help when asked if
he needed an ambulance. Mr. Hovland determined that it was
prudent to notify the Maricopa County Sheriff Office and
also requested an ambulance be dispatched to the scene.
M.C.S.O. requested an ambulance and also notified the Ariz.
Dept. of Public Safety, requesting hazardous materials
assistance. Upon returning to the scene, Mr. Hovland discovered
that Gates had been picked up by another individual who
began transporting him to West Valley Emergency Medical Center,
ignoring the request to wait for the arriving ambulance.
VI-177
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Upon the arrival of the ambulance and with the victim gone,
the ambulance called for firo crews and the road was blocked
off. Fire crews responded from both the North and South sides
of the incident, when D.P.S. arrived the vehicle was approached
for investigation. The vehicle was found with the engine still
running and the radio on. Personnel could get no response from
the Waste Management base station. When no apparent problem
could bo located at the vehicle, the investigation wac moved to
the landfill site. The load in question was located and a search
begun. A crushed plastic container was discovered containing a
small amount of a substance thought possibly to be Muriatic Acid,
along with other containers of chemicals improperly disposed of.
In the same portion of the load was other materials consisting
of combustibles, metal shavings, oily rags, etc. There was evidence
of earlier combustion, but at the time of discovery there was no
longer any fire requiring extinguishment.
By this time OSHA, and the Hazardous Waste Division of the
Az. Dept. of Health Services were involved and at the scene. The
suspected materials were contained and removed for analysis.
My concerns and recomendations are several.
First: When the Rainbow Valley Landfill was opened it was
designated for non commercial use only. I am interested in learning
what brought about the change to allow commercial use. 1 recomend
that commercial use of this landfill be discontinued.
Secondi In the enclosed copy of the Maricopa County Landfill
letter to Mr. Esterbrooks, there is no mention of the crushed
plastic container, which to my knowlege has not had its contents
analysed yet. There is also no emphasis placed on the toxicity
of the material involved or the severity of the potentially deadly
situation to the driver. I wonder really how close he came to
losing his life? Would it have taken just one more breath of the
smoke? We will never know that answer and I am sure that the driver
would not care to be involved in further research. I can understand
the Landfill Departments desire to downplay the situation. Maybe
if I were in their position I would not want to make waves either.
One more reason to close the site to commercial use.
Third: I am. appalled at the letter to Unidynamics Phoenix Inc.
requesting their cooperation in this type of situation. Really
now, what kind of corrective action is that? I beleive there are
tougher penalties for an improper turn at an intersection. I would
recomend penalties more in line with the potentially deadly
situation created.
Fourth: I am sure that the industry in question was aware of the
proper method of chemical disposal, particularly in light-of the
length of time the industry has been in operation in this area.
If industry will not comply with chemical disposal regulations,
maybe they should be monitored, of course at their expense.
VI-178
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I am asking for your support from a legislative point
of view in preventing this type of incident from occuring
again, and would like to know what your response is to this
issue, also what actions your office may be taking with regards
to this situation.
Sincerely
Chief McCarty
Enclosures included.
Copies to.
Gov. Bruce Babbitt
St. Fire Marshal, Paul Saundera
Az. Corp. Comm. Jack Vaughn
Az. Dept. of Hlth. Svcs. Norm Guinenik
Rep. Jim Hartdegen
Rep. Renz Jennings
Rep. James Ratliff
Rep. Bob Denny
Sen. Polly Getzwiller
County Supervisor Ed Pastor
County Engineer Bob Esterbrook
Management, Unidynamics Phoenix Inc.
VI-179
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m\wi nun norm itmwii
1325 W«sl OuranflO Slrwl
Pno«nix. Arizona 85009
(602) 269-2681
DATE September 2, 1982
MEMO TO Mr. R. C. Esterbrooks, Director of Public Works & County Engineer
SUBJECT INCIDENT AT RAINBOW VALLEY LANDFILL
The following is a recap of what happened on Friday, August 27, 1982.
At .approximately 11:45 a.m. I received a call from Che Maricopa County
Sheriff's Office (westside) reporting a possible problem at the Rainbow
Valley Landfill, The deputy aaid an unknown fume asphyxiated a truck
driver after leaving the Landfill at a location just north of the Tuthill
Road Bridge. The truck driver is an employee of Universal Waste Company.
At approximately the same time I notified Mr. Manny Garcia to dispatch him
to the landfill. Both Manny and I were unable to contact the landfill
attendant.
Approximately at Noon I recalled the Sheriff's westside dispatch, confirming
the report ^"4 the deputy said emergency fire truck and rescue were on their
way to both locations. In addition, the Department of Public Safety was
also summoned.
D.P.S. notified the Department of Public Safety Watch Commander in which
identified the situation as a "Hazardous Materials Emergency" initiating
the response plan and notification oC jurisdictions! authorities.
The following arrived at the Rainbow Valley Landfill within a short time
thereafter. The landfill was closed at approximately 12:30 or 1:00 p.m. to
all commercial and private citizens.
Mr. Nick Sciarro - Maricopa County landfill Department
Mr. Manny Garcia - Maricopa County Landfill Department
Mr. Steve W. Rhodes - Industrial Commission, OSHA's Industrial Hygienist
Mr. Norm Gumenik - ADHS Hazardous Waste Specialist
Waste Management of Phoenix - Spill Coordinator
Chemical Waste Management Inc. (Phx.) - 2 man Hazardous Waste Removal
team
Volunteer Fire Department - 4 man team
Department of Public Safety Officer - Highway Patrol
VI-180
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Mr. El. C. Esterbrooks
September 2, 1982
Page 2
Findings:
No Maricopa County Personnel injured or asphyxiated.
Arizona Department of Health Services and OSHA representatives recommended
undetermined dangerous waste be removed from landfill.
ADHS, through phone dispatcher of Waste Management of Phoenix, requested
their parent company to remove the waste.
Removal of waste occurred at approximately 5:15 p.m., August 27. 1982.
Reexamined landfill; found no further problem.
Resumed landfill covering of remaining exposed household waste to comply
with, cover regulations.
Secured Landfill at approximately 6:30 p.m., August 27, 1982.
Resumed operations August 28, 1982 ac 8:00 a.m.
Condition of truck driver (hauler) unknown.
Waste found on site:
Condition of containers - unrinsed, not crushed, not. punctured.
Contents - Perchloric Acid
Fluorinert
Electric liquid
Label with company name delivered - Unidynamics Phoenix Inc.
1000 Litchfield Road
Goodyear, Arizona 85338
Note: Attached is a letter of notification from us to Unidynamics Phoenix
Incorporated. Also photos taken of containers.
ek Sciarro
Landfill Administrator
NS:mar
Enclosures
VI-181
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Ml [IP! CIVITf Lllirill
332S W«t Oumnqo Str*K
Phoenix. Aflion* aiOOi
September 1, 1982
Onidynamics Phoenix lac.
1000 Litchfield Road
Goodyear, AZ 35338
Gentlemen;
On. Friday, August: 27, 1982, a-Waste Management of Phoenix garbage hauler
was asphyxiated by chemicals chat had been illegally dumped in a refuse
container and then delivered to the Uarlcopa. County Rainbow Valley
Landfill.
Mr. Norm Gumenik, a Hazardous Waste Specialist for the Arizona Department
of Health Services, determined that the items delivered to the landfill
were improperly rinsed and disposed of, canalng the Waste Management of
Phoenix employee to be overcome by the fumes.
Containers disposed of at the Rainbow Valley landfill were identified
with your address on the container as perchloric acid, fluorlnert and an
electric liquid. The hazardous waste removal team from Chemical Waste
Management Inc.. removed the wastes for proper disposal and analysis.
Maricopa County Landfill, policy and Arizona Department of Health Services
regulations prohibit the improper disposal of. these wastes. Proper
disposal measures can be determined by contacting the State Health
Department. Your cooperation -in prohibiting further disposal of these
products at our landfill will be greatly appreciated.
Very truly yours,
R, C. ESTEKBROOKS, P.E.
DIRECTOR OF PUBLIC WORKS
AMD COONTT ENGINEER
Landfill Administrator-
NJS:cf
VI-182
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- w (
•^>— ^ C' f&Ui-'^. /-i*G^-
VI-183
-------
Exhibit 5
Rainbow
ARIZONA STATE
U N I V E R S I T Y
TEMPE, ARIZONA 35281
DEPARTMENT OF PSYCHOLOGY
February 8, 1983
Dear Resident,
In August 1982 you participated in a survey about the proposed hazardous waste
facility and asked that the results be sent to you. I am happy to send you these
results and want to personally thank you for your time and cooperation.
Let me begin by explaining why the survey was conducted. First, it was to
better understand the feelings and concerns of the entire community. Many
people are not able to attend special meetings to voice their opinion and others do
not care to attend such gatherings. Also, in a survey, everyone has an equal
voice, not just those who shout the loudest. Second, it was to document what
the people were like in Rainbow Valley and Mobile in 1982 in terms of health,
feelings about the community, and opinions of themselves. Such information is
extremely important for both practical and research reasons. If the facility is
built, there is now a record of the "before picture" to compare with the "after
picture." Third, the survey was designed to answer research questions about
coping and community involvement.
This project has involved a number of people and organizations. The Department
of Health Services was actively involved during the planning stage, and con-
siderable staff time and clerical support was provided by the Bureau of Waste
Control and the Division of Disease Control. Faculty members from the Depart-
ment of Psychology at Arizona State University served as consultants, and
research assistants and doctoral students in psychology conducted the many
interviews. The Sierra Club of Arizona provided some needed funding on short
notice, when the Department of Health Services decided not to participate in the
project at the last moment.
I take full responsibility for the contents of this report and would be glad to
receive comments and questions. I am presently working in South Carolina and
can be reached at the following address: Medical University of South Carolina,
Department of Psychiatry, 171 Ashley Avenue, Charleston, South Carolina 29425.
Cordially,
Kenneth M. Bachrach, M.A.
VI-184
-------
Mr. Bachrach's report has been reprinted in Section IV,
Socioeconomics: Quality of Life Concerns. See pages IV-60 to
IV-64.
VI-185
-------
PHONE (602) 257-9138
Be A
Do-Something
Democrat
Exhibit 6
Rainbow
MARICCPA COUNTY DEMOCRATS
1001 North Central • Phoenix. Arizona 85004 • Phone 254-4179
P 0. Sot 1944, Phoenix, AZ. 85001
'l
\. *
enne
ClAltflAN
January 29, 1981
Governor Bruce Babbitt
State Capitol, Executive Wing
1700 West Washington
Phoenix, Arizona 85007
Dear Governor Babbitt:
The following resolution was passed by the Maricopa County
Democratic Central Committee on January 28, 1981.
The resolution was presented by William Giliard, Chairman
of Legislative District 6 and seconded by Rep. Leon Thompson,
Chairman of Legislative District 23. After much discussion,
the resolution passed by the following vote: 16 yes, 2 no,
and 1 abstention.
We hope you will take this resolution under serious
consideration.
Sincerely
Jennie P. Cox, Chairman
Maricopa County Democrats
cc : William GilJard
Rep. Leon Thompson
VI-186
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f'HONE (602) 257-9125
MARSCOPA COUNTY DEMOCRATS
1001 North Canlnl . Phoenix, Arizon. 85004 • Phone 254-41 79
P. 0. Box 1944, Phoenix, AZ. 85001
'J
enne
Be A
Do-Something
Democrat
January 29, 1981
WHEREAS the Senate Health Committee has voted out a bill
selecting a site in-Rainbow Valley for hazardous
waste disposal; and
WHEREAS the Rainbow Valley site is in the drainage area of
Waterman Wash and the Gila River and any seepage
of hazardous wastes would have disastrous results;
and
WHEREAS the Rainbow Valley site has the largest number of
people in the immediate area of any of the sites
considered by the Department of Health Services
and the area is growing rapidly; and
WHEREAS the Senate committee rejected without adequate
investigation other sites recommended by DHS for
purely political reasons;
THEREFORE be it resolved by the Maricopa County Democratic
Central Committee that it opposes the selection of
Rainbow Valley as the site of hazardous waste disposal
and urges Governor Babbitt to veto any bill passed by
the Legislature selecting Rainbow Valley for
hazardous waste disposal.
VI-187
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Exhibit 7
Valley. AZ
1 :ter 83
DO YOU LIVE IN ARIZONA? DO YOU KNOW WHAT IS GOING-ON?
HAZARDOUS WASTE
Re: PROPOSED SITE ---MOBILE
Quote taken from page 5-1 Environmental Inpact Statement, "The
Mobile site is located about 6 miles southwest of the community of
Mobile, which is about 65 miles southwest of Phoenix".
THIS IS NOT TRUE
SEE MAP ON REVERSE SIDE
The majority of the metropolitan area of Phoenix (approximately
llj million people) live within 40 miles of the Mobile facility. Some
as close as 26 miles.
WHY-SUCH-A-BIG eRrOR FOR MOBILE??
The distance to Western Harqaahala Plain site is approximately 90
miles west of Phoenix, south of I-10 (this is OK). The Ranegras Plain
site is about 100 miles west of Phoenix (this is OK).
WHO WILL MOST LIKELY BENEFIT FROM THE MOBILE SITE IN THE NEAR FUTURE?
Possible answer:
PROVIDENT ENERGY COMPANY (oil refinery to be located near the
Mobile School).
WHY
1. Could possibly save 31,000,000. in construction cost. Hazardous
waste wouldn't have to be stored on location, but could be taken im-
mediately to the site 6 miles down the road.
2. The cost of hauling it 6 miles instead of 120 to 150 miles could save
hundreds of thousands of dollars. The exact amount of savings would
depend on what capacity the facility operated at and the exact dif-
ference in miles traveled.
WHO?? OVER-RULED THE DEFT. OF HEALTH'S RECOMENDATION OF:
WESTERN BARQUAHALA SITE?
From the 'Report to the Arizona State Legislature Regarding Siting
of a. Statewide Hazardous Waste Disposal Facility' (Executive Summary
Jan. '81).
Page 1-1
VI-188
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Page 1-1 continued:
ADH's selection of the Western Harquahala area.was based upon
8evera 1 specific factors:
a) Remoteness from existing or potential habitation
b) Lack of downgradient water uses within ten alles
c) Depth to groundwater (300 feet)
d) Presence of clay soils throughout the area
e) Easy access from Interstate 10
f) Location downgradient from the Central Arizona Project canal
In order to remove doubt a thorough check should be made to oake
sure that no one in the legislature was operating as a consultant to
Provident Energy Co. or was a consultant to anyone else that was work-
ing for Provident Energy Co. The people of Arizona have a right to
know what is going on, even if there is no conflict of interest. The
following article was taken from the Phoenix paper regarding Ari::cna
financial disclosure statue.
Senate panel clears Usdane:
of wrongdoing in faking fee
By The Associated Prewi
The state Senate Ethic* Committee has agreed
Majority Leader Robert Usdane dirt not breach
Senate ethics in accepting a $47,450 fee as a health
consultant
The committee convened late Tuesday to take
the final step alter two investigations that cleared
the Scottsdale Republican of any "criminal wrong-
doing."
• Committee Chairman Ha) Runyan, R-Litchfield
"Park, said a formal report to the Senate president
would say that Usdane had not violated Senate
ethics.
"We will wait for the attorney general's sugges-
tions on what changes should be made in the
financial disclosure law before considering any
legislation," Runyan said at conclusion of the 15-
minute hearing.
The hearing followed investigations by Attorney
General Bob Corbin and retired Arizona Chief
Justice Fred C. Strucimeyer Jr., which said Usdane,
who headed the Senate health committee last year,
did'not violate conflict-of-interest laws by accepting
the fees in 1979-80 from a group of doctors seeking
advice on setting up a health-maintenance organiza-
tion.
Dr. Bruce Shelton, who headed that group, later
became the major centractor uncer the state's
indigent health-care program, a 1931 law in which
Usdane had a principal role.
Usdane's finanical disclosure statement, required
annually of state officials, revealed neither \'ne
source nor amount of the fee. Both invesrgators
said Usdane had met the "minimal requirements"
of the law, but the attorney general suggested
changes are needed.
"The financial disclosure statute is 50 general in
its requirements and riddled with exceptions that a
conflict of interest would almost never be revealsd
through completion of the form ..." Corbir, satu.
Usdane has said ha intends to seek legislation to
tighten financial-disclosure requirements.
VI-189
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Hazardous WASTE from OUT- OF-STATE
I. How LARGE A VOLUME POSSIBLE from CALIFORNIA? (Taken from page C-5
Environmental Impact Statement)
Variables influencing the potential for import of wastes
from California are even more complex. California is a major
generator of hazardous wastes, and is in the process of develop-
ing a state hazardous waste control program which would restrict
or discourage the landfilling of many types of regulated wastes.
Also, several disposal facilities in southern California have
closed or may close in the near future, leaving this major indus^
trial area without sufficient nearby disposal capacity.
II. NEED-FOR-WASTE from OUTSIDE ARIZONA
Arizona May Import *±
Hazardous Wastes &
TUCSON, Ariz. (AP) - The state 51 *Q
may havo to Import hazardous waste ^»
from other suit) b*xuuic it can'i j(- fc*
ford to run a burial and treatment JIJ* ***
facility on what Arizona alone pn>- 5«J X
ducea, an official frays.
Tifcaldo Cancj, head of the stato \
Bureau at \Vjstc Contrjl. said Arizona *l
cannot meet Ine costs of running a J15 ^&
inillion hazardous wastes sue unlras it .^
encourages other states to its^
v/aite here. A
The Legislature has set amde 640 •&
acres between Pho*ntx and Glla B«na ^
for thi wastu dump. yv
VI-190
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco, Ca. 94105
2 0 JAN 1933
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CONCERNED
CITIZENS:
Attached for your review is the Draft Environmental
Impact Statement (DEIS) for the proposed Arizona Hazardous
Waste Management Facility. This DEIS, prepared in accord-
ance with the National Environmental Policy Act of 1969,
addresses the proposed sale of federal land by the U. S.
Bureau of Land Management (BLM) to the State of Arizona
for the purpose of siting a hazardous waste facility.
At BLM's request, the Environmental Protection Agency
(EPA) assumed the role of lead agency in preparing the
EIS. BLM and the Arizona Department of Health Services
(ADHS) haved served as cooperating agencies.
Public hearings will be held on Tuesday, March 1,
1983, to receive testimony on this DEIS. The times and
places are listed below. All interested persons are
invited to express their views at these hearings.
9:00 a. m.
Arizona Department of Health Services
Conference Rooms A and B, 4th floor
1740 West Adams Street
Phoenix, Arizona
7:30 p. m.
Buckeye Elementary School Cafeteria
210 South 6th Street
Buckeye, Arizona
In addition, the public is invited to meet with
representatives of EPA, BLM, and ADHS to discuss the EIS
in an "open house" public meeting to be held between 7:30
and 9:30 p. m. on Thursday, February 17, 1983, at the
Mobile Elementary School, in Mobile, Arizona, 14 miles
west of Maricoca on the Maricopa-Mobile Road.
Public comments on the DEIS may be submitted for 45 days
after notice of the DEIS appears in the Federal Register.
All'comments, questions, and requests for additional copies
VI-191
-------
of the DEIS (available in limited supply) or of the Summary
should be directed to:
U. S. Environmental Protection Agency, Region 9
ATTN: Chuck Flippo (T-2-1)
215 Fremont Street
San Francisco, CA 94105
phone: (415) $74-8128
Copies of this DEIS are also available for review at
these agencies and libraries:
U. S. Environmental Protection Agency
Region 9
Library-Information Center
215 Fremont Street
San Francisco, CA 94105
U. S. Environmental Protection Agency
Public Reference Unit, Library
401 M Street SW, Room 2922
Washington, DC 20460
U. S. Bureau of Land Management
Phoenix District Office
2929 West Clarendon
Phoenix, AZ 85017
Arizona Department of Health Services
Library
1740 West Adams
Phoenix, AZ 85007
Arizona Department of Health Services, Northern
Regional Office
2501 North'Fourth Street
Flagstaff, AZ 86001
Arizona Department of Health Services, Southern
Regional Office
403 West Congress
Tucson, AZ 85701
Arizona Department of Library, Archives, and Public
Records
State Capitol Building
Phoenix,~AZ 85007
Central Arizona Association of Governments
1810 Main Street
Florence, AZ 85232
VI-192
-------
District IV Council of Governments
1020 Fourth Avenue
Yuma, AZ 85364
Maricopa Association of Governments
111 South Third Avenue
Phoenix, AZ 85004
Northern Arizona Council of Governments
119 East Aspen Street
Flagstaff, AZ 86001
Pima Association of Governments
405 Trans-America Building
Tucson, AZ 85701
Southeastern Arizona Governments Organization
118 Arizona Street
Bisbee, AZ 85603
Clifton City-Greenlee County Library
Riverside Drive
Clifton, AZ 85533
Cochise County Library
6 Main Street
Bisbee, AZ 85603
Flagstaff City-Coconino County Library
11 West Cherry
Flagstaff, AZ 86001
Maricopa County Library
3375 West Durango
Phoenix, AZ 35009
Miami Memorial-Gila County Library
1052 Adonis Avenue
Miami, AZ 85539
Mohave County Library
219 North Fourth Street
Kingman, AZ 86401
Nogales City-Santa Cruz County Library
548 Grand Avenue
Nogales, AZ 85621
Final County Free Library
1301 Pinal
Florence, AZ 85232
VI-193
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Prescott Public-Yavapai County Library
215 East Goodwin Street
Prescott, AZ 36301
Roxanne Whipple Memorial-Navajo County Library
420 West Gilraore
Winslow, AZ 86047
Safford City-Graham County Library
808 Eighth Avenue
Safford, AZ 85546
St. Johns-Apache County Library
75 West Cleveland
St. Johns, A3 85936
Tucson Public-Piraa County Library System
200 South Sixth Avenue
Tucson, AZ 85729
Yuma City-County Library
350 Third Avenue
Yuma, AZ 85364
Arizona State University
Documents Service
Hayden Library
Tempe, AZ 85281
Northern Arizona University
Library
Flagstaff, AZ 86001
Health Sciences Center Library
University of Arizona
Tucson, AZ 85724
VI-194
-------
Exhibit 9
-------
'/
,
V
c /
VI-196
-------
auuwa withrdaw its wards from the home with
lit 10
It River roles
nt for poison
Stanton - T
t ia aaking state and federal environmental
(of permission to dump more toxic
--;:-,7 substances than is allowed into th« Salt River irom
. •Ł 7". i$»J>Ist Avenue Sewage Treatment Plant ,
':f^: '* The city has been in chronic violation of state and
for cadmiwiv chromiuitt, copper
, and
;
"
^^'tli* standards, which it feels are too strict, said
t -William Korbitz, assistant director in charge of
JJ"' wart* water for the city.
..:'-'•-' Thesa and other heavy metals enter the sewer
^* jyttmn when they are flushed down the drain by
«{ectronics firms and others using electroplating, h»
Mid.-- ' ' - , , __,__._ .. .
,''•; Concern has been expressed that n»* standards
: •?* 'ipouM threaten downstream wildlife refugee depend-
" j^; "1n»J 'on the water. The change 'is befng fought by a
:-~-\Ł i public-interest group-, th« Arizona Center for Law in
• ;it .the^Public Interest,' oh grounds; that it would
'-^ undermine efforta-to protect public health.
'•'_'-Ł State and federal water-quality official* indicated
-• - : gympathy for the city's position but said ambigui-
• . • ' ties in state regulations may prevent them from
, complying with the request State water-quality
~ officials must decide the issue and make a
recommendatiuft to thp. Environmental Protection
Agency; wfiWfr-iiK-Biafaty conrtmed*cthit--th»
'proposal receives public review.
''--Korbitz said discharge limits OB tie 'four Uak-
" -wastes were set in a 1980 permit from th« EPA aad
iie'stricter than now required by state law in order
I-J lo-- protect agricultural water, th« mini u»»-,ft»±
'•»i|- treated effluent from the plant •:".'",' V'^*
: '5.; ; . The city wants the EPA and the tUieVto, wlaj';
' '3 lirots on the maximum allowable concentration per
- .;"« JliUMf effluent forth* fonrtoxie wastes and on tb*
-':' | -' total amount poured'daily into the Salt River/
; '; Proposed changes would increase the por-liUr
' ': limit on cadmium to five times the current level
V.j Umita on copper would be 10 times the current
.*3. 'level and concentrations of cyanide would double. ,
'. ^ ," The current limit on hexavalent chromium, the
• T 'moat toxic form of that metal, would be inelvea} in
H • Javm of a limit on combined form* of ehromiuuv
', --\ Korbitz said.
-,^_,. Jn addition, expansion of-the facility, whickr
^-4 -'handles 90 million gallons a day, will boost plant
...j: capacity by 30 million gallons when completed ip;
^;l>Marcfcor April, he said. .V
;.;-! • "We need to increase the total daily-load allowed .
f-1 !for these substances to accommodate tthe additional
'-3 volume of effluent," Korbitz said. "The new limita
"-would still be more than strong enough to ensure .
: that the water is safe for the purposes it is used for."
The Arizona Center for Law in th» Public'
Interest challenged proposed relaxation of the
standards on grounds that it would violate the
Clean 'Water Act and Btata stream standards.
VI-197
-------
Continiwrt *.*OTIJ .'U
"Such*a modification would ... be contrary to the
goal of protettmg public health and environmental
quality," said David Baron, a lawyer for the group.
Baron cintonded that limits on toxic wastes
discharged into the Salt River should be as low as
possible. H* urged the city to clamp down on users
of industrial sewer systems in order to limit the
amouBt :'of- the substances coming into sewage-
sr«aupeai plants.
Kdrbjjj contested the. claims and 'said the city
cannot .meet current standards for cadmium,
chromium, copper and cyanide without installing
of dollars in additional sewage-treatment
.
• -/Hi'said the city is violating the standards even
it limits discharges of these materials by
i&ty officials contend that copper plumbing
*
-------
Exhibit 11
Rainbow
Valley. V,
I Mar 63
VI-199
-------
^^
!\ • M. ^^
•^^ .', .'-•. 3 ,.',aty-tj .:. ". Z i:~r.. ' • x^^' .----vy-7|-^=h.f- --f • y^~ . .,r_^.j^I ' . • " • " ' • .;#-1 • Kvt.n^SJ...'
...;.,;.. .j , •-. i :
• J .!!-•' '
\ J*i
, ^>.- -. .i. rr,
:.^r<>v7" . • -~f-
-VI-200
-------
HAZARDOUS WASTE vs. HAZARDOUS MATERIAL
Hazardous MATERIAL is being hauled through the cities and across
bridges(carrying our drinking water) thousands of times each day. This
MATERIAL in many cases is acre dangerous than HAZARDOUS WASTE, 'what
are we doing to protect the citizens of Arizona from this hazard? Haz-
ardous waste will not amount to 17. of the risk involved.
COST TO CONSTRUCT ROAD TO MOBILE SITE (RAINBOW VALLEY) compared to
WESTERN HARwUAHALA or RANEGROS PLAINS
Twenty mi lea of road will have to be paved in order to bring Haz-
ardous Waste to the Mobile Site (Rainbow Valley). This road will be
used by many people, and will cost millions of dollars. This cost can
run to $20,000,000. The other sites will need only 3 to 5 miles of roads
and could be a private road (possible). The cost to build this road is
only a fraction of the coat of Building the MOBILE SITE ROAD.
WHO WILL PAY THE COST OF THE ROADS?
We have been lead to believe that the Company operating the Haz-
ardous Waste Site will pay for the roads construction in order to bring
waste to the site. However, the cost of building a road is so high
that other alternatives are being considered. The most discussed alter-
native is to have the Refinery, Hazardous Waste Site, Pinal county and
Maricopa county share the cost. If this plan were adopted then the cit-
izens of Arizona would in fact be subsidizing 507. of the construction
cost of the road. At the other sites the road construction would be nom-
inal a» compared to the Mobile Site and the Site could afford to pay 1007.
of the road cost.
THE PURPOSE OF THE HAZARDOUS .HASTE SITE WAS TO SAVE THE COMPANIES HAVING
WASTE MONEY BY HAVING A FACILITY IN ARIZONA
There is a big question whether this would occur at the Mobile Site.
The Dept. of Health has been having difficulty getting bids. The Co.'s
bidding know that if their charges are too high that the people having
waste will either haul the waste out of state or find a way of handling
it on location. The Mobile Site is costly to build because of the high
cost of building roads into it. The coat of the Har^uahala or Ranegros
Plains Site would be substantially less and would be near the big Cal-
ifornia market. If the Site could get part of the California market
they would have a better chance at making * profit, and at the same time
have a cheaper rate for the Arizona user.
VI-201
-------
Hazardous WASTE from OUT- OF-STATS
I. How LARGE A VOLUME POSSIBLE from CALIFORNIA? (Taken from page C-5
Environmental Impact Statement)
Variables influencing the potential for import of wastes
f r o 7i California are even more complex. California is a major
generator of hazardous wastes, and is in the process of develop-
ing a state hazardous waste control program which would restrict
or discourage the landfilling of many types of regulated wastes.
Also, several disposal facilities in southern California have
closed or may close in the near future, leaving this major indus
trial area without sufficient nearby disposal capacity.
II. NEED-FOR-WASTE from OUTSIDE ARIZONA
Arizona May Import ^
Hazardous Wastes K
TUCSON, Aria. (AP) - The state St fca
may havo to Import hazardous wmlc ^W
from other suu-a b«cau:.c it can'i. ,if- ** ^
ford to run a buridl and treatment J^ **l
facility on what Arizona alunc pci- *»y V
duccs, an official says.
Tibaltlo Cancz. head of tha nut^ \
Burtao of Waste Control, mid Armenia ^ ^
cannot meet the costs ot running a 315 ^ ^ V,
tniihon hazardous w.istcs site imli'iis it,,-J ^
encourages oUlcf ststea to [Jump its^
v/aste here. A
The LefisUture has set aside 640 '<*
acres between Phoenix and Oila S«na ^
for the wastu dump. »v
>
VI-202
-------
ADH's selection of die Western Harquahala area was based upon
several specific factors:
a) Remoteness from existing or potential habitation
b) Lack of downgradient water uses within ten niles
c) Depth to groundwater (300 feet)
d) Presence of clay soils throughout the area
e) Easy access from Interstate 10
f) Location downgradient from the Central Arizona Project canal
In order to remove doubt a thorough check should be made to make
sure that no one in the legislature was operating as a consultant to
Provident Energy Co. or was a consultant to anyone else that was work-
ing for Provident Energy Co. The people of Arizona have a right to
know what is going on, even if there is no conflict of interest. The
following article was taken from the Phoenix paper regarding Arizona
financial disclosure statue.
Senate panel clears Usdane
of wrongdoing in taking fee
By Th» Associated Press
Tht state Senate Ethic* Committee has agreed
Majority Leader Robert Usdane did not breach
Senate ethics in accepting a 347,430 fee aa a health
consultant.
The committee convened late Tuesday to take
the final step after two investigations that.cleared
the Scottsdale Republican of any "criminal wrong-
doing." - , .
; Committee Chairman" Hal Runyan. R-Litchfield
'Park, said a formal report to the Senate president
would say that Usdane had not violated Senate
ethics.
"We will wait for the attorney general's sugges-
tions on what changes should be made in the
financial disclosure law before considering any
legislation," Runyan said at conclusipn of the 15-
minute hearing.
The hearing foUowed investigations by Attorney
General Bob Corbin and retired Arizona Chief
Justice Fred C. Struckmeyer Jr., which said Usdane,
who headed the Senate health committee last year,
did'not violate conflict-of-interest laws by accepting
the fees in 1979-80 from a group of doctors seeking
advice on setting up a health-maintenance organiza-
tion.
Dr. Bruce Shelton, who headed that group, later
became the major csntractor under the state's
indigent health-care program, a 1981 law in which
Usdane had a principal role.
Usdane's finanical disclosure statement, required
annually of state officials, revealed neither the
source nor amount of the fee. Both investigators
said Usdane had met the "minimal requirements"
of the law, but the attorney general suggested
changes are needed.
"The financial disclosure statute is so general in
its requirements and riddled with exceptions that a
conflict of interest would almost never be revealed
through completion of the form ..." Corbin said.
Usdane has said he intends to seek legislation to
tighten financial-disclosure requirements.
VI-203
-------
DO YOU LIVE IN ARIZONA? DO YOU KNOW WHAT 13 GOING-ON?
HAZARDOUS WASTE
Re: PROPOSED SITE ---MOBILE
Quote taken from page S-l Environmental Inpact Statement, "The
Mobile site is located about 6 miles southwest of the community of
Mobile, which is about 65 miles southwest of Phoenix"
THIS IS NOT TRUE
SEE MAP ON REVERSE SIDE
The majority of the metropolitan area of Phoenix (approximately
llj million people) live within 40 miles of the Mobile facility. Some
as close as 26 miles.
WHY-SUCH-A-BIG eRrOR FOR MOBILE??
The distance to Western Harqaahala Plain site is approximately 90
miles west of Phoenix, south of 1-10 (this is OK). The Ranegras Plain
site is about 100 miles west of Phoenix (this is OK).
WHO WILL MOST LIKELY BENEFIT FROM THE MOBILE SITE IN THE NEAR FUTURE?
Possible answer:
PROVIDENT ENERGY COMPANY (oil refinery to be located near the
Mobile School).
WHY
1. Could possibly save 31,000,000. in construction cost. Hazardous
waste wouldn't have to be stored on location, but could be taken im-
mediately to the site 6 miles down the road.
2. The cost of hauling it 6 miles instead of 120 to 150 miles could save
hundreds of thousands of dollars. The exact amount of savings would
depend on what capacity the facility operated at and the exact dif-
ference in miles traveled.
WHO?? OVER-RULED THE DEPT. OF HEALTH'S RECOMENDATION OF:
WESTERN HARQUAHALA SITE?
From the 'Report co the Arizona State Legislature Regarding Siting
of a Statewide Hazardous Waste Disposal Facility' (Executive Summary
Jan. '81).
VI-204
-------
SECTION VII
LIST OF PREPARERS
In addition to the persons listed in Section 5 of the Draft
EIS, the following individuals participated in the preparation of
this Final EIS.
ARIZONA DEPARTMENT OF HEALTH SERVICES
Norm Weiss, Planning Manager
Post-Graduate Studies - Arizona State University, Tempe
Planning and Public Administration
M.A. - Arizona State University, Tempe
Geography and Land Use Studies
B.S. - Arizona State University, Tempe
Biology
Mr. Weiss is responsible for managing program development
and remedial action planning programs for the Bureau of Waste
Control. He assisted in the preparation of portions of the EIS
dealing with the facility development process.
William D. Wiley, Hydrologist
M.S. - University of Arizona, Tucson
Hydrology
B.S. - Arizona State University
Physical Geography
Mr. Wiley, a hydrologist in the Bureau of Waste Control,
is working on development of the hazardous waste facility. He
helped prepare portions of the EIS dealing with surface water.
VII-1
-------
SECTION VIII
COORDINATION LIST
This EIS has been sent to the following agencies and organ-
izations for review.
FEDERAL AGENCIES
Advisory Council on Historic Preservation
Department of Agriculture
Forest Service
Soil Conservation Service
Department of Defense
Corps of Engineers
U. S. Air Force
Department of Health and Human Services
Indian Health Service
Department of the Interior
Bureau of Indian Affairs
Bureau of Land Management
Bureau of Reclamation
Geological Survey
National Park Service
Department of Transportation
Federal Highways Office
STATE AGENCIES
Arizona Agriculture and Horticulture Ccnmission
Arizona Department of Health Services
Bureau of Air Quality
Bureau of Water Quality
Bureau of Waste Control
Local Health Services
Arizona Department of Public Safety
Arizona Department of Transportation
Arizona Department of Water Resources
Arizona Division of Emergency Services
Arizona Game and Fish Department
Arizona Natural Heritage Program
Arizona Office of Economic Planning and Development
Arizona Outdoor Recreation Coordination Commission
Arizona State Clearinghouse
Arizona State Historic Preservation Officer
Arizona State Land Department
VIII-1
-------
Attorney General's Office
Governor's Commission on the
Arizona Environment
LOCAL AGENCIES
Central Arizona Association of Governments
District IV Council of Governments
Association of Governments
County Board of Supervisors
Civil Defense
Development Agency
Health Department
Highway Department
Landfill Department
Manager
Planning and Zoning Department
Council of Governments
District Sanitation Department
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa
Maricopa County
Northern Arizona
Phoenix
County
County
County
County
County
County
Pinal County
Pinal County
Pinal County
Pinal County
Southeastern
Administrator
Board of Supervisors
Highway Department
Planning and Zoning Department
Arizona Council of Governments
Tucson City Attorney's Office
Yuma County Board of Supervisors
Health Department
Highway Department
Planning and Zoning Department
Yuma County
Yuma County
Yuma County
INDIAN TRIBES
Ak Chin Tribal Council
Colorado River Indian Tribe
Gila River Indian Community
Inter-tribal Council
Papago Tribal Council
OTHER ORGANIZATIONS
Arizona Association of Industries
Arizona Cattle Growers Association
Arizona Cotton Growers Association
Arizona Environmental Alliance
Arizona Farm Bureau
Arizona Mining Association
Arizona Parks and Recreation Association
Arizona Wildlife Federation
Arizona 4-Wheel Drive Association
Audubon Society
VIII-2
-------
Environmental Council of Arizona
iaaae Waiten fceagae
League of Women Voters
Maricopa County Farm Bureau
Phoenix Metropolitan Chamber of Commerce
Salt River Project
Sierra Club
Southern Arizona Environmental Council
Tucson Environmental Council
Tucson Metropolitan Chamber of Commerce
University of Arizona, Council for Environmental Studies
Wildlife Society
Yuma County Farm Bureau
VIII-3
-------
SECTION IX
REFERENCES
1. Arizona Department of Health Services, Bureau of Waste Control.
Final Report to the Arizona State Legislature Regarding Siting
a Statewide Hazardous Waste Disposal Facility. 1981.
2. Southall, J. (Consultant to ENSCO, Inc.) Personal Communica-
tion. April 1983.
3. Martin, J. (Vice-President, Pyrotechnic Systems, Inc.) Per-
sonal Communication. June 1983.
4- U. S. Environmental Protection Agency. Engineering Handbook
for Hazardous Waste Incinerators. Publication No. SW-889.
1981 .
5. Governor's Office of Appropriate Technology, Toxic Waste
Asessment Group. Alternatives to the Land Disposal of
Hazardous Wastes; An Assessment for California. 1981.
6. Drye, R. (ENSCO, Inc.) Personal Communication. May 1983.
7. Johnson, J. (BKK, Inc.) Personal Communication. May 1983.
8. Dubois, S. M., A. W. Smith, N. K. Nye, and T. A. Nowak, Jr.
Arizona Earthquakes, 1776 - 1980. Bulletin 193. State of
Arizona, Bureau of Geology and Mineral Technology, Geological
Survey Branch, and University of Arizona, Tucson, Arizona.
[1982.]
9. Darmiento, F. (Salt River Project) Personal Communication.
June 1983.
10. U. S. Environmental Protection Agency. "Hazardous Waste
Management System; Permitting Requirements for Land Disposal
Facilities." Federal Register, July 26, 1982 (47 FR 32274),
11. Stulik R. Maps showing groundwater conditions in the
Waterman Wash area, Maricopa and Final Counties, Arizona —
1982.Arizona Department of Water Resources Hydrologic Map
Series Report #8. June 1982.
12. Van Haveren, B. P. Hydrologic Risk and Return Period Selection
for Water Related Projects. U. S. Department of the Interior,
Bureau of Land Management Technical Note. September 1970.
IX-1
-------
13. Southall, J. (Consultant to ENSCO, Inc.) Personal Communi-
cation. April 1983.
14. U. S. EPA Region 6. Incineration of PCBs, Summary of Approval
Actions, Energy Systems Company (ENSCO), El Dorado, Arkansas
(permit document). February 1981.
15. U. S. EPA Region 6. Incineration of PCBs, Summary of Approval
Actions, Rollins Environmental Services, Deer Park, Texas
(permit document). February 1981.
16. Texas Department of Water Resources. Receiver Monitoring
Report — Industrial Solid Waste System (data base).
May 17, 1983.
17. Aundrey, R. (Southern Pacific Railroad) Personal Communica-
tion. May 1983.
18. Southall, J. (Consultant to ENSCO, Inc.) Personal Communica-
tion. May 1983.
19. U. S. Department of Transportation, Federal Railroad Admini-
stration. Accident/Incident Bulletin No. 150, Calendar Year
1981. June 1982.
20. Arizona Department of Transportation. [Data base] 1982.
21. Arizona Department of Transportation. Arizona Hazardous
Materials Survey. May 1981.
22. Schmit, A. (U. S. Department of Transportation, Federal
Railroad Administration) Personal Communication. May 1983.
23. Kahler, J., R. Curry, and R. Kandler. Calculating Toxic
Corridors. Headquarters Air Weather Service (MAC), Scott
Air Force Base, Illinois. No. AWS/TR-80/003. 1980.
24. U. S. Department of Health and Human Services and U. S.
Department of Labor. NIOSH/OSHA Pocket Guide to Chemical
Hazards. DHEW (NIOSH) Publication No. 78-210. 1978.
25. Arizona Lung Association. Coccidioicomycosis; Cocci;
Valley Fever. [no date]
26. Jeffrey, D. "'Valley Fever1 Spores are Widespread Threat."
BLM Newsbeat (U. S. Department of the Interior, Bureau of
Land Management, California State Office). May 1979.
27. Flynn, N., P. Hoeprich, M. Kawachi, K. Lee, R. Lawrence,
E. Goldstein, G. Jordan, R. Kundargi, and G. Wong. "An
Unusual Outbreak of Windborne Coccidioidomycosis." New
England Journal of Medicine 301(7): 358-261. 1979.
IX-2
-------
28. U- S. Department of the Interior, Bureau of Indian Affairs.
Ak Chin Water Supply Project, Draft Environmental Impact
Statement. 1981.
29. Mix, B. (Arizona Public Service Co.) Personal Communication,
June 1983.
30. Southall, J. (Consultant to ENSCO, Inc.) Personal Communi-
cation. June 1983.
31. U. S. Environmental Protection Agency. A Study of State Fee
Systems for Hazardous Waste Management Programs. Publication
No. SW-956. 1982.
32. Fryman, F. (Arizona State Historic Preservation Office)
Personal Communication. July 1982.
IX-3
-------
Appendices
-------
APPENDIX A
VOLATILE ORGANIC COMPOUNDS AND TOXIC EMISSIONS
The distinction made in this EIS between volatile organic
compounds (VOC) and potentially toxic emissions is somewhat
artificial because many VOCs may also be toxic compounds.
According to theoretical estimates made, volatile emissions at
the proposed facility should be relatively low, since the State's
plans call for liquid organic compounds to be mixed with solids
and placed in barrels. The Draft EIS notes, however, that
experience at other landfills suggests the possibility of toxic
emissions from the landfill.
In order to address this issue more fully in the Final EIS,
EPA staff attempted to obtain empirical data characterizing
emission rates and/or ambient levels of organic compounds for
landfills comparable to that suggested in the representative
design.* This research yielded few data concerning air quality
or emissions which could reasonably be applied to the proposed
Arizona facility.
A report recently released by the California Department of
Health Services indicates that elevated ambient levels of
organic compounds can occur near landfills (1).t The landfill
examined in this study, however, differs from the representative
* Several potential sources of information were consulted, including:
EPA staff in in Region 9, the Office of Solid Waste, the
Office of Toxic Substances, and the Industrial Environmental
Research Laboratory in Cincinnati, Ohio;
An EPA contractor performing ongoing projects related to air
emissions from treatment, storage, and disposal facilities;
Papers from Air Pollution Control Association conferences
related to toxic air contaminants (2,3);
EPA Region 9 reports relating to air and soil emissions from
an abandoned hazardous waste site in California (4,5);
California Air Resources Board (ARE) reports relating to air
quality in the vicinity of hazardous waste facilities (6,7);
• ARB staff.
t Compounds found include benzene, tetrachloroethylene, and
trichloroethylene.
A-1
-------
design for the Arizona facility in several important respects.
First, methods of disposal at the California landfill lend
themselves well to volatilization of organics, in that hazardous
liquid waste is simply mixed with solid landfill waste and
covered over with soil. Lower emissions could be achieved at a
facility which was operated with more attention to preventing
volatile emissions.
Second, the monitoring at the California landfill took place
at the perimeter of the landfill. Monitoring further downwind
(for example, at a distance comparable to that separating the
community of Mobile from the Mobile site) would probably show
dispersion of the emitted compounds.*
Third, no solvent recovery system is used at the California
facility, whereas the representative design for the Arizona
facility calls for solvent recovery at the landfill.
These projected differences, if actually realized at the
proposed facility, would result in much lower emissions and
ambient levels of volatile organic compounds at the Arizona
facility compared to the facility monitored in California.
The DEIS notes that the mixing of acid and alkali wastes
could generate heat and change the pH of solutions, which could
cause reactions or the evolution of organic or toxic compounds
into the air (DEIS p. 4-13). The Draft EIS states that, while
such reactions should prove negligible or non-existent under
normal operating conditions, the possibility of such emissions
should be recognized. The Draft EIS fails to clarify that if
the operator complies with the requirements in EPA's regulations
concerning ignitable, reactive, and incompatible wastes (40 CFR
264.17), there should be no generation of fumes from reactions.
REFERENCES
1. California Department of Health Services, California Air
Resources Board, and South Coast Air Quality Management
District. Ambient Air Monitoring and Health Risk Assessment
for Suspect Human Carcinogens around the BKK Landfill in
West Covina. 1983.
* It should be noted that monitoring to determine the emission
rate of a compound (amount of the compound which is being
emitted by the facility) is generally done as close to the
source as possible. The ambient concentration of the compound
(amount in the air in a given area) would be monitored at
varying distances from the source and would reflect dispersion
of the compound.
A-2
-------
2. Lynch, E. R., R. K. Goldman, and W. V. Blasland, Jr. Develop-
ment and Implementation of an Air Monitoring Program at an
Inactive Hazardous Waste Disposal Site — A Case Study.Paper
presented at the 75th Meeting of the Air Pollution Control
Association, New Orleans, LA. 1982.
3. Angiola, A. J. and J. M. Soden. Predicting and Controlling
Downwind Concentrations of PCB from Surface Impoundments.
Paper presented at the 75th Meeting of the Air Pollution
Control Association, New Orleans, LA. 1982.
4. The Radian Corporation. The McColl Site Investigation. 1982.
5. TRC Environmental Consultants, Inc. Final Report on the Air
Quality and Odor Portions of the Environmental Investigation
Program of the McColl Site. 1982.
6. California Air Resources Board. An Assessment of the Volatile
and Toxic Organic Emissions from Hazardous Waste Disposal in
California. 1982.
7. California Air Resources Board. Suggested Control Measure to
Reduce Organic Compound Emissions Associated with Volatile
Organic Waste Disposal. 1982.
-------
APPENDIX B
EMISSIONS CALCULATIONS FOR A HAZARDOUS WASTE SPILL
The emissions in the spill scenario presented in Section IV
are calculated as follows:
(A) Puddle area calculation
# gallons of toxic compound * (0.90 x 5,000)
= 4,500 gallons
2.31 x 102 in3
puddle volume = (4,500 gal)( gal )
= 1 .04 x 106 in3
Assuming a one-inch depth, then:
1.04 x 1Q6 in3
puddle area * ( 1 in )
» 1.04 x 106 in2
(B) Emission rate calculation (1)
Q = 0.08 V3/4 A(1 + (4.3 x 10~3)(T_2))Z
where,
Q = emission rate (kg/hr)
V = wind speed (assumed to be 2.5 meters per second)*
A =• spill area (n\2) (from (A) above)
Tp = toxic chemical pool temperature (assumed to be
26.7°C, or 80° F)
Z = dimensionless factor determined by chemical (for
benzene, Z - 22.67; for methylene chloride,
Z = 76.7)
• Q (benzene) = 9.86 x 103 kg/hr
" * Q (raethylene chloride) * 3.33 x 10* kg/hr
Given these emission rates, ambient levels of benzene and
methylene chloride at given distances from the spill can be
calculated (2):
* The reason for assuming this wind speed is discussed in Section
IV, Air Quality.
B-1
-------
where
X = ambient concentration (g/m3)
Q = emission rate, from (B) above
Eyiz = horizontal and vertical dispersion coefficients
U = wind speed (assumed to be 2.5 m/s)
These calculations assume worst case meteorological condi-
tions ("F" stability) and a wind speed of 2.5 meters per second
(m/s). Ambient levels (X) in g/m3 at given distances from the
spill are given in Table IV-5.
REFERENCES
1. Kahler, J., R. Curry, and R. Handler. Calculating Toxic
Corridors. Headquarters Air Weather Service (MAC), Scott
AFB, IL. AWS/TR-80/003. 1980.
2. U. S. Environmental Protection Agency. Workbook of Atmospheric
Dispersion Models. Publication No. AP-26. 1974.
B-2
-------
APPENDIX C
MILEAGE AND FUEL CONSUMPTION ESTIMATES
Mileage and fuel consumption estimates for waste shipments
generated within Arizona are based on the number of shipments
likely to be generated in Phoenix and Tucson. About 90% of the
hazardous waste generated within the State is generated in these
two metropolitan areas. Approximately 2,000 shipments per
year are expected to be generated in the Phoenix area, while 320
shipments per year are expected from Tucson (see DEIS Appendix
N). Because of the assumptions made in making these calculations,
fuel consumption figures should be viewed as rough indicators,
rather than actual estimates, of fuel consumption.
Table C-1 shows one-way mileage figures for the Mobile site
and the Western Harquahala Plain/Ranegras Plain sites, using the
longest access routes identified in the Draft EIS (see DEIS
pp. 4-19, 4-20, and 4-23). Also shown are distances to the nearest
existing out-of-state waste facility: the BKK facility in West
Covina, California (j'ust east of Los Angeles). Table C-2 shows
the potential fuel consumption, based on an estimated mileage
figure for trucks of five miles per gallon.
The approximate amounts of fuel that could be saved by trans-
porting hazardous wastes generated within Arizona to an in-state
facility, rather than the nearest existing out-of-state facility,
are shown below.
Mobile
Gallons consumed to West Covina: 349,000
Gallons consumed to Mobile: 66,000
Gallons saved: 283,000
Western Harquahala Plain/Ranegras Plain
Gallons consumed to West Covina: 349,000
Gallons consumed to WHP/RP: 119,000
Gallons saved: 230,000
As the figures show, fuel savings would likely be greater at the
Mobile site than at the Western Harquahala Plain and Ranegras
Plain sites by about 53,000 gallons per year.
C-1
-------
Table C-1. Travel miles of hazardous waste shipments to proposed
Arizona sites and nearest out-of-state site
Destination
Mobile
WHP/RP**
West Covina
From Phc
Distance
65
110
360
)enix
Travel
Miles*
130,000
220,000
720,000
From Tuc
Distance
107
242
473
:son
Travel
Miles*
34,240
77,440
151 ,360
Total
Travel
Milest
164,240
297,440
871 ,360
* Travel miles are calculated by multiplying the distance by the
estimated number of hazardous waste shipments per year (2,000
from Phoenix, 320 from Tucson).
t Total Travel Miles are the combined travel miles for both cities.
**WHP/RP = Western Harquahala Plain/Ranegras Plain sites.
Table C-2. Estimated fuel consumption of in-state
hazardous waste shipments
Destination
Mobile
WHP/RP**
West Covina
Total
Round-Trip
Travel Miles*
328,480
594,800
1 ,742,720
Total
Fuel Consumption
(Gallons)t
65,969
118,960
348,544
* Travel Miles from Table C-1 have been doubled to represent the
round-trip mileages.
t This figure equals total round-trip miles divided by an
estimated average truck mileage rate of five miles per gallon.
**WHP/RP = Western Harquahala Plain/Ranegras Plain sites.
C-2
-------
If a PCB incinerator were located in Arizona, PCB shipments
from western states going to the existing incinerator in El
Dorado, Arkansas, would likely be routed instead to the Arizona
facility. Estimates of the number of shipments that would be
expected annually at the facility from various western cities
are shown in Table C-3, along with travel miles to the proposed
and alternative sites as well as the El Dorado facility. Table
C-4 shows estimated fuel consumption.
Approximate fuel savings achieved by shipping PCB wastes to
an Arizona facility rather than the Arkansas facility are shown
below.
Mobile
Gallons consumed to El Dorado: 255,000
Gallons consumed to Mobile: 117,000
Gallons saved: 138,000
Western Harquahala Plain/Ranegras Plain
Gallons consumed to El Dorado: 255,000
Gallons consumed to WHP/RP: 100,000
Gallons saved: 155,000
Potential fuel savings for PCB shipments would be greater at the
Western Harquahala Plain and Ranegras Plain sites than at the
Mobile site, since the former sites are closer to California on
the route the majority of shipments would be expected to travel.
The difference would amount to approximately 17,000 gallons.
As noted above, fuel savings for shipments of hazardous
waste generated within Arizona would be greater if the proposed
facility were located at the Mobile site rather than at the
Western Harquahala Plain or the Ranegras Plain site. The reverse
would be true for PCB shipments. Considering total fuel con-
sumption from both hazardous waste and PCB shipments, use of
the Mobile site would result in an overall fuel savings of
about 37,000 gallons over the amount saved by using either of
the other two sites.
C-3
-------
Table C-3. Travel miles of PCB shipments to proposed Arizona sites
and existing PCB incinerator (El Dorado, Arkansas)
Point
of
Origin
Boise, ID
Boulder, CO
Denver, CO
Klamath Falls, OR
Los Angeles, CA
Phoenix, AZ
Portland, OR
Sacramento, CA
Salt Lake
City, UT
San Francisco-
Oakland, CA
Seattle, WA
TOTAL
Est.
Number
Tripst
2
5
48
4
67
13
45
5
21
148**
3
361
Mot
Dis
1035
878
857
1058
458
65
1333
834
716
847
1505
sile
Trv Mi
2070
4390
41136
4232
30686
845
59985
4170
15036
125356
4515
292421
Destii
WHI
Dis
1070
913
892
893
293
100
1168
669
751
682
1340
lation*
VRP
Trv Mi
2140
4565
42816
3572
19631
1300
52560
3345
15771
100936
4020
250656
El DC
Dis
1833
1017
994
2164
1661
1268
2265
1977
1471
1990
2337
jrado
Trv Mi
3666
5085
47712
8656
111287
16484
101925
9885
30891
294520
7011
637122
* Distances (Dis) are highway mileages from the Standard Highway
Mileage Guide (1). Travel Miles (Trv Mi) are the Estimated
Number of Trips multiplied by Distance. WHP/RP stands for
Western Harquahala Plain/Ranegras Plain sites.
t Estimated number of trips (annually) is based on marketing
estimates from ENSCO, Inc. (2).
**The high number of estimated shipments from the San Francisco
Bay Area is primarily due to the Pacific Gas and Electric
Company's program of replacing its capacitors which contain
PCB.
C-4
-------
Table C-4. Estimated fuel consumption of PCB waste shipments
Destination
Mobile
WHP/RP**
El Dorado
Total
Round-Trip
Travel Miles*
584,842
501 ,312
1,274,244
Total
Fuel Consumption
(Gallons) t
116,968
100,262
254,849
* Travel miles from Table C-3 have been doubled to represent the
total round trip mileages.
t This figure equals total round trip miles divided by an
estimated average truck mileage rate of five miles per gallon.
**WHP/RP = Western Harquahala Plain/Ranegras Plain sites.
REFERENCES
1. Rand McNally and Co. Standard Highway Mileage Guide. 1969.
2. Drye, R. (Ensco, Inc.) Personal Communication. May 1983.
C-5
-------
APPENDIX D
POPULATION RISK FACTORS FOR
PCS TRANSPORTATION
Tables D-1 and D-3 show the estimated population risk factors
presented by the shipment of PCB waste on access routes to the
proposed sites, using estimated numbers of PCB shipments from
Table C-3 (Appendix C). The methodology used to arrive at these
figures is described in DEIS Appendix N. In Tables D-2 and D-4,
the population risk factors attributable to the PCB shipments
are added to the population risk factors presented in the Draft
EIS for hazardous waste shipments to show the total population
risk factor along these routes. The percent increase in the
population risk factors due to the PCB shipments is also shown.
Table D-1. Population risk factor for PCB transportation to the
Western Harquahala Plain and Ranegras Plain sites*
Exposure
Miles
105
Est.
No.
Trips
89
Travel
Milest
9345
Accident
Rate§
0.0008
Accident
Proba-
bility**
0.007
Population
of Impact
Areatt
103,415
PCB
Population
Risk Factor§§
773
* The route from Phoenix to these sites follows Buckeye Road from
Phoenix to Buckeye, then follows Interstate 10 to the sites (See
DEIS, p. 4-23).
t Travel miles = Exposure miles x Est. No. trips.
§ Accident rate = accidents per 1000 vehicle miles (from State of
Arizona Department of Transportation, 1982).
**Accident probability for hazardous waste transport (accidents
per year) = accident rate x (travel miles/1000).
ttFrom the Draft EIS (DEIS Table 4-8).
§§PCB population risk factor = accident probability x population of
impact area.
D-1
-------
Table D-2. Increase in population risk factor due to PCB
shipments to the Western Harquahala Plain and
Ranegras Plain sites
PCB
Population
Risk Factor
773
Hazardous Waste
Population
Risk Factor*
18f615
Total
Population
Risk Factort
19,388
Percent Increase
Due to PCB
Shipments
4%
* From Table 4-8 in the Draft EIS (DEIS p. 4-25).
t This figure equals the PCB population risk factor plus the
hazardous waste population risk factor.
D-2
-------
Table D-3. Population risk factors for PCB transport to the
Mobile site
Route*
A
B
C
D
Expo-
sure
Miles
93
107
42
105
Est.
No.
Trips
361
361
361
272
Travel
Milest
33,573
38,627
15,162
28,560
Acci-
dent
Rate§
0.0004
0.0006
0.0003
0.0008
Accident
Proba-
bility**
0.013
0.023
0.005
0.023
Population
of Impact
Areatt
133,030
132,400
104,410
103,415
PCB
Population
Risk Factor§§
1 ,729
3,045
522
2,379
* Routes are as follows (from Draft EIS, p. 4-20):
A: Phoenix-Chandler-Arizola (1-10). Arizola-Casa Grande-Maricopa-
Site (Maricopa Road).
B: Phoenix-Chandler-Exit 194 (1-10). Exit 194-Casa Grande-Stanfield
(Hwy 84). Stanfield-Maricopa-Site (Maricopa Road).
C: Phoenix-Chandler (1-10). Chandler-Maricopa-Site (Maricopa
Road) .
D: This route covers the additional PCB traffic on 1-10 and
Buckeye Road between the Western Harquahala Plain/Ranegras
Plain sites and Phoenix.
Tucson routes are not included, since no regular PCB shipments
have been estimated for the Tucson area.
t Travel miles = Exposure miles x Est. No. trips.
§ Accident rate = accidents per 1000 vehicle miles (from State of
Arizona Department of Transportation, 1982).
**Accident probability for hazardous waste transport (accidents
per year) = accident rate x (travel miles/1000).
ttFrom the Draft EIS (DEIS Table 4-6).
SSPCB population risk factor = accident probability x population
of impact area.
D-3
-------
Table D-4. Increase in population risk factors due to PCB
shipments to the Mobile site
Route
A
B
C
Combined PCB
Population
Risk Factor*
4,108
5,424
2,901
Hazardous Waste
Population
Risk Factort
9,312
17,212
2,088
Total
Population
Risk Factor**
13,420
22,636
4,989
Percent Increase
Due to PCB
Shipments
44%
32%
139%
* This figure includes the population risk factor for each access
route from Phoenix (Routes A, B, and C) plus the population
risk factor for PCB traffic on 1-10 between the Western Harquahala
Plain and Ranegras Plain sites and Phoenix (Route D).
t From Table 4-6 in the Draft EIS (DEIS p. 4-21).
**This figure equals the PCB population risk factor plus the
hazardous waste population risk figure.
D-4
-------
APPENDIX E
MODIFIED MERCALLI INTENSITY SCALE
The following pages explain the Modified Mercalli Intensity
Scale used in Section IV to indicate the intensity of earthquakes
affecting Yuma and Maricopa Counties. The explanation is reprinted
from:
Dubois, S. M., A. W. Smith, N. K. Nye, and T. A. Nowak, Jr.
Arizona Earthquakes, 1776 - 1980. Bulletin 193, Arizona
Bureau of Geology and Mineral Technology, Geological Survey
Branch, and University of Arizona, Tucson, Arizona. [1982.]
E-1
-------
(Appendix V continued)
(Appendix V-B continued)
W
I
B. MODIFIED MERCALLI INTENSITY SCALE OF 1931
(Unabridged)
(Adapted from Sieberg's MeTcalli-Cancani scale, modified and condensed]
I. a. Not felt - or, except rarely under especially favorable
circumstances.
Under certain conditions, at and outside the boundary of the
area in which a great shock is felt:
b. Sometimes birds, animals, reported uneasy or disturbed.
c. Sometimes dizziness or nausea experienced.
d. Sometimes trees, structures, liquids, bodies of water, may
sway, doors may swing, very slowly.
II. a. Felt indoors by few, especially on upper floors, or by
sensitive, or nervous persons.
Also, as in grade I, but often more noticeably:
b. Sometimes hanging objects may swing, especially when delicately
suspended.
c. Sometimes trees, structures, liquids, bodies of water, may
sway, doors may swing, very slowly.
d. Sometimes birds, animals, reported uneasy or disturbed.
e. Sometimes dizziness or nausea experienced.
III. a. Felt indoors by several . . .
b. Motion usually rapid vibration.
c. Sometimes not recognized to be an earthquake at first.
d. Duration estimated in some cases.
e. Vibration like that due to passing of light, or lightly loaded
trucks, or heavy trucks some distance away.
f. Hanging objects may swing slightly.
g. Movements may be appreciable on upper levels of tall structures.
h. Rocked standing motorcars slightly.
IV. a. Felt indoors by many, outdoors by few.
b. Awakened few, especially light sleepers.
c. Frightened no one, unless apprehensive from previous
experience.
d. Vibration like that due to passing of heavy, or heavily
loaded trucks.
e. Sensation lil.e heavy body striking building, or falling
of heavy objects inside.
f. Rattling of dishes, windows, doors; glassware and crockery
clink and clash.
g. Creaking of walls, frame, especially in the upper range of
this grade.
h. Hanging objects swung, in numerous instances.
i. Disturbed liquids in open vessels slightly.
j. Rocked standing motorcars noticeably.
V. a. Felt indoors by practically all, outdoors by many or most.
b. Outdoors direction estimated.
c. Awakened many, or most.
d. Frightened few—slight excitement, a few ran outdoors.
e. Buildings trembled throughout.
f. Broke dishes, glassware, to some extent.
g. Cracked windows — in some cases, but not generally.
h. Overturned vases, small or unstable objects, in many
instances, with occasional fall,
i. Hanging objects, doors, swung generally or considerably.
j. Knocked pictures against walls, or swung them out of place.
k. Opened, or closed, doors, shutters, abruptly.
1. Pendulum clocks stopped, started, or ran fast, or slow.
m. Moved small objects, furnishings, the latter to slight extent.
n. Spilled liquids in small amounts from well-filled open
containers.
o. Trees, bushes, shaken slightly.
VI. a. Felt by all, indoors and outdoors.
b. Frightened many, excitement general, some alarm, many ran
outdoors.
c. Awakened all.
d. Persons made to move unsteadily.
e. Trees, bushes, shaken slightly to moderately.
f. Liquid set in strong motion.
g. Small bells rang—church, chapel, school, etc.
h. Damage slight in poorly built buildings.
i. Fall of plaster in small amount.
j. Cracked plaster somewhat, especially fine cracks (in) chimneys
in some instances.
k. Broke dishes, glassware, in considerable quantity, also some
windows.
1. Fall of knickknacks, books, pictures.
m. Overturned furniture in many instances.
n. Moved furnishings of moderately heavy kind.
VII. a. Frightened all — general alarm, all ran outdoors.
b. Some, or many, found it difficult to stand.
c. Noticed by persons driving motorcars.
d. Trees and bushes shaken moderately to strongly.
e. Waves on ponds, lakes, and running water.
f. Water turbid from mud stirred up.
g. Incaving to some extent of sand or gravel stream banks.
h. Rang large church bells, etc.
i. Suspended objects made to quiver.
j. Damage negligible in buildings of good design and construction.
k. (Damage) slight to moderate in well-built ordinary buildings,
considerable in poorly built or badly designed buildings,
adobe houses, old wafls (especially where laid up without
mortar, spires, etc.
1. Cracked chimneys to considerable extent, walls to some extent.
-------
M
I
Co
(Appendix V-B continued)
m. Fall af plaster in considerable to large amount, also some
stucco.
n. Broke numerous windows, furniture to some extent.
oa Shook down loosened brickwork and tiles.
p. Broke weak chimneys at the roofline (sometimes damaging
roofs).
q0 Fall of cornices from towers and high buildings.
r. Dislodged bricks and stones.
s. Overturned heavy furniture, with damage from breaking.
t. Damage considerable to concrete irrigation ditches.
VIII. a. Fright general — alarm approaches panic.
b. Disturbed persons driving motorcars.
c. Trees shaken strongly—branches, trunks, broken off,
especially palm trees.
d. Ejected sand and mud in small amounts.
e. Changes: temporary, permanent; in flow of springs and wells;
dry wells renewed flow; in temperature of spring and well
waters.
f. Damage slight in structures (brick) built especially to
withstand earthquakes.
g. (Damage) considerable in ordinary substantial buildings, partial
collapse; racked, tumbled down, wooden houses in some cases;
threw out panel walls in frame structures, broke off decayed
piling.
h. Fall of walls.
i. Cracked, broke, solid stone walls seriously. Wet ground to
some extent, also ground on steep slopes.
j. Twisting, fall, of chimneys, columns, monuments, also factory
stacks, towers.
k. Moved conspicuously, overturned, very heavy furniture.
IX. a. Panic general.
b. Cracked ground conspicuously.
c. Damage considerable in (masonry) structures built especially to
withstand earthquakes.
d. Threw out of plumb some wood frame houses built especially to
withstand earthquakes.
e. (Carnage) great in substantial (masonry) buildings, some collapse
in large part; or wholly shifted frame buildings off foundations,
racked frames.
f. (Damage) serious to reservoirs.
g. Underground pipes sometimes broken.
X. a. Cracked ground, especially when loose and wet, tip to widths
of several inches; fissures up to a yard in width ran
parallel to canal and stream banks.
b. Landslides considerable from river banks and steep coasts.
c. Shifted sand and mud horizontally on beaches and flat land.
d. Changed level of water in wells.
(Appendix V-B continued)
e. Threw water on banks of canals, lakes, rivers, etc.
f. Damage serious to dams, dikes, embankments.
g. (Damage) severe to well-built wooden structures and bridges,
some destroyed.
h. Developed dangerous cracks in excellent brick walls.
i. Destroyed most masonry and frame structures, also their
foundations.
j. Bent railroad rails slightly.
k. Tore apart, or crushed endwise, pipelines buried in earth.
1. Open cracks and broad wavy folds in cement pavements and
asphalt road surfaces.
XI. a. Disturbances in ground many and widespread, varying with
ground material.
b. Broad fissures, earth slumps, and land slips in soft, wet
ground.
c. Ejected water in large amounts charged with sand and mud.
d. Caused sea-waves ("tidal" waves) of significant magnitude.
e. Damage severe to wood frame structures, especially near
shock, centers.
f. (Damage) great to dams, dikes, embankments, often for long
distances.
g. Few, if any, (masonry) structures remained standing.
h. Destroyed large well-built bridges by the wrecking of
supporting piers, or pillars.
i. Affected yielding wooden bridges less.
j. Bent railroad rails greatly, and thrust them endwise.
k. Put pipelines buried in earth completely out of service.
XII. a. Damage total—practically all works of construction damaged
greatly or destroyed.
b. Disturbances in ground great and varied, numerous shearing
cracks.
c. Landslides, falls of rock of significant character, slumping
of river banks, etc., numerous and extensive.
d. Wrenched loose, tore off, large rock masses.
e. Fault slips in firm rock, with notable horizontal and vertical
offset displacements.
f. Water channels, surface and underground, disturbed and modified
greatly.
g. Dammed lakes, produced waterfalls, deflected rivers, etc.
h. Waves seen on ground surfaces (actually seen, probably, in
some cases).
i. Distorted lines of sight and level.
j. Threw objects upward into the air.
Source: Brazee, R. J., 1978, Reevaluation of Modified Mercalli Intensity scale
for earthquakes using distance as determinant: NOAA Technical Memorandum
EDS NG-SDC-4, 65 p.
-------
APPENDIX F
ADDITIONAL STUDIES NEEDED FOR THE
ARIZONA HAZARDOUS WASTE FACILITY
Table F-1 suggests additional studies which would be
needed to properly design, operate and/or close a hazardous
waste facility at the proposed site near Mobile. The Table,
prepared by ADHS, is not intended to be comprehensive nor does
it represent the minimum that could be needed.
F-1
-------
Table F-1. Additional studies needed for the Arizona
Hazardous Waste Facility
brl
f
to
Information Needed
Groundwater
1. Static water levels
2. Flow - aquifer characteristics
3. Water quality
4. Interconnected aquifers
5. Recharge areas
6. Aquifer responses
Subsidence/Faulting
1. Evidence
2. Magnitude
3. Location
Surface Water
1. Drainage patterns/area
2. Floodplains-overbank areas
3. Channel characteristics
4. Flows
Soils
1. Surface distribution
2. Engineering uses (dikes, etc.
3. Vadose zone - layers (clays)
4. Attenuative ability
5. Porosity/permeability
6. Infiltration capacity
Climate/Weather
1. Magnitude/duration and
direction of wind
2. Evaporation
3. Precipitation
Methods
1. Monitoring wells
production welIs
2. Borings
3. Geophysical surveys
4. Computer modeling
5. Piezometers
6. Down hole logging
1. Geophysical survey
2. Borings
3. Surface survey
4. Control points
5. Down hole logging
1. Air photos
2. Channel surveys
3. Stream gages
4. Vegetation mapping
5. Computer modeling
1. Air photos
2. Soil survey
3. Lab tests
4. Borings/sampling
5. Infi1trometers
6. Vadose zone monitoring
equipment
1. Evaporation pans,
lysimeters
2. Precipitation gauges
3. Thermometers, psychrometers
4. Solar energy
5. Anemometers
Data Collected
Transmissivities, storage coefficients, drawdown,
hydraulic conductivity, yield, depth to water,
water quality samples, chemical fluctuations,
depth to bedrock, recharge zones, permeable zones,
clay layers, perched zones, vertical conductivity
Depth to bedrock, location of fracture zones,
existing subsidence zones, potential subsidence
areas, magnitude of subsidence
Flows, channel changes, high water marks,
thalweg slope, scour, overbank flow, water
quality, diversion structure location, poten-
tial recharge zones, drainage patterns, head cutting,
down cutting, basin slope
Grain size, plastic limit/liquid limit/engineer-
ing properties, soil distribution, infiltration
rates, attenuation of specific wastes, porosity,
vadose monitoring zones, spatial distribution,
down hole profile, moisture content, caliche
layers, texture, cation exchange capacity
Rainfall, windspeed, wind direction, wind dura-
tion, evaporation, solar energy, temperature
Collector
Contractor and ADHS (Advisor)
Sub-Contractor in conjunction
with ADHS and Contractor
Contractor and ADHS
Contractor and Sub-Contractor
Contractor
-------
APPENDIX G
PUBLIC NOTICE OF HEARINGS ON THE DRAFT EIS
The following pages show documents which were used to provide
public notice of the public hearings on the Draft EIS.
5-1
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE:
SUBJECT:
TO:
March 14, 1983
Public Notice of Draft EIS Meeting and Hearings
Chuck Flippo
EIS Project Officer (T-2-1)
Files (SOW HAZ 5-3-1)
Notice of the availability of the Draft EIS, and of the public
meeting and hearings to be held on the Draft EIS, was given
through distribution of the four attached documents. They are:
1. A notice dated January 14, 1983, notifying concerned
persons of the pending availability of the Draft EIS and the
schedule of public meetings and hearings to be held on the docu-
ment. This notice was mailed to over 1500 persons, including
all persons on the mailing list compiled by ADHS's Bureau of
Waste Control during the site selection process; all persons who
participated in the EIS scoping process; and national organiza-
tions whose addresses were compiled by EPA Region 9.
2. Legal notices placed in the Phoenix Gazette and the
Arizona Republic of January 14, 1983.
3. A notice of the public meeting and hearings, dated
January 20, 1983, which was mailed with copies of the Draft EIS.
These copies were initially distributed to approximately 200
agencies, Indian tribes, organizations, and individuals, most
of whom had also been sent the January 14 notice.
4. A press release sent to newspapers in Arizona. The news
release was sent to the major daily newspapers in Phoenix and
Tucson as well as the Buckeye Valley News, the Casa Grande
Dispatch, the Gila Bend Herald, the Gila Bend Sun, the Parker
Pioneer, and the Yuma Daily Sun.
G-2
EPA FORM 1320-6 (REV 3-76)
-------
^°>i
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
1 4 JAN L83 San Francisco, Ca. 94105
TO ALL CONCERNED PERSONS:
The Environmental Protection Agency (EPA), Region 9,
has prepared an Environmental Impact Statement (EIS) on the
proposed sale of federal land to the State of Arizona for
the purpose of developing a hazardous waste management facility.
The Arizona Department of Health Services (ADHS) proposes to
purchase a 1-square mile parcel of land near the community
of Mobile, Arizona, for the facility.
AVAILABILITY OF THE DEIS
The, Draft Environmental Impact Statement (DEIS) has been
prepared in compliance with Section 102(2)(c) of the National
Environmental Policy Act. The DEIS will be available for
distribution to the public and other government agencies on
or about January 20, 1983. A summary of the DEIS will also
be available upon request. Persons wishing to review the
draft EIS or the summary should request a copy from:
U. S. Environmental Protection Agency
Region 9
ATTN: Chuck Flippo (T-2-1)
215 Fremont Street
San Francisco, CA 94105
You may also phone your request to EPA at (415) 974-8128 01:
ADHS in Phoenix at (602) 255-1162. A limited number of
copies will also be available at a public meeting to be held
in Mobile (see below).
'Copies of the DEIS will be available for public review
at EPA offices in San Francisco and Washington, D. C., as
well as at depository libraries and government agencies in
Arizona. A list of these libraries and agencies is attached.
"PUBLIC MEETING
EPA, in cooperation with the U. S. Bureau of Land
Management and ADHS, will hold a public meeting on Thursday,
February 17, 1983, so that interested persons may meet with
agency representatives to discuss the contents of the EIS
G-3
-------
and answer questions about the document. The purpose of the
meeting is to present information rather than to receive
formal comments on the DEIS. Two public hearings have been
scheduled to receive oral and written public comments at a
later date (see below).
The public meeting will be held in the Mobile Elementary
School, 14 miles west of Maricopa on the Maricopa-Mobile
Road, between 7:30 and 9:30 p. in. The meeting will be in an
"open house" format. A short opening statement will be made
to summarize the contents of the EIS. Afterwards, persons
with specific concerns or questions will be able discuss them
individually with agency representatives.
PUBLIC HEARINGS
Public hearings on the Draft EIS will be held on Tuesday,
March 1, 1983, at these times and places:
9:30 a. m. Arizona Department of Health Services
Conference Rooms A and B, 4th Floor.
1740 West Adams Street
Phoenix, Arizona
7:30 p. m. Buckeye Elementary School
Cafeteria
210 South 6th Street
Buckeye, Arizona
All persons are invited to express their views at these hearings
either orally or in writing. Oral statements should summarize
extensive written materials so that there will be time for
all interested persons to be heard.
Written comments may also be sent to EPA Region 9 at the
address given below. The Agency will receive written comments
for a period of 45 days after notice of the DEIS appears in
the Federal Register on or about January 28, 1983.
FOR FURTHER INFORMATION, CONTACT:
Chuck Flippo, Environmental Protection Agency, Region 9,
215 Fremont Street, San Francisco, CA 94105; (415) 974-8128
(Commercial); 454-8128 (FTS).
Attachment
-------
J,' J, -fwe u. s. ENvmcNMeN&L PROTECT** AGENCY
L IMPACT STATEMENT
' ARIZONA HAZARDOUS WASTE MANAGEMENT FACILITY
fr" Tw TL i iNVTWNWriil PrWtcllori Avtocv (EPA). R«4oo I ,
~f«r D>W»i an Envf onmwtl* imcwel llttaifwii (ElS) M tht.
\ erOMWd wt of fM*r« land lo fhf SUM oJ Arliona or h* -
VfUTVMf of dl/»*oXPg • Hiiardout wailf maoaifftunl faclnfy.
f "ni wliww 0«o*f lrr*K o< H««ifl Scrvlcn (AOHSt prooowt to
•urcntH • 1-wuart mm Mrc«4 of land rwar IM community of
MoWW, Arltww, for iht (•clilly.
W- TIM Dri^l Envlronmto'al lrro«ct Sfattnwil (OEISJ h« Mm
PftfiMnd (n comMmcfl wilh Helton 107 (2 MO of ttw Nalwtal
'•'EnviremnMfil Poltcy Act. Thlt Drift EIS wiri b* tv«ll»W« 1)
Ian FraneHtt, CA HIM
Rtflu*ttt(orcoDltim«va)we«m^tbvpNontte
-«)J» or AOHS Hi PhtMnli «l («»> 1SS-UM A fl
[•
n of tti* DEtS w* b* •«•(!•«• for pubflc rtvttw •( EPA
n *«« *«
dveMllorv iibraf let and »,
•ddrntn of ihmt toeailo
IramADHl
PUBLIC MEETING
a •nd Wwntofllon.TT ?.. n
«jv«rnment woncm in Arlton
ltom fe •w«n«Mc from EPA B
*« »|
ton*. A lh> of
eaton 9 or
— _ ------- ,, „
Mf*Mn^73(r*nd »•» o.
hodu" formal. A itwt
to iwnrwrtit- M»
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco, Ca. 94105
2 0 JAN 1983
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CONCERNED
CITIZENS:
Attached for your review is the Draft Environmental
Impact Statement (DEIS) for the proposed Arizona Hazardous
V7aste Management Facility. This DEIS, prepared in accord-
ance with the National Environmental Policy Act of 1969,
addresses the proposed sale of federal land by the U. S.
Bureau of Land Management (BLM) to the State of Arizona
for the purpose of siting a hazardous waste facility.
At BLM's request, the Environmental Protection Agency
(EPA) assumed the role of lead agency in preparing the
EIS. BLM and the Arizona Department of Health Services
(ADHS) haved served as cooperating agencies.
Public hearings will be held on Tuesday, March 1 ,
1983, to receive testimony on this DEIS. The times and
places are listed below. All interested persons are
invited to express their views at these hearings.
9:00 a. m.
Arizona Department of Health Services
Conference Rooms A and B, 4th floor
1740 West Adams Street
Phoenix, Arizona
7:30 p. m.
Buckeye Elementary School Cafeteria
210 South 6th Street
Buckeye, Arizona
In addition, the public is invited to meet with
representatives of EPA, BLM, and ADHS to discuss the EIS
in an "open house" public meeting to be held between 7:30
and 9:30 p. m. on Thursday, February 17, 1983, at the
Mobile Elementary School, in Mobile, Arizona, 14 miles
west of Maricopa on the Maricopa-Mobile Road.
Public comments on the DEIS may be submitted for 45 days
after notice of the DEIS appears in the Federa1 Regis t er.
All comments, questions, and requests for additional copies
G-6
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of the DEIS (available in limited supply) or of the Summary
should be directed to:
U. S. Environmental Protection Agency, Region 9
ATTN: Chuck Flippo (T-2-1)
215 Fremont Street
San Francisco, CA 94105
phone: (415) 974-8128
Copies of this DEIS are also available for review at
these agencies and libraries:
U. S. Environmental Protection Agency
Region 9
Library-Information Center
215 Fremont Street
San Francisco, CA 94105
U. S. Environmental Protection Agency
Public Reference Unit, Library
401 M Street SW, Room 2922
Washington, DC 20460
U. S. Bureau of Land Management
Phoenix District Office
2929 West Clarendon
Phoenix, AZ 85017
Arizona Department of Health Services
Library
1740 West Adams
Phoenix, A2 85007
Arizona Department of Health Services, Northern
Regional Office
2501 North Fourth Street
Flagstaff, AZ 86001
Arizona Department of Health Services, Southern
Regional Office
403 West Congress
Tucson, AZ 85701
* Arizona Department of Library, Archives, and Public
Records
State Capitol Building
Phoenix, AZ 85007
Central Arizona Association of Governments
1810 Main Street
Florence, AZ 85232
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District IV Council of Governments
1020 Fourth Avenue
Yuma, AZ 85364
Maricopa Association of Governments
111 South Third Avenue
Phoenix, AZ 85004
Northern Arizona Council of Governments
119 East Aspen Street
Flagstaff, AZ 86001
Pima Association of Governments
405 Trans-America Building
Tucson, AZ 85701
Southeastern Arizona Governments Organization
118 Arizona Street
Bisbee, AZ 85603
Clifton City-Greenlee County Library
Riverside Drive
Clifton, AZ 85533
Cochise County Library
6 Main Street
Bisbee, AZ 85603
Flagstaff City-Coconino County Library
1 1 West Cherry
Flagstaff, AZ 86001
Maricopa County Library
3375 West Durango
Phoenix, AZ 85009
Miami Memorial-Gila County Library
1052 Adonis Avenue
Miami, AZ 85539
Mohave County Library
219 North Fourth Street
Kingman, AZ 86401
Nogales City-Santa Cruz County Library
548 Grand Avenue
Nogales, AZ 85621
Final County Free Library
1301 Pinal
Florence, AZ 85232
G-8
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Prescott Public-Yavapai County Library
215 East Goodwin Street
Prescott, AZ 86301
Roxanne Whipple Memorial-Navajo County Library
420 West Gilmore
Winslow, AZ 86047
Safford City-Graham County Library
808 Eighth Avenue
Safford, AZ 85546
St. Johns-Apache County Library
75 West Cleveland
St. Johns, AZ 85936
Tucson Public-Pima County Library System
200 South Sixth Avenue
Tucson, AZ 85729
Yuma City-County Library
350 Third Avenue
Yuma, AZ 85364
Arizona State University
Documents Service
Kayden Library
Tempe, AZ 85281
Northern Arizona University
Library
Flagstaff, AZ 86001
Health Sciences Center Library
University of Arizona
Tucson, AZ 85724
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United States Region 9 Arizona
Environn al Protection 215 Fremont Street California
Agency San Francisco, CA 941 Ot> Nevada
Pacific Islands
FOR IMMEDIATE RELEASE John J. Zemaitis
February 8, 1983 (415) 974-8083
PUBLIC San Francisco, February 8 - The Environmental Pro-
MEETING SET tection Agency will hold a public meeting on its
FOR WASTE recently released Draft Environmental Impact
FACILITY Statement (DEIS) on the hazardous waste facility
ENVIRONMENTAL the State of Arizona proposes to develop near the
IMPACT community of Mobile, Arizona. The meeting will be
STATEMENT held at the following place and time:
Thursday, February 17, 1983
7:30 - 9:30 P.M.
Mobile Elementary School
Maricopa-Gila Bend Road
Mobile, Arizona
The February 17 public meeting will be in an "open
house" format. Persons attending the meeting will
be able to meet individually with the EPA, Bureau
of Land Management (BLM), and Arizona Department of
Health Services (ADHS) officials to ask questions
or discuss the contents of the document. This will
enable members of the public to discuss their con-
cerns informally with the agency staff members
who are most familiar with those issues.
The Agency also plans to hold two public hearings
to receive testimony concerning the DEIS. The hear
ings will be held at the following places and times
Tuesday, March 1, 1983
9:30 A.M.
Conference Rooms A&B, 4th floor
Arizona Department of Health Services
1740 West Adams
Phoenix, Arizona
- more -
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- 2 -
Tuesday, March 1, 1983
7:30 P.M.
Buckeye Elementary School Cafeteria
210 South Sixth Street
Buckeye, Arizona
The public hearings will be held to receive prepared
written or oral comments on the DEIS. Persons may also
mail their comments to EPA's San Francisco Regional Office.
The DEIS describes the potential impacts of locating the
proposed hazardous waste facility at the Mobile Site in
lower Rainbow Valley. The site is some 65 road miles
southwest of Phoenix in Maricopa County. The DEIS also
describes the impacts of locating the facility in two
alternative sites, both of which are located in the new
County of La Paz. One of the alternative sites is in the
Western Harquahala Plain, approximately 90 miles west of
Phoenix, while the other is in the Ranegras Plain, some
100 miles west of. Phoenix.
The three sites were recommended as suitable hazardous waste
sites in a report submitted by the Arizona Department of
Health Services to the State Legislature in January 1981.
After receiving the Report, the Legislature selected the
Mobile site as the future location of the facility. The
facility would be built and operated by a private firm under
contract to ADHS.
The DEIS was prepared because the State has asked to purchase
the land from the federal Bureau of Land Management. Under
federal law, an environmental impact statement must be pre-
pared whenever a major federal action, such as the sale of
federal land for the siting of a hazardous waste facility,
would significantly affect the quality of the human environ-
ment. BLM asked EPA to prepare the EIS because of the EPA's
greater expertise in the field of hazardous waste management.
Both the public meeting and the hearings are open to all in-
terested members of the public. For further information
contact:
Chuck Flippo
Environmental Protection Agency
215 Fremont Street
San Francisco, CA 94105
(415) 974-8128
Information is also available from ADHS1 Bureau of Vvaste
Control in Phoenix at (602) 255-1162.
###
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Proposed Hazardous Dump
Meeting Tuesday Night
Tuesday evening you will
have an opportunity to convey
your feelings regarding the pro-
posed hazardous waste manage-
ment facility (dump) which is
planned to be built near Mobile
at the far south end of Rain-
bow Valley.
A public hearing will be
held at the Buckeye Elemen-
tary Schoorcafeterla' at 7:30
p.m. Tuesday night. Since the
land is now under the jurisdic-
tion of the federal government
and must be sold to the state
before a dump can be realized,
the hearing has been called in
order to allow you the oppor-
tunity of commenting on the
proposed sale of the federal
land.
The Draft Environmental
Impact Statement (DEIS) has
been prepared and will be the
primary topic of conversation.
Everyone attending is free to
comment on any aspect of the
facility.
Involved in the procedure
are the EPA, BLM, and ADHS-
the ADHS is Arizona Depart-
ment of Health Services. No
doubt you are well acquainted
with the other initials.
Prospective features of the
proposed dump include sur-
face ponds, storage tank and
distillation unit, landfarm and
secure landfill. The ponds
would take care of acids and
alkalis which would be neutra-
lized and evaporated and
would also handle wastewaters
with heavy metels. Cyanide
solutions would likewise be
destroyed in a pond through
treatments and allowed to
evaporate.
Various solvents would be
contained in the storage tank
where organic solvents would
be recovered by distillation,
Various biodegradable organics
would be taken care of at the
landfarm with the wastes de-
graded by soil microorganisms.
Metal sludges, cyanide solids,
pesticides, reactive wastes, igni-
table wastes, halogenated or-
ganics and miscellaneous inor-
ganics and asbestos would be
taken care of in the secure land-
fill where the material would
be buried in "cells specifically
constructed to avoid hazards
G-12
to workers arid the environ-
ment — all wastes will be treat-
ed prior to landfilling by stabi-
lization, fixation, solidifica-
tion, etc."
There has been some con-
cern by Rainbow Valley resi-
dents and others that some-
how various hazardous wastes
would be carried by either air
or water into populated areas.
Mobile is about 30"rnile^ direc-
tly southeast of Buckeye.
It is expected that a num-
ber of people will attend the
hearing here.
Hearings of this nature are
required by law. Similar past
hearings conducted for various
purposes hereabouts have
meant little or nothing as far
as local comments have been
concerned.
P"f
L.
GPO 690
-875/2
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