EPA-908/5-79-001A
SUMMARY
FINAL ENVIRONMENTAL IMPACT STATEMENT
JACKSON WASTEWATER TREATMENT SYSTEM
TOWN OF JACKSON, WYOMING
FEBRUARY 1979
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION VIII, DENVER, COLORADO
80203
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EPA - 908/5-79-001A
Summary
Final Fnvironmental Impact Statement
for
Jackson Wastewater TreatmentDSystem
Town of Jackson, Wyoming
by
U.S. Environmental Protection Agency
Region VIII, Denver, Colorado
February, 1979
Approved
Alan Merson
Regional Administrator
Date: FEBRUARY 12, 1979
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DISCLAIMER
This report has been reviewed by the EPA, Region VIII, Water Division
and approved for publication. Mention of trade names or com-
mercial products does not constitute endorsement or recommenda-
tion for use.
DOCUMENT AVAILABILITY
This document Is available 1n limited quantities through the U.S.
Environmental Protection Agency, Environmental Evaluation Branch,
1860 Lincoln St., Denver, Colorado 80295. This document 1s also
available to the public through the National Technical Information
Service, Springfield, Virginia, 22161.
This report 1s printed on 100/K recycled paper
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I : :;
TABLE OF CONTENTS
Section
A.
B.
C. •
D.
E.
History of the Town of Jackson 201 Facilities
Plan EIS and Decision /• Making Process
Description of S
Major Issues a
Surrounding Each
Impacts and Possible^fefclutioi;
N
EPA's Decision on the Se
and Alternatives
Page No.
1
6
15
22
27
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SUMMARY FINAL ENVIRONMENTAL IMPACT STATEMENT
JACKSON WASTEWATER TREATMENT SYSTEM,
TOWN OF JACKSON, WYOMING
A. HISTORY OF THE TOWN OF JACKSON 201 FACILITIES PLAN EIS AND
DECISION MAKING PROCESS
The National Environmental Policy Act of 1969 (NEPA) established as
national policy, goals and procedures for protecting and enhancing en-
vironmental quality. The Act requires that any action developed, imple-
mented or funded by an agency of the Federal Government that may "signif-
cantly affect the quality of the human or natural environment" must be
preceded by a detailed environmental review process. The primary pur-
pose of the process is as "an action-forcing device to ensure that the
goals and policies defined in the Act are infused into the ongoing pro-
gram and actions of the Federal Government."
In accordance with this directive, the U.S. Environmental Protection
Agency (EPA) environmental review and assessment procedures are defined
in: "Council on Environmental Quality", April 23, 1971; the Handbook
of Procedures for Construction Grants Program for Municipal Treatment
Works, February, 1976; and the "National Environmental Policy Act Pro-
posed Regulations for Implementing Procedureal Provisions," 40CFR,
Parts 1500-1508, June, 1978. These procedures require that municipali-
ties planning for construction of publicly-owned wastewater treatment
works evaluate the environmental impacts of construction and subsequent
operation of the treatment works, and prepare an environmental assess-
ment. EPA then reviews the environmental assessment along with the rest
of the facilities plan, and ultimately issues either a negative declara-
tion; or if the project is anticipated to have significant adverse pri-
mary or secondary environmental effects, or is expected to be highly
controversial, prepares an environmental impact statement (EIS).
Primary environmental impacts are those directly related to construction
and operation of the project. Secondary impacts are usually associated
with indirect or induced changes in population and economic growth and
land use, or other environmental effects resulting from these changes
(i.e., increased public costs for providing adequate schools and trans-
portation facilities) . While primary impacts are generally readily
apparent, secondary impacts likely to be facilitated by implementation
of an alternative are often more difficult to forecast.
The history of the decision making process for the Environmental Impact
Statement, Jackson Wastewater Treatment System, Town of Jackson, Wyoming,
began in March, 1974, when EPA approved a grant to the Twon authorizing
the development of a wastewater facilities plan for a new or expanded
sewage treatment plant. The firm of Nelson, Haley, Patterson and Quirk,
Inc. (NHPQ) , was retained by the Town to develop this plan. Their ini-
tial studies indicated the need for an extensive flow and infiltration
study to analyze sewer problems. This study was subsequently authorized
and funded by EPA.
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In October, 1974, the facilities plan was completed by NHPQ. The plan
identified consideragle infiltration/inflow problems, hydraulic overload-
ing of the existing treatment facilities, and the need for expansion of
the facilities to handle increased flows due to additional resident and
tourist populations. The plan recommended as the most cost-effective
alternative a mechanical treatment plant at the present plant site at an
approximate capital cost of $1.5 million. As a second preferred option,
the plan recommended a similar facility west of Jackson near Boyle's
Hill at an approximate cost of $2.9 million. The third option involved
construction of a waste stabilization lagoon 4,5 miles south of the Town,
at an approximate cost of $1.8 million. The facilities plan-recognized
several problems for these alternatives including the fact that the
location for the proposed alternative (upgrading the existing plant) was
directly in the path of the Town's current growth expansion. Major con-
sequences of the Boyle's Hill alternative included the requirement for
additional high cost lift stations and pumping facilities to serve future
South Park development, and complications involving discharge to the
Snake River. The stabilization lagoon at South Park involved Game and
Fish property for the lagoons, effects on elk populations (approximately
2,000 elk feed in the grounds during the winter months), and secondary
growth implications of extending an interceptor into the undeveloped
South Park area.
After the Town of Jackson's November, 1974 hearing on the plan, and
largely due to EPA's notification to the Town that an EIS would be re-
quired if the decision were made to locate the facility in the South
Park Elk Feedground, NHPQ was requested to reevaluate the comparative
costs of the treatment plant at the present site versus the Elk Feed-
ground alternative. A January 5, 1975 supplement to the facilities plan
by NHPQ concluded that the total cost of upgrading the existing treat-
ment plant was less expensive than the South Park lagoon.
On April 30, 1974, the Wyoming Department of Environmental Quality, (DEQ),
issued a National Pollution Discharge Elimination System (NPDES) permit
to the Town of Jackson. Provisions of the permit included the require-
ment that the Town submit a final wastewater facilities plan to DEQ
by September 30, 1975. On November 4, 1975, following delays in submit-
tal, the Town was issued a Notice of Violation requiring the plan in
30 days. The Town's reply to DEQ indicated that the Town Council did
not concur with the recommended alternative of the Facilities Plan, and
that the South Park Elk Feedground alternative had been selected by the
Council. This decision was based on the following criteria:
1) Lower operation and maintenance costs of a lagoon system;
2) ultimate unlimited service capacity of a plant located at the
South Park Elk Feedground site; and
3) The Town Council's assumption that being public lands, the
South Park Elk Feedground site would be available for the Town's
use as the location for the selected lagoon treatment system
alternative.
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On January 30, 1976, following review of the facilites plan by EPA, the
decision was made to prepare an EIS on the selected alternative based on
anticipated public controversy and potential adverse environmental im-
pacts associated with the South Park Elk Feedground site. On July 23,
1976, EPA contracted the firm of James M. Montgomery, Consulting Engi-
neers, Inc., to assist the agency in preparing the EIS. A "Notice of
Intent to Prepare an EIS" was issued by EPA on August 26, 1976, and
mailed to all interested individuals and agencies.
As a result of the analysis developed in the Draft Environmental Impact
Statement, Jackson Wastewater Treatment System, Town of Jackson, Wyoming,
(draft EIS), which concluded that the South Park Elk Feedground option
would pose serious legal difficulties in acquiring the land in the feed-
ground and adversely affect the elk herd; that the proposed site was
located in the 100-Year floodplain; and would conflict with the goals
established by the Wild and Scenic River Study; and that the proposal
would "open up" the entire rural South Park area to urban/suburban level
development; the decision was made by EPA not to fund the selected
South Park Elk Feedground option.
During the draft EIS process, it became apparent that although the
majority of the Town Council continued to support the South Park Elk
Feedground alternative, several council members and a number of Teton
County officials were concerned over potential growth impacts of locat-
ing the treatment facility in lower South Park. Town Council members in
opposition to the selected alternative maintained the treatment facility
would become a County rather than Town of Jackson system. The County,
which was involved in the development of an overall Comprehensive Plan
and Implementation Program and a Section 208 Water Quality Management
Study, did not endorse the selected alternative due to the fact that the
treatment plant location and interceptor route were in direct conflict
with the proposed comprehensive plan goals and policies supporting the
retention of the rural character and ranching economy of Teton County;
encouraging compact urban growth with minimization of costs for public
services and facilities necessary to support new development; and di-
recting development out of areas subject to flooding and other natural
hazards. In addition, at a. public workshop conducted by EPA during the
EIS process, a large majority of citizen participants rejected the
proposal stating reasons including adverse effects of development .facil-
itated by extending sewers into Lower South Park, reservations about
lagoons as a method of treatment, and impacts on the elk herd. A major-
ity of citizens polled preferred expansion of the existing Jackson
treatment plant.
Following the decision by EPA not to fund the South Park Elk Feedground
option, a majority decision was made by Jackson Town Council to locate
the new sewage treatment plant at the South Park Road site. This
decision was again challenged by two of the three Teton County Commis-
sioners who indicated their opposition to the proposed location. These
commissioners maintained their position that a large treatment facility
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at the South Park Road site would open South Park to widespread develop-
ment, and conflict with the goals and policies of the proposed Teton
County Comprehensive Plan and Implementation Program. Two conflicting
State of Wyoming statutes concerning a Town's authority to go beyond
its boundaries to acquire property for liquid waste facilities and
County authority to conduct planning and zoning and restrict land users
outside city limits further complicated the situation.
The conflict continued through the summer of 1977. Those in opposition
to the South Park site favored expanding the existing treatment plant,
or construction of a new mechanical plant at Boyle's Hill, contending
that the South Park location constituted a "government subsidy of devel-
opment." Proponents of the South Park site maintained that the valley
was going to develop regardless of where the plant was located. They
further noted that a central treatment and collection system was pre-
ferable to individual septic tank systems in terms of groundwater pro-
tection and that the Comprehensive Plan and Implementation Program would
control growth in the area.
In early October, 1977, the EPA Regional Administrator met with the
Town's mayor and Council and the County Commissioners to discuss the
impasse. After reviewing the various advantages and disadvantages of
the respective sites, a proposal for limiting the rate of new tap-ins
outside the Town of Jackson and the Jackson Planned Expansion District
was made. Potential problems with this approach included legal implica-
tions of preparing a contract that would bind a legislative body beyond
its term of office, and difficulties in obtaining easements under such
a plan.
On October 25, 1977, EPA notified the Mayor of Jackson that while it
preferred the alternative which included expansion of the existing
treatment facilities, the agency could approve a South Park site under
the following conditions developed jointly by the Town of Jackson and
Teton County:
1. New taps along the proposed interceptor line outside the Town
of Jackson should be approved by Teton County, or jointly by
by town and county.
2. The maximum number of residential units outside the Town tap-
ping into the line each year should be specified (allowances
for an increase each year should also be considered).
3. All residential units tapping into the proposed interceptor
should comply with the provisions of the Comprehensive Plan,
or at least be compatible with its provisions dealing with
physical environmental constraints (i.e., floodplains, steep
slopes, and high groundwater).
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4. The period of effect of these conditions must be specified
(i.e., ten, 20, or 40 years, life of the project, or life of
the interceptor).
5. The Town and County should enter into a contractual arrange-
ment with EPA, or develop another mechanism to assure that
conditions are binding, including a provision allowing any
citizen of Teton County to enforce these restrictions. The
restrictions agreed to by the Town of Jackson, Teton County,
and EPA could then be incorporated as grant conditions to the
Step III construction grant.
Initially, these conditions were ,not met favorably by either the Town or
the County. As a result, the firm of Biscoe, Murray, Maphis and Lamont
was hired by EPA on December 14, 1977, to negotiate a settlement. The
proposed set of conditions developed by the mediator in the ensuing
months included a plant capacity based on a six (6) percent growth for
1995, and "out-of-city" tap-in allocation of 51 equivalent taps per
year. Following a legal opinion from EPA on February 8, 1978, which
stated that such contractual arrangements were indeed binding, a subse-
quent meeting was scheduled in Washington, D.C. to sign the proposed
agreement. However, at the meeting a significant amendment was sub-
stituted to the agreement permitting Teton County to independently
establish its own growth management policy as an element of the County's
Comprehensive Plan. The amendment stipulated that the tap-in rate be
determined no later than the date the treatment plant became operational.
On April 13, 1978, the agreement was signed and all parties conceded to
proceed with the updated facilities plan considering only alternative
locations near the proposed South Park Road site. C.E. Maguire, Inc.,
(formerly NHPQ) was selected to update the plan. Due to the difficulty
of constructing an outfall line to the Snake River that would remain
hidden (a probable requirement of the Wild and Scenic River Study iden-
tified in the draft EIS), it was decided to investigate a non-discharg-
ing lagoon/rapid infiltration land application system. Also, because
land costs are extremely high in the area, the decision was made to
consider the option of constructing a mechanical plant (oxidation ditch)
in order to reduce these costs and land requirements.
On September 11, 1978, the facilities plan alternatives were presented
to the Jackson Town Council, at which time agreement was reached that
the South Park Lower Bench site with an aerated lagoon/rapid infiltra-
tion system should be the recommended plan. Formal approval of the
recommended plan was received from the Town of Jackson by C.E. Maguire,
Inc., on September 29, 1978.
In October, 1978, the draft Jackson, Wyoming 201 Wastewater Facilities
Plan Update was completed by C.E. Maguire, Inc. The following section
outlines the wastewater management alternatives developed in the
facilities plan, followed by a brief discussion of tjie major issues and
potential controversies surrounding the respective wastewater treatment
alternatives.
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B. DESCRIPTION OF SELECTED PROJECT AND ALTERNATIVES
The project selected by the Town of Jackson was developed following the
decision by EPA not to fund a deep aerated stabilization pond system in
the South Park Elk Feedground because of probable adverse impacts iden-
tified in the draft EIS. The project involves construction of an aerated
lagoon/rapid infiltration treatment system on approximately 40 acres of
land at the South Park Lower Bench site (Alternative 3), (Figure 4).
The land has been dedicated to the Town of Jackson for the facility,
with an additional ten acres of land for future expansion being offered
to the Town for sale.
Two lagoon cells would be aerated, with the third serving as a storage
basin. Approximately seven infiltration beds would be built for efflu-
ent disposal with material excavated from the east side of Flat Creek.
This proposal and the three alternatives considered in the plan also in-
volve a septic tank dump station.
The selection of the lagoon/rapid infiltration treatment alternative was
based on the following considerations:
• Lowest average annual and annual operation and maintenance
(O/M) costs.
• The use of rapid infiltration beds does not involve a discharge
to Flat Creek except during the winter if ice conditions in
the beds prevent their use.
• Visual impacts and odor problems are considered minor.
• No problems are anticipated in site acquisition, and the pro-
posed location includes adequate land for future expansion.
• Sludge management requirements are minimal for a lagoon system.
• The site is not located in the 100-year floodplain.
• No major impacts should occur on elk migration, and the pro-
ject may have significant beneficial effects on fish and
waterfowl habitats.
• The system provides for treatment and energy consumption is low.
The project would also require installation of a four mile long (22,000
feet) interceptor pipeline running south through South Park along the
general Flat Creek route to the Lower Bench site (Figure? ). This
route has the lowest average annual and capital costs to the town. Pre-
liminary discussions with local land owners also indicate that no
major right-of-way problems are anticipated.
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Other treatment alternatives to the selected project which are evaluated
in detail in this EIS document include an aerated lagoon/rapid infiltra-
tion system located at the South Park Upper Bench site near U.S. Highway
189 (Alternative 1)(Figure 2). As with the Lower Bench Site, the upper
site is not located in the 100-year floodplain. Although the site is
owned by the same individual as the selected location, there is reluc-
tance to sell the site due to higher development values, and the poten-
tial for adverse visual impacts from the highway.
Treatment Alternative 2 utilizes an oxidation ditch process at the Upper
Bench site (Figure 3). This type of plant is typically an activated
sludge process that uses a continuously recirculating loop channel or
channels (in this case two loop oxidation basins) as an aeration basin.
Approximately four (4) acres of land at the Upper Bench location are
required for the system, with an additional 15 acres of land needed for
sludge burial.
The final treatment alternative (Alternative 4) considered in the facil-
ities plan and described in this document is an oxidation ditch process
at the Lower Bench site (Figure 5). However, the proposed method for
sludge disposal involved truck transport due to soils and groundwater
conditions at th site which prohibited burial or land application.
Comparative treatment works costs for the selected project and alterna-
tives are presented in Table 1. Estimated costs are provided for total
capital investment for the treatment facilities, annual operation and
maintenance, equivalent annual cost, and average annual cost to the Town
of Jackson. The equivalent annual cost represents the costing approach
which EPA uses to determine the cost-effectiveness of treatment alterna-
tives. The annual average cost to the Town of Jackson differs from the
equivalent annual cost provided, assuming that EPA will participate in
75 percent funding of the aerated lagoon and oxidation ditch system, and
85 percent funding for the rapid infiltration beds as an "innovative
process and technique". Thus, the average annual cost to the Town more
closely approximates the real cost to the community than does the equiv-
alent annual cost. A detailed discussion of these costs is presented
in Section IV of this document.
In addition to the selected Flat Creek route, an alternative interceptor
route was considered in the Facilities Plan Update. The County Road
alternative route is shown in Figure 6. The route would start at the
Town of Jackson and follow a westerly alignment to the County Road south
for three miles before turning east to Flat Creek, then south to the
Lower Bench site, (approximately 31,490 feet total length), or southeast
to the Upper Bench site (approximately 32,920 feet total length). Due
to the existing narrow right-of-way along County Road, and limited pur-
pose easements, this option would require additional easements for
sewer alignment.
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FIGURE 2
ALTERNATIVE 1-AERATED LAGOONS/RAPID INFILTRATION SYSTEM
AT SOUTH PARK UPPER BENCH SITE
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FUTURE
EXPANS
AREA
**«
**•*•» * * •*£.»•*^ -Jr
STATE ELK FEEDING REFUGE
FIGURE 4
ALTERNATIVE 3-AERATED LAGOONS/RAPID INFILTRATION SYSTEM
AT SOUTH PARK LOWER BENCH SITE
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FIGURE 6
INTERCEPTOR SEWER LINE
COUNTY ROAD ALTERNATE ROUTE
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LOWKlf Sin* flH
\
EXITING WWTP
ii i. y m
I fj illi rP
sf if Mil 1:1
!J i IHi iH
FIGURE 7
INTERCEPTOR SEWER LINE
FLAT CREEK ALTERNATE ROUTE
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LEGEND
1- LAB, SLUDGE HANDLING CONTROL BUILDING
2.- OXIDATION DITCHES
3.- CLARIFIERS
4.- CHLORINE CONTACT CHAMBER
5.- AEROBIC DIGESTER/SLUDGE STORAGE
SOURCE: C.E. MAGUIRE 1078
SOUTH PARK
INTERCEPTOR
FIGURE 3
ALTERNATIVE 2
OXIDATION DITCH AT
SOUTH PARK UPPER BENCH SITE
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OJ
SOUTH PARK ^
INTERCEPTOR
LEGEND
1- LAB. SLUDGE HANDLING CONTROL BUILDING
2.- OXIDATION DITCHES
3.- CLARIFIERS
4.- CHLORINE CONTACT CHAMBER
5.- AEROBIC DIGESTER/SLUDGE STORAGE
SOURCC: C.E. MAGUIRE 1878
FIGURE 3
ALTERNATIVE 2
OXIDATION DITCN At
SOUTH PARK UPPER BENCH SITE
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TABLE
ALTERNATIVE TREATMENT COST ESTIMATES,
TOWN OF JACKSON 201 WASTEWATER FACILITIES PLAN
Average
Capital Equivalent Annual
Alternative Cost Annual O/M Annual Cost to
No. Description ($) Cost ($/YR) Cost ($/YR) Town ($/YR)
Aerated 2,286,000 61,700 271,200 140,200
Lagoon/Rapid
Infiltration
At Upper
Bench Site
Oxidation 2,903,000 123,000 389,100 198,600
Ditch At
Upper Bench
Site
Aerated 2,342,000 61,700 277,100 110,800
Lagoon/Rapid
Infiltration
At Lower
Bench Site
Oxidation 2,801,800 123,000 379,800 189,100
Ditch At
Lower
Bench
Site
c
Source: c.E. Maguire, October, 1978
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Comparative cost estimates of the two interceptor routes for the Upper
and Lower Bench sites 'are presented in Table 2. These estimates assume
EPA will participate in 75 percent of the funding of the sewer inter-
ceptor line. Costs are largely determined by interceptor length.
C. MAJOR ISSUES AND POTENTIAL CONTROVERSIES SURROUNDING EACH ALTERNATIVE
A detailed discussion of the major issues and potential controversies
surrounding the selected project and proposed alternatives is presented
in Sections IV and V of this document. These impacts generally fall
into seven major categories:
1) Surface and groundwater quality;
2) Land use and growth versus the Tri-Party, Tap-In Agreement;
3) Secondary effects on public services and facilities;
4) Public attitudes and preferences;
5) Costs;
6) Odor problems and visual intrusion; and
7) Effects on important fish and wildlife resources.
A brief narrative on the impacts of the selected project for those
categories is included in this section, followed by a summary discussion
of the impacts for the alternatives identified in the Facilities Plan
Update.
Selected Project (Aerated Lagoon/Rapid Infiltration Lower Bench Site,
Flat Creek Interceptor Route
• Surface and groundwater quality.
An aerated lagoon/rapid infiltration system at the Lower Bench
site would not involve discharge to Flat Creek under normal
operating conditions. Therefore, effluent limits identified
by EPA in the draft NPDES permit for Flat Creek would apply
only during possible winter discharge (in the event the infil-
tration basins fail due to icing). While the selected project
would undoubtedly improve Flat Creek water quality, the pro-
posed site is characterized by high groundwater conditions
(0.6 to 6.2 feet below the surface). For this reason, careful
design and management of the system to avoid problems with
groundwater mounding, and a system of groundwater observation
wells and monitoring program will be required to better define
the recharge area. It should also be noted that by removing
the effluent discharge to Flat Creek, flows will be reduced by
approximately 1.6 cfs in the reach of the stream between the
existing treatment plant and the proposed Lower Bench site.
• Land use and growth versus the Tri-Party, Tap-In Agreement.
The potential impacts of locating the Town of Jackson waste-
water treatment plant at the Lower Bench site are in part
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TABLE _2_.
ALTERNATIVE INTERCEPTOR ROUTE COSTS,
TOWN OF JACKSON 201 WASTEWATER FACILITIES PLAN. /
Capital Annual Equivalent Average Annual
Cost O/M Cost Annual Cost Cost to Town
Interceptor Route ($) ($/YR) ($/YR) ($/YR)
County Road
Upper Bench
County Road
Lower Bench
Flat Creek
Upper Bench
Flat Creek
Lower Bench
3,627,300 14,510 344,480 87,150
o
3,497,700 13,990 332,170 84,040
2,197,300 8,790 208,670 52,790
2,065,900 8,300 196,190 49,650
Source: c.E. Maguire, October, 1978
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dependent upon out-of-city tap-in priorities and the number of
out-of-city taps developed Teton County in accordance with the
Tri-Party, Tap-In Agreement. Other political actions which
have not been fully determined and could potentially affect
local growth and develop ment patterns would be the decision
by the County to fund additional wastewater treatment capacity
beyond the proposed 3.5 mgd at its own expense; any determina-
tion by the Town and County to amend the existing Jackson
Planned Expansion District (this area is excluded from the
"out-of-city taps" definition, and is subject to the Town's
development standards); or any amendments to the Teton County
Comprehensive Plan and Implementation Program which would
result in significant revisions to existing land use district
boundaries, authorized uses, or reductions in development
permit requirements (minimum acreages) and development stan-
dards. For example, should an excessive number of annual
out-of-city taps be allowed, it is likely that the planned
wastewater facility would not be capable of adequately treat-
ing the projected flows through the year 1995, given the ex-
pected six (6) percent growth rate. This situation would
result from additional development in areas of the South Park
where such development is currently limited due to wastewater
treatment constraints (°i.e., high groundwater, septic tanks).
The close proximity of the Flat Creek Interceptor would fur-
ther complicate the situation. Likewise, any decision by the
County to increase the treatment plant capacity in combination
with a high annual number of out-of-city taps could have a
major impact on land development patterns in South Park in
terms of a potentially increased service area and subsequent
pressure for growth resulting from fewer development restric-
tions (i.e., wastewater treatment).
Secondary effects on public services and facilities
Numerous studies have shown that changes in land use do occur
as expanded centralized sewer facilities replace septic tanks.
These changes are invariably accompanied by substantial re-
quirements for additional public services and facilities. The
decision to locate the Town of Jackson wastewater treatment
plant at the South Park Lower Bench site will place additional
pressure on -the County's ability to provide adequate schools,
police and fire protection and transportation facilities; as
well as increase costs for those services.
The service most likely to be adversely affected as a result
of implementation of the selected project would be schools.
During the past ten years, school attendance has increased an
average of 1.93 percent a year, considerably above the nation-
al norm. As a result, the three existing school facilities
serving the Town of Jackson and South Park area are at or
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near capacity, resulting in the need for a new high school
which is currently under construction at an estimated cost of
$4.5 million. Discussions with Jackson School District offi-
cials indicate that the continuation of recent development
trends in lower South Park will result in the need for an
additional elementary facility in the area within the next
three years. Other important public services not paid for by
developers as a portion of the total development costs which
will undoubtedly be impacted by the proposed project include
police and fire protection. While the Jackson Police Depart-
ment and the Teton County Sheriff's Office acknowledge that
additional growth in the South Park area will increase depart-
ment responsibilities, both indicated they anticipated no
major problems with serving the additional population, pro-
vided their respective manpower forces were proportionally
increased with the growth. The level of growth potentially
facilitated by central sewer availability may also result in
the need for the County to require public water for new sub-
divisions sufficient to provide adequate fire protection.
This requirement is currently being imposed by the Town of
Jackson within one (1) mile of its jurisdictional boundaries.
Public attitudes and preferences.
At the second of two public workshops held in connection with
preparation of the draft EIS, a majority of citizens attending
the session rejected the proposed South Park Road location.
The most common reason given was potential adverse effects of
additional development in Lower South Park facilitated by
sewer availability; and the unavailability or high costs of
land in the area for locating the proposed stabilization
ponds. Although the results of the recent Jackson Town Coun-
cil and Teton County Commission races tend to indirectly
contradict this opinion to some degree (winners of both races
generally indicated opposition to limiting the number of sewer
hookups in South Park), the conclusions of the workshop along
with those of an earlier summary questionnaire on the proposed
Comprehensive Plan indicating a desire for controlled growth
would seem to represent the basic views of the area's resi-
dents'. Approximately 40 acres of land have been dedicated
to the Town for the proposed project, with an additional ten
(10) acres of land for future expansion available for sale.
Costs for acquiring the future expansion land would probably
be minimal.
Project costs.
Comparative cost estimates for the selected treatment works
and alternatives are shown in Table 1. Costs are presented as
capital costs, annual O/M costs, equivalent annual cost, and
average annual cost. Total capital costs for the selected
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project are approximately $2,342,000. This figure is approxi-
mately $540,200 less than for the oxidation ditch alternative
at the Lower Bench site. Average annual costs to the Town are
lowest for aerated lagoon/rapid infiltration system at the
Lower Bench site. This is due in part to the assumption that
EPA will fund 85 percent of the infiltration beds as innovative
or alternative wastewater treatment processes, and that the 40
acres of land at the Lower Bench site needed for the lagoons
would be donated to the Town of Jackson. Annual 0/M costs are
also considerably lower for the aerated lagoon/rapid infiltra-
tion alternatives (approximately one-half of the oxidation
ditch alternatives).
Comparative costs for the two interceptor alignments are pre-
sented in Table 2. These costs are largely determined by
size, length, depth and trenching conditions. Costs shown
assume 75 percent EPA participation, and are for total capital
investment, annual 0/M, equivalent annual cost, and average
annual cost to the Town of Jackson. Tptal capital costs for
the Flat Creek route to the Lower Bench site are approximately
$1.4 million less than the County Road Alignment. This is
largely due to the County Road route being 9,490 feet longer,
and requiring approximately four miles of resurfacing follow-
ing trenching and alignment. The Flat Creek route to the
Lower Bench site also offers the lowest average annual cost
($49;630/year) and lowest capital cost to the Town ($516,474).
Odor problems and visual intrusion.
An aerated lagoon/rapid infiltration system will undoubtedly
periodically produce some odor nuisance. However, the poten-
tial for seasonal nuisance is considered slight, provided
aeration equipment is properly functioning. The immediate
location area is also very sparsely populated. Although the
proposed project will require approximately 40 acres of land
for construction of the lagoons and infiltration beds, the
Lower Bench site is better shielded from the views of local
residences than the Upper Bench site, and is not highly visi-
ble from the existing road. Extensive landscaping is planned
to further minimize visual impacts of the facility on the
residence to the north.
Effects on important fish and wildlife resources.
Excavation work along the Flat Creek interceptor alignment
will undoubtedly create some short-term turbidity problems in
Flat Creek, with corresponding impacts on the local fishery
resources. However, contract specifications and compliance
with the requirements of regulatory agencies (i.e., sedimenta-
tion basins to remove suspended solids before discharge to the
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stream or for irrigation uses, diffusers to reduce soil erosion
and ditchbank slumping) will minimize impacts on water quality
and aquatic life. The adjacent Flat Creek wetlands habitat
would be expected to be enhanced through the construction of
several small lakes along the watercourse. The lakes would be
created as a result of excavation of materials for construc-
tion of the infiltration beds. The project is not expected to
have major effects on the elk migration, but will require the
relocation of a gate at the State Elk Feedground to allow
migrating elk access to the feedground.
Rejected Treatment Alternatives
• Alternative 1- Aerated Lagoon/Rapid Infiltration Upper Bench
Site.
This alternative would utilize the same treatment process as
previously described for the selected project. However, the
treatment facilities would be located at the Upper Bench site.
Water quality impacts of this alternative would also be similar
to those discussed for the proposed project. A major advan-
tage of this site would be the greater depth to groundwater
which is approximately 15 feet. This location would not
require the importation of fill material for construction of
the infiltration beds. Effects of this proposal on land use
and growth patterns in South Park, as well as future public
services and facilities requirements, would be identical to
those for the Lower Bench site, and determined by the effec-
tiveness of the Teton County Comprehensive Plan and Implemen-
tation Program to guide and manage future development. Al-
though capital, O/M and equivalent annual costs are essentially
the same for Alternative 1 and the proposed project, the
average annual cost to the Town of Jackson is approximately
$29,400 more for the Upper Bench location due to the require-
ment to purchase the 40 acres for the site. This land is not
eligible for EPA funding assistance. Additional problems at
the site involve available land area for future expansion
which is severely limited. Visual impacts associated with the
Upper Bench site are much greater than those for the lower
site due to its close proximity to U.S. Highway 189. This
alternative would not have significant impacts on elk migra-
tion or waterfowl habitat.
• Alternative 2 - Oxidation Ditch at South Park Upper Bench
Site.
Alternative 2 would involve the u^e of an oxidation ditch
treatment process at the Upper Bench site. This system in-
volves an extended aeration type of activated sludge process
using two continuously recirculating closed loop channels as
aeration basins. The configuration also involves two clari-
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fiers, an aerobic digester/sludge storage basin, and chlorine
contact chamber. Unlike the proposed project, this option
would involve discharge to Flat Creek. The primary water
quality impacts for this system include significant decreases
in BOD, fecal coliform, ammonia nitrogen, total phosphate and
total suspended solids in comparison to the present situation,
due to improved treatment efficiencies and effluent limita-
tions described in the Town's NPDES permit. It does not
appear that recommended phosphorus concentrations or instream
toxic ammonia levels for cold water fisheries would be exceed-
ed at design flow. The alternative would require only four
acres of land, with an additional 15 acres needed for sludge
burial or approximately 320 acres for land application. The
location of the facility and its impacts on South Park land
use and development patterns, and public services and facili-
ties requirements, are the same as those described for Alterna-
tive 1. Capital cost for this treatment alternative is approxi-
mately $561,000 more than for the selected option. Operation
and maintenance and average annual costs to the Town of Jackson
are also substantially higher for this alternative. Visual
effects of the facility would be lessened through extensive
landscaping. The potential for odor problems would be greater
for this system than the selected project due to the higher
potential for equipment breakdown, particularly during cold
weather operation. Elk migration would not be affected mea-
surably by this option.
Alternative 4 - Oxidation Ditch at the Lower Bench Site.
The primary and secondary impacts of construction of an oxi-
dation ditch mechanical treatment facility at the Lower Bench
site would be the same as those for Alternative 2. The system
would be designed to meet NPDES effluent limitations. Com-
pliance would also be met for monitoring and any additional
requirements defined in the permit. Flat Creek water quality
would be expected to improve. Land use changes and develop-
ment patterns would be determined by comprehensive planning
goals and policies and development regulations, and the annual
number of out-of-city taps allowed by the Town and County.
Costs are comparable to those for Alternative 2. Potential
visual intrusion is considered less at this site due to its
remoteness. Sludge hauling problems are somewhat greater than
for the upper Bench site because access is through South Park
and private lands, rather than directly to the highway.
Rejected Interceptor Route
*
The County Road interceptor routes to the Upper and Lower Bench sites
were rejected on the basis of comparative costs, route availability, and
construction impacts. Total capital costs for the County Road route to
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the Lower Bench site, for example, were approximately $1.4 million more
than for the Flat Creek Lower Bench route. This difference is due to
the County Road route being approximately 9,500 feet longer, and an
additional requirement to resurface approximately four miles of County
Road as a portion of the project. Discussions with land owners along
the County Road routes also indicated a potential problem in securing
sewer line easements. Construction along the County Road would also
result in disruption and rerouting of local traffic.
D. IMPACTS AND POSSIBLE SOLUTIONS
The major issues and potential controversies are discussed in detail in
Section V of the Final EIS document. These impacts and possible solu-
tions in their approximate order of significance are briefly described
in the section that follows. It should be noted that the "Tri-Party
Agreement," which must be considered a major issue in the EIS process,
is not discussed as an issue by itself, but rather in the context of
how it may affect several of the issues identified in this section.
1) Flat Creek Water Quality
Problem - Flat Creek water quality is significantly impacted by
discharge from the Jackson Treatment plant. Water quality data
collected by the Teton County 208 Program and other studies indi-
cate that fecal coliform standards are frequently exceeded down-
stream from the plant, with ammonia and total phosphate concentra-
tions also showing substantial increases. The existing treatment
facilities are not capable of meeting the draft NPDES permit re-
quirements established by EPA.
Solution - The Jackson, Wyoming 201 Wastewater Facilities Plan
Update (October, 1978) identified four alternative wastewater
treatment systems for the Town of Jackson. Selection and imple-
mentation of one of these alternatives would provide the Town of
Jackson with treatment facilities designed to adequately serve the
community through 1995.
Option 1 - This option involves selection of a no-discharge alter-
native. An aerated lagoon/rapid infiltration system at either the
Upper or Lower Bench site would not involve discharge to Flat
Creek, and also would not be subject to effluent limitations iden-
tified in the draft NPDES permit. The discharge of effluent for
current estimated peak wastewater flows (approximately 1.59 mgd)
treated by the Jackson treatment plant would be eliminated. This
option would significantly improve Flat Creek water quality. The
dilution factor for groundwater flow would be adequate to protect
groundwater'quality.
Option 2 - A second option would be the selection of an oxidation
ditch system located at the Upper or Lower Bench site. This sytem
would discharge to Flat Creek, and involve additional sludge dis-
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posal requirements. Treatment efficiencies would be improved sig-
nificantly over the existing system. However, this option would
still involve discharge to Flat Creek. Estimated 1995 flows are
projected at 3.50 mgd.
Conclusion - Maximum protection of Flat Creek water quality is pro-
vided by the no-discharge alternative. The level of treatment
achieved by the system, combined with the background quality and
5:1 dilution factor would not be expected to result in any viola-
tions of drinking water standards for the groundwater. A ground-
water monitoring system would be required at the site to measure
background levels and water quality impacts.
2) Land Ose Changes in South Park and the Teton County Comprehensive
Plan and Implementation Program
Problem - The proposed location for the selected treatment facility
will provide the potential for increased urban type development in
South Park due to the availability of central sewer facilities.
This growth potential is in direct conflict with the goals and
policies of the Teton County Comprehensive Plan and Implementation
Program which generally encourages the preservation of the "ranch-
ing lifestyle and economy," designates South Park for low density
development, and specifies that sewage treatment plants and other
facilities should be located where they will not foster scattered
development. The potential growth impacts of the proposed location
are also contrary to the public opinion shown in polls conducted by
the County.
Solution - In order to minimize this conflict, the Town of Jackson,
Teton County and EPA have entered into a tri-party agreement which
attempts to restrict the number of out-of-city tap-ins to the
treatment plant. The number of out-of-city tap-ins by the County
must be determined prior to completion of the facilities.
Option 1 - Select the proposed alternative (South Park Lower Bench
site) for construction of an aerated lagoon/rapid infiltration
treatment system. The selection of an oxidation ditch treatment
process would have similar effects on land use development patterns.
Option 2 - Study the feasibility of a new location for the treat-
ment plant in closer proximity to the Town of Jackson and the
proposed Jackson Expansion Area. One such option would be the
Boyle's Hill location which was identified in the draft EIS.
Conclusion - The Facilities Plan Update has identified the South
Park Lower Bench site with an aerated lagoon/rapid infiltration
system as the most cost-effective, environmentally sound, and
publicly acceptable alternative. The Jackson Town Council gener-
ally supports this recommendation. Similarly, a majority of the
Teton County Commission (1979 elected term) have also indicated
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support. This support, coupled with a carefully defined out-of-
city tap-in rate, will result in an implementable solution to the
area's wastewater treatment needs. However, the decision will also
probably result in the need to amend the County's Comprehensive
Plan and Implementation Program to the theme of urbanization of
South Park. Most of this area, which includes approximately 6,500
acres of undeveloped land, is currently planned for a maximum
development of one (1) unit per six (6) acres, or not more than one
(1) unit per three (3) acres if groundwater levels drop below three
(3) feet upon removal of irrigation. These density limitations are
based primarily on wastewater treatment constraints, which would be
effectively removed by central sewer availability.
3) Costs of the Wastewater Systems
Problem - Minimizing federal and local expenditures for construc-
tion and operation and maintenance of a wastewater treatment facil-
ity is a primary goal in the overall facilities planning process.
The use of innovative or alternative wastewater treatment processes
and techniques can also provide additional federal funding assis-
tance (85 percent of the cost of construction as opposed to 75
percent for conventional treatment system). Cost information for
the four treatment alternatives and alternate interceptor align-
ments analyzed in the Facilities Plan Update are presented in
Table 3. These costs are based on a 1995 design flow of 2.65 mgd,
plus capacity to handle uncorrected infiltration (approximately
0.85 mgd).
Solution - A financing plan that provides the least expensive, most
effective and publicly acceptable solution to the collection and
treatment of the Town's wastewater should be selected and imple-
mented. These criteria would tend to eliminate several of the
options analyzed in the Facilities Plan Update from further consid-
eration.
Option 1 - Implementation of Alternative 3, an aerated lagoon/rapid
infiltration system at the Lower Bench site would provide the most
financially feasible option to the Town of Jackson. This option in-
volves a total estimated capital cost of $2,342,000, and an average
annual cost to the Town of Jackson of $110,800. This option also
provides the lowest annual O/M cost of the proposed alternatives.
The Flat Creek interceptor route to the Lower Bench site has the
lowest capital cost and average annual cost to the Town of Jackson.
Option 2 - Selection of the oxidation ditch treatment process at the
Lower Bench site would provide an effluent system at an estimated
cost of approximately $2.8 million. The average annual cost to the
Town of Jackson for this option would be approximately $190,000.
Annual O/M costs (approximately $123,000) are higher for this
mechanical process.
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Conclusion - Implementation of Alternative 3 would minimize costs
to the Town of Jackson. Under this option, the majority of land
area required for the facility would be dedicated to the Town. ;
Also, the rapid infiltration process would qualify for 85 percent
EPA funding assistance.
3) Associated Public Services and Facilities Investment
Problem - The relationship between sewer service and land use
development patterns, and the influence of the pair on public
services and facilities investment is a difficult problem to
address. Without effective land use controls, the location of an
interceptor may result in scattered development patterns, and ex-
cessive costs for providing adequate schools, police and fire pro-
tection, and transportation facilities.
Solution - The selection of a wastewater management alternative
which is appropriately sized to serve the projected 1995 popula-
tion, and more importantly one that includes a reasonably defined
service area, will reduce future community services and facilities
costs.
Option 1 - The Town of Jackson and Teton County can establish a
mutually acceptable "community service area" for the proposed
wastewater treatment facilities. This service area would take into
account all public services and facilities. Providing sewer service
outside this area would be subject to Town and County approval, and
would be required to comply with the overall comprehensive plan-
ning programs of these entities.
Option 2 - The Town of Jackson and Teton County can establish an
annual out-of-city tap-in agreement as part of Teton County's Com-
prehensive Plan and Implementation Program. This agreement would
take into account fiscal and other forms of impact upon the Town
and County, scenic preservation activities, schools and other com-
munity service systems.
Conclusions - In order to minimize future public services and
facilities investment, the Town of Jackson and Teton County must
develop an annual out-of-city tap-in agreement as part of the
County's Comprehensive Plan and Implementation Program. This
agreement should include the definition of a mutually acceptable
"community service area," and be based on the six (6) percent
growth figure established in the Facilities Plan. Priorities for
out-of-city tap-ins must be defined. These priorities may be
defined as "phased expansion areas," and should be determined on
the basis of the community's ability to provide all necessary ser-
vices and facilities, as well as compatibility with local compre-
hensive planning programs.
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5) Odors and Visual Intrusion
Problem - The present wastewater treatment plant has objectionable
odors and is unsightly. Consideration of aesthetics in the design,
construction, and operation of wastewater treatment works is neces-
sary to minimize significant adverse effects.
Solution - A successful wastewater facility site design makes use
of the existing and developed features of the site to satisfy the
demands of the treatment facility and its neighbors. Selection of
a site removed from present and future residences will help to re-
duce visual and odor problems. Proper design and operation minimize
odor problems.
Option 1 - Select an oxidation ditch or aerated lagoon/rapid infil-
tration treatment alternative at the Upper Bench site. This option,
as well as Option 2, would include development of a site plan, I
landscaping, and adequate buffer areas.
Option 2 - Select an oxidation ditch or aerated lagoon/rapid infil-
tration treatment alternative at the Lower Bench site.
Conclusion - The Lower Bench site would be less visually impacted
than the Upper Bench site, due to the latter's closer proximity
to U.S. Highway 189. Similarly, potential odor problems would also
probably be less at the Lower Bench site due to the remoteness of
the location. It should also be noted that the Lower Bench site
does provide adequate land area for future expansion of the facili-
ties. Approximately $60,000 has been included in the proposed
budget for the recommended wastewater management plan (Alternative
3) to landscape and fence the facility.
Particular attention in the Step 2 design phase of the project
should be directed to building orientation and aesthetics, access,
and landscaping for the facilities. Public input during the Step 2
design phase is welcomed. The feasibility of utilizing the pro-
posed interceptor right-of-way for potential recreational oppor-
tunities should also be considered.
6) Wild and Scenic River Study
Problem - The section of the Snake River flowing from Teton National
Park to Palisades Reservoir is a candidate for classification as a
"Wild and Scenic River" under the provisions of the Wild and
Scenic River Act (P.L. 90-542). The designation potential identi-
fied for the river is "recreation." An important criteria in the
evaluation of wastewater treatment options for the Town of Jackson
must be the selection of an alternative which would not damage the
potential for this designation.
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Solution - The Town of Jackson should consider only those alterna-
tives which would not jeopardize the eventual designation of the
Snake River as a "recreation" classification. This designation
potential has been identified, and it is currently assumed that the
final statement to be issued during the summer of 1979 will be for
such a classification. Management objectives of the classification
include optimization for public use, and permitting new structures
for habitation and public use in close proximity to the river.
Option 1 - The Town of Jackson can select the proposed alternative
(aerated lagoon/rapid infiltration system at the Lower Bench site) ,
or.the same treatment system at the Upper Bench site. Neither of
these options involve an outfall line and discharge to the Snake
River. The alternatives also would not require extensive archi-
tectural treatment identified for several of the options discussed
in the draft EIS to adequately reduce the visibility and obtrusive-
ness of an outfall line.
Option 2 - Select either of the two oxidation ditch treatment
alternatives which involve a discharge to Flat Creek.
Conclusion - While none of the facilities planning options involve
a discharge to the Snake River, the two rapid infiltration treat-
ment Alternatives identified in the Facilities Plan Update provide
the best degree of protection to Flat Creek and the Snake River
water quality. The design engineer has projected a 5:1 water
quality dilution ration between the groundwater and infiltrated
wastewater. The proposed level of treatment provided by the rapid
infiltration system, and the projected dilution factor, would appear
to be sufficient to adequately protect local surface water quality
for the proposed "recreation" classification currently being con-
sidered under the Wild and Scenic River Act.
E. EPA'S DECISION ON THE SELECTED PROJECT
EPA and the Wyoming Department of Quality propose to approve in
thirty days the Jackson Facility Plan update. This grant approval will
allow the Town of Jackson to authorize its consulting engineer . to com-
plete engineering plans and specifications for the selected treatment
alternative of a lagoon/rapid infiltration system at the lower bench
site utilizing the Flat Creek interceptor route. This approval includes
the following grant conditions:
1. The provisions agreed to in the April 13, 1978, Tri-Party
agreement are binding conditions on the Town of Jackson,
Teton County, and EPA. Said agreement in its entirety shall be
conditions to this acceptance of this grant. One major pro-
vision of the April 13, 1978, agreement is the completion of
Teton County's out-of-city tap in provisions. This policy
statement is due to EPA prior to sewage facility operation.
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According to the present schedule, these facilities should be
operational by July 1, 1980. The County is reminded that its
out-of-city tap in policy is due by that date or earlier.
EPA has determined additional groundwater data is necessary
in order to complete the design for the rapid infiltration
basins. The Town of-Jackson will be required to direct its
consultant to obtain depth to groundwater measurements dur-
ing the seasonal high (May s June of 1979), to drill a new
well and run an aquifer pump test, and to determine the
rate of groundwater flow by dye tests. EPA shall require
that the minimum separation between the seasonal high ground-
water and the bottom of the infiltration basin shall be three
feet. No additional facility plan work is required since
these additional items can be accomplished under the Step
II grant. This delay in completing the design for the infil-
tration basin will not delay the interceptor and lagoon por-
tions of the facility. EPA expects that the interceptor and
lagoon design will be submitted to the Wyoming Department
of Environmental Quality no later than July 1, 1979. If the
additional ground water data indicates conditions are so
adverse so as not to provide the expected dissipation of
effluent, an alternative site may need to be acquired. Thus,
if the lower bench site were determined to be unsuitable for
rapid infiltration, the upper bench site may have to be
acquired by the Town. •.-
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SOUTH PARK
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-908/5-79-001A
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Summary Final Environmental Impact Statement
Jackson Wastewater Treatment System
Town of Jackson, Wyoming
5. REPORT DATE
Fghrnary 19 1Q7Q
i. PERFORMING'ORGANIZATION CODE
8W-EE
7. AUTHOR(S)
Ed Cryer, James M. Montgomery Engrs.
Weston W. Wilson, EPA
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
J.M. Montgomery Engineers
1301 Vista Ave.
Boise, Idaho 83705 (202) 345-5865
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln St.
Denver, Colorado 80295 (303) 837-4831
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Draft Environmental Impact Statement dated May 1, 1977 EPA 908/5-77-002
Final Environmental Impact STatement dated February 12, 1979 EPA 908/5-79-001B
16. ABSTRACT
This 1s a summary of the final environmental Impact statement (EIS) for proposed con-
struction of additional wastewater treatment facilities at Jackson Hole, within
Teton County, Wyoming. The U.S. Environmental Protection Agency (EPA), Region VIII,
Denver, under the authority of Section 201 of the Federal Water Pollution Control
Act Amendments of 1972, 1s authorized to grant 75 percent matching funds for construc-
tion costs of designated wastewater treatment facilities. Sewage discharges as a
result of area growth and development together with non-point source runoff have
degraded the water quality of Flat Creek. Therefor, additional sewage treatment
facilities are needed to meet water quality goals.
The recommended action 1s to construct aerated lagoons followed by rapid infiltration
basins 4 miles downstream of the existing plant. The new facility will enhance
development 1n the undeveloped South Park area. Ground water monitoring will be
required.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Croup
Sewage Disposal. Financing
Sewage IRr1gat1on
Rapid Infiltration Basins
Water Pollution
Infiltration/percolation
Regional Planning
Environmental Impact Statement
Jackson Hole Scenic
Area
Snake River Wild and
Scenic River Study
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
21. NO. OF PAGES
34
20. SECURITY CLASS (Thispage)
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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