United States Region 6 EPA 906/9-82-012
Environmental Protection 1201 Elm Street September 1982
Agency Dallas TX 75270
Water
Environmental Supplemental
Impact Statement Final
Wastewater Treatment
Facilities-Sludge
Management System
Albuquerque, New Mexico
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
12OI ELM STREET
DALLAS, TEXAS 7527O
September 20, 1982
TO ALL INTERESTED AGENCIES, OFFICIALS, PUBLIC GROUPS AND INDIVIDUALS:
Enclosed is a copy of the Final Supplemental Environmental Impact
Statement (EIS) on the awarding of a grant under Section 201 of the Clean
Water Act for construction of a sludge management system for the city
of Albuquerque, Bernalillo County, New Mexico. This EIS has been prepared
in compliance with the National Environmental Policy Act of 1969 and
implementing regulations.
Because changes from the Draft Supplemental EIS are minor, this Final
Supplemental EIS incorporates the Draft Supplemental EIS by reference
and includes the following: (1) a revised and updated summary;
(2) a revised alternatives discussion including changes to the city's
proposed project; (3) EPA's proposed action; (4) revisions necessary
to the draft Supplemental EIS; and (5) EPA's response to comments
received on the Draft Supplemental EIS. This Final Supplemental EIS
shall also serve as the Final Responsiveness Summary.
The Final Supplemental EIS is being distributed to those who made comments
on the Draft Supplemental EIS and to those who requested a copy. The
document is also available for review at the following locations:
1. Albuquerque Public Library
Main Branch
501 Copper N.W.
Albuquerque, New Mexico
2. Prospect Park Branch Library
8205 Apache N.E.
Albuquerque, New Mexico
3. Zimmerman Library
University of New Mexico
Government Publication Department
Albuquerque, New Mexico
4. Esperanza Branch Public Library
5600 Esperanza N.W.
Albuquerque, New Mexico
5. Los Griegos Branch Public Library
1000 Griegos N.W.
Albuquerque, New Mexico
6. Albuquerque Wastewater Treatment
Plant No. 2
North Street S.W.
Albuquerque, New Mexico
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Comments or inquiries on this EIS should be addressed to Mr. Clinton B. Spotts,
Regional EIS Coordinator, at the above address by the date stamped on the cover
sheet following this letter.
Sincerely yours,
#UUL*J 0} . N^j^CAjCCx^^
Whittington, P.E.
Re'gional Administrator
Enclosure
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FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
CITY OF ALBUQUERQUE, NEW MEXICO
SLUDGE MANAGEMENT SYSTEM
Responsible Agency: US Environmental Protection Agency Region 6 (EPA)
Cooperating Agencies: US Department of Agriculture, Soil Conservation
Service; US Department of Energy
Administrative Action: Award of a Construction Grant to the City of
Albuquerque for an innovative/alternative sludge management system.
Contact for Further Information:
Clinton B. Spotts, Regional EIS Coordinator
US Environmental Protection Agency (6ASAF)
1201 Elm Street Dallas, Texas 75270
(214) 767-2716 or FTS 729-2716
Comments on the Final Supplemental EIS Due: 1 5 Nf)V
Abstract: The City of Albuquerque proposes to construct a sludge management
system consisting of sludge thickening and stabilization units at
Treatment Plant No. 2, followed by transfer of sludge via pipeline to
Montesa Park where the sludge will be mechanically dewatered, dried in a
solar greenhouse, disinfected by irradiation with Cesium-137, and
disposed by landspreading on public lands. EPA has evaluated the City's
proposal and 13 additional alternatives. EPA has determined that the
project currently proposed by the City is cost-effective and
environmentally sound. EPA proposes to award a grant to the City of
Albuquerque for the construction of their proposed project.
Responsible Official:
fckWhittington, P.E.
Regional Administrator
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CHAPTER 1
SUMMARY
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1.0 SUMMARY
1.1 DESCRIPTION OF ADMINISTRATIVE ACTION
The National Environmental Policy Act (NEPA) stipulates that each
Federal agency shall "... include in every recommendation or report on
proposals for legislation and other major Federal actions significantly
affecting the quality of the human environment, a detailed statement by the
responsible official on the environmental impact of the proposed action; any
adverse environmental effects which cannot be avoided should the proposal be
implemented; and alternatives to the proposed action ..." This legislation
is the basic framework for the Environmental Impact Statement (EIS).
One of the major EPA programs involving actions that may require an EIS
is the Construction Grants Program, as authorized by the Municipal Wastewater
Treatment Construction Grant Amendments of 1981 (Public Law 97-117). This
law authorizes the Administrator of USEPA to make a grant(s) to a State,
municipality, or intermunicipal or interstate agency for construction of
publicly-owned treatment works. P.L. 97-117 made major provisional changes
to the Clean Water Act of 1977 (CWA), Public Law 95-217. Many of the changes
are directed toward emerging public philosophies, and address concerns about
chemical pollution, resource conservation, resource recovery and recycling,
environmentally compatible treatment systems, and streamlining Federal
involvement in the planning and design of municipal wastewater treatment
facilities. Key provisions of P.L. 97-117 that directly affect the construc-
tion grants program include:
Municipalities will conduct planning and design efforts without
Federal funding prior to requesting construction grants from EPA.
Municipalities are required to consider alternative or innovative
systems that provide for reclaiming, reuse, or recycling of
.wastewater; elimination of discharges; and recovery of energy.
As an incentive for increased utilization of these systems, EPA
may provide 85% funding (through September 1984) for alternative
or innovative systems, as opposed to 75% for conventional sys-
tems, and will pay 100% of the cost of rebuilding or modifying an
alternative or innovative system that fails to meet its permit
conditions or shows higher operation and management (O&M) costs
within two years of completion of construction. All potential
Federal and State funding is subject to availability of limited
construction grant funds.
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0 EPA may provide a 15% "cost effective bonus" (through September
1984) for alternative or innovative systems when compared in a
cost-effectiveness analysis with conventional technologies.
Applicants for grant funds must analyze methods, processes, and
techniques to reduce use of or reclaim energy and to increase the
open space and public recreation potential of lands, waters, and
rights-of-way that are parts of a proposed project.
The objectives of P.L. 97-117 for sewage sludge management are to
ensure protection of public health and the environment by promul-
gation of minimum Federal standards for sludge disposal and
utilization and to maximize beneficial uses of sludges that
conform to Federal standards.
The principal technical planning document for wastewater collection and
treatment in the City of Albuquerque, New Mexico, and several outlying areas
is the Final Albuquerque Areawide Wastewater Collection and Treatment Facili-
ties Plan, which was prepared by the City of Albuquerque in 1977 under the
requirements of the CWA and funded by EPA as Grant No. C-35-1020-01 under the
construction grants program. Since the award of additional grants for design
and construction of any wastewater treatment facilities had the potential for
significant impact(s) to the natural and human environment, EPA determined
that preparation of an environmental impact statement (EIS) was necessary.
Draft and Final EISs were published during June and August 1977, respec-
tively. The 1977 Facilities Plan subsequently was incorporated into the
Albuquerque/Bernalillo County Comprehensive Plan.
On 27 September 1978, EPA published in the Federal Register final regula-
tions implementing significant changes caused by the CWA. Due to increased
significance and new funding incentives placed upon systems involving innova-
tive and alternative technology, energy conservation, resource recovery, new
Federal regulations governing land application of wastewater sludges,
increased public concern regarding odors, and desire to provide more in-depth
analyses of some of the facilities plan proposals and alternative processes,
the City of Albuquerque entered into a program of revising and upgrading its
areawide facilities plan. An additional study entitled "City of Albuquerque,
New Mexico Southside Wastewater Reclamation Plant No. 2 - Phase II Expansion
Report" was published during January 1980. The final version of this report
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was completed during January 1.981 and was received by EPA as a draft facili-
ties plan amendment on 27 January 1981. The City has initiated the review
process required to adopt the report as a final facilities plan amendment and
for having the final facilities plan adopted as an official amendment to the
Albuquerque/Bernalillo County Comprehensive Plan.
EPA determined that the awarding of funds to implement the City's pro-
posed changes was a major action with potentially significant impacts on the
human environment, and on 22 August 1980 issued a Notice of Intent to prepare
a Supplemental EIS (SEIS) on the City's proposed project. The Draft SEIS was
distributed to the public for comment in September 1981.
1.2 DESCRIPTION OF PROPOSED PROJECT
The City of Albuquerque recognized a need for a modified sludge manage-
ment program to supplement its wastewater treatment facilities because of the
evolution of several situations:
Increased quantities of sludge will be generated as a result of
expansion of the City of Albuquerque wastewater collection
system, expansion and modification of treatment Plant No. 2, and
population growth in the Albuquerque area. Existing sludge
drying beds are only adequate to handle approximately 35% of the
10,740 tons per year of dry solids projected for 1990. Compound-
ing the problem, state-owned land being used for dedicated land
disposal of excess sludge currently produced is available to the
City only on an emergency basis.
The public has expressed strong disapproval of sludge drying beds
currently used at Plant No. 2 because of aesthetic and odor
considerations.
New Federal regulations (40 CFR, Part 257.3-6) governing applica-
tion of sludge on land prohibit the continued practice of spread-
ing sludge on parks or golf courses without prior disinfection.
Numerous operation and maintenance problems with the City's
current sludge management system have been encountered since the
City's initial facilities plan was completed in 1977.
Because of these situations, the City's facilities plan amendment proposes
design and construction of a new sludge management system. The City's
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proposed sludge facilities include the following components (i.e., treatment
units):
Sludge thickening will be accomplished by expanded dissolved air
flotation units at Plant No. 2.
Stabilization will be accomplished by new, additional anaerobic
digesters at Plant No. 2.
Transportation of sludge to Montesa Park will be accomplished by
pumping sludge through an 8" PVC pipeline approximately five
miles long. Two lift stations will be required, one at Plant
No. 2 and one approximately half way to Montesa Park.
Conditioning of sludge prior to dewatering will be accomplished
by adding organic polymer(s).
0 Dewatering from 3% to 25% solids will be accomplished by using
belt presses constructed inside an enclosed structure. Complete
sidestream treatment and leachate control systems will be
included.
Drying from 25% to 40% solids will be accomplished using large,
solar-heated greenhouses. Exhaust from the greenhouses will be
scrubbed before being released into the atmosphere in order to
remove odors to the greatest extent possible.
Disinfection of the 40% solid sludge will be accomplished by
exposing the sludge to Cesium-137, a nuclear waste product. This
process will be conducted within a massive underground reinforced
concrete irradiator. Following disinfection, the sludge will be
stockpiled at Montesa Park. The stockpiling will take place
inside an enclosed structure containing a leachate collection
system.
« Disposal of the 90% solid, stockpiled sludge will be accomplished
by the City Parks Department hauling sludge (up to 7000 tons per
year) to city parks and golf courses for ultimate disposal by
landspreading. An additional 3740 tons of sludge per year will
be disposed on other public lands, or by selling to consumers
either in bulk or in bags.
Federal financing for the proposed sludge management facilities has been
requested by the City of Albuquerque. The City's consultants have estimated
the total construction cost of the proposed sludge management facilities to
be approximately $26 million at December 1980 price levels (COM 1980b).
Under current EPA funding guidelines, the proposed project may be eligible
for an 85% grant. In addition, the proposed project potentially is eligible
for a 12.5% grant from the New Mexico Environmental Improvement Division
(NMEID).
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i.3 ENVIRONMENTAL CONSEQUENCES OF THE CITY'S PROPOSED PROJECT
Primary effects to earth resources will result from construction of the
new sludge pipeline from Plant No. 2 to Montesa Park, and construction of
sludge management components at Montesa Park. Soils along the pipeline route
and at Montesa Park have moderately high erosion susceptibility characteris-
tics, thus moderate short-term erosion at both sites is anticipated. Appli-
cation of sludge at the land application sites (e.g., city parks and golf
courses) will have beneficial effects upon the soil and park turf.
Direct impacts on surface water resources will be minor. Surface water
quality in Tijeras Arroyo and the Rio Grande River will not be degraded
significantly unless raw sludge is spilled via a pipeline break. Surface
water quality will be improved over the long-term due to the improved removal
of solids from the plant effluent.
No significant environmental effect on groundwater is anticipated due to
construction and operation of the proposed project.
Direct air quality impacts of the proposed project will occur during the
construction and operation phases. Moderate amounts of fugitive dust will be
generated during plant construction, pipeline construction and construction
of the sludge management components at Montesa Park. These fugitive dust
emissions potentially will affect local residents sensitive (e.g., allergic)
to dust. Operational impacts caused by long-term emissions from gas and
diesel-fueled engines will not be significant. Secondary, minor air quality
degradation will occur due to growth in the project area. Beneficial impacts
to the population surrounding existing treatment plants will occur due to the
abandoning of Plant No. 1 and the proposed improvements at Plant No. 2.
Adverse odors are not anticipated from the new facilities at Montesa Park
since odors will be minimized by scrubbing equipment and enclosed facilities.
Noise generated by construction of the sludge pipeline may cause distur-
bance to outdoor activities of persons living or active within approximately
one-half mile of the construction activity. However, any one area is not
expected to be affected by construction noise for a long period of time.
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Noise effects in the vicinity of construction at Plant No. 2 and Montesa Park
also will be temporary and short-term, and are not anticipated to be of
significance.
Environmental consequences of the proposed project on terrestrial flora
and fauna will be largely temporary. Disturbance of plant and animal commu-
nities by construction and operation of the proposed sludge pipeline and
sludge management components will occur, but the proposed project will not
destroy critical habitat or be deleterious to wildlife. No endangered ter-
restrial species are known to inhabit the proposed project site (i.e., Plant
No. 2, pipeline route, and Montesa Park).
No presently known historical or archaeological resources will be af-
fected by the proposed project. Should significant cultural resources be
discovered during construction, the City will be required by grant condi-
tion (s) to notify EPA, the State Historical Preservation Officer (SHPO) and
the Department of Interior.
As a direct result of the proposed action, very minimal changes in popu-
lation size, characteristics and distribution in the project area will occur.
No significant impact is anticipated on population due to the proposed pro-
ject; however, it is recognized that the project will facilitate growth in
the area.
Land use at Plant No. 2 and Montesa Park will remain as it currently
exists (i.e., municipal facilities). Effects on neighboring land use should
be minimal; however, construction of the pipeline would temporarily alter
current land uses. Transportation systems in the project area will have to
expand slightly to accept moderate project growth. Long-range comprehensive
plans will have to be changed to include the City's proposed project.
Beneficial impacts on the local economy will be realized by the receipt
of Federal and State grant funds.
No direct or indirect effects on energy use or supply are anticipated
due to the proposed project.
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No large scale direct or indirect environmental health effects are anti-
cipated to occur to persons in the vicinity of the proposed project or to
persons in the City of Albuquerque. Operators of the proposed irradiator
potentially will have a lifetime risk of premature death from radiogenic
cancer that is 0.05% above normal (i.e., 5 out of 10,000). The additional
radiation (50 millirems per year) to which the operators will be exposed is
equivalent to the additional yearly radiation dose a person will receive if
he moves from a wooden home into a brick home. Living in a brick house
contributes between 50 and 100 millirem (mrem), in a concrete house 70-100
mrem, and in a wooden house 30-50 mrem per year of radiation to the occupant
(International Atomic Energy Agency, 1979).
Recreation activities that occur in and near Tijeras Arroyo will be
temporarily affected during construction. No long-term effects upon recrea-
tion and aesthetics are anticipated due to operation of the proposed project.
It is noted that the City's proposed project does include several un-
avoidable adverse impacts. The preceding, paragraphs describe environmental
consequences that will occur due to implementation of the City's proposed
project, including the many mitigative measures that will be incorporated by
the City. Therefore, each of the adverse effects mentioned in the previous
paragraphs are unavoidable adverse impacts. Construction and operation of
the City's proposed project will also involve an irreversible and irretriev-
able commitment of labor, energy, fuel, construction materials, and land
utilized as the project site.
1.4 ALTERNATIVES EVALUATED
Several alternatives to the City's proposed action were evaluated by the
City and/or EPA. One alternative to the proposed action is no action.
Implementation of no action by the City would result in 60 mgd of wastewater
in 1990 flowing into a treatment facility designed to treat 47 mgd, and with
a sludge management system that is only able to handle the sludge produced by
treating 30 to 33 mgd of wastewater. If the no action alternative was imple-
mented, sludge produced by treating 30 to 33 mgd of wastewater would be
dewatered on existing sand drying beds, and then stockpiled at Montesa Park.
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Sludge produced by treating the remaining 27 to 30 mgd of wastewater poten-
tially would be stored in sludge lagoons adjacent to treatment Plant No. 2.
EPA has determined the no action alternative is not a feasible alternative.
The City of Albuquerque evaluated 7 action alternatives in their facil-
ities plan (6 alternatives plus the proposed project). The City's alterna-
tives primarily included evaluations of various transportation options (pump-
ing sludge through pipelines, or hauling it by truck); various disinfection
options (Cesium-137, electron beam, and composting); and various utlimate
disposal options (landspreading, landfilling, and dedicated land disposal).
EPA evaluated 14 action alternatives plus the no action alternative; however,
the main options for transportation, disinfection, and disposal evaluated by
EPA were basically identical to those evaluated by the City. The 14 action
alternatives were grouped according to ultimate disposal method as follows:
Group 1 alternatives (1A-1H) involved disposal by landspreading on public
lands; Group 2 alternatives (2A-2B) involved disposal in a municipal landfill
north of the City; and Group 3 alternatives (3A-3D) involved dedicated land
disposal on one of two 3,580-ac sites west of the City. EPA has determined
that all Group 1 alternatives qualify as innovative/alternative systems.
EPA also determined that alternatives involving open air drying or composting
are not environmentally sound.
The fact that sludge is a valuable resource is recognized by EPA.
Information provided by the City, private consultants, and other Federal
agencies concerning the monetary value of sludge in terms of dollars per ton
was evaluated by EPA. EPA has determined a $70/ton credit acceptable for all
Group 1 alternatives, since these alternatives include ultimate disposal of
sludge on public lands as a soil conditioner.
A cost-effectiveness analysis determined that, of the remaining alterna-
tives, the City's proposed project (Alternative IB) is the most cost-
effective system and is within the required cost range to receive innovative/
alternative technology funding (if available) from EPA.
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1.5 EPA'S PROPOSED ACTION
EPA encourages the use of innovative/alternative technologies and the
recovery of valuable resources. The City's proposed innovative project has
been determined to be cost-effective and environmentally sound. Therefore,
EPA proposes to give the City of Albuquerque a grant (up to 85%) for the con-
struction of the City's proposed project. In addition, it is anticipated
that the New Mexico Environmental Improvement Division will award to the City
a 12.5% grant.
1.6 COORDINATION
EPA Region 6 has made a concerted effort to involve other Federal,
State, and local agencies and the general public in the development of this
SEIS. A public scoping meeting was held on 7 October 1980 in Albuquerque.
Two Federal agencies (USDA/SCS and USDOE) agreed to be cooperating agencies.
A public hearing to receive comments on the Draft Supplemental EIS was held
on 18 November 1981. Many Citizens' Advisory Committee meetings were held
throughout the project and on 9 December 1981, the Citizen's Advisory
Committee voted on their final recommendation to the City concerning the
sludge management system. Additionally, public information depositories were
established and are being maintained in 6 convenient public buildings located
throughout Albuquerque. Written comments on the draft Supplemental EIS were
received from approximately 23 Federal and State agencies, local community
organizations, public interest groups, and private citizens.
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CHAPTER 2
TABLE OF CONTENTS
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2.0 TABLE OF CONTENTS
Page
1.0 SUMMARY 1-1
1.1 DESCRIPTION OF ADMINISTRATIVE ACTION 1-1
1.2 DESCRIPTION OF PROPOSED PROJECT 1-3
1.3 ENVIRONMENTAL CONSEQUENCES OF THE CITY'S
PROPOSED PROJECT 1-5
1.4 ALTERNATIVES EVALUATED 1-7
1.5 EPA'S PROPOSED ACTION 1-9
1.6 COORDINATION 1-9
2.0 TABLE OF CONTENTS 2-1
LIST OF TABLES 2-3
LIST OF FIGURES 2-4
3.0 DESCRIPTION OF ALTERNATIVES 3-1
3.1 DESCRIPTION OF APPLICANT'S PROPOSED
PROJECT, INCLUDING REVISIONS 3-1
3.2 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED PROJECT 3-10
3.2.1 Direct and Indirect Consequences 3-10
3.2.2 Unavoidable Adverse Impacts of
the City's Proposed Project 3-19
3.2.3 Irretrievable and Irreversible
Resource Commitments 3-21
3.3.3 Relationship Between Short-Term Uses
of Man's Environment and Maintenance
and Enhancement of Long-Term Productivity 3-22
3.3 DESCRIPTION OF ALTERNATIVES EVALUATED 3-22
3.3.1 Alternatives Evaluated in the Draft SEIS 3-22
3.3.2 Alternatives Evaluated After
Issuance of the Draft SEIS ;.. 3-25
3.3.3 Environmental Consequences of Alternatives 3-26
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TABLE OF CONTENTS - Concluded
Page
3.4 COST-EFFECTIVENESS ANALYSIS OF ALTERNATIVES 3-29
4.0 EPA'S PROPOSED ACTION AND ENVIRONMENTAL CONSEQUENCES 4-1
4.1 ALLOWANCE OF CREDIT FOR SLUDGE , 4-1
4.2 IDENTIFICATION OF FUNDABLE ALTERNATIVES 4-1
4.3 IDENTIFICATION OF EPA'S PROPOSED ACTION 4-3
4.4 ENVIRONMENTAL CONSEQUENCES OF EPA'S PROPOSED ACTION ..... 4-4
5.0 CORRECTIONS AND ADDITIONS TO THE DRAFT SUPPLEMENTAL EIS 5-1
5. 1 MINOR CORRECTIONS 5-1
5. 2 MAJOR CORRECTIONS 5-3
6.0 COORDINATION 6-1
6.1 RECOMMENDATIONS OF THE CITIZENS' ADVISORY COMMITTEE 6-1
6. 2 SUMMARY OF PUBLIC HEARING , 6-3
6.3 EVALUATION OF PUBLIC PARTICIPATION PROGRAM 6-4
6.4 RESPONSES TO VERBAL COMMENTS RECEIVED
AT PUBLIC HEARING 6-1
6.5 RESPONSE TO WRITTEN COMMENTS 6-20
6.6 MAILING LIST FOR FINAL SEIS 6-89
7. 0 BIBLIOGRAPHY 7-1
APPENDICES
APPENDIX A. SIGNIFICANT CORRESPONDENCE A-l
APPENDIX B. COST-EFFECTIVENESS ANALYSIS B-l
APPENDIX C. REVISED COST INFORMATION . C-l
APPENDIX D. TOXICITY TEST REPORTS D-l
APPENDIX E. ALTERNATIVE SITE ANALYSIS E-l
APPENDIX F. PRELIMINARY SLUDGE SURVEY F-l
INDEX 1-1
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LIST OF TABLES
Table Page
3-1 Potential disposal of sludge on public lands
in the vicinity of Albuquerque, New Mexico 3-9
3-2 Mitigative measures incorporated into the
City's currently proposed project 3-11
3-3 Action alternatives evaluated in the Draft
SEIS for the Albuquerque sludge management system 3-23
3-4 Summary of environmental consequences of
14 optimal alternatives 3-27
3-5 Cost-effectiveness of optimal alternatives 3-30
6-1 Members of the Albuquerque Citizen
Advisory Committee 6-6
6-2 Index of public comments 6-21
6-3 Mailing list for the Final SEIS 6-90
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LIST OK KIGURRS
Figure
3-1 Site of City's currently proposed project,
location of Plant No. 2, sludge pipeline,
and Montesa Park 3-2
3-2 Detailed site layout of the proposed sludge processing
facilities at Montesa Park 3-3
3-3 Schematic plan of Montesa Park sludge processing
facilities 3-6
3-4 Schematic of a Cesium-137 irradiator 3-7
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CHAPTER 3
DESCRIPTION OF
ALTERNATIVES
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3.0 DESCRIPTION OF ALTERNATIVES
The Draft SEIS described and evaluated fourteen (14) optimal alterna-
tives, including the City's proposed project (Alternative IB). The evalua-
tion included both an environmental impact assessment and a cost-
effectiveness analysis. Subsequent to issuance of the Draft SEIS, the City
made substantial changes to their proposed project as a result of input from
the CAC, the general public, and the SEIS process. In addition, another
process for conditioning and disinfecting sludge (the Zimpro thermal
conditioning process) was evaluated subsequent to issuance of the Draft SEIS.
This chapter presents a description of the City's currently proposed project
(including the revisions made since issuance of the Draft SEIS) and a
description of the environmental consequences of the City's currently pro-
posed project; a summary of other alternatives and their environmental
consequences; and a new cost-effectiveness analysis which Incorporates
changes in estimated costs developed by the City for their currently proposed
project.
3.1 DESCRIPTION OF APPLICANT'S PROPOSED PROJECT, INCLUDING REVISIONS MADE
SINCE ISSUANCE OF THE DRAFT SEIS
The City's currently proposed project is composed of treatment processes
to achieve the following: sludge thickening, stabilization, transportation
of sludge to Montesa Park, conditioning, dewatering, drying, disinfection,
temporary storage, and ultimate disposal by land application. Figure 3-1
illustrates the location of Plant No. 2, the proposed sludge pipeline and
Montesa Park. A detailed site layout of the proposed sludge processing
facilities at Montesa Park is shown In Figure 3-2.
Sludge thickening will be accomplished by constructing two new 300 sf
(each) high rate type dissolved air flotation (DAF) thickening tanks, to be
located adjacent to three identical DAF units currently being utilized at
Plant No. 2. Each of the new units will have a 300 sf flotation zone, and
will be rated for a solids loading of 2.0 Ibs. dry solids per sq ft per hour
when fed with sludge having a solids content varying between 0.5% and 1.5%.
The new units will be designed to achieve 95% solids capture, producing a
sludge thickened to approximately 4.0% solids. The new units will make
maximum use of chemical feed, pumping, piping, and control systems, currently
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TIJERAS CANYON INTERCEPTOR
MONTESA, PARt< BOUNDARY ,
BOOSTER PUMP STATION f ,.^
X-^l»!J_a««" _^..- ?^v< Tkji
DEWATERWG ANO
DISINFECTION
e 10 SLUM*, K»pe MAW
BOOSTEfK.POMP STATION ,.-
Figure 3-1. Site of City's
currently proposed project
Illustrating location of
Plant No. 2, sludge pipe-
line, and Hontesa Park.
Source: CDM and WM and Asso-
ciates. 1980b.
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u>
PROPOSED MONTESA PARK SLUDGE PROCESSING FACILITY
Figure 3-2. Detailed site layout
of the proposed sludge process-
ing facilities at tontesa Park!
Source: Khera, A.K. 1982a.
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used for the three existing DAF units. The construction of two new DAF units
also will involve an addition to the DAF building structure at Plant No. 2.
Sludge stabilization will be accomplished by constructing four addi-
tional anaerobic digestors similar to those currently utilized at Plant No.
2. The new stabilization system will consist of three new primary digesters
and one secondary digester, each 120,000 cf in volume. The primary digesters
will be heated and mixed using diffuser-type gas mixing systems. Gas will be
collected from the new digesters, combined with gas from the existing units,
and compressed and stored in new spheres to be constructed at Plant No. 2.
The compressed digester gas will be utilized to fuel electrical generators
that will provide electrical power for plant use.
Sludge removed from the digesters will be transferred in wet form to
Montesa Park for further processing. The wet sludge transfer facilities for
the proposed project consist of an 8-inch PVC pipeline approximately 26,000
feet long. The pipeline will start from a pump station located in the di-
gester complex at the plant, and incorporate an intermediate booster pump
station located just east of Interstate 25 (Figure 3-1). Sludge from this
pipeline will discharge into a covered circular sludge holding tank at
Montesa Park located adjacent to a proposed belt filter press building. The
pipeline will have frequent cleanout fittings and will be equipped to permit
a swab to be passed through the line. In addition, the pipeline will be
arranged to facilitate flushing of the Line from either end with wastewater
effluent or water. The pump stations will each contain two centrifugal
service pumps, with a single positive displacement stand-by pump for backup.
Sludge conditioning and dewatering will be accomplished by adding poly-
mer to the sludge, followed by mechanical dewatering (via belt filter
presses) to approximately 25% solids. The required equipment will involve a
one-story building of about 5,500 square feet, containing four belt filter
presses, with provision for future equipment. Included in the facilities
will be a washwater reclamation system. Facilities for bulk storage of the
polymer and other chemicals used in the building also will be included.
Resulting sidestream from the washwater reclamation system as well as all
other process and sanitary wastewater from the dewatering complex will be
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piped directly to the exist Lriy 8 inch sewer on Los Picaros Road bordering the
property, thence fiowing by gravity through the Tijeras interceptor to the
headworks of Plant No. 2.
Sludge drying of the 25% solid belt press cake will be accomplished by
using innovative solar greenhouse technology (Figure 3-3) . Through a system
of belt conveyors and front-end loaders, the belt press cake will be conveyed
immediately to the 5-bay solar greenhouse drying facility. Each of the bays
will be approximately 365 x 60 feet in plan, containing drying beds floored
and walled with concrete, on which the sludge will be placed until reaching
approximately 40% solids. The greenhouses will, be of the pattern typically
used in nurseries and garden shops; the southerly portion of roof and walls
will be glazed, with all northerly surfaces being solid wall or roof mate-
rial. The greenhouses are expected to have a maximum roof height of 20 feet.
Air exhausted to the atmosphere from the greenhouse will pass through an odor
scrubbing system, probably of the ozone type. Dry cake from the greenhouses
will be passed via conveyors through a shredder into the feed hopper supply-
ing the disinfection facility, or to intermediate storage located within the
enclosed facilities.
Disinfection of sludge will be accomplished using Cesium-137, a nuclear
waste by-product, to irradiate the sludge and render it virtually sterile.
The proposed irradiator will involve a Cesium-137 source plaque (approxi-
mately 15 MCi) located in a concrete structure below the ground surface
(Figure 3-4). The Cesium-137 will remain stationary while sludge is passed
through the irradiator. The Department of Energy (DOE) will be responsible
for supplying the Cesium-137, delivering it to Montesa Park, installing the
Cesium-137 in the irradiator, replenishing the Cesium-137 periodically to
maintain the required dosage, and subsequently removing and disposing the
spent Cesium-137 at the end of the project life. Since the DOE will retain
ownership of the Cesium-137 throughout the project period, the DOE also will
be responsible for any cleanup and decontamination operations necessary due
to occurrence of an unforeseen accident. Following irradiation, the irradi-
ator output conveyor will discharge directly to a truck, via which sludge
will be moved immediately into finished sludge stockpiles.
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SLUDGE IRRAOtATOR BUILDING
SLUDGE STOCKPILE BUUHNG
TRUCK ACCESS (TYP) 7
-S65'
SO' (TYf. OF BAYS)
40% PUtS SLUDGE CAKE TO IRRADIATION
DISWFECTED SLUDGE
TO STOCKPILE 4 NO
FINAL DISPOSAL
TRUCK
UPPER CONVEYOR -
25% SLUDGE CAKE FROM BELT PRESSES
TO DRYING BAYS
LOUVERS(TYP) -
LOWER CONVEYOR
40% SLUDGE CAKE FTtOM DRYING BAYS
TO IRRAOIATOR
- 81-LEVEL CONVEYOR
MECHANICAL DEWATER1NG BLOG
STRUCTURAL COLUMNSCTYPI -
DOCK
BELT PRESS
(TYPI r-
I I
I I 2 I
I I I
J L_J
25% SLUDGE CAKE
CONVEYOR
ACCESS DOOR (TYP)-
I
I I
KK'-
-260'-
UOUIO SLUDGE FROM_
SOUTHSK3E WWTP
SOLAR GREENHOUSE BUILDING
- DRYING BAYS (TYP)
EQUIPMENT MAINTENANCE
BUILDING
-55'-
LIOUIO SLUDGE
CONVEYOR
Figure 3-3. Schematic plan
of MonCeaa Park sludge
processing facilities.
Source: CH2H HILL. 1982.
-------
CONVEYOR
DIGESTERS
DEWATERING
DRYING
GRINDING
SYSTEM
\
f
V77,
CONCRETE SHIELDING-
TO STOCKPILE
AND DISPOSAL
PROCESS FLOW SCHEMATIC
NOT TO SCALE
INPUT
OUTPUT
NATURAL
GROUND
CONVEYOR
SOURCE PLAQUE
IRRADIATOR SCHEMATIC ISOMETRIC
NOT TO SCALE
Figure 3-4. Schematic of a
Cesiura-137 irradiator simi-
lar to that proposed for
utilization by the City of
Albuquerque.
Source: CDM 1980b.
3-7
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Temporary storage of sludge prior to ultimate disposal on City parks and
other public lands will be accomplished by using covered stockpiles located
at Montesa Park. The stockpiles will be covered by a prefabricated metal
building approximately 180 x 260 feet. The facility will consist of complete
roofing and side enclosures, liberally fitted with screened ventilation
openings at the base of the peripheral walls and at the roof peak. It is
envisioned that the covered stockpile structure will consist of three frame
or truss type roof support systems, each approximately 70 feet in clear span
containing 10 bays, each 25 feet long, with a 12 foot eave height. The
covered structure will have asphalt paving for interior flooring, sloped to
drains connected to the sanitary sewer such that any leachate from the stock-
pile will be conveyed back to the plant through the Tijeras interceptor. The
height of the sludge stockpile within this structure will average approxi-
mately 7 feet. Approximately 25% of the enclosed floor area will be devoted
to roadways for loading and hauling vehicles. The structure will have the
capacity to store the entire design output of sludge for six months, although
in normal operation detention in the stockpiles prior to movement to the
parks for application will average closer to 4 months.
Other improvements at the Montesa Park site will consist of security
fencing, exterior lighting, drainage improvements, improvement to existing
on-site roadways, landscaping, and staff amenities. Absolute positive and
fail-safe capturing of all potential leachate or runoff which could in any
way possible be contaminated with potentially harmful materials, will be a
principal design criterion. Positive odor scrubbing equipment will be pro-
vided for all air exhausted to the atmosphere from the wet sludge processing
facility.
Ultimate disposal of sludge will involve loading sludge from temporary
stockpiles onto trucks, hauling it to a final disposal area, and spreading
the sludge on top of the ground as a soil conditioner. Areas where sludge
potentially will be placed are identified in Table 3-1. By design year 1990,
10,740 tons of sludge per year potentially will be utilized as a soil condi-
tioner on lands in and around Albuquerque, New Mexico. The City also is
investigating the feasibility of marketing sludge (either wholesale or
retail) as a commercial soil conditioner (see Appendix F). As much as 40%
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Table 3-1. Potential disposal of sludge on public lands in the vicinity of
of Albuquerque, New Mexico.
Potential User
City Parks
City Golf Courses
Bernalillo County Parks
UNM Golf Courses
UNM Miscellaneous Areas
Valley Gold Dairy
US Forest Service Nursery
Land Available
In 1990 (acres)
840
450
260
330
150
Not Defined
200
TOTAL
Sludge Application
(Tons/Year)
3,360
1,800
1,040
1,320
600
1,820
800
1
10,740
May utilize up to 3,600 tons of sludge per year, if available.
Source: Adapted from Camp Dresser and McKee, Inc., and William Matotan &
Associates, Inc. 1980b. City of Albuquerque, New Mexico southside
wastewater treatment plant phase II expansion program engineering
report. Prepared for City of Albuquerque, New Mexico Water Resources
Department. Albuquerque NM, variously paged.
3-9
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(approximately 4300 tons per year) of the total design year sludge production
may be disposed via commercial sale in lieu of disposal on public lands.
The City's currently proposed project differs in several aspects from
the City's originally proposed project (Alternative IB) that was evaluated in
the Draft SEIS. Partially in response to comments from the CAC, the general
public, and the SEIS process in general, the City has added numerous provi-
sions for mitigating adverse environmental consequences associated with the
original project. Mitigative measures which will be implemented by the City
as part of the currently proposed project are listed in Table 3-2.
To implement the proposed project, several steps must be completed. The
City's major sludge management planning effort was described in the Southside
Wastewater Treatment Plant Phase II Expansion Program Engineering Report
dated December 1980, which is commonly referred to as the Balloon Report. In
January 1981, the City submitted the Balloon Report to EPA as a draft Facili-
ties Plan Admendment. Upon completion of the public comment period associ-
ated with this final SEIS, the City must undertake the following steps prior
to initiation of engineering design efforts:
« The Balloon Report must be amended to incorporate changes made in
the City's proposed project as a result of the SEIS process.
» The Balloon Report must be adopted by the City Council as an amend-
ment of the City/County Comprehensive Plan's Wastewater Facilities
Plan element.
« The Balloon Report also must be adopted by other local governments
in the planning area associated with the City/County Comprehensive
Plan.
The City of Albuquerque will maintain an EIS and SEIS Record documenting
compliance with these stipulations. All required approvals and adoptions of
the proposed plan will be obtained prior to Initiation of engineering design
of the proposed project.
3.2 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED PROJECT
3.2.1 Direct and Indirect Consequences
The City's currently proposed project has been analyzed to determine
primary and secondary impacts and the short-term or long-term nature of the
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Table 3-2 Mitigative measures incorporated into the City's currently pro-
posed project.
Sludge holding tanks at Montesa Park will be covered.
Washwater reclamation tanks at Montesa Park will be covered.
Sludge dewatering facilities (belt presses) will be enclosed, and
air exhausted from the facilities will be scrubbed to remove odor.
The proposed solar greenhouse height has been reduced from 60 ft to
20 ft maximum.
Air exhausted from the solar greenhouse facility will be scrubbed
to remove odor.
All stockpiles will have asphalt paving, sloped to collection
drains to prevent leachate from reaching open ground.
All stockpiles will be enclosed and covered in prefabricated metal
buildings.
The Montesa Park site will be provided with security fencing, light-
ing, and drainage improvements.
Provision will be made for absolute, fail-safe collection and treat-
ment of leachate and contaminated storm water runoff (if any) to
prevent surface and/or groundwater contamination.
Liberal usage of landscaping and provision of staff amenities will
be utilized to make the proposed facilities pleasing to outside
observers as well as to the operational staff.
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impacts. Impacts are discussed in the paragraphs below for each environ-
mental parameter or category with both beneficial and adverse effects consid-
ered. Additional impacts that must be considered pursuant to CEQ guidelines,
such as irreversible and irretrievable commitments of resources and the
relationship of the project to long-term productivity, are discussed
separately in this section.
Earth Resources
The proposed sludge management system site is located on the East Mesa
in an Arroyo known as Tijeras Arroyo. The East Mesa is a broad alluvial
expanse at the base of Sandia Mountain. The proposed site (Montesa Park) is
flat, thus no adverse environmental impact on topography is anticipated.
Plant No. 2 is located in the floodplain of the Rio Grande River. No adverse,
impact on geology or topography is expected from expansion of the sludge
management system at Plant No. 2, as this expansion will be confined to the
boundaries of City property at the existing plant site. The vertical align-
ment of the City's proposed sludge pipeline will increase gradually from
about 4,930 ft msl at Plant No. 2 to 5,150 ft msl at Montesa Park. Since
this alignment follows the existing topography of Tijeras Arroyo, no adverse
impact to topography will occur as a result of pipeline construction.
Soils at the proposed project site (Montesa Park and Plant No. 2) con-
sists of loamy fine sands. These soils have a high permeability, and their
depth from the surface varies from 0-60 inches. These soils may be suscep-
tible to erosion during construction activities as indicated by their
moderately high soil erodibility (K) factor. However, sediment derived from
this erosion is not expected to contribute significantly to water quality
problems as a result of increased turbidity. The depth of excavation for
construction of the sludge pipeline will be limited by the soils within the
Tijeras Arroyo, because the cut-banks (i.e., sides of the trench) will tend
to cave in severely at moderate trench depths. However, this will not be a
significant problem since the proposed force main, unlike a gravity sewer,
can be constructed close to the ground surface. The pipeline construction
will not alter the soils of the Arroyo.
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A beneficial effect Is expected on soils at the land application sites
(i.e., in City parks and other public Land). The digested sludge applied to
these sandy soils will increase field moisture capacity, non-capillary poro-
sity, cation-ion exchange, and will replace valuable soil nutrients and trace
metals.
Surface Water Resources
Direct impacts to stream flow associated with the proposed construction
activities in or near the Tijeras Arroyo and the Middle Rio Grande River will
be minor, temporary, and of no significant consequence. The largest secon-
dary hydraulic impact of the proposed action will be augmentation of the base
flow of the Middle Rio Grande River. Sewage effluent discharged from Plant
No. 2 will increase from a current average of 39.0 mgd to approximately 60
mgd. This increase will consist of water taken mainly from groundwater
reserves rather than from upstream surface water sources. The result will be
that the base flow of the Rio Grande River, below the outfall of Plant No. 2,
will increase approximately 39.8 cfs.
One of the principal reasons for implementing the proposed action is to
improve the sludge management capability of the City of Albuquerque and
consequently to enhance the water quality of the Middle Rio Grande River.
Such enhancement will be both direct (e.g., reducing pollutant loads by
better sludge management practice) and indirect (e.g., by providing a large
base flow to buffer non-point source pollution). Construction activities for
improvements at Plant No. 2, the new sludge management components at Montesa
Park, and the pipeline construction have a potential for degrading water
quality due to suspended and bedload solids (i.e., siltation) from erosion of
disturbed material. This siltation is expected to be temporary (short term)
and of minor consequence.
Groundwater Resources
The greatest potential for groundwater quality degradation is due to
accidental breaks in the five mile long sludge pipeline that will lead from
Plant No. 2 to Montesa Park. However, accidental breaks and leakage and
subsequent groundwater quality reduction should be minimized through the use
of good engineering design practices.
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Air and Sound Quality
Of the five criteria air pollutants regulated by EPA, only total sus-
pended particulates (TSP) is of any significance to the proposed project.
Small amounts of other pollutants will be emitted during construction, but
their impact on existing ambient air quality will be negligible. Fugitive
dust emissions resulting from construction activities, particularly at
Montesa Park, will cause a short-term local increase in TSP levels. Persons
sensitive (i.e., allergic) to dust that live in close proximity to the con-
struction site may be temporarily affected by these fugitive dust emissions.
Electrical equipment primarily will be used to operate the sludge
management facilities and therefore will not create on-site sources of addi-
tional air pollutants. Secondary air quality impacts will occur due to
growth related aspects of the proposed action.
Odor impacts due to the proposed action can be summarized as follows:
(1) the abandoning of. Plant No. 1 will have a significant benefit to the
large population surrounding it; and (2) elimination of the sludge drying
beds at Plant No. 2 and construction of new sludge management components at
Montesa Park will result in a benefit to the population surrounding Plant No.
2. Mechanical dewatering, stockpiling, and the solar greenhouse are the most
probable sources of odors at Montesa Park. However, the production of odors
at Montesa Park will be minimized by the use of enclosed structures and by
odor scrubbing equipment, as mandated by court stipulations. Impacts will
vary seasonally and daily according to plant operating characteristics and
prevailing weather conditions.
Noise associated with construction and operation of the sludge manage-
ment facilities will generate both short-term and long-term effects. Short-
term noise will be caused by activity of construction equipment at Plant No.
2, along the pipeline route and at Montesa Park. Construction of a pipeline
will require equipment that is standard in earth-working and utility indus-
tries. A right-of-way will be cleared with bulldozers, and debris will be
removed with front-loaders and dump trucks. A ditch-digger or backhoe will
follow. The pipe laying activity will require moderately heavy trucks and
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other equipment. Operation of certain equipment will be a source of concern
at short distances (e.g., backhoes and concrete mixers). The actual sound
level at the construction site will, depend on equipment, duty cycle, and the
number and mixture of equipment types that are operating simultaneously.
Sensitive receptors (e.g., residences) located along the pipeline route will
be affected by construction noise. This noise will be short-term in nature,
and if conducted during the day, should not signficantly affect the resi-
dences .
Noise caused by operations at Treatment Plant No. 2 will be dominated by
components associated with air compressors and large electric motors. Use of
enclosed facilities at Plant No. 2 will minimize noise levels, thus long-term
operational effects to local residents will be minor.
Montesa Park currently is zoned SU-1 (special use zoning). There are no
sensitive receptors currently located near the park that will be affected by
noise level increases due to the operation of the proposed sludge management
facilities. The enclosure of all major equipment will keep noise increases
at the minimum possible level.
Biological Resources
Short-term direct effects on terrestrial and aquatic biota in the pro-
posed project area will occur due to construction at Montesa Park, the pump
station sites, and along the pipeline route. Construction of facilities at
Montesa Park will result in the disturbance of several natural plant commu-
nities. Typical vegetation species on this shrubland site include sagebrush,
creosote bush, tumbleweed, and various xeric grass species. Animals (black-
tailed jackrabbit, coyote, Red tailed Hawk, and American Kestrel) that utilize
these areas for feeding will leave temporarily because of construction noise
and increases in human activity. These species most likely will return after
construction. The temporary disturbance to plant and animal species due to
construction of the proposed project will not significantly affect the bio-
logical resources of the project area.
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No rare/endangered terrestrial plant or animal species or habitat criti-
cal for such species are currently known to occur at Montesa Park or along
the proposed pipeline route. Therefore, no effects to rare and endangered
species will occur.
« Cultural Resources
Montesa Park and the proposed Tijeras Arroyo pipeline route were sur-
veyed, and no surficial evidence of cultural resources was found in either of
these areas; however the possibility of encountering buried sites during
construction was noted (Banks 1981). In order to protect cultural resources,
EPA will condition any future grant to require that, if cultural resources
potentially eligible for listing in the National Register of Historic Places
are encountered during construction, the SHPO, EPA, and the Department of
Interior will be notified and the Advisory Council on Historic Preservation
(ACHP) offered an opportunity to comment in accordance with 36 CFR 800.
0 Population
No relocation of population is anticipated due to implementation of the
proposed project since the sludge management facilities will be built primar-
ily on vacant City-owned land. Additionally, none of the land utilized as a
buffer zone has occupied dwelling units. Construction and operation of the
proposed action will not cause a population growth but will facilitate those
increases currently projected by various planning agencies.
* Land Use and Transportation
Land use at Plant No. 2 or Montesa Park will not change since construc-
tion will be accomplished within existing City property boundaries. Prior to
initiation of engineering design, the City/County Comprehensive Plan which
designates Montesa Park as "open space" must be amended to include the pro-
posed use of Montesa Park for sludge management facilities. In addition,
Montesa Park currently is zoned Special Use 1 (SU-1). Site development plans
for the proposed project must be approved by the City Environmental Planning
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Commission as a condition of Montesa Park's SU-1 zoning. Land use along the
proposed pipeline route will be affected temporarily during construction of
the pipeline. However, no permanent change will result and the period of
pipe laying at any one site will be short.
As an indirect consequence of the proposed action, operations at
Treatment Plant No. 1 will cease. This land will remain as City property,
perhaps to be utilized for other City purposes. As a direct result of this
action, land values in the neighborhood may increase since the area near
Plant Site No. 1 will tend to be a more pleasant area in which to live.
Current transportation networks and utility services will not be signi-
ficantly affected by the proposed project. No additional transportation
facilities will be required beyond those currently being planned.
Economic Resources
Direct economic effects will result from (1) the increase in local
purchasing by construction and operation work forces, and (2) the sale of
materials for construction and operation of the proposed operation. Wages
and salaries paid to construction laborers will not signficantly alter local
wage rates. The cost of materials will be approximately 6-7 million dollars.
Much of the material will be purchased locally.
It is anticipated that Federal and State funds will be granted to the
City which will have a beneficial effect on the area since much of the money
will be spent locally. Indirect beneficial effects will accrue as the money
circulates. It is also anticipated that implementation of the City's
proposed project will cost additional money per connection (i.e., per family
paying a monthly sewer bill). The exact cost cannot be determined until the
project is financed and built. The cost should not represent a significant
economic burden as defined by PRM 79-8 (EPA 1979h). Therefore, the City's
proposed project will not result in any unavoidable adverse economic impacts.
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* Energy Resources
No direct effect of the proposed action on energy resources is antici-
pated. Electricity to meet the sludge management facilities operation
demands will be available as the Public Service Company of New Mexico is
currently capable of generating 20% above peak demand. The proposed action
will consume approximately 2.24 million kw-hr. per year. This demand repre-
sents approximately less than 0.2% of available reserve above peak (by phone,
Alex Gonzales, Public Service Company of New Mexico, 16 July 1981). In
addition, the expansion of Treatment Plant No. 2 will allow for on-site
generation of electricity (using digester gas) that potentially will meet or
exceed the plant's electrical demand for sludge processing.
Environmental Health
No large scale direct or indirect environmental health effects are
anticipated to occur to persons in the project area or within the City of
Albuquerque. The DAF thickeners and the anaerobic digesters at Plant No. 2
will have a beneficial effect due to the reduction or elimination of harmful
organisms in the sludge. Construction activities at Plant No. 2, along the
pipeline route, and at Montesa Park will generate fugitive dust that may
temporarily bother persons in the immediate vicinity that are sensitive to
dust due to allergies or other medical afflictions. Pathogenic aerosols and
other disease transmitting organisms are not anticipated to be significant at
Montesa Park since all facilities will be enclosed and exhaust air scrubbed
to remove odors and potentially some other particulates. Stockpiles will not
contaminate groundwater supplies becuase they will be built on impervious
paving with all leachate collected and treated.
The Cesium-137 irradiator will be designed so that, during normal opera-
tion, radiation exposure within 3 to 10 ft of the facility will not be
detectable above background levels. Material irradiated will not be radio-
active or exhibit any properties of radioactive material, thus the general
populace will be safe during normal operation. The full-time operators of
the irradiation facility potentially will be exposed to additional whole body
gamma radiation of 0.05 rem/year. Based on current risk estimating tech-
niques, this exposure potentially will cause the operators to have a lifetime
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risk oE premature death from radiogenic cancer of 0.05% above normal. There
potentially will be an approximately equal risk of the operators developing a
non-fatal radiogenic cancer (May 1981). Possible effects due to accidents at
the irradiator were thoroughly described in Appendix 10.2 of the Draft SEIS.
Recreation and Aesthetics
No long-term effects upon recreation or aesthetics are anticipated due
to the operation of the proposed project. During construction, noise, fugi-
tive dust, and truck traffic may mildly affect activities at the Albuquerque
Raceway, the New Mexico Timing Association Drag Strip, and the University of
New Mexico Golf Course. Localized hunting, hanggliding, target shooting, and
motorcycle and off-road vehicle activities in the Tijeras Arroyo also may
temporarily be affected.
3.2.2 Unavoidable Adverse Impacts of the City's Currently Proposed Project
The City's currently proposed project will cause some adverse environ-
mental impacts which cannot be avoided if the proposed project is implement-
ed. These unavoidable adverse impacts are summarized below. Mitigative
measures (if any) available to reduce the magnitude of the. impacts also are
discussed.
Surface Water Resources
An unavoidable adverse impact on stream water quality involves erosion
and a subsequent increase in suspended sediment associated with construction
of the sludge facilities at Montesa Park and along the pipeline route. The
principal adverse effect of this siltation consists more of temporary aesthe-
tic degradation than of habitat degradation in the receiving streams.
Generally such siltation can be readily minimized. The erosion and sedimen-
tation control plan required by the State of New Mexico for such facilities
should provide for effective sediment control through such measures as: (1)
minimizing construction in and adjacent to streams by environmentally sound
pipeline alignment; (2) avoiding steep slopes; (3) removing excess material;
(4) continuous backfilling of trenches; (5) diverting runoff away from undis-
turbed areas; and (6) using detention or retention basins in critical areas.
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Groundwater Resources
There are no Long-term unavoidable adverse impacts anticipated to occur
to the groundwater system due to implementation of the City's proposed project.
The primary impact of the proposed project is potential local groundwater
quality degradation due to accidental breakage of the new sludge pipeline.
The best mitigative measures for this potential problem is preventive mainte-
nance and assuring that all facilities are leak-proof via proper engineering
design and construction.
Air and Sound Quality
The only adverse air quality impact that will occur due to implementation
of the City's proposed project will be that caused by fugitive dust generated
by construction activities at Montesa Park and along the pipeline route. To
minimize dust generation, frequent watering will be employed. Dust generation
also may be reduced by restricting the speed of haul trucks traveling over un-
paved roads to the construction site.
Sludge handling and processing facilities at all times have been odor
sources, especially in summer conditions, and it is doubtful whether such
odors can ever by completely eliminated. However, if the sludge handling and
processing facilities are properly operated, adverse odor problems should be
minimal.
The Montesa Park site is located away from developed communities, thus
the number of people that potentially will be affected is minimal. Mitigative
measures, such as gas scrubbers for the solar greenhouse air exhaust system
and the covering of stockpiles with a prefabricated metal building have been
incorporated into the proposed project to control odor.
The major adverse impact of noise due to the City's proposed project will
be temporary and will occur during construction. The degree of effect will
depend heavily upon population density and proximity of human habitation to
noise sources. The impact of noise from construction activity and equipment
will be mitigated by proper maintenance of operating equipment and instal-
lation of noise-attenuating devices. Dozers and backhoes will be major noise
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sources, and modern exhaust muffling equipment will he used to significantly
reduce noise emanated from these pieces of construction equipment.
Biological Resources
The only short-term adverse impact that will occur as a result of imple-
menting the proposed action will be the disturbance of terrestrial flora and
fauna in areas of construction. These disturbances will be temporary and
will be mitigated by careful choice of access roads to construction sites,
muffling of engine noise, and use of the narrowest practical construction
easement along the sludge pipeline route.
Environmental Health
Unavoidable adverse consequences to environmental health that will occur
due to implementation of the City's currently proposed project include: (1)
fugitive dust will be generated during construction that may bother persons
sensitive to dust; and (2) full-time operators of the irradiator will
increase their lifetime risk of premature death from radiogenic cancer by
0.05% above normal.
3.2.3 Irretrievable and Irreversible Resource Commitments
Implementation of the City's currently proposed project will require
irretrievable and irreversible commitments of natural and man-made resources.
These resource commitments include:
Fossil fuel, electrical energy and human labor for construction and
operation of the proposed facilities will be expended.
Chemicals (especially polymer) for dewatering and thickening of
sludge will be expended.
Tax dollars for construction of the proposed sludge management
facilities will be expended and thus will not be available for use
in other government financed projects.
Land devoted as the project site will be lost for other uses.
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3.2.4 Relationship Between Short-term Uses of Man's Environment and
Maintenance and Enhancement of Long-Term Productivity
The short-term disruption and commitment of resources associated with
construction and operation of the City of Albuquerque's proposed sludge man-
agement system will be necessary to improve area aesthetics and water pollu-
tion problems. The anticipated short-term environmental impacts and resource
requirements associated with the City's proposed project will be offset by
long-term water quality improvements and reductions in public annoyance.
3.3 DESCRIPTION OF ALTERNATIVES EVALUATED
This section briefly describes alternatives to the City's currently pro-
posed project that were evaluated either prior to or subsequent to issuance
of the Draft SEIS. This section also presents a summary evaluation of the
environmental consequences of the alternatives evaluated.
3.3.1 Alternatives Evaluated in the Draft SEIS
The no action alternative and fourteen action alternatives were evalu-
ated in the Draft SEIS, consisting of the City's proposed project (Alterna-
tive IB) and 13 alternative projects. Each of the action alternatives
evaluated in the Draft SEIS is listed by component (i.e., treatment process)
in Table 3-3. The components are listed in the order they occur (i.e., the
dewatering process occurs before drying) with the exception of Alternatives
1G and 1H, in which the electron beam irradiation (disinfection) process
actually occurs before the belt press (dewatering) process. The alternatives
were categorized in three groups.
Group 1 alternatives involved the concept of disinfecting sludge and
disposing it by landspreading on city parks and other public lands as a soil
conditioner. Six of the group 1 alternatives used innovative technologies
(i.e., solar greenhouse drying, Cesium-137 irradiation, or electron beam
irradiation) and thus were potentially eligible for 10% additional Federal
funding. For the Group I alternatives, sludge would be thickened and stabi-
lized at Plant No. 2, and then transported to Montesa Park where the remain-
der of the sludge treatment processes would take place.
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Table 3-3. Action alternatives evaluated in the Draft SEIS for the Albuquerque sludge management system.
Group i - Landspread Concept
(1)
OJ
I
NO.
ALTERNATIVE THICKENING
Dissolved Air
1A Flotation
Dissolved Air
IB Flotation
Dissolved Air
1C Flotation
Dissolved Air
ID Flotation
Dissolved Air
IE Flotation
Dissolved Air
IF Flotation
Dissolved Air
1G Flotation
Dissolved Air
1H Flotation
STABILIZATION
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
Anaerobic
Digestion
TRANSPORTATION
Truck to
Montessa Park
Pipeline to
Montessa Park
Truck to
Montessa Park
Pipe to
Montessa Park
Truck to
Montessa Park
Pipeline to
Montessa Park
Truck to
Montessa Park
Pipe to
Montessa Park
CONDITIONING
Organic
Polymer
Organic
Polymer
Organic
Polymer
Organic
Polymer
Organic
Polymer
Organic
Polymer
Organic
Polymer
Organic
Polymer
DEWATERING
Belt Press
to 25%
Belt Press
to 25%
Belt Press
to 25%
Belt Press
to 25%
Belt Press
to 20%
Belt Press
to 20%
Belt Press
to 25%
Belt Press
to 25%
DRYING
Solar Greenhouse
to 40%
Solar Greenhouse
to 40%
Open Air
Drying to 40%
Open Air
Drying to 40%
Open Air
Drying to 40%
Open Air
Drying to 40%
DISINFECTION
Cesium-137
Irradiation
Cesium-137
Irradiation
Cesium-137
Irradiation
Cesium-137
Irradiation
Composting
Composting
Electron Beam
Irradiation
Electron Beam
Irradiation
(2)
DISPOSAL
Landspread on
City Parks and
Golf Courses
Landspread on
City Parks and
Golf Courses
Landspread on
City Park^s and
Golf Courses
Landspread on
City Parks and
Golf Courses
Landspread on
City Parks and
Golf Courses
Landspread on
City Parks and
Golf Courses
Landspread on
City Parks and
Golf Courses
Landspread on
City Parks and
Golf Courses
-------
Table 3-3. Action alternatives evaluated in the Draft SEIS for the Albuquerque sludge managment system (concluded)
Group 2 - Landfill Concept
NO. ALTERNATIVE THICKENING STABILIZATION CONDITIONING DEWATERING DRYING
Dissolved Air
9 2A Flotation
Dissolved Air
10 2B Flotation
Group 3 - Dedicated Land Disposal
Dissolved Air
11 3A Flotation
Dissolved Air
12 3B Flotation
to
1
£J Dissolved Air
13 3C Flotation
Dissolved Air
14 3D Flotation
Anaerobic Polymer Belt Press
Digestion to 20%
Anaerobic Lime/Ferric Pressure
Digestion Chloride Filters to 35%
Concept
Anaerobic
Digestion
Anaerobic
Digestion ~
Anaerobic
Digestion
Anaerobic
Digestion
DISINFECTION TRANSPORTATION
Truck to
Landfill
Truck to
Landfill
Truck to
Pajarito
Pipeline to
~ Pajarito
Pipeline to
Rio Puerco
Truck to
Rio Puerco
DISPOSAL
Landfill
Landfill
Dedicated
Land
Disposal
Dedicated
Land
Disposal
Dedicated
Land
Disposal
Dedicated
Land
Disposal
Not Applicable
(1) Beneficial reuse of sludge.
(2) Disposal also will involve marketing (i.e., commercial sale)
of upto 40% of the sludge produced.
-------
Group 2 alternatives Involved the concept of dewatering sludge and
disposing it in a municipal landfill north of the City. All sludge treatment
processes prior to disposal would take place at Plant No. 2.
Group 3 alternatives involved the concept of thickening and stabilizing
sludge at Plant No. 2 and disposing it by dedicated land disposal at a site
on the West Mesa. Two disposal sites were evaluated. The 14 alternatives
and the treatment processes involved with each alternative are fully
described in the Draft SE1S.
3.3.2 Alternatives Evaluated After Issuance of the Draft SEIS
The CAC requested that another alternative Zimpro Thermal Condition-
ing be fully evaluated as part of the SEIS process. The City of
Albuquerque and EPA both conducted independent evaluations of the Zimpro
thermal conditioning process. The evaluations were not completed in time to
incorporate them into the Draft SEIS; however, copies of both evaluations
have since been made available to the CAC and placed in local public informa-
tion depositories. These evaluations are summarized in the following para-
graphs.
Initially, the CAC requested that the wet air oxidation process be
evaluated. As described in the Draft SEIS, wet air oxidation is a sludge
treatment process that typically uses temperatures of 500°F and pressures of
1,800 psi to oxidize (i.e., to burn) sludge and thereby reduce the volume of
organic matter by 80-90%. Maximum temperatures of 600°F at 3,000 psi have
been used in some wet air oxidation systems. The Zimpro process which was of
interest to the CAC (although referred to by some as a wet air oxidation
system) is actually a low-temperature, low-pressure thermal conditioning
system. The Zimpro process typically uses temperatures of 350°F at 400 psi
to achieve a 5% reduction in organic matter in the sludge. The Zimpro sys-
tem, however, does achieve two characteristics of interest to this project:
(1) sludge is rendered disinfected by the Zimpro process; and (2) sludge is
easily dewatered.
3-25
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The City of Albuquerque conducted an evaluation of the Zimpro process at
the request of the CAC and the City Council. The City's evaluation con-
cluded:
Thermal conditioning is not particularly well suited to anaerobi-
cally digested sludge.
e Exhaust gases are quite odorous and difficult to scrub, even with
exhaust gas incinerators (which are not allowed by local ordi-
nance) .
9 Sidestreams are difficult to treat, and may cause odor problems at
the open primary clarifiers at Plant No. 2.
Sidestream treatment will require additional aeration units at
Plant No. 2.
« Thermal conditioning equipment such as boilers, heat exchangers,
and high pressure pumps will require advanced operators and high
maintenance costs.
Thermal conditioning is not as cost-effective as other disinfection
systems available for the Albuquerque project.
EPA also conducted an independent evaluation of the Zimpro process.
EPA's evaluation concluded:
e Thermal conditioning will create unacceptable odors. Acceptable
reduction in odor levels can only be achieved by exhaust gas incin-
eration, which is not allowed by local ordinance.
Thermal conditioning is not as cost-effective as other sludge man-
agement systems available for the Albuquerque project.
Upon completion of the above evaluations, EPA determined that it was not
necessary to further evaluate Zimpro thermal conditioning as a viable alter-
native for the Albuquerque project.
3.3.3 Environmental Consequences of Alternatives
Environmental consequences of the 14 optimal alternatives were described
and illustrated in matrix form in the Draft EiS. Following issuance of the
Draft SEIS, the City of Albuquerque made several changes to their proposed
project by incorporating mitigative measures where possible. A re-evaluation
of environmental consequences made on this basis is summarized in Table 3-4.
3-26
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Table 3-4. Summary of environment.;! 1 consequences oT 14 optimal alternatives.
IMPACT CATEGORY IMPACT
Earth Resources Heavy metals and
toxic elements in
soil
Erosion and loss of
soil productivity
Temporary erosion
Temporary surface
disturbance
IMPACT TYPE
& DEGREE IMPACT DESCRIPTION
Primary: Alternatives ICj ID, 1C, 1H:
Long-term
These alternatives use open air drying which could be a potential source
of sludge leachate and/or surface runoff that could contaminate soil in
and near Montesa Park.
Alternatives 3A, 3B. 3C, 3D:
Method of disposal (DLD) in these alternatives will result in severe dust
problem and loss of soil productivity. Also water erosion and erosion due
to wind are of potential concern.
Primary: Alternatives IB, ID, IF, 1H:
Short-term
Temporary sloughing of cut-back slopes may cause minor erosion during
pipeline construction.
Primary:
Long-term
Primary:
Short-term
All Alternatives:
Construction will cause temporary disturbances of surficial soils.
Surface Water
Resources
Non-Point source
runoff
Floodplain
Hater quality
Primary:
Short-term
Primary:
Short-term
Primary:
Long-term
Alternatives IB, ID, IF, 1H, 3B, 3C;
A temporary increase in turbidity due to siltation from erosion will occur
as a result of pipeline construction.
All Alternatives:
Construction-related impacts will be minimal.
All Alternatives:
Impacts on flood hazard areas are expected to be minimal.
Alternatives 3A, 3B. 3C, 3D:
Sedimentation and toxic runoff from DLD systems may affect water quality
in local streams.
Groundwater
Groundwater quality
Primary:
Long-term
Alternatives 1C, ID, IF, 1G. 1H. 3A, 3B, 3C. 3D:
The potential for nitrate contamination exists in these alternatives.
Even though the groundwater level underneath Montesa Park is deep,
contaminated surface runoff from open air drying may proceed down
Tijeras Arroyo into areas where groundwater is shallow enough to be
contaminated by vertical seepage. Contamination due to pipeline breaks
or improper operation of DLD activities also is possible.
Air and Sound
Quality
Odor
Emissions
Primary:
Long-term
Primary:
Long-Term
Alternatives 1C, ID. 1G. IB;
Open air drying will result in significant odors that cannot easily be
mitigated.
Alternatives 3A, 3B, 3C, 3D:
DLD disposal of sludge will also result in an odor problem.
Alternatives 1A, 1C, IE, 1G. 2A, 2B, 3A, 3D:
Minimal Increases in emissions along truck routes may affect local
residential areas.
Dust and noise
Primary:
Short-term
All Alternatives:
Temporary increases in dust and noise due to construction may affect local
residential areas.
Biological
Resources
Aquatic organism
degradation
Loss of habitat
Primary:
Long-term
Alternatives 3A, 3B. 3C, 3D;
Aquatic organisms in local drainage canals and streams may be affected by
sedimentation and water quality degradation.
Primary: All Alternatives:
Short-term
Temporary loss of habitat will occur during construction of all facilities.
Cultural
Resources
None
NA
NA
3-27
-------
Table 3-4. Summary of environmental consequences of 14 optimal alternatives (concluded),
IMPACT CATEGORY IMPACT
Population Induced growth
IMPACT TYPE
6, DEGREE IMPACT DESCRIPTION
Secondary:
Long-term
All Alternatives:
Sludge management facilities, will facilitate growth In the
project area consistent with local planning.
Transportation, Traffic
Community
Service and
Land Use
Land Use
Community services
Primary:
Long-term
Primary:
Long-term
Secondary:
Long-terra
Primary:
Short-term
Alternatives 1A, 1C. IE,. 1C, 2A, 2B, 3A. 3D:
Truck traffic will cause some congestion, noise, and dust problems in
residential areas. Damage to residential streets also may occur.
Group 1 (1A-1H) and Group 3 (3A-3D):
Montesa Park and OLD areas will be rezoned to conform with proposed uses.
Land will change to urban uses due to expected population growth.
Alternatives IB, ID, IF. 1H, 3B, 3C:
Construction of pipelines potentially will cause temporary disruptions in
utility services to residential and commercial areas in South Albuquerque.
Economics
Economic stimulation Primary:
Long-term
Secondary:
Long-term
Financial burden
Primary:
Long-term
All Alternatives:
Federal funds for facility construction will enter and stimulate the
local economy.
All Alternatives:
Economic growth will be stimulated by expected population increases.
All Alternatives:
Monthly user charges of $0.51 to $1.91 will not be a financial burden to
the local community.
Energy Resources Energy consumption
Primary:
Long-term
Alternatives 1A, 1C, IE, 1G, 2A, 2B, 3A. 3D:
Additional fuel consumption will occur due to truck transportation
Environmental
Health
Airborne particulatee Primary:
Long-term
Radiation effects
Primary:
Long-term
Alternatives 1C, ID, IE, IF, 1G, 1H, 3A-3D;
Odors, disease vectors, and pathogenic aerosols potentially will be
generated by open air drying, composting, or DLD operations associated
with these alternatives.
Alternatives 1A, IB. 1C, ID, 1G, IB:
General population will not receive additional radiation. Operators will
have an Increased chance of fatal cancer of 0.05%.
Recreation and Area Recreation
Aesthetics
Visual Aesthetics
Primary:
Long-term
Primary:
Long-term
Alternative Group I (1A-1H):
Construction and operation will have a minor effect on shooting and
vehicle recreation near Montesa Park.
Alternative Group 3 (3A-3D);
DLD operations will be unsightly to nearby landowners.
3-21
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3.4 COST-EFFECTIVENESS ANALYSIS
Subsequent to issuance of the Draft SEIS, the City made several changes
to their proposed project, as previously described in Section 3.1. Included
in the changes made by the City were revisions in the estimated costs of the
proposed project. In addition, minor changes were made to costs associated
with other alternatives to correct miscellaneous inconsistencies contained in
the Draft SEIS. Information provided to EPA by the City included costs of
designing and constructing new sludge management facilities (i.e., capital
costs); costs for operating the facilities and making repairs as necessary
(i.e., annual O&M costs); and costs representing the value of certain useful
pieces of equipment or valuable land at the end of the planning period (i.e.,
salvage value).
Several of the alternatives have a high capital cost, but are inexpen-
sive to operate. Others are cheap to build, but expensive to operate. In
order to compare the alternatives on an equal basis, EPA conducted a cost-
effectiveness analysis of the optimal alternatives (Table 3-5). This analy-
sis indicates the total present worth (and total annual equivalent cost) of
each alternative for a 20-year period with an interest (discount) rate of
7 3/8% per year. The analysis also lists the total annual equivalent cost
per ton of sludge processed. The cost-effectiveness analysis determined that
the City's proposed system (Alternative IB) is the most cost-effective
system. The analysis also determined that all Group 1 alternatives poten-
tially are eligible for 85% funding as innovative/alternative systems.
3-29
-------
Table 3-5. Cost-effectiveness analysis of optimal alternatives, with a credit (10,740 ton/yr. at $70/ton) given for
utilization of sludge on public parks.
Alters.
1A*
IB*'1'
1C*
ID*
IE*
IF*
Y3 IG*
o 1H*
2A<2>
2B
3A
3B
3C
3D
Capitol
Grant Eligible
25,699,100
26,427,100
22,872,600
23,600,600
19,063,500
19,791,500
22,817,500
23,545,500
16,622,200
18,383,400
29,188,700
31,382,700
28,719,300
25,688,200
Cost
Ineligible
0
80,000
0
80,000
0
80,000
0
80,000
0
0
0
165,500
212,500
0
Annual
O&M
17,400
(224,800)
119,300
(122,900)
496,900
204,700
273,800
316,000
770,000
640,200
558,600
103,306
264,900
657,600
PW O&M
(10.2921)
179,100
(2,313,700)
1,227,800
(1,264,900)
5,114,100
2,209,100
2,818,000
3,252,300
7,925,900
6,589,000
5,749,200
1,063,200
2,726,400
676,800
Salvage
Value
2,030,100
4,092,000
597,000
2,659,500
(2,722,900)
(661,000)
523,100
2,585,000
1,785,800
2,601,900
9,475,700
13,103,000
8,084,800
3,893,000
PW
Salvage
Value
(0.2410)
489,300
986,170
14,400
640,900
(656,200)
(159,300)
126,100
623,000
43,000
62,700
228,400
315,800
1,948,500
938,200
Total PW
25,388,900
23,207,200
24,086,000
21,774,800
24,833,800
22,239,900
25,509,400
26,254,800
24,505,100
24,909,700
34,709,500
32,295,600
29,709,700
25,426,800
Total
Annual
Equivalent
(0.0972)
2,467,800
2,255,700
2,341,200
2,116,500
2,413,800
2,161,700
2,479,500
2,552,000
2,381,900
2,421,200
3,373,800
3,139,100
2,887,800
2,471,500
Cost
Per
Ton
230
210
218
197
225
201
231
238
222
225
314
292
269
230
Rank-
ing
8
3
4
1
6
2
10
11
5
7
14
13
12
9
* Potentially eligible for 85% Federal funding.
(1}Alternative IB is the City's proposed project.
C2.J -«« t- <=os=.t«=>:£iE &c.-td_-ve. dorwerLtional system.
-------
CHAPTER 4
ERAS PROPOSED ACTION
AND ENVIRONMENTAL
CONSEQUENCES
-------
4.0 EPA'S PROPOSED ACTION AND ENVIRONMENTAL CONSEQUENCES
Based upon the evaluation of information presented in the Draft SEIS,
public comment on the Draft SEIS, additional information received from the
City, and the evaluation of alternatives presented in Chapter 3.0, EPA has
made certain decisions concerning the allowable value of sludge and the
amount of grant funds which should be given to the City. This chapter
describes these recent EPA decisions, identifies EPA's proposed action, and
describes the environmental consequences of the proposed action.
4.1 ALLOWANCE OF CREDIT FOR SLUDGE
The fact that sludge is a valuable resource was noted in Section 5.7 of
the Draft SEIS. It was also noted that the City had requested a credit of
$70/ton for using sludge as a soil conditioner on public lands. This request
was based upon the fact that expensive commercial fertilizer would have to be
purchased for use on public lands if sludge was disposed by landfill or DLD,
and thus not available for use as a soil conditioner. At the time the Draft
SEIS was issued, EPA was not convinced that a credit of $70/ton was valid,
since no offsetting revenues would be generated by the City's self-utiliza-
tion of sludge. Subsequent to issuance of the Draft EIS, additional material
was provided by the City and EPA's Robert S. Kerr, Environmental Research
Laboratory which indicated that nitrogen, phosporous, chelated iron, and
valuable trace minerals found in sludge potentially are worth much more than
$70/ton (see letter in Appendix A dated 22 December 1981 to W.H. McMullen
from George A. O'Connor). Based upon the evaluation of this new material,
EPA proposes to allow a credit of $70/ton of sludge (i.e., $70/ton x 10,740
tons/year = $751,800/year) for all Group 1 alternatives, since these alter-
natives all propose disposal of sludge by landspreading as a soil con-
ditioner. This credit was reflected in the cost-effectiveness analysis
(Table 3-5) presented in Section 3.4 of this document.
4.2 IDENTIFICATION OF FUNDABLE ALTERNATIVES
Information presented in the Draft SEIS regarding Federal funding of
alternatives through the Construction Grant Program was based upon provisions
of the Clean Water Act of 1977 (P.L. 95-217). Major changes were made in the
Construction Grant Program by the Municipal Wastewater Treatment Construction
4-1
-------
Grant Amendments of 1981 (P.L. 97-117). These proposed changes were pub-
lished in draft form on 6 November 1981; interim final regulations were
published on 12 May 1982 and are effective for all grants awarded on or after
this date. The major regulations which affect the funding of the Albuquerque
project are as follows:
e Prior to 1 October 1984, a grant to construct a conventional
treatment system will be equal to 75% of the capital cost; on or
after 1 October 1984, a grant to construct a conventional system
will be equal to 55% of the capital cost.
Prior to 1 October 1984, a grant to construct an innovative or
alternative treatment system will be equal to 85% of the capital
cost; on or after 1 October 1984, a grant to construct an inno-
vative or alternative treatment system will be equal to 75% of
the capital cost.
This means that, as long as the City receives a construction grant prior to 1
October 1984, the allowable funding will be 75%/85% for conventional/
innovative systems respectively, which is the exact same funding that was
available under the old law described in the Draft EIS. Since the Phase II
expansion proposed by the City is to be built and operated from 1984-1990, it
is assumed for purposes of this final EIS that the City will receive a grant
prior to 1 October 1984.
Before a grant can be given, EPA must decide which alternatives are
conventional, and which (if any) qualify as innovative/alternative tech-
nology. Since each of the Group 1 alternatives (i.e., alternatives 1A-1H)
provides for the ultimate reuse of sewage sludge as a soil conditioner (i.e.,
resource recovery), EPA has determined that the Group 1 alternatives qualify
as an alternative system eligible for up to 85% funding. In addition, EPA
has determined that the solar greenhouse, and Cesium-137 irradiator are
innovative treatment processes. Since these processes have been determined
to be innovative, EPA potentially will fund up to 85% of the cost of each
process (subject to availability of funds), and in addition will fund up to
100% of the cost of replacing the process if it fails within two years after
start-up. Group 2 and Group 3 alternatives were determined to be conven-
tional treatment systems.
4-2
-------
Before an innovative/alternative system can be funded, its total present
worth cost must not be more than 115% of the most cost-effective conventional
system. The most cost-effective conventional system alternative (as shown in
Table 3-5) is Alternative 2A, which has a total present worth of $24,505,100.
Therefore EPA cannot grant funds for any innovative/alternative system that
has a total present worth of more than 1.15 x $24,505,100 = $28,180,900.
None of the Group 1 alternatives has a total present worth greater than this
amount; therefore, any of the Group 1 alternatives is fundable up to 85% of
the alternative's grant eligible capital cost.
EPA can only give a grant for a conventional system equal to 75% of the
capital cost of the most cost-effective conventional system. The capital
cost of Alternative 2A is $16,622,200; therefore, EPA can fund 75% of the
grant eligible capital cost of any conventional system up to a maximum of
0.75 x $16,622,200 = $12,466,700. This means that funding of any Group 2 or
Group 3 alternative will be limited to a maximum grant of up to $12,466,700.
4.3 IDENTIFICATION OF EPA'S PROPOSED ACTION
Based on the cost-effectiveness analysis (Table 3-5), the top ranking
alternatives occur in Group 1. However, the Draft SEIS and Section 3.3 of
this document both indicate that environmental problems might be associated
with some of the Group 1 innovative/alternative systems. Open-air drying,
involving sludge spread over a seven-acre area, potentially will generate
significant odors and dust problems that cannot be enclosed or controlled.
Similarly, composting will involve sludge piled over a four-acre area, poten-
tially generating similar odor and dust problems. Concerns also were raised
by the US Air Force and the general public regarding bird strike hazards
(i.e., bird interference with flying aircraft) and the dispension of patho-
genic aerosols due to the use of open air drying and/or composting systems.
The City of Albuquerque currently is under court stipulations to utilize best
available technology to avoid odor problems similar to those that have
occurred in the past at Plant No. 2. EPA does not believe that utilization
of open-air drying or composting would be in conformance with the court
stipulations placed upon the City. Because of the adverse environmental
impacts associated with the open-air drying and composting components, EPA
does not propose to fund Alternatives 1C, ID, IE, IF, 1G, or 1H.
4-3
-------
Of the two remaining alternatives (1A and IB), Alternative IB, the
City's currently proposed project, is the most cost-effective and environ-
mentally sound. Therefore, EPA proposes to give to the City of Albuquerque a
grant of up to 85% of the eligible costs of construction of Alternative IB.
In addition, the City potentially will receive a 12.5% state grant from the
New Mexico BID, which will leave approximately 12.5% of the costs of con-
structing Alternative IB to be financed by the City.
4.4 ENVIRONMENTAL CONSEQUENCES OF EPA'S PROPOSED ACTION
Since EPA proposes to fund the City's currently proposed project, the
consequences (i.e., effects) to the physical or natural environment that will
occur as a result of EPA's proposed action are described in Section 3.2 of
this document.
4-4
-------
CHAPTER 5
CORRECTIONS & ADDITIONS
TO THE DRAFT
SUPPLEMENTAL EIS
-------
5.0 CORRECTIONS AND ADDITIONS TO THE DRAFT SETS
This chapter contains revisions made to the Draft SETS based on new or
more complete information, changes in City of Albuquerque's project since
release of the Draft SEIS, or errors and omissions identified through the
public review process. Minor changes are incorporated as errata in Section
5.1. Where significant changes were required, the entire page from the Draft
SEIS has been reprinted, with the changes highlighted by vertical lines. The
reprinted pages are contained in Section. 5.2.
5.1 MINOR CORRECTIONS (Errata Sheet)
The following changes to the Draft SEIS are editorial in nature, and are
relatively minor. Consequently, the affected pages have not been reprinted
in full. The changes listed below are hereby incorporated into the Draft
SEIS (with respect to the page and paragraph numbering, paragraph 1 is
considered to be the first full paragraph on a page).
1. Page 1-4, paragraph 1, line 13: Delete end of sentence starting at
"funding of an ..." and add: "it is possible that some funding may be
available from the USDOE for the design and construction of the
irradiator."
2. Page 1-8, paragraph 3, line 2: Delete "... the design and ...".
3. Page 2-2, Sections 5.8 and 5.9: Change the page number to 5-49.
4. Page 2-7: Delete Table 5-17.
5. Page 3-1, paragraph 1, line 1: Change Step 1 Grant number to
(C-35-1020-01).
6. Page 4-2, Section 4.3: Add an additional bullet which reads as follows:
Potential impact on land use and potential development of lands
adjacent to Montesa Park.
7- Page 5-1, paragraph 2, line 10: Complete sentence by adding "... City's
Phase I-A expanson program scheduled for completion in 1984."
8. Page 5-7, continuation of paragraph from preceding page, line 2:
Change to read: "... was denied a grant offer and decided not to
construct either their preferred ...".
9. Page 5-11, Table 5-6: Add "Heat Treatment" to the options listed for
the disinfection component.
5-1
-------
10. Page 5-12, Table 5-7: Add the following footnote to the title:
A base option is defined as the sole wastewater solids
management system which, during evaluation of the feasible
alternatives, appears able to provide reliable treatment and
disposal of sludge at all times under all circumstances for
the specific situation being evaluated.
11. Page 5-18, Table 5-10, Alternative Group 1, Disinfection component:
Add the following footnote to the electron beam option: "Electron
beam irradiation would probably take place prior to dewatering."
12. Page 5-20, paragraph 2: Delete the first sentence and combine
paragraph 1 and 2.
13. Page 5-21, paragraph 4, line 1: Delete "such as the Zimmerman or
Zimpro process".
14. Page 5-22, paragraph 1, line 6: Change the words "to close" to
"approximately".
15. Page 5-22, paragraph 1, line 14: Change the word "feed" to "sludge".
16. Page 5-25, paragraph 1, line 9: Delete the phrase "also shown in
Figure 3-1."
17- Page 5-28, paragraph 3, line 7: Delete the words "open air".
18. Page 5-32, paragraph 2, line 8: Delete the word "using".
19. Page 5-42, paragraph 1, line 9: Change the phrase "to document" to
"reporting".
20. Page 5-42, paragraph 1, line 10: Change the sentence to begin: "This
amount was based upon the belief that ...".
21. Page 5-48: Delete Table 5-17.
22. Page 5-49, Section 5.8, line 1: Change (1) to begin: "issue a
construction grant ...".
23. Page 6-31, paragraph 2, lines 3 and 7: Add "and irrigation" after
the word application.
24. Page 6-38, paragraph 1, line 9: Change the word "Group" to "Division".
25. Page 6-38, paragraph 1, line 10 and line 12: Change "i.e." to "e.g."
26. Page 6-50, paragraph 2, line 1: Add the following phrase after "gamma
rays": "which are physically the same as X-rays,".
27- Page 6-52, paragraph 1, line 4: Change the line to read: "... levels
outside the Boston pilot facility ...".
5-2
-------
28. Page 6-69, paragraph 1, line 7: Change the words "Step 2 or Step 3
grants" to "construction grant".
29. Page 6-69, paragraph 1, line 12: Change the word "significant" to
"cultural".
30. Page 6-69, paragraph 1, line 13: Delete the word "potentially".
31. Page 6-83, paragraph 2, line 3: Delete the following part of the
sentence "if any alternative in Group 1 is selected, employment in the
local fertilizer industry potentially will stagnate or decrease due to
the City providing its own fertilizer for land spreading on City Parks".
32. Page 6-94, paragraph 1, line 3: Insert the following sentence at the end
of the first sentence: "Several types of safety systems provide redun-
dancy in the system and thereby substantially reduce the chance of
accidents.".
33. Page 6-95, paragraph 3, line 9: Change the word "eliminate" to
"reduce the".
34. Page 6-97, paragraph continued from the preceeding page, line 2:
Change "300" to "210".
35. Page 6-100, paragraph 1: Add the following sentence at the end of the
paragraph: "Hills on the south side of the Tijeras Arroyo are commonly
used for hang gliding.".
36. Page 6-103, paragraph 1, line 2: Reverse the first two words of the
sentence to read "Should EPA ...".
37. Page 6-103, paragraph 2, line 2: Change the words "only City and State"
to "other".
38. Page 7-2, paragraph 2, line 6: Change the line to read: "... appointed
by the City of Albuquerque".
39. Page 7-3, Table 7-1: Delete "Transcript of Public Hearing" (bullet
number 22).
40. Page 7-6, paragraph 1, line 3: change the line to read: "... Project
Engineer; Mr. Steve Romanow, EPA Construction Grants Project Engineer;
Mr. Steve Rubin, EPA Construction Grants Project Engineer; and by ...".
41. Appendix 10.2, second page, paragraph 1, line 1: Change the phrase
"5 to 7" to "15".
42. Appendix 10.2, thirteenth page, paragraph 1, line 6: Change the word
"exposure" to "overexposure".
5.2 MAJOR CORRECTIONS
The following pages were reprinted due to the inclusion of extensive
changes on the page. Sentences which have been changed are indicated by a
vertical line in the left margin.
5-3
-------
0 Applicants for grant funds must analyze methods, processes, and
techniques to reduce total energy consumption and to increase the
open space and public recreation potential of lands, waters, and
rights-of-way that are parts of a proposed project.
The objectives of the CWA for sewage sludge management are to ensure
protection of public health and the environment by promulgation of
minimum Federal standards for sludge disposal and utilization and to
maximize beneficial uses of sludges that conform to Federal standards.
The principal technical planning document for wastewater collection and
treatment in the City of Albuquerque, New Mexico, and several outlying areas
is the Final Albuquerque Areawide Wastewater Collection and Treatment Facili-
ties Plan, which was prepared by the City of Albuquerque under the require-
ments of the CWA, and funded by EPA as Grant No. C-35-1020-01 under the
construction grants program. Since the awarding of additional grants for
design and construction of any wastewater treatment facilities had the poten-
tial for significant impact(s) to the natural and human environment, EPA
determined that preparation of an environmental impact statement (EIS) was
necessary. This EIS was prepared simultaneously with the preparation of the
areawide facilities plan. Draft and Final EISs were published during June
and August 1977, respectively.
On 27 September 1978, EPA published in the Federal Register the final
regulations concerning Federal grants for the construction of treatment
works. These final regulations implemented the previously mentioned signi-
ficant changes in the FWPCA, as caused by the CWA. Due to the increased
significance and new funding incentives placed upon systems involving innova-
tive and alternative technology, energy conservation, resource recovery, new
Federal regulations governing the land application of wastewater sludges,
increased public concern regarding odors, and desire to provide more in-depth
analyses of some of the facilities plan proposals and alternative processes,
the City of Albuquerque entered into a program of revising and upgrading its
areawide facilities plan. An additional study entitled "City of Albuquerque,
New Mexico Southside Wastewater Reclamation Plant No. 2 - Phase II Expansion
Report" was published during January 1980. The final version of this report
was completed during January 1981 and was forwarded to EPA as a proposed
facilities plan amendment on 21 January 1981. The City has initiated the
review process required to formally amend the Comprehensive Plan's Facilities
Plan element by adopting the Phase II Expansion Program Report as an amend-
ment .
5-4 (DSEIS 1-2)
-------
Federal funding for wastewater treatment projects is provided under the
Municipal Wastewater Treatment Construction Grant Amendments of 1981 (Public
Law 97-117). This Act provides 75% Federal funding (i.e., grants) through
September 1984 and 55% thereafter for eligible planning, design, and con-
struction costs; the grant applicant pays the remainder of the capital cost
plus all operation and maintenance expenses. Portions of projects that are
defined as innovative or alternative are eligible for 85% funding through
September 1984 and 75% thereafter under P.L. 97-117. Funding of an addi-
tional 12.5% of eligible costs also is available under the New Mexico
Environmental Improvement Division (NMEID) Construction Grants program. A
three-step process was provided by the Clean Water Act of 1977. Step 1
involved facilities planning; Step 2 involved development of detailed engi-
neering plans and specifications; and Step 3 involved construction of the
pollution control facilities. With the 1981 ammendments, grants will now be
given at the beginning of Step 3, but may include some allowance for satis-
factory completion of facilities planning and design work. The City of
Albuquerque's sludge management project currently is in the planning phase
with the facilities plan amendment developed for design year 1990.
Public Law 97-117 requires that EPA identify and select for funding an
alternative that is cost-effective, environmentally sound, and publically
acceptable. EPA defines a cost-effective alternative as one that has mini-
mum total resource costs over the life of the project and meets Federal,
state, and local requirements. It is not necessarily the least-cost alter-
native. The choice of the most cost-effective alternative is based on both
capital (construction) costs and operation and maintenance costs for a
twenty-year period, although only capital costs are grant eligible.
3.3 OTHER FEDERAL AND STATE LEGISLATIVE REQUIREMENTS
Sludge management is subject to a number of legislative and insti-
tutional requirements; however, sludge usually has not been singled out for
separate legislative treatment at the state or Federal level. Instead, it
has been included within the statutory scope of regulations concerning
substances generally considered to be pollutants that are discharged into
water or disposed on land. Under these regulations, disposal of raw or
treated sludge into water is subject to restrictions relating to biochemical
oxygen demand (BOD), coliform organisms, suspended or settleable sol-
ids, and toxic materials. The net effect has been to inhibit disposal of
5-5 (DSEIS 3-3)
-------
Table 3-1. Pertinent Federal, state, and local environmental legislation
and regulations affecting sludge management alternatives
applicable to the City of Albuquerque sludge management system.
FEDERAL LEGISLATION
APPLICABLE FEDERAL REGULATIONS
Clean Water Act and
Federal Water Pollution
Control Act Amendments of
1981 (Public Law 97-117)
National Pollution Discharge
Elimination System (NPDES),
40 CFR Part 125
Criteria for the Classification of
Solid Waste Disposal Facilities
and Practices (40 CFR Part 257)
Federal Construction Grants
Regulations (40 CFR Part 35)
Safe Drinking Water Act
Clean Air Amendments
of 1970
National Environmental
Policy Act of 1969
Solid Waste Disposal Act
as amended by the
Resource Conservation
and Recovery Act
Toxic Substances Control Act
Atomic Energy Act of 1954,
as amended
Hazardous Waste Regulations
40 CFR Parts 260-265
Criteria for the Classification of
Solid Waste Disposal Facilities
and Practices (40 CFR Part 257)
PCB Regulations (40 CFR Part 761)
Standards for Protection Against
Radiation (10 CFR Part 20)
Domestic Licensing of Production
and Utilization Facilities
(10 CFR Part 50)
Packaging of Radioactive Material
for Transport and Transportation
of Radioactive Material Under
Certain Conditions (10 CFR
Part 71)
5-6 (DSEIS 3-5)
-------
Table 3-1. Pertinent Federal, state, and local environmental legislation
and regulations affecting sludge management alternatives
applicable to the City of Albuquerque sludge management system
(concluded).
STATE LEGISLATION
New Mexico Air Control Act
Public Nuisance Provision,
New Mexico Statutes
STATE REGULATIONS
New Mexico Water Quality
Act as amended
Water Quality Control Commission
Regulations for Surface Water
and Groundwater
LOCAL MUNICIPAL AND COUNTY REGULATIONS AND ORDINANCES
Air Pollution Control Regulations of the Albuquerque-Bernalillo County Air
Control Board
Zoning Ordinances of the Albuquerque/Bernalillo County Planning Department
1973 Lawsuit and Stipulation (Mt. View et al. vs. Fri et al.), control of
odor and use of "Best Practical Control Technology".
1980 Lawsuit and Stipulation (State of New Mexico vs. City of Albuquerque),
requiring the City to (1) not vent odorous gases, (2) discontinue the use
of sludge drying beds at Plant No. 1, (3) remove sludge on a daily basis
from Plant No. 1, and (4) renovate the sludge digesters.
Revised Ordinances of Albuquerque, New Mexico. 1974. Section 7-Environmental
Ordinances and Regulations, including: Chapter 6 (health, safety, and
sanitation), Chapter 7 (zoning, planning, and building), and Chapter 8
(water, sewer, and streets).
5-7 (DSEIS 3-6)
-------
Ib/day of dry solids would be produced. The effluent would violate limita-
tions established in the City's state and federal discharge permits.
It is expected that the City of Albuquerque would implement emergency
measures in order to handle 60 mgd of wastewater and the subsequent volume of
sludge produced. It is anticipated that existing drying beds would continue
in operation at maximum capacity. Sludge not dried on drying beds would be
stored in lagoons located north of the existing wastewater treatment facili-
ties. Sludge cake removed from the drying beds (47% solids) would be stock-
piled at Montesa Park, as at present. It is noted that EPA could exercise
its authority to levy fines against the City of Albuquerque for violation of
discharge permit effluent limitations. A civil penalty not to exceed $10,000
per day of such violation could be sought by EPA. If a violation is willful
or negligent, the fine may range from $2,500 to $25,000 per day of violation.
As a result of no action, there potentially would be environmental
degradation to the Rio Grande River from deteriorated effluent quality; to
groundwater from leachate emanating from the sludge lagoons to be located at
Plant No. 2, existing unlined drying beds, and stockpiles; and to receiving
surface waters from lagoon overflow and stockpile runoff. Water soluble com-
ponents of heavy metals currently found in the sludge that might contaminate
the groundwater or surface water via sludge leachate, are listed in Table 5.3.
The scenario outlined above could only exist on a short-term basis.
Although it is unlikely, the City of Albuquerque could choose to pay fines
levied against it for noncompliance with permit stipulations. However,
because lagoons and stockpiles require large land areas that are aesthetic-
ally displeasing, are unacceptable as long-term sludge disposal methods., and
would be In violation of recent legal stipulations, the City of Albuquerque
eventually would have to take long-term action to address the needs of their
sludge management system.
5.3 SCREENING OF PRELIMINARY SLUDGE TREATMENT AND DISPOSAL COMPONENTS AND
COMPONENT OPTIONS' ~~
The screening (i.e., evaluation) of preliminary sludge management alter-
natives was accomplished based on the following steps:
« selection of relevant evaluation criteria,
5-8 (DSEIS 5-8)
-------
walls. Sludge would be removed from the open air stockpile at approximately 40%
solids. Figure 5-3 illustrates the proposed site layout for solar drying facili-
ties at Montesa Park. The second drying option is open air drying, consisting of
six 50,000 sq ft drying areas (6.9 acres) similar in design to the drying areas
that would be used after the solar greenhouses. The sludge would be tilled daily
during open air drying. Figure 5-4 illustrates the proposed site layout for open
air drying facilities at Montesa Park. The concept of using drying facilities at
sites other than Montesa Park was not investigated by the City.
5.5.6 Disinfection
In the past, disinfection was not required prior to the application of
sludge on land. The City of Albuquerque has utilized undisinfected sludge on
parks and golf courses for many years. This practice was stopped with the
promulgation of EPA's current sludge disposal regulations (40 CFR Part 257)
requiring disinfection of sludge prior to application on land or incorporation
into the soil. For landfilling and dedicated land disposal, anaerobic digestion
adequately reduces pathogens if certain restrictions are placed on the use of the
site (these restrictions are discussed in more detail in Section 6.11). However,
for landspreading on public lands, additional disinfection is now required by EPA
regulations. Irradiation using Cesium-137, electron beam irradiation, or com-
posting are the three disinfection options selected for further study. A
detailed description of the Cesium-137 irradiator and the electron beam irradi-
ator is presented in Appendix 10.2 and 10.3, respectively.
The City of Albuquerque and the DOE have agreed that DOE will loan the
Cesium-137 to the City, deliver it to the Montesa Park site, install Cesium-137
in an irradiator, and subsequently remove spent Cesium-137 from the site if the
Cesium-137 irradiation option is selected. All handling and transportation of
Cesium-137 would be carried out with DOE assistance and/or supervision in com-
pliance with all applicable Nuclear Regulatory Commission (NRC) regulations and
guidelines, as well as other Federal regulations (Table 3-1). Irradiation would
take place in a concrete structure below the ground surface. The Cesium-137
would remain stationary while sludge would be passed through the system. DOE
would replenish the Cesium-137 supply periodically, by adding source capsules.
It would not be necessary to remove the spent capsules. In discussion with DOE,
the City has been assured that DOE would take the lead in any possible accident
which might involve clean-up. A formal agreement will be executed addressing
this and other aspects of DOE participation if this alternative is approved for
funding.
5-9 (DSEIS 5-29)
-------
Table 5-11.
COMPONENT
Thickening
Potential environmental concerns associated with each optimal component option evaluated for the
Albuquerque sludge management program.
OPTION
Dissolved
Air Flotation
SIGNIFICANT CHARACTERISTICS
Emissions may contain volatile organics
CATEGORY POTENTIALLY AFFECTED
Air
Stabilization Anaerobic
Digestion
Supernatant return may cause treatment
plant upsets
Surface water
Conditioning
Polymer
Lime/Fed.
Toxic in high concentrations
Cost tied to energy (oil) prices
Increases sludge production
Operator safety
Economics
(Depends on disposal option)
I
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Transportation Truck
Pipeline
Increased traffic, noise, and exhaust;
fuel consumption
Traffic disruption, noise, dust during
construction; possible leaks to soil,
arroyos, or river at crossing; energy re-
quired for lift stations
Public safety, nuisance,
air, energy
Public safety, nuisance,
air, groundwater, surface
water, energy
Dewatering
Belt Press
Filter Press
Odors, leachate
Odors, leachate
Air resources, surface water,
groundwater
Air, surface water,
groundwater
Drying
Solar Green-
house
Open Air
Buildings and air drying require
significant land area; may generate
fugitive dust; odor
Large land requirement; dust; odor;
possible leachate; possible insect
attraction, and therefore bird strike
hazard
Land, aesthetics, surface
water, groundwater, air,
nuisance
Land, aesthetics, surface water,
groundwater, air, airplane safety
-------
matter content, total nitrogen, and soil aggregation increased significantly.
Benefits were found to be greater in sandy soil than in loam. These benefits
are largely the result of tilling the sludge into the soil. When the sludge
is spread on top of the soil, the primary benefit will be the leaching of
fertile nutrients and trace minerals from the sludge (National Academy of
Sciences 1977).
Concentration of nutrients that increase soil fertility (nitrogen,
phosphorus, and potassium) are considerably lower in sludge than in commer-
cial fertilizers. Therefore, sludge generally needs to be applied very
heavily in comparison to commercial fertilizers in order to deliver similar
nutrient value. Much of the nitrogen in sludge is organic and is only slowly
available to plants since it must first convert to inorganic forms. Phos-
phorus and potassium are considered to be as available in sludges as in
commercial chemical fertilizers (National Academy of Sciences 1977). Thus,
if sludge is applied at somewhat conservative rates as compared to its "safe"
nutrient limits, there is much less likelihood of soil contamination prob-
lems. Similarly, if sludge is applied heavily in order to achieve nutrient
values comparable to commercial fertilizers, toxic metals entering soil from
the sludge may exceed "safe" limits.
Landfilling
The alternatives utilizing landfilling involve the use of a refuse
landfill for the disposal of sludge from treatment Plant No. 2. Proper
construction and management of the landfill in accordance with state and
Federal requirements should effectively limit any environmental problems.
The importance of this is emphasized due to the sandy and gravelly subsurface
in possible landfill areas, which allows for more extensive leaching possi-
bilities. Proper installation of a clay liner will prevent toxic elements
from entering the soil or geologic strata outside the landfill boundaries.
Nitrates, gases, pathogens, and toxic metals occurring in a landfill empha-
size further the importance of its proper construction and the use of a
liner. The impact of the disposed sludge is significantly lessened due to
the presence of toxic materials already disposed in typical municipal solid
waste landfills.
Wind and/or water erosion are potential problems associated with land-
fill operations. Soil to be' used in the landfill operation is likely sandy
5-11 (DSEIS 6-16)
-------
and easily wind-blown in the. Albuquerque area. Water erosion could affect
the surrounding area by carrying contaminated surface runoff outside the
boundary of clay linings if the topography of the landfill were to rise above
the surrounding area. A further consideration concerns usefulness of the
sludge itself. The potentially beneficial fertilization and soil condi-
tioning characteristics from landspreading are lost by use of the landfill
disposal method.
Dedicated Land Disposal at Pajarito and Rio Puerco
An additional alternative for sludge disposal involves setting aside a
particular land area for the sole purpose of sludge disposal. The upper soil
layer is directly affected by the process of plowing and sludge injection.
As with other alternatives, careful management practices should make this a
viable alternative while adverse affects could result from improper moni-
toring. The City's description of OLD alternatives do not describe proposed
monitoring programs.
One item of environmental concern to earth resources is the effect upon
soil productivity at a DLD site. Nothing will grow during active OLD opera-
tions, and productivity following its use as a DLD site is questionable.
Careful monitoring of toxic elements, following USDA guidelines, should allow
for food chain crop growth following the site's use as a disposal area.
Copper is the only toxic parameter which, from sludge sampling, exceeds the
USDA guidelines. Toxics will build up so that unlimited use of an area
following DLD operations will be limited over a period of years (probably
between 20 and 30).
Another major environmental concern is water erosion and erosion due to
wind blowing. During dry periods severe dust problems are likely in the two
barren areas proposed for DLD sites because of the constant plowing and
loosening of topsoil.
Lagoons are proposed at the DLD sites to store sludge prior to its
application by injection. Since the lagoons will have a concentration of
toxics directly received from the treatment plant, they deserve more inten-
sive environmental monitoring than the DLD application area.
5-12 (DSEIS 6-17)
-------
Table 6-2. Effects of Optimal Alternatives for the City of Albuquerque Sludge Management Program on Earth Resources.
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No. Alternatives
1. 1A
2. IB
3. 1C
4. ID
5. IE
6. IF
7. 1G
8. IH
9. 2A
10. 2B
11. 3A
12. 3B
13. 3C
14. 3D
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» Water Rights
New Mexico's water rights allocations near Albuquerque will be indirect-
ly affected by all action alternatives. Each alternative assumes increased
population, industrialization, water demand, and water use. These increases
are dependent on current appropriations and if increases are sufficient,
acquisition of new or abandoned allocations will be necessary.
Currently, the City receives a credit for all groundwater returned via
sanitary sewer to the Rio Grande River. As demand and discharge increase
this credit will increase also.
6.3 GROUNDWATER RESOURCES
6.3.1 Existing Conditions
All of the alternative sites share some common groundwater character-
istics as well as some differences. A major similarity of all sites is that
they are all recharged by the following methods: precipitation; seepage from
streams, drains, canals, surface reservoirs, and applied irrigation water;
and underflow from adjacent groundwaters. The order of importance depends on
local conditions. All sites have a southwesterly flow, except for the Rio
Puerco and Pajarito sites, which are located on the west side of the
"trough," and thus have a southeasterly flow. Differences occur in depth to
the water table, hydraulic gradient, quality, and uses of water as discussed
below.
Approximate depths to water at each site are as follows: Plant No. 2,
less than 10 feet; Montesa Park, 210 feet; Pajarito, 470 feet; and Rio
Puerco, 800 feet. Possible landfill sites vary in their depth to water,
though the general region being considered has an average depth of approxi-
mately 100 feet. The gradient is steepest underneath the Rio Puerco site,
though it is still less than 1%.
5-14 (DSEIS 6-28)
-------
Table 6-7. Potential air effects associated with sludge management
options (continued).
Cesium-137 Irradiator
small potential for overexposure to radiation of occupational personnel
and the public due to abnormal events (accidents); for more information
see Appendix 10.2
during normal operation, the irradiator will be designed so that there
will be no discernible radiation exposure outside the facility
during normal operation of the pilot irradiation facility at Sandia
Laboratories there has been no dose rate over 0.05 rems per year to
workers inside the irradiator facility
since irradiated sludge has a higher content of biodegradable organic matter
than composted sludge, it would be more likely to produce an odor problem.
However, since Albuquerque has been land applying sand-bed-dried, anaero-
bically-digested sludge for years, this probably is not a problem (Kowal 1981)
Electron Beam Irradiator
extremely small potential for radiation exposure of occupational personnel
and the public since interlocking safety system would shut the system off
in case of accidents; when the system is off there is no production of
radiation; for more information see Appendix 10.3
the facility will be designed so that there will be no discernible
radiation exposure outside the facility
during normal operation of a pilot irradiator there has been no
measurable radiation exposure to the workers inside the facility
since irradiated sludge has a higher content of biodegradable organic
matter than composted sludge, it would be more likely to produce an
odor problem. However, since Albuquerque has been land applying sand-
bed-dried, anaerobically-digested sludge on City parks for years without
significant complaints from residents living near the parks, this probably
will not be a problem (Kowal 1981)
Composting
significant odor could be generated from the sludge before it is covered
with an insulating layer if the sludge is not properly digested; minor
odor present after insulating layer is applied; odor associated with the
air drawn through the pile is greatly reduced by being released into a small
pile of screened compost which absorbs the malodorous gases
pathogenic aerosols could be released during the stacking of the sludge
before the insulation layer is placed on the pile
high concentration of Aspergillus fumigatus (fungi that pose a pathogenic
threat to man); generally restricted to the immediate composting area and
should not pose a significant health threat to surrounding area
5-15 (DSEIS 6-43)
-------
With Group 1 alternatives (1A.-1H) the major sources of malodorous emis-
sions associated with sludge management will be located at Montesa Park.
Sludge will not be transported to Montesa Park in the second (2A and 2B) and
third (3A-3D) groups of alternatives; therefore, the odors associated with
these alternatives will be located at Plant No. 2 and the disposal sites.
The Group 1 alternatives involving disposal by landspreading on city
parks include, with the exception of IE and IF, either solar greenhouse or
open air drying which are both potentially significant sources of odorous
emissions. Stockpiles, another cause of odors, would also be a part of the
first group of alternatives. Alternatives 1A, IB, 1C, ID, 1G and 1H will
have three stockpiles. One stockpile will be at 20% solid, one at 40% solid,
and one at 40% solid that will eventually dry to approximately 90% solid.
The 40-90% stockpile would be the largest due to the longer retention time.
Alternative IE and IF will have two stockpiles: one at 20% solid, and one at
approximately 70% drying to 90% solid.
There will be no drying component (greenhouse or open air drying)
included in Group 2 or Group 3 alternatives. There will be one stockpile/
storage area with a short retention time included in the Group 2 alterna-
tives. The Group 3 alternatives will have no stockpiles. The dedicated land
disposal option included in the third group of alternatives is a significant
source of odor. These odors will originate at the disposal sites.
Malodorous pollutants related to the sludge handling facilities will
either be emitted from a point source (i.e., exhaust gases from the DAF,
greenhouse, etc.) or from open sources (i.e., stockpiles, OLD, etc.). These
odorants will be transported and diluted by the wind and are greatly influ-
enced by local topography. For instance, the wind and therefore the pollu-
tants are channeled in pronounced valleys such as the Tijeras Arroyo. It
should be understood that the intensity of these odors is highly dependent on
the proper functioning of the sludge management facility and atmospheric
dispersion. Existing and future development surrounding the various alterna-
tive sites could be affected during incidents of malodorous upsets at the
sludge management facility.
5-16 (DSEIS 6-49)
-------
eastern end of the property. The Tijeras Arroyo traverses Montesa Park from
east to west and drains into the Rio Grande River. Kirtland Air Force Base
is located along the north and east sides of Montesa Park, and the University
of New Mexico owns a large tract of land to the south. Montesa Park cur-
rently is remote from residential areas and is expected to remain as such
(COM 1980a).
Montesa Park and the area to the north is within municipal jurisdiction,
and is zoned SU-1, (Special Use for Sludge Treatment Facility). The area to
the south of Montesa Park is zoned A-l, rural and agricultural by the
Bernalillo County Planning Commission (Vanervan, J. 1981). Montesa Park has
been designated in the Plan for Major Open Space as public open space "to be
used for passive recreation, maintenance of scenic areas, preservation of
essential resources and other environmental purposes."
A part of Montesa Park is in the 100 year floodplain; however, none of
the proposed construction activities are located in the floodplain. In
addition, none of the land is considered to be prime or unique farmland (US
Department of Agriculture 1980). Access to Montesa Park is provided by Los
Picaros Road.
The area north of the City where a landfill site might be chosen con-
tains a mixture of rural residential and agricultural land. The landfill
site will be outside the jurisdiction of the City and would be under the land
use control of the Bernalillo County Planning Commission. Transportation of
the sludge would occur along Interstate 25. New industries in the northern
part of the City are anticipated to cause major traffic jams on the frontage
roads along Interstate 25.
Land use surrounding both the Rio Puerco and Pajarito sites is undevel-
oped grassland and shrubland (Middle Rio Grande Council of Governments of New
Mexico 1979). There are no residences near the site. Access to the Pajarito
site would be provided by Padillas Road, while access to Rio Puerco would be
provided by a lightly used rural road. Both of these sites are under the
land use jurisdiction of the Bernalillo County Planning Commission and are
zoned A-l, rural and agricultural.
5-17 (DSEIS 6-73)
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A pipeline to Rio Puerco will disturb the residential area along
Lakeview Road and Gun Club road. In addition, construction of a pipeline to
Rio Puerco or Pajarito will pass by Harrison Junior High School, which may
cause disruptions during construction. In addition, the possibility of
someone falling into an open trench is greater.
A total of 47 round trips by truck per day will be needed to haul
liquid sludge between Plant No. 2 and Montesa Park, Pajarito, or Rio Puerco.
The trip to Rio Puerco will require trucks to pass through one of the highest
traffic volume areas in Albuquerque, thereby increasing the possibility of
accident. Disposal at a landfill site will require trucks to pass through
the same high traffic area. However, only 5 to 9 round trips per day will be
needed.
Trucks might have to use a highly congested frontage road along
Interstate 25 for disposals at the landfill site. Five to 9 trucks will use
the landfill site per day; 200 to 300 trucks per day use the present landfill
site (by phone, V. Brown 1981). Therefore, the addition of 5 to 9 trucks
will have a minimal impact.
The truck route to the Pajarito DLD site crosses the Rio Grande via
the Rio Bravo Bridge. There is some question as to whether this bridge has
the capacity to handle this additional traffic. Major structural problems
with this bridge developed in 1980, and for significant periods the bridge
either was entirely closed or restricted to one lane traffic while heavy
repair work was made on the bridge substructure and foundation pile caps.
If the open air or composting methods attract birds, these uses would
be incompatible at Montesa Park with the adjacent airport. Current infor-
mation regarding bird strike hazards near composting operations indicates
this should not be a problem.
Both Pajarito and Rio Puerco are zoned rural and agricultural. This
zoning will have to be changed to allow for the disposal of sludge. The
change will not cause a conflict with adjacent land uses.
The effects of each of the 14 action alternatives on transportation and
land use are designated in Table 6-16.
5-18 (DSEIS 6-75)
-------
Table 6-16. Effects of the action alternatives on transportation and land use.
Transportation
Alternative
1A
IB
1C
ID
IE
IF
1G
IH
2A
2B
3A
3B
3C
3D
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Sensitive
Disrupt Urban
Services Areas Streets
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- Major Effect
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5-19 (DSEIS 6-76)
-------
minor and the sump pump would clear it out. The likelihood of the flood
water coming into contact with the radioactive material is extremely low
since an undetected leak in a source pin would have to occur, concurrently.
Albuquerque is classified as a region of low occurrence of tornadoes,
with an annual frequency of 0.1 or less. Because of the low frequency of
tornadoes and the fact that most of the structure of the facility is under-
ground, tornadoes are not a significant design consideration. If a tornado
were to pass directly over the facility, the most severe damage expected
would be damage to the part of the conveyor that extends above the facility.
The technology for using radiation to disinfect sewage sludge is rela-
tively new, with operating irradiators located in West Germany and South
Africa. However, irradiation is used routinely to sterilize certain pharma-
ceutical equipment. Most of the existing industrial irradiators use cobalt
(Co-60) as the source of gamma rays, as compared to Cs-137 which is proposed
in this project. Although the Albuquerque irradiator will be larger than the
existing irradiators and uses a different gamma ray source, the basic tech-
nology is similar and therefore it would be useful to present the safety
record of some of the existing irradiators. The Director of the appropriate
Nuclear Regulator Commission (NRG) must be notified within 24 hours of any
incident involving the radioactive material which may have caused or
threatens to cause:
(1) Exposure of the whole body of any individual to 5 rems or more
of radiation; exposure of the skin of the whole body of any individual
to 30 rems or more of radiation; or exposure of the feet, ankles, hands,
or forearms to 75 rems or more of radiation; or
(2) The release of radioactive material in concentrations which, if
averaged over a period of 24 hours, would exceed certain specified
limits; or
(3) A loss of one day or more of the operation of any facilities
affected; or
5-20 (DSEIS Appendix 10.2, pg. 12)
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CHAPTERS
COORDINATION
-------
6.0 COORDINATION
6.1 RECOMMENDATIONS OF THE CITIZEN ADVISORY COMMITTEE
On 9 December 1981, the Citizen Advisory Committee (CAC) of the City of
Albuquerque held their twenty-first meeting and voted on their final recom-
mendation to the City concerning the Albuquerque Wastewater Facilities
Expansion Plan, Phase II. Fourteen (14) members of the 15-person committee
voted and one member was absent. The vote indicated:
1. A ten-vote majority for resource recycling (i.e., sludge disposal
by landspreading) over four votes for dedicated land disposal and
no votes for landfill;
2. A nine-vote majority to four votes for the Cesium-137 irradiator
over thermal conditioning. There were no votes for composting or
electron-beam irradiation and one abstention;
3. A five-vote majority for siting the disinfection facility at Waste-
water Treatment Plant No. 2 against three votes for Montesa Park,
two votes for Kirtland Air Force Base, two votes for other sites
and two abstentions;
4. A seven-vote majority for solar greenhouse drying against five
votes for the filter press, two votes for a combination and no
votes for open air drying; and
5. For sludge transportation, an eleven-vote majority for the pipeline
against two for trucking and one abstention. For dedicated land
disposal, a ten-vote majority for the pipeline, two for trucking
and two abstentions.
The actual vote was as follows:
VOTE
1. If dedicated land disposal were selected as the
most favorable sludge disposal technique, which
transportation process would you favor?
A. Trucking 2
B. Pipeline 10
Abstentions: 2
2. With dedicated land disposal as the sludge
disposal action, which area would you recommend?
A. Pajarito 0
B. Rio Puerco 0
C. Others 11
Abstentions: 3
6-1
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VOTE
3. If landfill were selected as the most favorable
sludge disposal technique, which conditioning
process would you favor?
A. Polymer utilization 9
B. Lime/Ferric Chloride utilization 2
Abstentions: 3
4. If landfill were selected as the sludge disposal
action, which general area of the city extended to
county lines do you favor for site selection?
A. Northeast Quadrant 3
B. Northwest Quadrant 0
C. Southeast Quadrant 0
D. Southwest Quadrant 2
E. Others 6
Abstentions: 3
5. If sludge recycling were selected as the most
favorable sludge disposal technique, which
disinfection process do you favor?
A. Composting 0
B. Electron Beam Irradiation 0
C. Thermal Conditioning 4
D. Cesium-137 Irradiation 9
Abstentions: 1
6. With sludge recycling as the selected process,
which general area do you favor for site selection?
A. Montesa Park 3
B. Adjacent to Plant #2 5
C. Air Force Base 2
D. Others 2
Abstentions: 1
7. With sludge recycling as the selected process,
which transportation process do you favor?
A. Trucking 2
B. Pipeline 11
Abstentions: 1
8. With sludge recycling as the selected process,
which final drying procedure do you favor?
A. Open Air Drying 0
B. Solar Greenhouse 7
C. Filter Press 5
D, Combination 2
Abstentions: 0
6-2
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VOTE
9. Which basic sludge disposal procedure do you
favor as best answering the City of Albuquerque
problem?
A. Landfill 0
B. Dedicated Land Disposal 4
C. Sludge Recycling 10
Abstentions: 0
Along with their recommendations, the CAC submitted the following
statement of protest:
The Citizen Advisory Committee objects to being pressured
into adopting recommendations prior to any EPA response
to its inquiries, comments and evaluation. It is on
record as finding the DEIS to be seriously deficient in
the critical areas of project definition, alternate sites
and mitigation measures. The DEIS does not contain
substantial evidence for a comparative evaluation of the
proposed project. It believes that pressure to adopt
recommendations under the threat that if it does not do
so by December 14, 1981, its recommendations will not
appear in the Final EIS, seriously undermines the CAC
public participation and EIS processes in their entirety.
Therefore, it adopts the recommendations under protest.
6.2 SUMMARY OF THE PUBLIC HEARING
A public hearing was sponsored by EPA at 7:00 p.m., 18 November 1981 at
City Hall in Albuquerque, New Mexico. The meeting was attended by represent-
atives of EPA and their consultants, the Water Resources Department and their
consultants, and approximately 70 interested citizens. The agenda of the
meeting was divided into two basic parts: (1) formal presentations by a
panel of representatives from EPA, the Water Resources Department, and the
Citizen Advisory Committee (CAC), and (2) statements, comments, and questions
from the audience. The panel presenting formal statements and the subject of
their presentations were as follows:
Person Topic of Statement
Miles Schulze Introductory remarks;
StafE Attorney Rules of Procedure
Regional Counsel
EPA Region 6
6-3
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Person
David Neleigh
Construction Grants Engineer
EPA Region 6
Darlene Owsley
Environmental Specialist
EIS Preparation Section
EPA Region 6
James C. Varnell
Project Manager
WAPORA, Inc.
A.K. Khera
Water Resources Department
and
John Burgh
Camp, Dresser, and McKee
Wiley Smith
Member, Citizen Advisory
Committee (CAC)
Topic of Statement
Facilities Planning Process
Environmental Impact
Statement and Public
Participation
Evaluation of Optimal
Alternatives
City's Preferred
Alternative
Preliminary Preferred
Options of the CAC
Following the formal statements, comments and questions were solicited
from the audience. A summary of the comments and EPA's responses is
presented in Section 6.4 of this document.
6.3 EVALUATION OF THE PUBLIC PARTICIPATION PROGRAM
The Public Participation Program consisted of a joint effort to educate
and encourage involvement of the public in selecting the safest and most
economical method of sludge treatment and disposal for Albuquerque. The
following agencies/organizations participated in this effort:
- Citizen Advisory Committee (CAC);
- USEPA Region 6;
- City of Albuquerque;
- Camp Dresser and McKee, Inc., (the City of Albuquerque's engineering
consultant); and
- WAPORA, Inc. (EPA's EIS Consultant).
6-4
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Input for preparation of this evaluation was received from members of the CAC
and the public. These comments were obtained through the use of a checklist
distributed at CAC Meeting No. 21, held on 9 December 1981. Twelve of the 15
CAC members and four members of the general public responded to the check-
list. Valuable input also was obtained from the City of Albuquerque's Public
Participation Staff.
A major element of the Public Participation Program was the formulation
of the Citizen Advisory Committee. This committee was developed in December
1980 to study the sludge treatment alternatives available to the City of
Albuquerque in order to recommend a preferred alternative. An attempt was
made to select CAC members based upon a balanced representation of the Albu-
querque population. As a result, the final CAC membership consisted of three
public officials, four public interest group representatives, three private
citizens and five representatives of economic interest. The members of the
CAC (listed in Table 6.1) reside throughout all sections of the city, and
various ethnic groups in the area were represented on the committee.
In the final evaluation, most of the CAC members felt that the member-
ship was well balanced. However, two members stated that the committee was
"weighted for the irradiator from the beginning." Another member commented
that the committee was balanced on the surface only.
The CAC worked long hours through 21 meetings to learn more about the
alternatives and to formulate their recommendations. The CAC requested that
independent consultants present information on various alternatives to help
the CAC in their evaluations. The consultants and the subject of their
presentation are as follows:
Dr. Norman Kowal - Epidemiological Aspects of Composting and Cs-137
Irradiation
Dr. John A. Ulrich - Epidemiological Aspects of Composting, Cs-137
Irradiation, and Wet Air Oxidation
Dr. J.C. Robertson - Radiation Hazards and Safety
6-5
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Table 6-1. Members of the Albuquerque Citizen Advisory Committee.
Name
Kay Grotbeck
Gene Martinez
Stan Read
Fred Ward
Fred Seebinger
Jay Sorenson
Wiley Smith
Rosa Grado
Evelyn Oden
Douglas Smith
Category
Public Interest
Public Interest
Public Interest
Public Interest
Public Official
Public Official
Public Official
Private Citizen
Private Citizen
Private Citizen
Stephen Verchinski Private Citizen
Herb Denish
Ivan Rose
Walter Webster
Jim Wiegmann
John Castillo
Economic Interest
Economic Interest
Economic Interest
Economic Interest
Economic Interest
Affiliation
Conservation Coordinating Council
Sierra Club (Citizen Activist)
Economic Opportunity Board
(Water and Sewage Coordinator)
South Valley Area Council
(Attorney)
Black Leadership Council
Kirtland Community Association
(Director of the John Marshall
Center)
County Environmental Planning
Commission (Businessman)
Water Quality Commission
(Professor at UNM)
City Environmental Planning
Commission (Professional
Civil Engineer)
South Valley Resident
(Social Worker)
South Valley Resident
(Pediatrician)
S.E. Area Citizen
(Graduate Student)
NE Heights Citizen
(Social Security Employee)
Denish and Associates Inc.
(Consultant)
Kirtland Airforce Base
(Professional Civil Engineer)
Consulting Engineer's Council
(Professional Civil Engineer)
University of New Mexico
(Budget Director)
GTE Lenkurt, Inc.
6-6
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Also, the chairperson of the CAC visited a treatment plant with a wet air
oxidation system located in Indio, California.
Various mechanisms to inform and involve the public in the EIS process
were included as part of the overall public participation program. These
mechanisms, which included public information depositories, mailing lists,
public notices, newsletters, public meetings, and the CAC newsletters, are
discussed below.
Six public information depositories were established in January 1981 and
routinely maintained for public reference. These were:
- Public Library, Main Branch, 501 Copper, N.W. (Downtown),
- Prospect Park. Branch Library, 8205 Apache Avenue, N.E.,
- Zimmerman Library, University of New Mexico,
- Esperanza Branch Library, 5600 Esperanza, N.W.,
- Los Griegos Branch Library, 1000 Griegos, N.W., and
- Wastewater Treatment Plant No. 2, 300 North Street, S.W.
Each of these locations provides access to copying facilities. Page 7-3 of
the Draft SEIS lists the documents on file at each depository location. In
addition, a list of reports available from Sandia National Laboratories (SNL)
is filed at each depository. These documents contain further information on
sludge irradiation and the SNL Beneficial Uses Program.
An EIS mailing list was compiled of persons expressing an interest in
the project. It was continually updated based on specific requests and meet-
ing attendance. At the close of the project, there were 120 persons on the
EIS mailing list. These persons received agendas for upcoming meetings,
pertinent documents, and meeting minutes upon request. In addition, an
expanded mailing list was developed for distribution of newsletters. News-
letters were mailed to a total of 360 interested citizens and organizations.
Those receiving newsletters included: (1) everyone on the EIS mailing list;
(2) all senior citizen centers and community centers in the city; (3) neigh-
borhood associations that expressed interest in the project; (4) many addi-
tional Federal, state, county, and city agencies.
6-7
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Public notices to inform the. public of the project's inception, the
formulation of the CAC, the two public meetings, the public hearing and most
CAC meetings were published in the Albuquerque Journal, the Albuquerque
Tribune, El Hispano, and the New Mexico Independent. In addition, public
meetings and the public hearing were advertised in the Pueblo News, a monthly
Native American publication.
Meeting notices listed the time and place of the meeting, topics for
discussion, and the contact person's name and telephone number. In addition,
each notice contained a statement encouraging attendance. Notices were
published 30 to 45 days prior to the public meetings and hearings. CAC
meeting notices were published ten days prior to the meeting date when possi-
ble. Since some of these meetings were scheduled at a late date, notices of
these meetings were published the weekend before (at least 3-5 days) the
scheduled meeting date. Of all of the meetings in which CAC business was
conducted, four meetings, Nos. 9 through 12, were not publicized by legal
notices.
Input received from the CAC and the public regarding notices was gen-
erally positive; however, one CAC member and one attendee felt that issues
were not clearly stated in the notices.
Additional efforts to encourage public participation at public meetings
and CAC meetings and to keep the public informed of the progress of the EIS
included:
- The Mayor's Weekly Calendar - Distributed to all Departments of the
City of Albuquerque.
- Announcements - in the What's Happening column of the Albuquerque
Journal and the Tribune's Diversion column.
- Bilingual Fliers - Distributed to libraries/recreation centers and
general distribution throughout the City by the public participa-
tion staff and CAC members.
- Public Service Announcements - Provided to area radio and television
stations.
-------
- Preas Releases - Provided to area newspapers and radio and television
stations.
- Press Packets - Provided to area newspapers and radio and television
stations.
Throughout the EIS process materials were prepared to inform and educate the
public and the CAC. The first major documents prepared in conjunction with
this Public Participation Program were a public participation workplan and
fact sheet. The workplan listed all major activities to be performed
throughout the process, the staff assigned to perform the activities, and
scheduled completion dates. It should be noted that the schedule remained
flexible throughout this program in order to accommodate unforeseen circum-
stances. The fact sheet included a narrative description of the nature and
scope of the project, a list of CAC members, depository locations, consulting
engineers, contacts and estimated project costs.
Four CAC members expressed some dissatisfaction with the workplan and/or
fact sheet. They felt that the documents were either biased, incomplete,
unclear, or schedules not followed.
Materials requested by the CAC were provided as soon as possible by the
Water Resources Department, EPA, and/or WAPORA, Inc. In the final evalua-
tion, the majority of the CAC had positive comments on the distribution of
materials. However, several CAC members expressed discontent. One member
felt that the information provided was biased and incomplete, especially that
pertaining to wet-air oxidation and composting. Another stated that the
information was confusing. Four of the CAC members stated that information
was not provided in a timely manner, and two of them specifically cited EPA
as the responsible agency.
Two public meetings and one public hearing were held to provide infor-
mation on this project and to give the public an opportunity to make com-
ments. In addition, the CAC held 21 meetings (open to the public) to gather
information and formulate their recommendations.
A public scoping meeting was held 7 October 1980 at 7:30 p.m. in the
City Council Chamber Room of City Hall. The purpose of this meeting was to
6-9
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provide an opportunity for the public to comment on what should be included
within the scope of the SEIS. Four persons provided brief presentations on
the background of the project, which were followed by public comments and
questions. A record of the meeting was made available in the form of an
official transcript. In addition, a responsiveness summary was prepared and
distributed to all interested persons.
A public meeting was held on 8 July 1981 at 7:30 p.m. in the Council
Chamber Room of City Hall. The purpose of the meeting was to discuss the
optimal sludge treatment alternatives available to the City of Albuquerque.
Although the agenda provided for a question and answer session, several
complaints were received concerning the length of the presentations scheduled
prior to the question and answer session. However, all persons who indicated
a desire to make a comment were allowed to do so. The record of this meeting
was made available in two forms: minutes and a responsiveness summary. Both
of these documents were made available to the public.
On 18 November 1981 at 7:00 p.m., a public hearing was held in the
Council Chamber Room at City Hall to discuss the Wastewater Treatment
Facilities Plan Amendment and the Draft SEIS. A summary of the public
hearing is included in Section 6.2 of this Final SEIS. Verbal comments
received at the public hearing and EPA's response to these comments are
presented in Section 6.4 of this Final SEIS. On request from the CAC, the
comment period for this hearing was extended from 23 November until 14
December 1981.
As previously stated, input from CAC members and the general public was
obtained through an evaluation checklist distributed at CAC Meeting No. 21.
Checklists will remain on file with the City's Public Participation Staff and
are available for review.
In general, the CAC checklists reflected a favorable impression of the
Public Participation Program. Of the twelve checklists received from CAC
members, two were entirely favorable and six were favorable in nearly all
areas. The primary concern of these six members related to the timely
distribution of information provided to the CAC. Two other CAC members
6-10
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criticized the materials provided and the balance of interest within the
committee as being biased.
Whereas a majority of the CAC members and members of the public provided
positive feedback, one person from the audience had several complaints about
the Public Participation Program. This person's dissatisfaction was asso-
ciated with the perceived untimely provision of materials to the CAC and the
way in which the meetings were arranged.
Concerning the CAC meetings, the overall tone of the comments received
was positive. The primary complaint, as noted by two CAC members and one
member of the public, was that the agendas did not always permit pubic com-
ment. In contrast, another CAC member objected to the public dominating the
CAC meetings.
In regards to the public consultations, responses from the checklists
indicated general approval. One criticism was the belief that the public
felt intimidated by the seating arrangement utilized during the scoping
meeting of 7 October 1981. Responses concerning the public meeting of 8 July
1981 suggested briefer presentations consisting of less biased information.
Every effort was made to accommodate these concerns in the formulation of
subsequent public consultations. As a result, commentors praised the final
public consultation the public hearing of 18 November 1981.
6.4 RESPONSES TO VERBAL COMMENTS RECEIVED AT THE PUBLIC HEARING
(C = Comment; R = Response)
Cl. Pat Lopez
Complained about the current odor. He hopes the City will do some-
thing about the odor and not make idle promises.
Rl. Comments noted.
C2. Carla Baron
a. She is against sludge irradiation because (1) it is an experi-
mental process, (2) would require the transport and storage of
6-11
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Cs-137 in Albuquerque, (3) risk of accidents, and (4) long-term
effects of exposure to irradiated sludge are unknown.
b. Please elaborate on public health effects of gamma radiation.
R2. a. Comments noted.
b. Information on public health effects of the Cs-137 irradiator is
included in Section 6-11 and Appendix 10.2 of the D-SEIS. Addi-
tional information on the health effects of gamma radiation in
general is included in the following documents which should be
available at local libraries:
Government Accounting Office. 1981. Problems in assessing
the cancer risks of low-level ionizing radiation exposure
EMD-81-1. Washington DC, variously paged.
National Council on Radiation Protection and Measurements.
1975. Review of the current state of radiation protec-
tion philosophy. Washington DC, Report No. 43, variously
paged.
Upton, Arthur C. 1982. The biological effect of low-level
ionizing radiation. Scientific American 246(2):41-49.
C3. Clara Nanninga
a. Concerned about: (1) the effects of whatever alternative is
chosen on the people living and working in the Southeast Valley,
(2) possible water pollution due to the high water table in the
Valley, and (3) the effect of odors on the people close-by as well
as the people in the SE Heights and downtown.
b. She did not see any publicity about the meeting, and felt the
meeting should be advertised in the newspaper, the radio, and TV.
R3. a. Comments noted.
b. An evaluation of public participation activities (including
meeting announcements) is included in Section 6.3 of the Final
SEIS.
C4. Rosamund Evans
a. She would like to see the comments of the two cooperating agen-
cies listed in the EIS. :
b. The value of the sludge should be weighed against the cost of a
disinfection system.
c. The SEIS did not describe the pre-treatment of industrial
wastes.
6-12
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d. The danger of building-up toxics in the soil due to the applica-
tion of sludge is not addressed in the SEIS.
R4. a. All written comments and responses are provided in Section
6.5 of this Final SETS.
b. The cost-effectiveness analysis presented on pages 5-44 and 5-45
of the Draft SEIS evaluates the value of sludge (hypothetically set
as $0/ton and $70/ton) on all alternatives. The effect of the
actual value (cost credit) of sludge accepted by EPA is described
in the cost-effectiveness analysis presented in Section 3.4 of this
document.
c. Pre-treatment for industrial wastes was described in detail in
the Facilities Plan Amendment. This discussion was not repeated in
the SEIS since the scope of the SEIS is limited to the sludge
management system. A copy of the Facilities Plan Amendment is
available at the public depositories.
d. The potential of toxic build-up in the soil due to sludge appli-
cation is discussed on pages 6-15, 6-16, 6-17, 6-18, 6-27, 6-31,
and 6-97 of the Draft SEIS.
C5. Evelyn Oden
a. Information on the health effects of the Cs-137 irradiator are
scant and should be addressed in more detail.
b. She is concerned about the possibility of the Cs-137 contami-
nating the groundwater, especially if the Irradiator is located at
the Plant No. 2 site. A complete analysis of soils, groundwater
table, and floodplains for all of the alternative sites should be
completed.
c. The Draft SEIS should have compared magnitude and capacity of
the Co-60 irradiators and the Cs-137 irradiators.
d. The Draft SEIS said there was no overexposure to workers in the
two incidents where the workers entered the room where the source
plaque was kept what was the exposure? What was the estimate of
doses to the workers in the fire incidences in NRC Region 1?
e. The other "time-proven" methods of disinfection (i.e., compost-
ing and wet-air oxidation) pose less danger to the people of Albu-
querque.
R5. Dr. Oden submitted her comments in writing as well as presented
them orally at the public hearing. EPA's responses to her comments
are included in Section 6.5 of this Final SEIS.
6-13
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C6. Gary Socha
Requests that the DOE agree to clean up any spills of Cs-137.
R6. In formal correspondence between the City of Albuquerque Water
Resources Department and EPA, the City stated that:
We have discussed the subject of support for any
cleanup work with local DOE officials, and have been
assured that DOE would take the lead in any accident
containment and recovery which might ever be neces-
sary. We will be executing a formal agreement
addressing in detail this and other aspects of DOE
participation, after final approval of the proposed
irradiation system plan.
C7. Bruce Thomson
a. He believes that sludge should continue to be used in a benefi-
cial fashion. Both composting and Irradiation would achieve the
stated goals, but his personal preference is irradiation because:
(1) it is a simpler process, (2) the thoroughness and consistency
of disinfection is better, (3) it is safer for the plant operator,
and (4) it does not destroy any of the nutritive value of the
sludge.
b. He does not believe the disadvantages of trucking were ade-
quately addressed. The number of potential accidents (fatal and
non-fatal) and the effects on the existing roads should be
addressed.
c. He questions locating the facilities at Montesa Park because of:
(1) large capital expenses associated with the pipeline, (2) large
O&M expenses associated with the pipeline, and (3) potential fail-
ures with the pipeline and pumping stations. A more viable option
would be to use funds available for the pipeline to buy land near
Plant No. 2 in order to locate the facility at Plant No. 2 and to
have extra land set aside for a buffer zone.
d. The EIS does not adequately consider the potential problems
associated with O&M. Sludge management options which require
sophisticated operations should not be considered and the cost of
O&M should be figured into the cost-benefit analysis, if possible.
R7. Dr. Thomson submitted his comments in writing as well as presented
them orally at the public hearing. EPA's responses to his comments
are included in Section 6.5 of this Final SEIS.
C8. Ken Zook
a. He believes Sandia National Laboratories is looking for benefi-
cial uses for nuclear wastes. Exposure to maintenance workers who
6-14
-------
have to service the device is a problem with the irradiator. The
-SEIS dismisses this exposure as insignificant and no more than
background radiation.
b. He does not see that the irradiator deals with the odor problem.
There should be more clarity as to how the odor problem will be
handled. There is the potential that the odor problem will just be
moved to another location.
R8. a. Comments noted.
b. The irradiation of sludge does not affect the potential of the
sludge for causing odor. Potential odor problems are discussed in
Section 6.4 of the D-SEIS, and additional odor controls which will
be included as a result of public comment are presented in Section
3.1 of this Final SEIS.
C9. Rosa Grado
a. She questions the legal disclaimer that appears on the front of
Sandia documents which discuss the irradiator. She objects to the
irradiator being built since we have so little information on the
cost and impacts of the irradiator.
b. She is concerned about psychological effects on the people of
Albuquerque resulting from the irradiator.
c. She would like to see the SEIS document the public objection to
the irradiator.
d. Not all alternatives were thoroughly evaluated, for example the
alternative of using sludge to grow an "energy crop."
e. EPA has not said whether land application of sludge is harmful.
She does not want to see sludge, especially if it has been irradi-
ated, put on the parks. She thinks that the City could find an
alternative that takes care of the odors but at the same time does
not endanger the public.
f. Who is going to pay for the clean-up if there is an accident?
R9. a. Comments noted.
b. Comment noted.
.c. All public comments expressed at the public hearing and written
to EPA are included in Sections 6.4 and 6.5 of this Final SEIS.
d. The general alternative of non-conventional disposal of sludge
via agricultural development is discussed and dismissed on pages
7-122 to 7-127 in the Facilities Plan Amendment (Balloon Report
available at the public depositories). In further discussion of
6-15
-------
this alternative, the City justified this dismissal in a letter to
the EPA, by stating the following:
Using sludge to help stimulate the production of
fuel crops (as well as other useful agricultural
by-products) must be seen in context of the overall
agricultural environment as discussed on pages 7-103
to 7-114 in the report [the Facilities Plan Amend-
ment]. Even if production of crops which do not
compete with the existing local agricultural com-
munity is eventually found feasible, any of these
schemes will involve major issues of land use and
water rights, in common with agricultural schemes
based on more conventional cropping. Further,
identification of any economically-sound fuel crop-
ping scheme would presumably at once attract private
sector investment in the same scheme, likely sooner
or later placing the City in the position of compet-
ing with local farmers. Any basic policy for the
City to embark on an agriculturally-based system
would have to be an enactment by the City Council.
Given that all available information suggests this
disposal technique is neither economic nor depend-
able in these circumstances, the Water Resources
Department could not recommend to the Council that
this basic approach be adopted.
e. EPA research determined that land spreading of raw biological
sludges potentially is harmful to public health. Thus, Part 257 -
"Criteria for Classification of Solid Waste Disposal Facilities and
Practices" of the Resource Conservation and Recovery Act estab-
lished two (2) levels of pathogen destruction (i.e., sludge disin-
fection) to protect public health. The first level of pathogen
kill will be accomplished by the anaerobic digestion facilities
proposed by the City. The second, and more thorough level of
disinfection will be achieved by the irradiator proposed by the
City. The City's proposed project will achieve the level of disin-
fection required to protect public health, as determined by EPA.
f. See response to Comment No. 6.
CIO, Gene Martinez
He does not believe that sufficient consideration was given to the
routing of the pipelines to the two dedicated land disposal (OLD)
sites. The pipeline will transverse part of the Rio Bravo State
Park. How would the pipeline be affected by the force main on
Lakeview (going to Lift Station No. 20)? Was research conducted to
determine the land ownership patterns in the Pajarito DLD site? It
is difficult to get access or clear title to this land without
causing undue financial burden on the City.
6-16
-------
RIO. The Water Resources Department delineated the routes for the trans-
portation of sludge for the various alternatives. Pipeline routes
were selected based upon geographic features, availability of
existing right-of-way, physical obstructions, and other engineering
criteria. The City did assess the real estate situation in
general. The City Real Estate Officer advised that, although the
City does have right of eminent domain, many landowners would be
involved and obtaining clear title to the land would be difficult,
time consuming, and expensive, regardless of the route chosen to
the DLD sites. This is partially the reason the DLD alternatives
were so expensive.
Cll. Connie Lopez
She is against the feeding of sludge to cattle which will be
slaughtered for human consumption.
Rll. Sludge will not be fed to cattle for any purpose. The City's
proposed project involves only disposal of sludge by land
spreading. See Comment 13.
C12. Kiki Saavedra - State Respresentative, District 10
His biggest concern is the odor problem. If the sludge is trucked,
it should not be routed through a residential area.
R12. Comment noted.
C13. Bill McMullen
It is illegal under the Food and Drug Administration regulations to
feed human sewage solids to cattle for human consumption. This
procedure can only be done for experimental purposes.
R13. Comment noted.
R14. Bernie Zak
a. The term overexposure means an exposure in excess of government
standards.
b. The EIS should be more specific as to how capsules are treated
in the irradiator. New capsules will be added when necessary,
without the removal of the used capsules.
c. The EIS should make clear that there is an irradiator operating
in Germany and South Africa.
d. Data provided to EPA by DOE was not an estimate for the exposure
to the workers; rather, it was the record of the radiation exposure
6-17
-------
to two workers who were Involved in this project. They also were
involved in many other projects where they received some radiation
exposure. Therefore, it is not fair to say that these levels are
predictive of exposures to be expected.
e. The EIS may be unclear about the fact that the additional radia-
tion is a small percentage of the background exposure.
f. The SEIS should address the fact that gamma rays and X-rays are
physically the same.
R14. a. Comment noted.
b. Page 5-29 of the Draft SEIS has been amended and is included in
Section 5.0 of this Final SEIS.
c. Appendix 10.2 has been amended as presented in Section 5.0 of
this Final SEIS.
d. Data used in the EIS for an estimate of radiation exposure to
personnel working at the proposed irradiator were taken from a
letter dated 7 July 1981 from William H. McMullen of the Department
of Energy to Darlene Owsley of EPA, which stated:
It, therefore, appears reasonable to conclude that a
person working 40 hours per week at a sludge irradi-
ator designed as conservatively as SIDSS [the Sandia
Irradiatior for Dried Sewage Solids] would receive
less than .05 rem/year of occupationally incurred
penetrating radiation exposure ... This adds up to 7
or 8 individuals who might recieve up to .05 rem per
year each of penetrating radiation.
e. Text in the Final SEIS (page 1-7) provides clarifying statements
in response to this comment.
f. Page 6-50 of the Draft SEIS has been amended and is included in
Section 5.0 of this Final SEIS.
C15. Paul Robinson
a. The irradiator facility may or may not be applicable for Federal
funding since this is a time of change in the construction grants
program. The EIS should address the effects of changes in EPA
funding on this project.
b. He does not believe the Draft SEIS has the total cost of the
full process train for the alternatives. For example, where are
the costs of the 3-day stockpile before and after irradiation?
c. The pipeline and trucking alternatives are in the range of $3
million per year. He does not believe we gain $3 million worth of
reduced odors. There has not been a good analysis of the non-
trucking option.
6-18
-------
d. The land beside Treatment Plant No. 2 should be considered for
the location of these facilities.
e. At least one beneficial use option should have been located some
where other than Montesa Park.
f. The EIS has not looked at a wide-enough range of alternatives.
R15. a. Various EPA funding scenarios were addressed in Tables 5-15 and
5-16 in the Draft SE1S. Funding applicable due to current regula-
tions is addressed in Section 4.2 of this Final SEIS.
b. The costs of miscellaneous items such as runoff control, stock-
pile operation, and landscaping were included in a 15% contingency
fee added to each process train, and were reflected in the overall
capital costs shown in Tables 5-13 and 5-14 in the Draft SEIS.
c. Comment noted.
d. A 60-acre parcel of land located directly north of Plant No. 2
was evaluated as a sludge processing site by the City's consul-
tants, but eliminated due to the high groundwater table and the
City's commitments to eliminate odors near the plant site. See
Appendix E for additional information concerning site analyses.
e. Comment noted.
f. The scope of the supplemental EIS was established by EPA through
consultation with the Water Resources Department and the public.
C16. Kent Zook
Even background radiation is potentially harmful. Additional use
and exposure to more radiation is a concern.
R16. Comment noted.
C17. Bernie Zak
The "As Low As Reasonably Achievable" (ALARA) concept of effects of
low level radiation as used in the Draft SEIS is the appropriate
stance.
R17. Comment noted.
CIS. Tim De Young
He would recommend that in the future when preparing an EIS, EPA
should try to find people in the area to prepare the EIS.
R18. Comment noted.
6-19
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C19. Ron Grotbeck
a. The EIS is deficient because they fail to point out that the
only reason for the irradiator is to render the sludge useful as a
soil conditioner for the parks of Albuquerque.
b. The money required is not balanced by the benefit obtained from
the use of the sludge as a soil conditioner.
c. The EIS should extend the expected value of the sludge and
balance it against the cost of the irradiator.
R19. a. The purpose of disinfection was described in Section 5.5.6 (page
5-29) of the Draft SEIS.
b. Comment noted.
c. See response to Comment 4.b.
C20. Jack Tills
Has the City considered retro-fitting the existing facility?
R20. The City is proposing all necessary plant improvements and expan-
sions consistent with their approved Facilities Plan. However,
upgrading and continuing the existing sludge management system is
not allowed by current EPA regulations or recent court stipula-
tions; thus a new sludge management system is needed.
C21. Paul Robinson
It would be better not to block bid the EISs. It would be advan-
tageous to have an Albuquerque bid rather than a Region 6 bid, then
more of a New Mexico interest would be involved. Locating a con-
tact in town also would serve to increase communications.
R21. Comments noted.
6.5 RESPONSES TO WRITTEN COMMENTS RECEIVED ON THE DRAFT SEIS
The Draft SEIS on the City of Albuquerque sludge management system was
published by EPA on 25 September 1981. The period for receiving written com-
ments on the Draft SEIS was extended by EPA until 14 December 1981. EPA
received 23 written letters of comment from the City of Albuquerque, Federal
and State agencies, public interest groups, CAC members, and private citi-
zens. Table 6.2 is an index of the comment letters received. These comment
letters and EPA's responses to the comments are presented on the following
pages.
6-20
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Table 6-2. Index of public
NO. DATE OF COMMENT
1 19 October 1981
2 2 November 1981
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
3 November 1981
9 November 1981
9 November 1981
11 November 1981
13 November 1981
16 November 1981
16 November 1981
17 November 1981
17 November 1981
18 November 1981
19 November 1981
19 November 1981
20 November 1981
20 November 1981
3 December 1981
7 December 1981
9 December 1981
9 December 1981
10 December 1981
11 December 1981
14 December 1981
comments.
AGENCY, ORGANIZATION, OR INDIVIDUAL PAGE
S.E. Reynolds, State Engineer 6-22
New Mexico Citizens for Clean Air 6-23
and Water
Larry Caudill, City of Albuquerque 6-25
Department of Housing and Urban 6-42
Development
State of New Mexico Environmental 6-43
Improvement Division
A.K. Khera, City of Albuquerque 6-45
Department of Transportation 6-53
USDA Soil Conservation Service 6-54
J.B. Sorenson, Chairman CAC 6-56
Evelyn Oden, CAC Member 6-59
James Wiegmann, CAC Member 6-63
Evelyn Oden, CAC Member 6-65
United States Department of the 6-66
Interior
Bruce M. Thomson 6-67
Federal Emergency Management Agency 6-71
Department of Health and Human Service 6-72
Citizens Against Nuclear Threats 6-75
Eileen Grevey Clifford, Chairman 6-76
Water Resources Citizen's Advisory
Board
Fred Seebinger, Gene Martinez, 6-79
Stan Read, Walt Webster, and
Rosa Grado, CAC Members
Department of the Air Force 6-82
Department of the Air Force 6-84
Vern C. Hagen, Associate/Director 6-86
Planning
Stan Read, CAC Member 6-88
6-21
-------
PLANNING DIVISION
I
K>
N>
DATE: 10-19-81
TO:
S.E. Reynolds, State Engineer
Hater Resources Division
FROM: Betsy Reed, Planning Bureau
RE:
$ & A DIVISION
SAI NUMBER
Planning Division
Supplemental DEIS. Wastewater Treatment Facilities, sludge
PROJECT TITLE Management System, Albuquerque
LEAD AGENCY
Please review and comment on the above application and return to the sender by 11-19-31
1. Does this plan duplicate any programs which have similar goals and objectives to the proposed application?
Yes (If yes, please identify these programs.)
Not aware of any.
2. Does the proposed application conform with a comprehensive plan developed for the area in which it is located?
Not applicable
Yes
No (If no. please explain in what way it is not compatible.)
As far as we Jcnow.
3. Does the proposed application conflict with any applicable statute, order, rule, or regulation (federal, state or local)?
Yes (If yes. please cite the conflicting statute, order, rule or regulation.)
Not aware of any.
4. Describe any suggestions or means of improving or strengthening the proposed application.
^o interest in, or comment on, this project.
oposal is supported.
roposal is supported with recommendations.
i is not supported.
Further information needed, review suspended and applicant notified of request.
-Comments attached.
;ted my response,andyor recommendations above.
Engineer
basis ofjmy
IX
f Reviewer
October 22, 1981
Date
Approved July, 1979
Secretary, DFA
Water Resources Division
Agency
1 - whit*- toappbc-inL
1 yellow -SPDc-r:-
2 pink
1 - lead agency
I - review division
Responses to Coanents froa S.E. Reyonda.
State Engineer, Water Resources Division,
Albuquerque, New Mexico (19 October 1981)
1. Coi
t noted.
-------
Oeui Mexico Citizens for Clean f)ir and Water
34o|
I
t-0
LO
) a.,«3^ 28,
Responses to Comments from James V. Lewis
New Mexico Citizens for Clean Air and Water
Albuquerque, New Mexico (2 November 1981)
1. Comment noted.
2. Table 1-2 was intended to be a general summary of the entire Chapter 6 of
the Draft SEIS. For more detailed Information on each discipline see
Chapter 6 of the Draft SEIS. Loss of the fertilization and soil condi-
tioning characteristic of the sludge was discussed under the OLD option
in Section 6.1.3 and has been added to the landfill option under Section
5.2 - Major Corrections on page 5-11 of this Final SEIS. The environ-
mental effects have been altered due to new Information from the City and
comments from the public, and are presented in Chapter 3.0 of this Final
SEIS.
-------
ReBponaes to Comments from James V. Lewis - Concluded
3. Coranent noted.
4. Currently it is not technically or economically feasible to construct a
solar disinfection unit. The only solar unit being proposed for this
project is a solar greenhouse used for sludge drying.
5. The work task addressed is beyond the scope of the SKIS. However,
through its Sewer Ordinance and Pretreatment Program, the City of Albu-
querque will make certain that heavy metals discharged by industries are
in accordance with Industrial Pretreatment regulations.
-------
CITY OF ALBUQUERQUE
ALBUQUERQUE, NEW MEXICO
INTER-OFFICE CORRESPONDENCE
November 3, 1981
REF. NO...
TO: Jay Sorenson, Chairman, Citizens' Advisory Committee
FROM. Larry T. Caudill, CIP Environmentalist, MDD/CIP
SUBJECT: REVIEW/COMMENT ON THE DRAFT S.E.l.S. ON WASTEWATER TREATMENT
FACILITIES - SLUDGE MANAGEMENT SYSTEM
TRANSMITTAL LETTER. EPA RESPONSE NOT REQUIRED.
I
M
Ui
As per your request, I am providing copies of my review/comments on the
subject draft to you and the Citizens' Advisory Committee.
In my capacity as staff environmentalist, my evaluation consists solely of
an objective analysis of the content of the document, and does not consider
intentions, promises, or understandings between the cooperating agencies
and departments and their consultants. My comments are intended to im-
prove the quality of the draft by eliminating what I perceive to be defi-
ciencies. In attempting to strengthen the document, my hope is that those
making recommendations or decisions about alternatives will be doing so
with the benefit of all necessary information and after the elimination of
ambiguities and uncertainties about precisely what is proposed. General
criticisms and recommendations are presented first, followed by very spe-
cific items identified by section, page, and paragraph or line number.
My review is provided for the information of the committee members. They
may utilize my input to whatever extent they wish in formulating both
individual positions and /or a committee position on the draft or in making
final recommendations on sludge-handling alternatives. I will be available
to the committee the evening of November 11 in order to respond to any
questions or concerns you may have about the rationale behind my com-
ments.
LTC/mm
-------
RtVltW & UMHHsTS: UKAT-T S.K.I .S.
WASTEWATER TREATMENT FACILITIES SLUDGK MANAGtMENT SYSTEM
The Draft S.E.l.S. is deficient in three principal areas:
1. The project is not clearly defined. lack of information or inconsistencies in
what is described prevent a clear understanding of precisely wtuit is pro-
posed, including both hardware and process descriptions. ThLs deficiency
makes assessment of in^acts difficult nncl mngnilU'K tlir umLic.uit it's uf pro-
posed mitigative measures.
2. There is inadequate consideration of alternatives, particularly as regards the
disinfection/drying/storage site. One disinfection technique, vat air
oxidation, was rejected based on improper criteria, since the process des-
cribed in the draft is not the same as that proposed for Albuquerque .
3. The section on mitigation measures is totally inadequate. Mitigation mea-
sures proposed are ill defined and generally phrased in permissive language
("could", "should" or "Wy"), rather tlian in directive language ("will,
"shall," or '\nust"). There are no guarantees of what will be done to mini-
mize impacts, hence the nature and magnitude of residual impacts is impossible.
Impacts (-) mitigation « unmitigated impacts or the environmental
consequences of the proposed action.
As stated in the draft, the mitigative measures section does not comply with re-
quirements set forth in the CBQ requlations. Specific comments follow, with sec-
tion, page, paragraph, and line cited as appropriate.
Abstract Page
The U.S.D.A. - Soil Conservation Service is given as a cooperating agency, how-
ever there is no indication of participation or input to the draft; particularly
in the area of nutrient and trace mineral content of sludge, sludge application
rate or nitrogen loading limit per acre treated. S.C.S. input in these areas
should be incorporated (40 CPR, Part 1501.6).
1.2 - Summary
Dewaterinft - Is sludge 3 or 4 or 4.8% solids? There is
at the belt press stage.
mention of odor control
Responses to Comments from Larry T. Caudlll
City of Albuquerque
Albuquerque, New Mexico (3 November 1981)
1. Based on comments and questions raised during the EIS process the City's
proposed alternative has been further defined and la Included In Chapter
3.0 of the Final SKIS.
2. The Draft SEIS properly describes the conventional wet air oxidation pro-
cess which achieves 951 oxidation of organic natter, as well as a substan-
tial volume reduction. The Zinpro process discussed by the CAC during
the public participation process Is not a wet air oxidation process,
rather It is a thermal conditioning process that achieves approximately
51 oxidation in organic natter. Conventional wet air oxidation was
screened out for Albuquerque due to high O&M costs, particularly high
energy costs. An evaluation of the Zimpro thermal conditioning process
was conducted due to a request by the CAC following Issuance of the Draft
SEIS. This evaluation Is Included In Section 3.3 of the Final SEIS.
3. Mitigative measures were not Included for the 14 alternatives discussed
In the Draft SEIS because the City did not propose any. The Draft SEIS
assumed the City would only do what Is required by Federal and state
regulations and local ordinances. A thorough set of mitigative measures
have now been Included by the City in their currently proposed project,
as described in Chapter 3.0 of this Final SEIS. The nature and magnitude
of the effects of what the City now proposes. Including the mitlgatlve
measures they guarantee to undertake, also are described In Chapter 3.0
of this Final SEIS.
4. The SCS provided written comments on the Draft SEIS In November 1981.
Their comments and EIA's responses are Included In this section of the
Final SEIS.
5. Sludge Is 4.81 solids when It enters the digester, and digested sludge Is
3.01 solids when It leaves the digester; hence the Draft SEIS Is correct.
Odor control (via enclosed structures) at the belt press stage Is now
included in the City's proposed project. Refer to Section 3.1 and Figure
3.2 for a complete description of propoaed odor control facilities.
-------
teview S. Comments Draft S.E.I.S.
Page 2
- Greenliouse area is not given. Ihere is no mention of odor control at
this stage. Duration of air drying, volume present at a given time, and drainage
control measures are also not given.
Pisinjection - Ce 137 source strength/volume should be given as should gamma
radiation dosage to which sludge will be exposed. Volume stockpiled, duration oL
storage, and storage method (coverd, open bagged,) should be given.
Disposal - The total acreage (1400 +) of lands to be treated should be given. At
7000 tons annually, this would amount to some 5 + tons per acre. The application
rate should be jointly determined by S.C.S. and City Parks in order to insure
that the application rate projected is appropriate. what "other public lands"
would be used for disposal?
1.3 - Alternatives to the Proposed Project
(P. 1-5)
No site other than Montesa Park was considered ior dewatering drying or
disinfection, under group 1 alternatives.
6
8a
8b
9
Responses to Comments from Larry T. Gaudill - Continued
6. A full description of the City's proposed project including greenhouse
area, duration, volume present, odors and drainage control measures la
Included In Section 3.1 of the Final SEIS.
7. As stated In the Draft SEIS, the source plaque size for the Cs-137 irra-
dlator would be approximately IS million curies. The radiation dosage to
which the sludge will be exposed would be 1 Mrad. The volume of sludge
stockpiled, duration of storage, and storage method Is presented In
Section 3.1 of the Final SEIS.
83. The sludge application rates have not been determined. These rates will
be determined by the City and will be based on EPA and USDA guidelines
and recommendations, and will not exceed state regulations.
8b. The "other public lands" identified in the Facility Flan Amendment to be
used for land spreading of sludge included the county parks, OHM golf
courses, UNM miscellaneous areas, Valley Gold Dairy, and the US Forest
Service Nursery. As was stated in the Draft SEIS on page 5-42, documen-
tation [i.e., letters of intent] that these other entities are willing to
purchase sludge or utilize their lands for landspreading activities was
not'provided to EPA.
9. A summary of the City's evaluation of alternative sites was provided In
Table 7-40 of the Facilities Plan Amendment. At the request of EPA and
their consultants, a more detailed analysis of alternative sites was sub-
mitted in March 1982. This evaluation la included In the Final SEIS In
Appendix E.
10. Specific mitigation measures for the City's proposed project are included
In Chapter 3 of the Final SEIS.
11. SCS conments are Included in this section of the Final SEIS.
- Environmental Consequences of the Alternatives
Environmental consequences of a proposed action cannot be determined without
knowledge of the mitigation measures to be implemented as an integral part of the
project. To be ''currently evaluating mitigation measures that are available" is
a poor basis for making conclusions about environmental consequences.
10
1.5 - Coordination
(P. 1-10)
While U.S.D.A./S.C.S. agreed to be a cooperating agency, there is no indication
that the S.C.S. was involved in any significant way in the preparation of the
drait. E.P.A. should provide documentation of S.C.S. input if it occurred.
11
-------
I
Review Si Cotonents Draft S.E.l.S.
Page 3
3.0 - Introduction
Table 3-1 (P. 3-6)
The list ol local environmental controls (ordinances, regulations, court
stipulations) is largely incomplete- A list of local environmental ordinances is
attached so that this deiicieucy may be corrected.
Qiapter 4.0 - Need and Purpose
(P. 4-2) j Item 02
Air drying at hontesa Park should be mentioned here ior consistency with the
project description given in the summary.
4.3 - K£.'y Issues
(P. 4-2)
Potential impact on land use and development potential of lands adjacent to
Montesa (Ut'W/State, Kirtland, private) is also a key issue.
Chapter 5.0 - Description k Evaluation of Alt.
5.1.2 - (P. 5-2)
A sludge solids concentration of 3%.is mentioned in the summary and 4.8% is used
here. This inconsistency should be resolved.
5.2 - (P. 5-7)
Documentation of the termination date and non-renewability of tlie lease should be
12
13
14
00 provided. Where will sludge currently being placed there be disposed of on
expiration of the lease?
15
16
Responses to Comments from Larry T. Caudill - Continued
12. Table 3-1 on page 3-6 of the Draft SEIS has been corrected and la
presented in Chapter 5 of the Final SEIS.
13. More recent Information fron the City Indicates that the 3 acres of open
air drying will not be necessary and this change has been reflected in
the Summary and Section 3.1 of the Final SEIS.
14. The change has been made to the text as is indicated in Chapter 5.0 of
the Final SEIS.
15. See response to Question No. 5.
16. According to the City, the lease expired In January 1982. The City
currently ia negotiating for a 3-year extension. The City has not
submitted a contingency plan to EPA stating what sludge disposal method
will be utilized if the lease terminates prior to completion of the
proposed Phase II facilities.
17. A civil penalty not to exceed $10,000 per day of violation can be sought
by EPA. If a violation is willful or negligent, the penalty may range
froa $2,500 to $25,000 per day of violation. The Final SEIS incorporates
this Information in Chapter 5.0.
18. The alternative sites evaluated by the City were included in the Balloon
Report. At the request of EPA and their consultants, the City has con-
ducted a more extensive evaluation of alternative sites and this reviev
is Included in Appendix E of the Final SEIS.
5.2 - (P. 5-8) Lines 9-11
Slrauld EPA exercise this authority, what is the penalty range and the projected
maximum dollar liability?
17
Table 5-5 - (P. 5-10)
Compatibility with existing land use plans is an evaluation criterion which may
render the Montesa Park site "ineligible" for the proposed project; particularly
if air drying is used. Alternate sites should have been considered, including
Plant 112 and a 20-25 acre site purchase from the State or a private land owner.
18
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Review & Comments Draft: S.E.l.S.
Page 4
Table 5-6 - (P. 5-11)
Under "Drying" it isn't clear wlmt Solar-assisted Beds/kilns m-ans, particularly
since "solar greenhouses" and "air drying'1 have fat-en used previously. Undi_T
"disinfection" wet air oxidation should be added as an option to be evaluated.
'^eduction" should be deleted in order to remain consistent with the chosen
sludge disposal option (as per line 14 page 5-9 "Ihe method of ultimate solids
disposal usually controls the selection of solids treatment system, and not
vice-versa").
Under "Drying" Solar drying is ambiguous since solar greenhouses and air drying
in combination has been mentioned previously. Which method (s) lias/have been
evaluated for cost effectiveness? Under "Disposal to Land" does the
cost-effectiveness analysis consider only the 7000 tons to be used on city parks
or is the balance of 3740 tons going to the public as well?
Wet Air Oxidation - (P. 5-21)
The process described and evaluated is not the sane one described to the C.A.C.;
differing in several parameters: 1) oxidation and burning aren't necessarily the
same, and 2) the temperatures and pressures shown are much higUx. Ihe process
was rejected on the basis that these systems are "capital intensive" (operation,
maintenance, construction (?)), yet no economic datu or analysis is presented.
Rejection was also based on an erroneous assumption that incineration was to be
the ultimate disposal method. The wet air oxidation process itself cannot be
considered incineration according to the definition of Incinerator in ABCAQC
Regulations - Sec. 2.20 - "Incinerator means any device intended or used for
burning waste material to effect a reduction in volume "
The wet air oxidation process should be evaluated on the basis of a correct
description and the same level of economic analysis as the rest of the
alternatives considered.
19a
19b
19c
20a
20b
21
22
Responses to Comenta tram Larry T. C«udill - Continued
19a. Table 5-6 presents the preliminary screening of the general option*
applicable to the Albuquerque sludge management system. At this prelim-
inary stage, general solar-assisted facilities (Including beds and kilns)
were evaluated. Specifically, a solar greenhouse (a type of solar
assisted bed) was chosen for the Albuquerque sludge management aystem.
19b. Aa discussed In EPA's response to Question Ho. 2, conventional wet air
oxidation Is an option of the reduction component. Heat treatment (<.(.,
the Zlmpro process) has been added to the list of options under the dis-
infection component.
19c. Reduction Is s viable treatment coBponent and la therefore listed la
Table 5-6 as having been evaluated during preliminary screening for
applicability to the Albuquerque sludge management system. Table 5.8
Indicates that reduction Is not a required component and It was not
selected by Albuquerque for use In any of the optimal alternatives
Identified In Table 5-10.
20a. For alternatives 1A and IB a solar greenhouse followed by a 3 acre opan
air drying area was evaluated and costed. For alternatives 1C, ID, 1C,
and 1H a 6.9 acre open air drying area was evaluated and coated. The
cost-effectiveness analysis Information Is presented In Table 3-5 of the
Final SEIS.
20b. The evaluation and cost effectiveness analysis In the Draft SEIS were
baaed on the disposal of all 10,740 tons of sludge to be produced In
1990.
21. The wet air oxidation process described on page 5-21, 5-22, and 5-23 of
the Draft SEIS Is the conventional wet air oxidation process and Is not
to be confused with the heat treatment (thermal conditioning) process.
The Zlmpro firm manufactures both types of systems. For more Information
on these two systems see EPA's response to Comment No. 2. To avoid con-
fusion the names of the manufacturing firms have been removed from the
discussion on wet air oxidation on page 5-21.
22. An evaluation of the thermal conditioning process has been Included In
Section 3.3 of the Final SEIS.
23. Alternative pipeline and trucking routes were not Identified by the City
nor evaluated by EPA. An analysis of alternative sites provided by the
City Is Included In Appendix E of the Final SEIS.
5.5.3 - Transportation - (P. 5-25)
Since no site other than Montesa was considered lor dewatering, drying,
disinfection, and stockpiling, there was no consideration given to altematie
pipeline routing. Since they are tied together, both alternate sites and
pipeline routing should be considered.
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Page 5
5.5.4. - Dewatering (P. 5-28)
Regardless of which option (belt or filter press is selected the draft should
state that the unit will be enclosed and that gases (odors) will be scrubbed.
5.5.5. Secondary Drying - (P. 5-28)
The use of solar greenhouses and open air drying is implied, but no clear
selection is made. The combination "can dry to 40Z in 6 days'1 - but will it?
Two 40' X 120' open air drying areas are to be located in each of three
greenhouses (6 total?)... "Open air drying" versus "in greenhouses" is
contradictory. These inconsistencies should be resolved.
5.5.6 - Disinfection - (P. 5-29 to 5-32)
While a complete description of the irradiator is given in the appendicies
(10.2) this information is not referenced.
D.O.E. responsibility for clean-up and decontamination is not stated,
contrary to an earlier C.A.C- recommendation.
The description of electron beam irradiation in appendix 10-2 is not
referenced.
Composting is described briefly, but is not given equal attention in terms of
an appendixed description.
Ditto re: wet air oxidation
Failure to consider a discrete 20-25 acre site on City, State, or private
land for all disinfection processes (ie. for everything proposed) is again
noted.
Quantification is given tor volumes (cu. yards) but not in iirea required.
This disparity makes comparison of the areas required (and surface exposed)
difficult. Area required for all three options + wet air oxidation should be
given.
24
25
26
27
28
29
31
32
33
Respogses to Comments from Larry T. Caudlll - Continued
24. Since the Draft SEIS was issued, the City has proposed odor scrubbing
equipment for all air exhausted to the atomsphere from the wet sludge
processing facility. This revision to the project has been included in
Section 3.1 of the Final SEIS.
25. In the Draft SEIS the proposed drying option was a solar greenhouse with
3 acres of open air drying. More detailed design for the solar green-
house has indicated that the 3 acres of open air drying will not be a
necessary addition to the solar greenhouse option for drying the sludge
to 40Z solids. The exact time for drying to occur is highly dependent on
ambient weather conditions which exist at the particular time.
26. As described on page 5-28 of the Draft SEIS, there will be six drying
areas (two in each of the three greenhouses). The phrasing on page 5-28
has been changed to further clarify open air drying versus greenhouse
drying.
27.
As indicated in Section 5.2 of the Final SEIS, this reference has been
Included on page 5-29 of the Draft SEIS.
28. This information was made available to EPA after the Draft SEIS was
Issued. The text on page 5-29 of the Draft SEIS has been changed to
reflect this comment.
29. Page 5-29 of the Draft SEIS, has been corrected to Include this
reference.
30. Due to CEQ recommended length restrictions (150 pages) an in-depth
description of all options is not feasible. A detailed description of
Cesium-137 Irradiation and electron beam irradiation was Included In the
Appendix since they both involve radiation which was a key issue in this
SEIS. Additional Information on composting was provided in the City's
amended facilities plan (i.e.. Balloon Report).
31. See EPA'a response to Question No. 30. A two page description on page
5-21 and 5-22 of the Draft SEIS was considered adequate to describe wet
air oxidation.
32. See EPA's response to Question No. 18.
33. The area required for all three disinfection options and thermal condi-
tioning are given below.
Process Component
Composting
Ganma Ray Irradiation
Electron Beam Irradiation
Thermal Conditioning
Approximate Land Area
Square Feet Acres
192,000
5,000
4,500
4,000
4.4
0.1
0.1
0.1
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Page 6
5.5.7 - Disposal - (P. 5-32 to 5-34)
Stockpiling at Montesa ".... until tlie Parks Department could pick it up..."
is an ill-defined time frame, and could be as long as 10 months.
If it is to be picked up periodically und stored elsewhere lor februray -
March application, then the effects of dust, odor land use impact for site
'V must be considered.
The economic analysis for landspreading options (Group 1A-H) should consider
the costs of handling and application; alternately a rationale for not
considering diem should be presented.
Unanswered questions include:
1. If sludge can be dried from 257= to 40% in 6 days, why will sludge remain in
the drying beds 140-150 days to attain the same 40% solids?
2. If air drying only were used, what would drying time be irou, 25% to 40%
solids?
3. What would be the health effects on workers tilling 6.9 acres of
undisinfected sludge daily for 150 days or more?
4. Will greenhouse exhaust gases be scrubbed for odor control?
5. What provisions are to be made for drainage/leachate disposal from a drying
floor of either 3 or 6.9 acres?
6. The area of drying beds at Plant 112 is 508,000 ft.(sq.) (11.5 acres). What
is the potential odor problem or odor control needed for (>.') acres of beds
located at Montesa?
34
35
36
37
38
39
40
41
42
Responses to Comments from tarry T. Gaud ill - Continued
34. According to Information provided by the City since Issuance of the Drift
SEIS, after disinfection the sludge will be stockpiled in an enclosed
building which has the capacity to store 6 months of sludge, although in
normal operation detention In the stockpiles prior to movement to the
parks would average closer to 4 months. In only rare cases would the
actual stored volume In most years ever exceed 8,000 cubic yards.
35. The temporary storage of sludge at Individual parks may be occasionally
necessary while awaiting optimal conditions for spreading. Due to the
diverse locations of the City parks, the effects of the temporary storage
at City parks Is out-of-scope for this SEIS.
36. If sludge is applied to parks, it must be stored, picked up, hauled, and
spread. If sludge is disposed by landfill or OLD, commercial fertiliser
for the parks mist be stored, picked up, hauled, and spread. EPA deter-
mined this cost was common to all alternatives; thus, components and
associated cost for all Group 1 alternatives were taken free on board
(F.O.B.) Montesa Park.
37. Misleading wording on page 5-29 has been corrected.
38. The drying time necessary for open air drying alone was not provided by
the City. However, it has been determined that open air drying is not an
acceptable option for the City of Albuquerque.
39. The purpose of Section 5.5 of the Draft SEIS was to describe the compo-
nent option and not to present impacts such as helath effects. Environ-
mental consequences of the alternatives were discussed in Chapter 6.0.
Health effects from the various component options were discussed in
Section 6.11.3 of the Draft SEIS.
40. Yes.
41. Since open air drying is not environmentally sound for the City of Albu-
querque, leachate control measures are not required.
42. Open air drying was found to be not environmentally sound.
43. The drying area is part of the stockpile beds depicted. Figure 5-3, 5-4,
and 5-5 are of poor quality and lack some detail. A better site layout
map is Included as Figure 3-2 in the Final SEIS.
Figure 5-3 - Site Map of Montesa Park
The drawing is not in agreement with the preceding description:
1. No paved drying area is noted or depicted.
43
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Page 7
2. ND drainage system is noted or depicted.
3. No direct access between the irradiutior and the rest o£ the facilities is
shown.
A. The limits of both 100 and 500 year flood hazard areas should be clearly
depicted and shown relative to the location of all facilites.
The irradiator is shovn located between two access roads. The non-contiguous
site seems inappropriate both for reasons of accessibility and site security.
Table 5-11 - (P. 5-35 k 5-36)
Significant Characteristics for certain components should be expanded upon as
follows:
Component Option
Conditioning Polymer
Transportation Pipeline
Dewatering F, S< B, Press
Drying
S. Greenhouse
Open Air
Significant Characteristic
Cost tied to energy (oil) prices
Arroyo instead of river crossing
Odor production (Unless enclosed and odors
scrubbed)
Exhaust gases scrubbed for odor control
w/6.9 acres k daily tilling, effects would
seem similar to .those given for composting,
including bird strike hazard.
44
45
46
47
48
Responses to Comments from Larry T. Gaudill - Continued
44. See EPA'8 response to Question No. 43.
45. See EPA's response to Question Ho. 43.
46. The 100-year floodplain was shown (poor quality) In Figures 5-3, 5-4, and
5-5. EPA has no requirement or regulation concerning the 500-year
floodplain.
47. See EPA's response to Question No. 43.
48. Table 5-11 has been changed to reflect this comment.
49. Figure 5-6 is schematic in nature and is not Intended to indicate
physical characteristics or design criteria for any of the processes.
Areal extent and height of the stockpile enclosing structures and the
duration time are included in Section 3.1 of the Final SEIS.
50. See EPA's response to Question No. 49.
51. EPA's decision concerning the credit for sludge is described in Section
4.1 of the Final SEIS.
Table 5-6 - (P. 5-39)
1 & 2 do not indicate duration or volume stored, nor are drainage
controls included.
Cdor controls at belt press and greenhouse drying stages are not shown.
5.7 Cost Effective-ness Analysis
49
50
(P. 5-42) - lines 9^12
The $70 figure ior sludge value- is given, but no documentation provided. The
city letters mentioned here and in the following paragraph should be included
51
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Page 8
in Che appendix. The validity of the $70/ton figure should be determined by
athird party such as Che S.C.S. Cither entities are mentioned us potential users,
but again no documentation is provided. Lacking documentation, use on these
other public lands cannot be realistically considered an option.
Market value appears to be a more appropriate means of determining the worth of
sludge, as opposed to a $70 figure which is undocumented in the draft.
Tables 5-13 to 5-17 (p. 5-44 to 5-48)
An economic analysis should be provided for the wet air oxidation process, just
as for all other alternative disinfection/disposal methods.
Chapter 6 - £nvironmental Consequences
The format used in this section is both cumbersome and confusing. Instead of
taking each component of each action alternative Chrough an intact analysis for
each of thirteen (13) parameters; analysis of each discrete alternative ''package"
is recommenced.
52
53
54
Responses to Comaents from Larry T. Gaud ill - Continued
52. The City did not provide letters of intent from other entities. A pre-
liminary market survey containing information on potential sludge users
and buyers Is contained in Appendix F of this Final EIS.
53. See EPA's response to Comment 51.
54. Thermal conditioning Is discussed In Section 3.3 of the Final SKIS.
55. Comment noted.
56. The section this comment refers to is titled "Earth Resources" and there-
fore a discussion of odors and health effects would be Inappropriate In
this section. Odor problens and health effects are discussed in Section
6.4 and 6.11, respectively.
57. Sludge application rates will be established In accordance with EPA and
USDA guidelines and recommendations.
58. The text on page 6-16 of the Draft SEIS has been changed to reflect this
comment.
55
6.1.2 - Action Alteratives:
Os
UJ
Drying - Open Air Drying (p. 6-15)^
Odor probleiLS have been mentioned previously but do not appi^ar here. Tte
asphalt drying area and the addition of a drainage system will prevent the
leachate/run-off problem mentioned here. There would be some potential
health effects from the daily tilling operation.
Disposal - Landspreading (P. 6-15)
Application rate should be determined by tho outcome ol an ongoing research
project and the input of S.C.S. as to what uptake rates are and what heavy
metal accumulations can be expected in soils.
56
57
While sludge has some benefit as a soil conditioner, the texture and moisture
holding improvemenCs envisioned for sludge can occur only ii it is mixed into
Che soil as a soil amendment. Use as a top dressing only will largely
restrict beneficial effects to the nutrients and trace minerals that are
leached irooi the surface and percolaLe to root depth.
58
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Comments trait S.E.I.S.
Transportation - fi|x.'line (P. 6-18)
The Drait does not address the impact of a pipeline break at the So.
Diversion Channel or Tijeras Arroyo Crossings, and resulting flow of an
undetermined amount of sludge into the drainageways. The pipeline should be
equipped with check valves "upstream1' of both crossings to prevent drainage
of the sludge in the line above the break.
Floodplains (P. 6-22)
Latest N.F.I.P. flood hazard mapping should be used to establith 100 year and 500
year flood hazard areas/lines in Tijeras arroyo, and particularly through the
proposed site in Montesa Park.
6.3 Groundwater Resources
59
60
Responses to Comments from Larry T. Caudlll - Continued
59. The effect of potential breaks or leaks In the pipeline are acknowledged
in Section 6.1 (page 6-18) and Section 6.2 (page 6-27) of the Draft SBIS.
EPA will review and verify the specific engineering design necessary to
lessen the potential effects of pipeline breaks during the review of the
City's engineering plans and specifications, prior to award of a con-
struction grant.
60. The latest publicly available floodplaln maps were used to establish the
100-year floodplains. The floodplain maps are currently being up-dated
but these Baps are not available for publication (by phone, Diane
Leatherwood, Federal Emergency Management Agency, 8 February 1982). The
Inclusion of the 500-year floodplain hazard area is not required by EPA.
61. Comment noted.
62. Comment noted.
63. See EPA'3 response to Question No. 57.
64. This information was already included In the Air Quality Section of the
Draft SEIS on pages 6-38 and 6-47.
Crying (P. 6-30)
Leachated and runoff will not reach the soil if the aforementioned drainage
system (return to Tijeras interceptor?) is defined as a part of the project.
Transportation (P. 6-30)
Check or safety values can be added at appropriate locations to prevent
leakage from a ruptured line from flowing into low areas or drainageways.
Disposal (P. 6-31)
Safe application levels/locations should be determined with the
assistance/input of the S.C.S.
61
62
63
6.4 Air Quality and Ambient Noise Level* (Word Change)
Ambient Air Quality (P. 6-33)
The particulate AQ parameter could be adversely affected by dust and traffic
associated with soil disturbance and construction. This short-term impact
can be moderated by compliance with provisions of the Topsoil Disturbance
Permit which will be required under ABCAQCB regulations
64
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Review S. Comments Drolt S.L.l.S.
Page 10
Regulations (P. 6-38)
"Group" should be changed to "Division'1. The 3/4 acre threshold applies to
any area disturbed including pipeline R.O.W. and construction site at
Montesa. Particulate controls would apply both during construction and
operation of the facility, landfill or otherwise.
Odor (P. 6-41)-
Belt presses should also be considered a potential odor source. Ot those
mentioned, two (belt presses and greenhouses) can be or art enclosed and
should have odors scrubbed. Odors item open air drying and sludge stockpiles
are still a potential problem. Enclosed stockpiles or bagged sludge could
not be re-hydrated and thereiore is less likely to be an odor source; liowever
the precise storage/stockpile method is not defined.
Table 6-7 (P.6-42)
Again, both greenhouse and open air drying are shown but no determination is
made as to which method (or combination) will be used. If open air drying
for 150 days (with daily tilling) is used, then it would seem that there
would be health effects similar to those postulated for composting (i.e.
Aspergillus tumigatus). Wet air oxidation should be added to the alternative
disinfection methods being considered.
Stockpiling ot Sludge (P. 6-45)
The storage method, size/volume of storage area/building, drainage system (if
any) and duration of sludge storage must be defined before any realistic
assessment of odor dust, etc., can be undertaken. This applies to all group
1 alternatives.
65
66
67a
67b
I67c
68
Responses to Comments from Larry T. Gaud111 - Continued
65. The text has been changed to reflect this comment.
66. On page 6-42 of the Draft SEIS, belt presses were identified as a source
of minor odors. Since the Draft SEIS was Issued, the City has made
revisions to the proposed project which include installing odor scrubbing
equipment for all air exhausted to the atmosphere from the wet sludge
processing facility. Alternatives with open air drying have been removed
from further consideration and all stockpiles have been enclosed. These
revisions are discussed in Section 3.1 of the Final SEIS.
67a. See EPA's response to Comment No. 25.
67b. Health effects were discussed in Section 6.11 of the Draft SEIS.
67c. See EPA's response to Comment No. 2. An evaluation of the effects of wet
air oxidation has been included In Section 3.3 of the Final SEIS.
68. More detailed information on the topics mentioned in this comment has
been provided by the City since issuance of the Draft SEIS. This infor-
mation has been included in Section 3.1 of the Final SEIS. The environ-
mental effects of the alternatives have been reevalusted based on these
new revisions and are Included in Section 3.3 of the Final SEIS.
69. Comment noted.
70. The Bird Aircraft Strike Hazard (BASH) report prepared by the US Air
Force expressed concern about the attraction of birds to lagoons at
Hontesa Park. Although the City did at one time propose using sludge
lagoons as an interim measure, none of the alternatives for ultimate
treatment and disposal of sludge as evaluated in the Draft SEIS proposed
the use of lagoons at Hontesa Park. At CAC Meeting 17, a member of the
Air Force BASH team expressed concern about the attraction of birds to
open air drying beds. Since issuance of the Draft SEIS, the City has
made certain changes which Include: (1) deleting open air drying from
consideration due to being not environmentally sound; and (2) enclosing
all stockpiles. These changes should alleviate concerns over the
attraction of birds to the proposed sludge handling facilities.
(P. 6-49), Paragraph 2 S. 4
Anbiguity and lack ot project definition continue to make determination of
magnitude of the problem difficult.
6.5 Biological Resources
69
Table 6-12 - (P. 6-60)
Bird strike hazard has been previously mentioned as a concern. The input
from the Air Force BASH team should be factored into this section.
70
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Page 11
6.6 Cultural Resources
6.6.1. - (P. 6-64)
The draft indicates a need to reevaluate effects on cultural resources,
particularly as determined by transportation and disposal. Depending on the
site, the dewatering, drying, disinfection, and stockpiling coniponents could
also impact cultural resources. Consideration of cultural/social impacts
should not be restricted to transportation and disposal only.
6.7 Population
No coosnent.
6.8 Land Use and Transportation
6.8.1. - (P. 6-73)
(Par. 1) The proposed development was not approved by the Environmental
Planning Commission. This decision was appealed by the developer, and the
appeal was denied by the City Council on October 26, 1981.
(Par. 2) tontesa Park was zoned M-2 until August 21, 1980, when a Water
Resources Department request for a zone change to SU-1 was approved, subject
to certain findings (copy attached).
(Par. 3) As mentioned previously, 100-Year and 500-Year Flood Plain lines
should be shown on pertinent graphics in the draft, particularly with
reference to the location of proposed facilities.
71
72
73
74
Responses to Comments from Larry T. Caudill - Continued
71. EPA and the State Historic Preservation Office (SHPO) have determined
that there will be no significant impact on cultural resources caused by
the proposed project. If any other alternative is chosen, EPA will
require the City to coordinate with the SHPO to protect cultural
resources In accordance with the National Historic Preservation Act of
1966, and Advisory Council Procedures (36 CFR 800).
72. The text in the Draft SEIS has been changed to reflect this comment.
73. The text in the Draft SEIS has been changed to reflect this coranent.
74. The 100-year floodplain boundary is presented in Figures 5-3, 5-4, and
5-5. The quality of these graphics is poor therefore the 100-year flood
boundary is difficult to distinguish. Presentation of the 500-year flood
hazard area Is not required by EPA.
75. See EPA's response to Comment No. 70.
76. See Chapters 3 and 4 of the Final SEIS for a description of the proposed
project.
6.8.3. Environmental Consequences - (P. 6-75)
(Par. 4) Information presented on bird air strike hazards is not consistent
with that provided to the CAC. This portion should be revised to include the
input of the Air Force BA9J team.
Depending on which of multiple possibilities for the type of facilities to be
located at Msntesa is selected, there may be adverse affects on land use and
the land values for adjacent properties. Potential effects cannot be
addressed until a clear definition of the proposed project is made, i.e.,
open or enclosed dewatering; greenhouse or open air drying or a combination
thereof; odor controls, if any; and area, nethod and duration of stockpiling,
etc.
75
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Page 12
b.9 bconomics
6.9.3. - (P. 6-61)
The ijnpact on land values will be largely determined by the- type of
facilities constructed at Montesa and the degree to which odors, dust, and
aesthetic impact are controlled by the city.
Employment - (P. 6-83)
11 adverse affects on the local fertilizer industry is postulated as a
consequence of landspreading on city parks, then it should be docunented. It
is doubtlul chat the city's action alone would have much impact on the
fertilizer industry one way or another.
Polymer costs are related oil/energy costs and should be factored into the
energy analysis.
6.11 Environmental Health
Cpen Air Drying - (P. 6-93J
As previously mentioned, a detention tine ol 150 days and daily tilling would
appear to pose hazards similar to those indicated for composting (Aspergillus
tumigatus). Control oi leachates and runoff is again mentioned, but is not a
firm part of the project description.
77
78
79
80
Solar Greenhouse Drying - (P. 6-93)
Release of odors and pathogenic aerosols is mentioned. Filtration or
scrubbing of these emissions has been alluded to, but is nut clearly a part
ot the project description.
The wet air oxidation alternative is not addressed. 182
81
Responses to Co amenta ftom Larry T. Caudill - Contlnaed
77. Coanent noted.
78. The text In the Draft SEIS has been changed to reflect this comment.
79. An Increase of 31 pec year for land and 41 per year for natural gas was
Included In the cost-effectiveness analysis as required by EPA
regulation. Increases In prices for other materials or Inflation
specifically are not allowed by EPA regulation.
80. Open air drying has been determined environmentally unacceptable.
Control of leachate and runoff was not clearly addressed in the City's
proposed project as presented in the Facilities Flan Amendment, but has
been included in Section 3.1 of the Final SEIS.
81. Exhaust gases associated with solar greenhouse drying will be scrubbed.
See Section 3.1 of the Final SEIS.
82. See EPA's response to Question Ho. 2. At the request of the CAC, a
fifteenth alternative, which Includes thermal conditioning, haa been
evaluated In the Final SEIS in Section 3.3.
83. The proposed project as presented in the Draft SEIS was to have the final
stockpile on a concrete floor with eight foot walla. The other stock-
piles would be placed on a bed of compacted earth In an unenclosed area.
Revisions made since Issuance of the Draft SEIS Include enclosing all
stockpiles and placing them on an asphalt floor. A discussion of the
revisions made since the Draft SEIS was Issued is Included in Section 3.1
of the Final SEIS.
84. See EPA's response to Comment Ho. 35 and Comment Mo. *9.
Stockpiling at Sludge - (P. 6-96 to 6-97)
Stockpiling on a concrete floor with 8' walls has been mentioned previously,
buc no such controls are considered lie re. Instead, stockpiles are "typically
placed only on a bed o£ compacted earth, ' creating problem.'; with drainage and
runoil. Again, the whole stockpiling question nevds resolution.
Additional stockpile locations are mentioned lor the first time, yet nmtoer,
location, stor/i^c voluuu, or UuiuLion ol ,sLi.ni);c i.s not diM.'U.stavl.
83
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Page 13
There is no discussion of the potential odor.s or associated problems at these
scattered and unknown locations.
Unless stockpiles are coveted, re-hydration, re-inlection, and "new1' odors
can result.
6.12 Recreation and Aesthetics
6.12.1. Existing conditions - (P. 6-98 to 6-100)
There is a city parks motorcycle course immediately to the West, as desig-
nated by the Open Space Management Plan. Hills on the South side of Tijeras
Arroyo are commonly used tor hanggliding. These recreational uses oi the
land may be impacted, so this issue stould be addressed.
85
86
87
Responses to Comments from Larry T. Gaudill - Continued
85. See EPA's response to Question No. 35.
86. Since the Draft SEIS was issued, the City has submitted revisions to EPA
which include enclosing all stockpiles.
87. The Draft SEIS acknowledges the recreational use of the area surrounding
Montesa Park for off-road vehicles. The text has been changed to Include
hang gliding. Impacts of recreational use of the land were addressed In
Section 6.12.3 of the Draft SEIS, and are addressed in Sections 3.2 and
3.3 of the Final SEIS.
88. Revisions to the proposed project made since Issuance of the Draft SEIS
include more specific mitigative measures. These revisions are presented
In Section 3.1 of the Final SEIS.
89. The proposed project, alternatives, mitigative measures to be Included,
short/long-term effects. Irreversible effects, and effects which cannot
be mitigated are discussed In Chapter 3.0 of the Final SEIS.
6.12.3. Environmental Consequences
Several improvements (10' chainlink lence, 8' walls, "careiul building
design, layout, landscaping," and a ''possible wooded buffer zone" are
mentioned as potential aesthetic improvements or mitigation, measures.
ftowever, none of these measures can be considered as such unless assured by
firm project definition/design and set iorth as guarantees in the
Section of the draft. As phrased here they are simply too ambiguous.
88
U)
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6.15 Mitigative Measures
The mitigation measures section of the draft is totally inadequate. Specific
deficiencies, inconsistencies, and departures from the requirements set forth
in 40 CFR, Parts 1500-1508, are presented below.
According to CEQ regulations (40 CTK 1502.16), this section requires that . .
."the discussion will include the environmental impacts of the alternatives
including the proposed action, any adverse environmental effects which cannot
be avoided should the proposal be implemented. . . Jurthcr, it shall
include (h) 'Veans to mitigate adverse impacts (if not fully covered under
1502.14 (f).
While mitigative measures were discussed tlicy were, with un<; exception,
focused entirely in permissive rather than directive language.
89
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heview it Comments Craft S.E.l.S.
Page 14
CEQ regulations include provisions whereby mitigation may be assured:
1502.2 Record of Decision in Cases Requiring HS's
(c) State whether all practicable means to avoid or minimize environmental
harm from the alternative selected have been adopted, and if not, why not. A
monitoring and enforcement program shall be adopted and suumarized where
applicable for any mitigation.
This mechanism is not referenced in the drait, nor does EPA state its
intentions regarding monitoring.
1505.2 Implementing the Decision
. . .mitigation 1505.2(c) and other conditions established in the
environmental impact statement or during its review and conmitted as part of
the decision shall be implemented by the lead agency or other appropriate
consenting agency. The lead agency shall:
(a) Include appropriate conditions in grants, permits, or othei approvals.
(b) Condition funding of actions on mitigation.
(c) Upon request, inform cooperating or commenting agencies on progress
in carrying out mitigation measures which they have proposed and which
are adopted by the agency making the decision.
(d) Ipon request, make available to the public the results of relevant
monitoring.
Suggested mitigation measures include:
1. Require compliance with local environmental ordin
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4S
O
Review & Comments Dvutt S.t-.l.b.
Page 15
7. Incorporate a drainage system into tin project desijjn in order to
address die potential adverse effects oi leachutes and runoff.
8. Incorporate check or backflow-preventer valves at initial locations,
drainageway crossings, and at low points in the pipeline.
9. Specify enclosed/covered/bagging oi sludge to minimize impacts from
stockpiling.
10. Stipulate that DOE will be responsible lor any clean-up decontamination
operations in the event of a spill or leakage of radioactive material.
11. Specify that landscaping of the site will be accomplished as an integral
part of the project in order to minimize aesthetic impact.
91
ATTACHMENTS TO LETTER FROM LARRY CAUD1LL
PROVIDED ON FOLLOWING PACE
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SECTION 7.
ENVIRONMENTAL ORDINANCES AND REGULATIONS:
Tlie following is a partial list of environnental ordinance.1:; and
regulations applicable to the work under this contract. Tin'!, list
is provided for the Contractor's information and the Cont/actor
should not consider tins list to be a complete listing of all
ordinances anil regulations which are applicable to this project.
ORDINANCES
ARTICLE 1
ARTICLE III
ARTICLE VIII
ARTICLE XV
ARTICLE XVI
AARTICLE XVIII
ARTICLE XXII
CHAPTER b - HEALTH, SAFETY AND SANITATION
Air Pollution Control.
Refuse Col lection.
Litter.
Weed Control
Joint Air Quality Control iiuard.
Insect and Rodent Control?
Noise Control.
ARTICLE V
ARTICLE XIX
ARTICLE XXIII
ARTICLE IV
ARTICLE VI
ARTICLE VII
ARTICLE XVI
CHAPTER 7 - ZOHlliG, PLANNING AHP HUILD1NG
Landmarks and Urban Conservation.
Flood Hazard Area Zoning.
Uinforr.i Adi.iini strati ve Code and
Technical Codes.
CAHPTER U - 'n'ATER, SEWER, AND STREETS
Water and Sewer Rates.
Sidewalks.
Street Excavation.
Water Waste.
I All ordinance citations are to die Revised Ordinances of Albuquerque,
j^ New Mexico, 1974. Copies of ordinances r.iay be obtained from tlie City
Clerk/Recorder.
REGULATIONS
Albuquerque/Bernal illo County Air Pollution Control Regulations
(Hay 197j, as amended).
DATE:
^ayu>*- i^.
NOTIFICATION OF DECJSION
Albuquerque, New Mexico 87103
°f
situated within^
T9K, R3E
On August 21 1980, the Environmental Planning Commission approved the above
request thereby changing the zoning to SU-1 (Special Use for Sludge Treatment
Facility) subject to the following Findings:
1. SU-1 for Sludge Treatment Facilities at Montesa Park is not inappropriate.
2' The final design and type of treatment has not yet been determined.
3.' Prior to construction a detailed site development plan is required for
review by this Commission.
4 Notification will be given to all surrounding land owners regardless or
distance from the property, including all parties that will be sensitive to
this facility, i.e., University of New Mexico, Kirtland Air Force Base, etc.
These parties shall be provided with a copy of the site development plan prior
to the public hearing to approve this plan and their comments shall be
requested.
If you won to appeal this decision, you must do so fay 9-5-80
described beiow. A non-refundable filing fee of WO is required at
filed.
in the manner
time Ae appeal a
\ew3l :o iht Citv Council. Any ptrjon itpievsd with »ny detcsaraoon 01 ihe jmronmeatj
Sisaaii -.JIET-JISOU icuoi anaer *» ore-nines may Sit an JBW^ to she C:ry Counci w
susfBitcis «mticn JBciiaDon on die yiannins Division form u uie Plinmoi Dmaon "limn .;
ud ominiDcas haTe aot
ieiri. "n be heart within 60 diyi of iu Hun;.
You will receive notice if any other person files an aopeal. If there is no appeal you can
receive building permits any time after the appeal deadline quoTEd aoove provided ail
conditions imposed « the time of approval have been met. Successful applicants are
reminded that other regulations of the Ciry mun be complied with, even after approval
of the referenced applicatJon(s).
IF YOU R=CHIVE APPROVAL FOR ANY REQUEST WHICH REQUIRES A SITc
DEVELOPMENT PLAN, Sc= ATTACHED SHE" FOR FURTHER INFORMATION.
gc
cc Bill J. Howeard, Airports District Office, 2930 Yale
Judy Epstein, P. 0. Box 13611; 87198-
Advice
S7106
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
FOHT WOHTH REGIONAL OFFICE
221 WEST LANCASTER AVENUE
P.O. BOX 29OG
FORT WORTH, TEXAS 76119
Responses to Comments from Victor J. Hancock
Department of Housing and Urban Development, Fort Worth Regional Office
Fort Worth, Texas (9 November 1981)
November 9, 1981
Mr. Clinton B. Spotcs
Regional EIS Coordinator
U.S. Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
10 198]
& A
S/ON
The Draft Supplemental Environmental Impact Statement for Waste-
water Treatment Facilities, Sludge Management System, Albuquerque,
New Mexico, has been reviewed in the Department of Housing and
Urban Development's Little Rock. Area Office and Fort Worth Regional
Office. The Department's comment: follows:
The text on Ambient Air Quality, 6.4.1, page 6-33, does
not correspond to Figure 6-4. In the text all of Bernalillo
County is nonattaioment for carbon monoxide which is not
indicated on the figure. The figure shows the entire county
as nonattainment for photochemical oxidants or ozone while
the text states only portions of the county is nonattainment
area.
The text on Ambient Air Quality (Section 6.4.1) on page 6-33 corresponds
exactly with Figure 6-4 on page 6-37. As indicated by the title. Figure
6-4 shows only part of Bernalillo County and not the entire county. The
figure shovs a portion of the county as nonattalntsnet for osone, and only
5 distinct areas as nonattalnoent for particulate natter, both of which
are consistent with the text. The legend of Figure 6-4 indicates all of
Bernalillo County Is nonattalnment for carbon monoxide, which also is
consistent with the text.
I
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Sincerely,
Clearance Officer
AREA OFFICES
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STATE OF NEW MEXICO
ENvytoim
ENVIRONMENTAL IMPROVEMENT DIVISION
P.O. Box Ma, Snot f*. New Mulco 87603
(505) 827-5271
Ttiomo E. Bat». M.P.H., Director
Bruce King
GOVERNOR
Goofg* S. Goidsi»(n. Ph.D.
SECRETARY
lony J. Gordon. M.J.. M.P H.
DEPUTY SECRETARY
November 9, 1981
Mr. Clinton Spotts
EPA - Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
Re: Supplemental Draft of EIS.
Sludge Management System:
Dear Mr. Spotts:
HOY 12
S & A DIVISION
Hastewater Treatment Facilities-
Albuquerque. NN.
The following are my comments on the referenced document:
1.
2.
Page 1-4, last sentence. Per our State Laws, the NME1D can provide
grant funds for a project only if EPA funds are provided. This
sentence may lead some person to believe that we are able to put
up funds if EPA funds are not available.
Page 3-1, first sentence.
C-35-1020-01.
The correct project number is as follows:
Responses to Commenta froa Mr. Ed Stokea, P.E.
The State of Hew Mexico, Environmental Improvement Division
Santa Fe. Hey Mexico (9 November 1981)
1. Page 1-4 of the Draft SEIS has been changed accordingly.
2. The project nuaber hau been corrected on page 3-1 of the Draft SEIS.
3. Table 5-17 (page 5-48 of the Draft SEIS) has been deleted.
4. The wording on page 6-69 of the Draft SEIS has been changed.
5. Page 6-103 of the Draft SEIS has been changed accordingly.
3.
5.
Table 5-17.
ill above.
This table is misleading and redundant. See comment
Page 6-69. Please check the wording in the last sentence ("Further,
if significant resources...") for meaning. I don't understand how
work can be stopped potentially.
Page 6-103, second sentence, first paragraph. This sounds to me as
though WAPORA is advising EPA not to fund this project. Perhaps
the word "if" got lost in the shuffle. In the first sentence of
the second paragraph reference to state funds is made yet again.
EQUAL OPPORTUNITY EMPLOYER
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Mr. Clinton Spotts
November 9, 1981
Page 2
If there are any questions, please do not hesitate to call this office.
Sincerely,
SIGNATURE PAGE. EPA RESPONSE MOT REQUIRED
ED STOKES. PE
Engineering Section
ESrvrt
xc: Steve Romano, EPA
A. K. Khera, City of Albuquerque
Dedie Snow, HWCGS
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I
-p-
Ui
5-1
5-7
5-12
5-17
5-18
5-23
5-25
5-29
Comments c.n I)»-,if I. _S 1,1:,
by A.K. Khcrn, City of A Jbii»|ii~rqiir ,
John Buryh, Camp iir^>:.or r, M<"K-
Commrr. I
Add ihr folli,wir.q I -, In',
State or Fcdcra 1 .igciiuje
"or oi.hr>
3 Statements n.irlc .ire i i.c-fii:S i s. l,cr, f w i l.h the text
and tables . A] so, ar.ulvs is is misleading from
local taxpayer 's standpoi nt.
Table 1-2 There should be another cotegrry, "Resource
Recovery" . Impacts ore inproprrlv assessed .
For ex-imp} e, there1 is no effect- of surface
water resources nr traffi c in Alt. 7.h and 2B.
This is hard to accept.
5.1.1 Phase IA facilities are not \'*\. coristruct.ed.
3 Phase IA faci 1 i Lies arc no t vc t constructed ,
Table 5-7 "Base Alterna tive" shou Id be Ucf ined in foot-
notes. Impacts arc not we 11 thouqhl out. OLD
has no impacts on re liability, environmen ta 1
and si te impact A ; is hard to accent. ULD in-
volves lagoon ir,q and Iherc fore i.-pp.irts of laqoon-
ing also apply to IM.U.
Table 5-9 These tables arc irrelevant and do not cor.tribute
anything but cor, f us ion. '.Vc '-n i r oxidal ion is
not incineration arid there fore not covered under
air quali ty rerjul.itions. However, exhaust gas
incinerators for odor cor,trol will be covered
by these ordinances.
Table 5-10 Electron beam disinfection has not been proven
feasible or, dried sludge cake.
1 Previous comment for Table 5-9 applies.
5.5.3 There will he '.0 round trips nr.il no*. 7. This is
a major i mpact. A pi pe 1 ir.e to Hio Pucrco will
have mn jor cnvi ronncn I al i"onr><-queries , be.c.i Hos
the fact Lh.it it wil 1 involve Hio Grande cross-
ir.g.
1 Other si I es wore ev;» lu.il rr| p^i Join, Hnrrjh'r. .11 id
Jim Gihtjr,1 prrsrr.t ,j I ini,.-, lo CAf or. <>/.-!'}/ »J 1 .
Copy of fxrcrpl:, ,.il.l..n-hc'l in (-.'liihil 1,
5
6a
6b
8
9
10
11
Responses to Comments from A.K. Khera, City of Albuquerque
and
John Burgh, Camp Dresser and McKee
Albuquerque, New Mexico (11 November 1981)
1. The text on page 1-4 of the Draft SETS has been altered to Imply this
meaning.
2. A cost-effectiveness analysis is conducted to determine cost to the
general public at-large, and not the local user. Local user charges
will be determined by the City following completion of construction.
3. The column headings are representative of the disciplines addressed in
Section 6.0 of the Draft SEIS. Resource recovery is a positive cost
benefit and is addressed in the cost-effectiveness analysis (Section 5. 7
of the Draft SEIS). EPA's position on assessing Impacts of the landfill
(Alternatives 2A and 2B) is that the landfill will exist regardless of
whether or not sludge is disposed there. The sludge vill comprise less
than 51 of the material disposed at the landfill. Impacts on water or
traffic from the sludge only are negligible.
4. The Draft SEIS has been changed to indicate Phase I will be complete in
1984, the sane year Phase II is to be complete.
5. See EPA response to Comment 4.
6a. Definition of base alternative which is presented on page 5-9 of the
Draft SEIS has been added as a footnote to Table 5-7 on page 5-12 of the
Draft SEIS.
6b. Table 5-7 (page 5-12 of the Draft SEIS) was presented as part of the pre-
liminary screening of general options to Identify major problems that
would remove options from further consideration. Storage of some type is
common with a OLD system; however, open lagoons are not a required com-
ponent of a OLD system. Lagoons were part of the OLD system evaluated
for the City of Albuquerque. At the preliminary screening stage the
specific Albuqerque system was not being evaluated, therefore lagooning
was not evaluated as part of the OLD option. EPA does not accept lagoons
as a means of ultimate disposal of sludge based on the environmental
effects of this option.
7. Conventional wet air oxidation involves temperatures and pressures of up
to 600 °F and 1,000 to 1,800 psig, resulting in approximately a 95Z oxida-
tion of organic material and approximately a 60X reduction in mass. The
Albuquerque/Bernalillo County Air Quality Control Board defines an incin-
erator as any device intended or used for burning waste material to
effect a reduction in volume. EPA has interpreted the definition of
incineration to Include wet air oxidation. It should be noted that Table
5-9 was presenting the preliminary screening of components and the
reduction component, including incineration and wet air oxidation, was
determined to be unnecessary for Albuquerque.
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FOR COMMENTS, PLEASE EEFER TO PREVIOUS PAGE.
Responses to Conmetits from A.K. Khera and John Burgh - Continued
EPA does not Interpret the definition of incineration to include the
thermal conditioning option of disinfection, since this process results
in only a minimal reduction in sludge volume. However, the most effec-
tive method of odor control for this system is exhaust gas incineration
which would be prohibited by the Air Pollution Control Regulations unless
a variance is obtained.
8. As is described in the text under Section 5.5.6 on page 5-32 "electron
beam irradiation probably would take place prior to dewatering, although
irradiation of sludge at 20% solids is possible." A footnote has been
added to Table 5-10 on page 5-18 of the Draft SEIS to Indicate that the
electron beam option would probably take place prior to dewatering.
9. See EPA'a response to Comment 7.
10. The statement on page 5-25 "Seven trucks will be required ..." is refer-
ing to the number of trucks, not the number of roundtrips. This section
of the EIS is describing the alternatives and does not address their
environmental effects. As stated in the Draft SEIS on page 5-25, a pipe-
line to either the Pajarlto or Rio Puerco DID site would require crossing
the Rio Grande.
11. The evaluation of alternative sites was developed and presented to the
CAC approximately one month after publication and distribution of the
Draft SEIS; therefore, it was impossible to include the information in
the Draft SEIS. Upon further request from EPA, the City conducted an
additional evaluation which was submitted to EPA in Harch 1982. This
evaluation is included in Appendix E of the Final SEIS.
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5-35
5-42
5-42
5-'.G
Klectr.in beam -li'.ii,feel ion h.i-, r.ot bee,, pruvn,
fear, ih 1 (. Oli drn.'iJ :,ludc)i' <'akc.
2 AlLcrn.Tl.ivi; si !.<. were cvalu.il.'d. :;(.i; commrr.1
fur pa^i. '.t-S.'J abuv-'
1 Statements regarding lanilflll ih:,po:,a] a i ,-
biased. We ayre, that landfill will be in
compliance wi Ih state and Ked' r,,l regulations
tinel so will b" other .11 U-rn.it i ver.. Therefore,
the 'treatment of a 1 tcrr.o ti ves should bns :
1. Debt service for bi.nd sale is not ir.rJuded.
2. KPA will not fund iai.d prr.euremen t .
3. t.l'A will not fund i eplnccmrn t of vehicles
or equipment such a.s injection trucks,
e tc.
Table 5-1/. Item 3H, Or,M coal, is in error'; therefore,
other cost.', are in error
Table 5-15 Items ?.I\ , M, 1A and 3B are throw-away options,.
Sludge credit is being inc]ud"d, which is wrong.
Fur Ui'Ti'iore , cu:,l per conin ft [on i .s not refit c-
tivc of the hiuh capital loc.,1 .share in i I '-m'-.
3rt , '(I), 'K and 111.
12
13
14
15
16
17
18
19
20
21
Responses to Comments from A.K. Khera and John Burgh - Continued
12. Baaed on communication with High Voltage Engineering, it is feasible to
utilize electron beam Irradiation on 20Z solid sludge. However, for the
Draft SEIS, EPA assumed that liquid sludge would be irradiated by Che
electron beam process. The cost information presented in the Draft SEIS
was provided by the City and was based upon the same assumption of irra-
diation of liquid sludge.
13. See response to Comment No. 11.
14. The Draft SEIS was based on the assumption that all applicable Federal
and State regulations will be complied with. Specified regulations that
apply to a particular option are mentioned, as in the case of landfills.
EPA believes that the applicability of Federal and State regulations has
been consistently applied to all alternatives.
15. Chapter 5.0 simply explains the alternatives evaluated in the Draft SEIS;
Chapter 6.0 presents the actual results of the evaluation of effects upon
the environment. Table 5-11 on page 5-35 simply lists categories of
effects which potentially can occur and often do occur as a result of
using the various components listed. Truck transportation often does
result in increased traffic and all of the things that happen as a result
of increased traffic (e.g., disruption to residents, damage to roadways,
Increased accidents, congestion of roadways, and all of the other things
mentioned in the actual effects evaluation presented in Section 6.8.3 of
the Draft SEIS).
16. The costs presented in the Draft SEIS were based completely on costs pro-
vided to EPA by the Water Resources Department of the City of Albuquerque.
EPA was of the understanding that the costs for electron beam disin-
fection, as provided by the City, were for irradiating liquid sludge.
17. Table 7-41 (page 7-116) of the City's facilities plan amendment indicates
that the city parks and golf courses can only utilize a maximum of 5160
tons of sludge per year. Disposal of the remaining 5580 tons per year
(which constitutes a majority of the sludge produced) is totally depen-
dant upon the acceptance of sludge by other entities over which the City
has absolutely no control. Thus, disposal of sludge to other entitles is
not only part of the base alternative (see definition of base alternative
on page 5-9 of the Draft SEIS), but is the critical link in guaranteeing
success of the City's proposed project. A letter of intent is not a
signed contract, but simply an expression of willingness of another part
to cooperate In a joint effort. EPA believes that obtaining such a
written expression of willingness simply constitutes good and thorough
planning. To date EPA has not received any Letters of Intent from
entities that the City believes will use sludge in the future. However,
EPA is aware that disposal of Albuquerque's sludge as a soil conditioner
has not been a problem In the past.
18. EPA's decision concerning sludge value is described in Section 4.1 of
this Final SEIS.
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Responses to Comments from A.K. Khera and John Burgh - Continued
FOR COMMENTS, PLEASE REFER TO PREVIOUS PAGE.
I
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CO
19. The Intent of Tables 5-15 through 5-17 is clearly explained on page 5-43
of the Draft SEIS. EPA assumed that an estimate of the cost of preparing
user charge determination studies (which is grant-eligible under Part
35.940-3 of the regulations) was included as a miscellaneous cost item In
the City's cost estimates. The costs of bond sales and interest on bonds
(which are not grant eligible) apparently were not included in the cost
estimates provided by the City and thus are not Included in the Tables in
the Draft SEIS; however, if the proposed facilities are built by 1984,
these coats should be minor. The cost tables also reflect the fact that
EPA does not fund pipeline easements, but will fund the cost of land for
a OLD system (per Part 35.940-3). In addition, the tables do reflect the
fact that EPA will not fund the replacement of vehicles; the replacement
costs were taken as a negative salvage value or as an additional O&M
expense, whichever was easier to compute. EPA agrees that the tables
were not correct since a sludge credit was given for Group 2 and Group 3
alternatives. However, the monthly cost per connection column for SO/ton
sludge credit was correct and did indicate the relative effect of each
alternative upon the rate payer. For this reason, EPA does not believe
the Tables were misleading.
20. This error has been corrected in Table 3-5 of this Final SEIS.
21. Comment noted. See EPA's response to Comment 19. The cost per connec-
tion given in the Draft SEIS was reflective of the high capital cost and
low O&M cost associated with the Group 3 alternatives.
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S-/.9
6-10
6-18
6-18
6-25
6-25
6-'.7
Table 6-3
Table 6-/.
Table G-4
Table 6-7
Table 0-7
Table G-9
Again, sliirkji: credit is i n'' 1 u-l'-rj ir, i t crn.'i 2A ,
?.U, 3A and 'SU, which i ft wrnng.
It has beer, assumed rh,-,( the r'lty wil! f i r.'\
on a 1 tern. 11. i vr I .ir,d r i I I ;, i le w I I h i I, rra.'."nab] C
distance, and that Iru.rjfil] uf refuse will con-
tinuo for the n^xt 'SO years. Thi:> <.ort of blan-
ket assuinptj on appear .«, f.jtj] ty.
No m i t i gat i on measure
Considers ti ons pertaining *"o resource recovery
with D1.D also apply to landfill.
We take exception to the fart thai f.rj-^o trucks
(round trips) of sludge will have !,u adverse
impacts , particularly when crossing the Hio
Grande where lack of adequate bridge capacity
is a pri-io concern.
Sludge wet well overflows will be connected
to the Tijeras interceptor; t'-.creft.re , there
is no potential for surface runoff from these.
Runoff from compost stockpile wil) be controlled
so there is no potential of r-'n !"am > no t ina surfoce
runoff .
We disagree with the evalua t i-..n i r, the l-.iblc
since the alternatives propos- d arc cons i T.I en t
with KPA regulations and yijid--lii.es.
This table is superfluous, nrvini ny less and in-
consistent with the fnct that df;,iuri will have
to meet EPfl/ICm guidelines.
We disaqree withlhc logic and rationale of
landfill - "Since landfill is a r.uis.incc , a
little more is no r,u i sance . " He think i ^ is
very poor treatment of facts.
Biodegradable material in all cases except
compo5,ting is ;il.ikc; therefor'', likelihood
of an odor1 potential is equal .
Poor Ionic for landfill optiui..
page G-32 appl ief. .
Comment ror
nisncirce with r v,,l u.il i >,n of AM. 'fl\ , 7D , T.A ,
3U, JC and 'ill .
22
23
24
25
26
27
28
29
30
31
32
33
|34
Responses to Comments from A.K. Khera and John Burgh - Continued
22. See EPA's responses to Comment 19.
23.
During conduct of the SEIS process prior to issuance of the Draft SEIS,
EPA received copies of budget documents from the City Planning Department
which indicated the City had budgeted $4,219.302 for a new City landfill
in City Zone Atlas Area B-17, which is exactly in the middle of the
"landfill zone" illustrated in Figure 5-1 on page 5-26 of the Draft SEIS.
The budgeted amount was allocated for the following items:
Land: 283 acres x $12,000/ac
Improvements (access roadt fence,
office trailer, berm, and utilities):
Miscellaneous
Total
$3,396,000
690,478
132,824
$4,219,302
The concept that the City would allocate this amount of funds with such a
detailed cost breakdown for nothing more than a blanket assumption
appears faulty.
24. Mltlgative measures were not included because no mitigative measures were
proposed in the City's Facilities Plan Amendment or in subsequent corres-
pondence with EPA prior to the publication of the Draft SEIS. Mitigative
measures appropriate to the City's proposed project are Included in
Chapter 3 of the Final SEIS.
25. The text has been changed on page 6-17 of the Draft SEIS to reflect this
comment.
26. This discussion of the trucking alternative la under the Earth Resource
Section and is therefore an inappropriate section for the discussion of
bridge capacities. However, this Is a valid comment for the Transporta-
tion section (Section 6.8 on page 6-71 of the Draft SEIS) and the text on
page 6-75 of the Draft SEIS has been changed to reflect this comment.
27. EPA is aware that the Tijeras Interceptor is available for overflow from
the lift stations associated with the proposed Montesa Park pipeline.
However, EPA is not avare of any interceptors available for connection to
the lift stations associated for the proposed pipelines to the Pajarito
and Rio Puerco OLD sites.
28. The control of runoff from compost stockpiles was not specified in the
City's facilities Plan Amendment, therefore it was not Included in the
Draft SEIS. Through the EIS process the City has now proposed to control
runoff from stockpiles and this change has been reflected in Chapter 3.1
of the Final SEIS.
29. Effluents meeting EPA standards can still have a significant effect upon
the environment. However, the major effects indicated in Table 6-4 on
page 6-26 of the Draft SEIS were based upon the assumption that runoff
from Montesa Park and the DLD sites would not be controlled, and that
breaks In the pipelines and/or overflows of the lift stations would
occur. Based upon recent City input, environmental consequences of the
-------
FOR COMMENTS, PLEASE REFER TO PREVIOUS PAGE.
I
Ln
O
Responses to Comments from A.K. Khera and Johg Burgh - Continued
City's currently proposed project and other alternatives have been
re-evaluated and are presented In Chapter 3.0 of this Final SEIS.
30. See EFA's response to Comment 29.
31. EPA's position is that the landfill is part of the existing conditions.
Stated another way, a landfill will be developed regardless of which
alternative is chosen to manage Albuquerque's sludge. The Braft SEIS
addressed only those additional impacts of the landfill caused by sludge
disposal. Since the sludge would comprise less than 5X of the refuse
disposed at the landfill, the effects caused by the sludge would be
minor.
32. The Draft SEIS text has been changed to reflect this comment.
33. See response to Comment No. 31.
34. The effects of the alternatives on various disciplines (e.g., air, water,
etc.) have been revised to reflect the changes the City Hade in the
alternatives since issuance of the Draft SEIS (i.e., the Inclusion of
mitigative measures).
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Comment
Ln
Table 6-12
Table 6-15
f.
Table 6-17
MIL icj;i I. i vc meai.urcs IKIVO been
Fifteen million curies is i,o! firm. T t; mav
be 5-1O mil lion curies.
There orr several l.ircjrr i rrnrl lit t.t-r"-, currpn t- 1 v
i n ir.du.-, t r i .1 1 use .
l.andf i ? ling (.if sludr-jr h.'j.s no l-io]ocjic:«il effects
hard to arcept .
Inconsistent and erroneous tr*- ,i Lmen I- of far ts .
Bird fttrikc hav.ard prob Ten muc t lie nddr'.'ssi'd
based or. other similar furi lilies and .situations
around i.hc cour, try .
23.5 mi I J ion is not. 75% of 3B .
Figures arc inaccurate and m1' £- leading. So. 61
credit applies only tc rrscur---. recovery opt. ions.
There is no major fcr tj 1 ir.er i r.dustry in
Albuquerque ; hrnre , there are 1,0 empl oymcn t
impacts ,
Mitigation measures nrc not ?>* ipulatcd or ;ic-
co tinted in the statcmor.tr, .
Safety features and redundancy arc standard
for the industry and there for r apply both to
electron be.im, Cesium-137 or flobeilt-60 irr.i-
diators .
Genera^ Comments
]n summary, we feel tihat the Draft SRI S prepared by WAPORA, I ri*-. , has prov id-?d
da ta cind assumpt i ijnr> tha t arc mi si end i nq arid i net H. si s I cf t. Ar> .HI cxanp I c ,
acqiij si tior, of l.ir.ci for I)[.f) 15, ntit fnr.d.thlo Ity KI'A .n.cl I hf pi-1 Hio Gr.unle r-rnss iiiar.cr
anyway and thorcforr depc ridor.ro 01. l.iiidfi 1 1 for' :. hidijf* ''' .'p":-i I h.ir. ti" i m-
pncts whatsoever.
fi-51
6-61
6-6G
6-75
6-80
6-82
6-83
6-93
35
36
37
38
39
40
41
42
43
44
45
46a
46b
46c
47
48
Responses to Comments from A.K. Khera and John Burgh - Continued
35. See response to Comment No. 24.
36. The actual source plaque size will be based on the gross tonnage of
sludge to be processed per day. The figure of approximately 15 million
curies was calculated by the Department of Energy (DOE) based on infor-
mation provided by the City. For further Information see the 5 October
1981 letter from the DOE to WAPORA, Inc. in Appendix A of this Final
SEIS.
37. Comment noted.
38. See response to Comment No. 31.
39. Comment noted.
40. EPA does not see any inconsistency with this comment and the statement on
page 6-75 of the Draft SEIS.
41. The economic evaluation on page 6-80 simply noted that, if all other
alternatives were found to be not environmentally sound, EPA potentially
could fund up to a maxiumum of 75X x $31,281,900 - $23,461,425 (roughly
23.5 million). EPA funding decisions, as explained in Section 4.3 of
this Final SEIS, Indicate EPA may fund up to 85t of the City's proposed
project.
42. Table 6-17 does not Indicate the $0.63 credit is applicable to all alter-
natives. It says' (footnote) that if sludge is sold, the cost per month
will be reduced by $0.63. If sludge is placed in s landfill or Injected
in the ground, it cannot be sold.
43. EPA agrees that there will not be a significant effect on the fertilizer
industry (i.e., fertilizer distributors) in Albuquerque; therefore, the
text on page 6-83 has been altered to reflect this comment.
44. See response to Question No. 35.
45. EPA concurs with this comment. Although the text of the Draft SEIS
implied that safety features and redundancy are standard for both the
electron beam and Cs-137 irradiators, the text has been changed to state
this explicitly (see Chapter 5 of the Final SEIS).
46a. Comment noted.
46b. EPA regulations (Part 35.940-3) state that the cost of land for OLD is
fundable, and therefore the cost of land was included in the cost analy-
sis in the Draft SEIS. The resulting economic burden on local taxpayers
(if any) was illustrated in the cost-effectiveness tables of the Draft
SEIS.
-------
FOR COtMENTS, PLEASE REFER TO PREVIOUS PAGE.
Responses to Comments from A.K. Khera and John Burgh - Concluded
46c. Appreciation of land at 3% per year is required by EPA regulations, and
is not subject to City concurrence, New cost-effectiveness analysis
tables are contained in Chapter 3.0 of this Final SEIS.
47. The subject of traffic congestion, particularly in the northern
industrial sectors, was addressed on page 6-75 (Section 6.8.3} of the
Draft SEIS. Both truck routes to the DID sites cross the Rio Grande.
The route to the Rio Puerco OLD site uses the 1-40 bridge across the Rio
Grande and is not expected to present any problems with capacity.
However, there Is concern about the capability of the Rio Brsvu Bridge
across the Rio Grande used by the truck route to the Pajarito DLD site.
The text on page 6-75 of the Draft SEIS has been changed to reflect this
concern.
48. See response to Comment No. 31.
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DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
FROM:
TO:
November 13, 1981
ABQ ADO-610
AIRPORTS DISTRICT OFFICE
2930 Yale, SE.( Room 109A
Albuquerque, NH 87106
Supplemental Draft, Environmental Impact Statement, Uasteuater
Facilities-Sludge Management System, Albuquerque, New Mexico
Chief, Airports District Office
Mr. Clinton B. Spotts
Regional EIS Coordinator
U.S. Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
We have reviewed the subject Supplemental Draft and offer the following
comments for your consideration:
Page 1-6, Alternative 1C, ID, IF and 1G. These alternatives require
open air drying as one of the steps in processing sludge. Care must
be taken to prevent such an operation from attracting birds. Any
concentration of birds in the project area could be a hazard to
aircraft arriving and departing Albuquerque International Airport.
Responses to Comments from Bill J. Howard
Department of Transportation, Federal Aviation Administration
Albuquerque, New Mexico (13 November 1981)
The Bird Aircraft Strike Hazard (BASH) report prepared by the OS Air
Force expressed concern about the attraction of birds to lagoons at
Montesa Park. Although the City did at one time propose using sludge
lagoons as an interim measure, none of the alternatives for ultimate
treatment and disposal of sludge as evaluated in the Draft SEIS proposed
the use of lagoons at Montesa Park. At CAC Meeting 17, a member of the
Air Force BASH team expressed concern about the attraction of birds to
open air drying beds. Since issuance of the Draft SEIS, the City has
made certain changes which include: (1) deleting open air drying from
consideration due to being environmentally unacceptable; and (2) enclos-
ing all stockpiles. These changes should alleviate concerns over the
attraction of birds to the proposed sludge handling facilities.
BILL J. HOW
Ln
U>
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United SUIes
Department of
Agriculture
Soil
Conservation
Service
Box 2007
Albuquerque,
87103
o^
-C-
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
16, 1981
19 J98I
S & A DIVISION
Dear Mr. Spotts:
A copy of the Draft Supplemental EIS for Waste Water Treatment Facilities-
Sludge Management System, Albuquerque, New Mexico, dated September 25,
1981, has been received.
We want to clarify the role of the SCS as a "cooperating agency" as
identified in the EIS pages i, 1-10, and 7-5. In response to a letter
dated August 28, 1980, from your office requesting that we participate
in the preparation of the DEIS, especially in relation to use of the
sludge as a soil fertilizer/conditioner, we agreed to supply soils
information, review, and technical information. To our knowledge, no
requests were ever made by EPA or by your consultant WAPORA, Inc., for
technical input from SCS.
We would like to address the proposed use of the "disinfected" sludge on
city parks and golf courses as a soil conditioner and fertilizer. The
primary source of our information is the 1978 report "A Plan for Irrigation
Water Management on Albuquerque City Parks" which we prepared for the
City of Albuquerque. In addition, Dr. B.D. McCaslin of New Mexico State
University furnished the approximate analysis of nutrient components
found in sludge from the Albuquerque Plant No. 2.
Our interpretation of this information indicates that plans to apply at
least 7,000 tons of sludge each year to some 1,400 acres of turf grasses
will exceed rates needed to maintain a sod cover that is satisfactory
for recreational uses. The excess will result in the need for the
application of additional irrigation water as well as for more frequent
mowing, raking, and disposal of grass clippings.
This is not to say that the proposed rates will be deleterious to the
turf, but to point out some of the management consequences. The rates
of sludge application do not exceed what could reasonably be expected to
be assimilated by irrigated turf grasses. The irrigation systems installed
in Albuquerque parks have sufficient delivery rates to accommodate the
needed increases.
RESPONSE TO COMMENTS FROM RAY T. MARGO.JR.
US DEPARTMENT OF AGRICULTURE. SOIL CONSERVATION SERVICE
ALBUQUERQUE, NEW MEXICO (16 NOVEMBER 1981)
EPA appreciates the SCS conaaents on the Draft SEIS. These coamenta along
with data from other sources (e.g., letter from George A. O'Connor, con-
tained in Appendix A) were taken into consideration by EPA when deter-
mining how much credit should be given for Albuquerque's sludge and ulti-
mately which alternative should be funded. EPA has decided to give the
sludge a credit of $70.00 per ton. The information provided by the SCS
was useful and appreciated.
-------
"r. Clinton B. Spotts
Ui
Ui
Proper irrigation rates of normally maintained turf grasses call for the
addition of water to only the upper 2-4 inches of soil, and only in amounts
sufficient to replace soil moisture lost to plant growth. With the proposal
to add supplemental amounts of sludge, the increased irrigation rates needed
will wet the soil to depths of one foot, and there would be leaching of soluble
materials to those depths.
If the irrigation management plan is followed, we would not foresee any
serious problems in using turf grasses to dispose of the stated amounts of
sludge. Also, 1f irrigation application rates and frequencies follow the
plan, we would not foresee any large-scale movement of irrigation water into
groundwater.
Section 5.7 Cost Effectiveness Analysis is difficult to comprehend and interpret.
Cost effectiveness of project alternatives is usually stated in terms of
dollars per unit. In this case, it could be stated as dollar cost per ton of
sludge treated. An array for all alternatives would aid in comprehension of
the economic considerations.
We feel that placing a value of $70 per ton for sludge is high. Me do not
agree that this value represents the true market value. A substitute product
in the form of steer manure in 50-pound bags sells for $40 a tonor about $20
a ton in bulk.
Section 6.9 Economics describes project effects in terms of social parameters;
i.e., city finances and expenditures, population and employment. It does not
provide an economic analysis and a display of the beneficial and adverse
effects. Such effects might Include project costs, operating costs, maintenance
and replacement costs, and cost savings.
Section 6.1.3 Environmental Consequences mentions wind or water erosion as
potential problems with both the landfilling or the dedicated land disposal
methods. We fefO that these problems would be of minor consequence and could
be easily mitiyated wi't'n infcVf'iTiV'.vb, "Convent')onaI conservation measures.
Section 6.3 Groundwater discusses. In several alternatives, the potential for
contamination of groundwater. It is implied that application rates for sludge
are critical; while in fact, It would be the application rates for irrigation
water that would determine the possibility of groundwater contamination.
We appreciate the opportunity to review this document.
Sincerely,
Responses to Comments from Ray T. Hargo, Jr.
2. The cost-effectiveness analysis presented in the Draft SKIS considers
construction cost, operating and maintenance costs, replacement costs,
and salvage value. The cost-effectiveness analysis in Section 3.4 of the
Final SEIS also considers new cost information provided by the City.
Section 3.4 also presents the costs of alternatives in dollars per ton of
sludge treated.
3. See EPA's response to Comment 1.
4. See EPA's response to Comment 2.
5. Section 3.3 of the Final SKIS presents these impacts as
minor.
6.
Page 6-31 of the Draft SEIS has been changed by errata to include
irrigation rates also as being significant.
6
Ray T,
State
Jr.
onservatlonist
Norman Berg, Chief, Soil Conservation Service, Washington, DC
Edwin Swenson, Biologist, Soil Conservation Service, Albuquerque, NM
-------
To: C.A.C.
From J.B.Sorcnson
Re: Draft HS/ Mici[;:irii
in Measures Addition-.
DEC 10 1961
S & A DIVISION
The DOE rccjui re.1-: £i_ S^Jj_^l_y Anjij^si s ,-uul !U'_vi_rw ^V_isL^B' study Tor ;i1 1
environmental, safety, ana heal t li (ESili) risks- 'i'iu s won 1 d apply to
the ir rad ia tor. There is no men lion of it in the 1'iMS. The- provision
for a safety ana] y sis to assure quality control for F.SM! risks should
be extended to all disinfection systems. It should also he m.Ttcj^ed
with a^ requirement for an independent jgud it j n d puM i i re^i ew o £ c t s i:
acceptability^ of the safety analysis.
The effect of the requirement of a safety analysis for ES6H risks
coupled with a requirement for an audit and public input and review
would be to be ajss u r ed _t h_aj:_p r on is e s regarding safety, health and
the environment have been kept. In brief, it will provide continuing
evidence and verification that:
- the facility for disinfection is built as intended
- it is operated as was proposed
- it is verified on 3 continuing b;isis as s.j U
The importance of establishing a safety analysis and an independent
audit and public review lEQuirment in the Mitigation Section of the
DEIS is twofold:
RESPONSES TO COMMENTS FROM J.B. SORENSON
CITIZENS' ADVISORY COMMITTEE"~
ALBUQUERQUE, NEW MEXICO (16 NOVEMBER 1981)
An Environmental Readiness Document (ERD) Is being prepared by DOE for
the Cs-137 sludge irradiator. A preliminary draft copy of this document
was made available to EPA. This document was not quoted in the Draft
SEIS since it is still at the preliminary draft stage and is at ill
subject to in-house review, and thus currently is not a public docuaent.
Provisions for audit and review of the ERD are subject to DOE procedures
which are beyond the Jurisdiction of EPA.
The Albuquerque Industrial Pretreatment Progran Development manual sub-
mitted to EPA on 29 June 1981 summarizes testing of the sludge for »etals
and other priority pollutant compounds. The data indicates that the
sludges in the sampling described were within the standards published by
the Water Quality Control Commission. This data also is consistent with
earlier test work on sludge quality. All this information supports th*
position that sludges produced in Albuquerque conform to all applicable
State and Federal regulations for land application. EPA toxicity testing
has also been conducted and the sludge quality is well within the care-
fully drawn and conservative published regulations and guidelines for
this type of disposal method. See Appendix D of this document for
laboratory report data resulting from toxicity testing of Albuquerque's
sludge.
1 . While the E1S is subjcc t to puhl ic
is not . Hence , we can escnbl i sh th
eview, die Safety An;i 1 ysi s
basis f<*r [»ub] i «. n.i rt it i-
pation with regard to safety, health and environments J concerns .
2. It will h'elp to assure tha^t_tiic- saf_ct>' concerns of c_hfc_ iom-
munity with regard to the irradiator and any other disinfection
process will be fully addressed o n a _c oiitj^mj uij|^bjajn.jy
Thus , it is proposed a^rnojtKJn be adopted to inc lude the ..bove statement
in the submission of our comments to EPA as a request of this committee.*
2. §10. 3 (no page) describes the Electron B--jam Process. Under Public lie. :i 1th
it states that this process toxic or grm^ j._c _i_h enm:^ j s n-si . irr. l in sonic- slud^s
Those toxic organic chemicals comprise pest ic idgs^ PCHs . hcrbic idj^s ,_ urgan^x
solvents and certain other carcinogenic compounds which .re ''mvujur^ii-t) bj1
most treatment processes , including .ipc_lju-_r_:i_t ion. " Elect r on bc-.jm energy
produces hydroxyl compounds and sufficient activation energy to degrade
these compounds.
The state Water Quality Control Commission has establish.^ the preseucc-
of organic contaminants in ground water .mil arc regulat Lr,g for o_i^ht (8)
of them. They are:
benzene/C H benzo] ; coal naj-iithn ; ryt 1 ohe-xatr i one ; pheny 1 hydr idti
-- - 66
In conpliance with CEQ Regs, fcr the imr^lefrentation of ;*EPA, 40 CFR Parts
1500-1508, specifically 1505.2
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oj
EDC/1.2- dichlorocthane/CJI Cl;/brocide; dutch liquid; e thentdichloridi-;
ethylene chloride; etfiylCTie- dichloridu; glycuKiiciiluridc; ^yni-di-
chloroethane
CC1,/carbon tetrachloride/bunzinoform; nccatorina; perchloromethane;
1,1-DCE/l. 1-d ichloroe tliylen.-/C..HzCl?/asym-d icTilorou thylene ;
1,1-dichloroethcnc; unr. aichloroethylene; vinylidene chloride;
PCBs/polychlorinated biphenyls/Commercial products such as the arochlors
(e.g., arochlor 1260) are complex mixtures of PCBs./Numerous
synonyms are listed in Sax, 1979, page 484;
PCE/tetrachloroethylene/C;Cl /ankilosten; carbon dichloride; didakene;
ethylene tetrachloriue; nema; perchloroethylene; perclene;
tetracap; tecrachloroethene; 1,1,2,2,-tetrachlorocthylene; tetropil;
Toluene/C-Hfl/mer.hacide; methylbenzene; phenylmcthane; toluol;
TCE/tricholorethylene/C;HCl /algylen; germalgene; trethylene;tri;
tri-clene; trichloran; trichloren; trichloroethene; 1,1,2-tri-
chloroethylene; trielene; trillne; trimar; westrosol;
The question is whether any of these ogranic contaminants, now found
in ground water in Albuquerque, are also present in the sludge.
If so, do they pose a health problem? I£ so, how will they be
treated? The DEIS, with the exception of the statement in §10.3,
does not touch on the question of organic toxics.
Thus, it is proposed a motion be adopted to include the above
statefment in che submission of our comments to EPA as a concern
of the CAC.
3. An alternative site to Montessa Park is to move the disinfection
facility to the federal lands, the Forest Service/Air Force lands,
that is adjacent to Montessa Park. Th;s site offers the potential
of solving most, if not all, of the problems associated with the
Montessa Park site: possible odor problems, the potential negative
economic impact on neighboring Ijnd owners, tin.' potential hird
strike hazard, the possible safety and security problems, and the
open spaces problem. The CAC, through its chairman, lias initiated
inquiries along these lines.
i Thus, itjLs proposed a motion be adopted to include a review of the
settt'-°-'J fedoral?ftnfdsalternative as an extension of the present DEIS, and
iitafe. that this motion be submitted to EPA as one of our comments on the
DEIS.
Responses to Comments from J.B. Sorenson - Continued
3 A Kirtland Air Force Base site was considered, but rejected because of
objections by Air Force officials and high punping cost. Refer to
Appendix E for additional Information regarding analysis of alternative
sites.
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Responses to Cpmmentg from J.B. Sorenson - Concluded
\
Ui
CO
The CAC , upon review u C the UL'IS , find-, j L scr ions I v dc i n- ,:! t w i i.'i
regard to the key pnramn ters of : tht.j identi f ic;i t1nn of .1 ] t L-rnn t ivcs
and a ssc'S sine n t of costs, the irnpOL L s, ;inij I lit- mi L i p. \ t ion mtvi-su rus .
The details of its specific findings ;rfc richidt'J in ,r CAC paclia^e of:
1. Review CowsncMit<; by Larry T.
of the CAC.
Cnndi 11
pru;-'.u T'-L .11 L In.1 reques L
2 . Review Comments by A. K. Kehra , prc.'p
Department and submitted to the CAC.
3. Comments by the CAC iricmLiTi
fur Li)( W;i tcr He-sources
4. EPA's responses to the specific comments of Larry T. Gaud111, A.K. Khera
and CAC members are contained in Chapter 6.0 of thia Final EIS.
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Statement on Che Draft EIS and Cs137 Irradiator
Given at the Public Hearing November 17, 1981
City Hall, Albuquerque, New Mexico
My name is Evelyn Oden, I am a physician, specializing in pediatrics
and a member of the Citizen's Advisary Committee. My major objective
while representing the citizens of Albuquerque has been directed towards
the health effects of the method of disinfection selected by the City
Of Albuquerque. The following comments summarize my position, as a health
care provider, on the disinfection process chosen by the City of Albu-
querque and described in the DEIS. The comments directly address the
137
Cs irradiator, as the health effects of this process presented in the
DEIS and to the CAC by Sandia National Labs are scant.
Odor has been a concern of the members of the CAC and the citizens
of Albuquerque, especially the people in the Mountainview area. It in-
deed is a health concern as it affects the quality of life. As described
in the DEIS, odor control depends greatly on the effectiveness of the pro-
cess of anaerobic digestion. It must be clearly understood by the citizens
of Albuquerque that the irradiator, in no way, solves the odor problem,
that excessive odors must be controlled in the processes preceeding ir-
radiation (anaerobic digestion, drying) and with stockpiling after the
disinfection process.
I would like to address certain aspects of Cs that were not men-
tioned in the DEIS nor considered by the CAC. It involves the activity
of Cs once it is ingested, where it is distributed and how it is eliminat
from the body.
Cs and potassium have similar chemical and biochemical properties.
Cs is dissolved in body fluids and is distributed throughout the body.
1
ed
Responses to Comments from Evelyn Oden, M.D.
Citizen's Advisory Committee
Albuquerque, New Mexico (17 November 1981)
The groundwatec table below Montesa Park ia approximately 210 feet deep.
The consent that "a site where groundwater IB close to the surface Is
being considered as an alternative to Montesa Park" Is correct. In that
other such sites were evaluated. These other sites were discarded,
primarily due to the shallow groundwater depth. For a complete descrip-
tion of the site analysis conducted by the City, see Appendix E,
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-2-
O
It is absorbed rapidly and completely in the digestive tract. The average
biological half life is 109 days with a range from 68 to 165 days. It
2
concentrates, among other places, in the muscles and is eliminated through
the kidneys. As a result of atmospheric weapons testing, there is a
slowly decreasing level of Cs in the environment and food that results
in man now having a body burden of approximately 25pCi/g of potassium,
delivering an annual radiation dose of about 500 mrads (NCRP, 1977a).
This information is important, in the "unlikely" event of ground water
contamination resulting in Cs contamination of public drinking water.
This is a real public health threat if the irradiator is located at a site
where ground water is close to the surface. A site such as this is being
considered as an alternative to Montessa Park for the irradiator. Al-
ternative sites for the irradiator have not been reviewed in the DEIS or to
date, by the CAC. A complete evaluation of soils, groundwater tables and
flood plains for all of the alternative sites is necessary before the ir-
radiator can be a safe and acceptable alternative.
As mentioned in the DEIS. . . "overexposure to personnel at the irradiate
is a more likely occurance of the accident scenarios ... In the event of
overexposure, impacts on personnel involved would be severe and extreme
cases would result in death. Unshielded exposure for a few seconds within
10 feet of the source plaque would result in instantaneous death"(p. 6-95) .
Detailed preventive and safety procedures are given int the Appendix 10.2
of the DEIS and Sandia documents .
Since the proposed irradiator will be the very first full-scale
137
experimental (40 pin 5 to 7 MCi) gamma irradiator using Cs ,
problems with the irradiator thatwill develop in its 20 year life
are unknown. The safety record of smaller Co irradiators currently
in use was inadequately described in the SEIS (Section 10.2). The
magnitude (curies) of gamma radiation and capacity of the irradiators
2
Responses to CocmentB from Evelyn Odeog H.D. - Continued
2. The aagaitude of the source plaque aad the capacity of the Co-60 Irradia-
tors is considerably araaller than the C8-137 irrsdiator which is proposed
for disinfection of Albuquerque sludge. The technology which is used in
the stsaller Co-60 irradiators Is similar to that which mcald be used in
the Cs-137 irradiator, therefore an examination o£ their safety records
was presented. This information vas given only to exemplify the type of
accidents that have happened with a similar technology. Aa asset corre-
lation for esjissiosa or exposure was not intended.
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-3-
was not given. This information should be provided in the final EIS,
as it is important for comparison. Listed are some of the examples
of accidents involving a few existing Co irradiators as reported
by the NRC. They include:
-Radiation exposure to workers (twice in 7 years). !
In each case, the worker entered the conveyor area when the source
plaque was exposed, even though those safety measures had been
designed into the system. It was reported that the incidences
resulted in no overexposure, but this is vague terminology. Over-
exposure could mean instantaneous death, radiation sickness, with
ensuing leukemia. An estimation of the dose needs to be cited.
-Two fires at irradiator facilities in NRC region 1
in the past 5 years. Amount of worker exposure is unknown, as it
is vaguely stated that these incidences resulted in no overexposure.
Again, estimates of the dose received need to be given.
-Three source pin leaks have occured in the past 8 years.
One cannot automatically conclude that these events will occur with
the proposed, larger Cs irradiator. Neither can it be assumed that
in the 20 year operational period that there will be no accidents re-
sulting in exposure to workers or to the general public. These uncertain
137
ties, along with the proven dangers of radiation, make the Cs irradia-
tor the least desireable alternative for disinfection. The other time
proven disinfection methods, namely composting and wet air oxidation, hav
less severe consequences for the citizen's of Albuquerque now and in
future generations.
Evelyn Oden, M.D.
Private Citizen
Citizen's Advisary
Committee
Responses to Comments from Evelyn Oden. M.D. - Concluded
3. The workers who entered the conveyor area when the source plaque was
exposed definitely received an overexposure to radiation. Overexposure
is defined as an exposure above the limits specified In the regulations.
A stricter definition would be any unplanned exposure. Section 10.2 of
the SE1S has been changed to further emphasize that the workers were
overexposed. The dose received by these two workers la not comparable to
the dose that would be received In a similar incident at the proposed
irtadlator since the source plaque would be considerably larger and less
time would be needed for overexposure. As was stated in the Draft SEIS
(page 6-95), unshielded exposure for a few seconds within 10 feet of the
source plaque would result in almost Instantaneous death. The two fires
at Irradiator facilities In NRC Region 1 resulted in no radioactive
material being released and no exposure to the workers or the general
population other than that which would have resulted from normal opera-
tion. At one of the fires, the specialized "clean-up" crew did receive
exposure greater than that resulting from normal operation, bat not
greater than the regulatory limit for radiation workers (by phone, Jim
Nicolosi, NRC Region 1, 5 January 1982).
-------
FOOTNOTES
1. NCRP Report #65, Management of Persons Accidentally Contaminated with
Radionuclides. NCRP, 1979
2. Safety Series #47. Recommended Manual on Early Treatment of Possible
Radiation Injury. International IAEA, Vienna, 1978.
3. NCRP Report #65,.p.78
FOOTNOTE PAGE. EPA RESPONSE NOT REQUIRED
-------
A nil-: UMVKK.sn vor.\'HU MI.XK.D
November i
Jay Sorenson, Chairman, Citizens' Advisory Comm i 11 L-L
James Wiegmann, CAC Member (Economic Interest)
Review and Comments Concerning Draft SEIS on
-Wasteviater Treatment Facilities - Sludge Management System
10 198!
s & A DIVISION
As per your request, 1 have reviewed the Urn ft SE TS and I offer the comments
thai follow. in the interest of avoiding redund-'jncy, points which have already
been made in reviews previously submittt d by Larry Caud11 and A. K. Khera will
be omitted.
Paragraph Comment
4 500-year ilood plain data should be included. !
Potential changes in drainage flow nat tern should
be studied in regard to probable development of
lands adjacent to and upstream of the Montessa
Park area.
6-5 Reports of soil problems encountered by the
thru abandoned Montessa Park Detention Facility have
6-13 not been mentioned or examined.
6-28 4 Depth to groundwater listed at 210 ft. in Montessa
Park conflicts with statement on pape 6-97, para- .
graph 1, where depth is described at 300 ft.
6-29 2 Statement which reads '..-, there is little use of
groundwater near Montessa Park or several miles
south" is probably correct at the present time. It
will be grossly incorrect within .1 few years as de-
velopment takes place. The area adjacent to Montessa
Park on the south is described in the Comprehensive
Plan as a j>otential location of a future urban center
or planned new community. City officials have stated
that this potential satellite community would probably
be required to construct its own water system. Leach-
ate from any facility at Montessa Park has to bt- con-
sidered as .1 possible groundwater contamination source
for a future community water system.
6-39 2 The future environmental impact of odor pollution from
a Montessa Park facility has not been addressed in
light of future development of the lands to the south.
The ".. , y«.-ar-round occurrence of winds from the north-
northwest" and "...impacts over an area of many square
miles..." should be examined for the proposed facility
as well as the Plant No. 2 area. Exportation of odor
pollution to an area of lesser present day population
might turn out to be a more temporary solution to a
]ong-term prob1 cm.
RESPONSES TO COMMENTS FROM JAMES WIEGMANN.CAC MEMBER
THE UNIVERSITY OF NEW MEXICO
ALBUQUERQUE, NEW MEXICO (17 NOVEMBER 1981)
1. EPA does not allow construction in 100-year floodplalns, however EPA has
no requirements concerning construction within the 500-year floodplain.
For this reason, presenting 500-year floodplain data was not within the
scope of this SETS. Changes in the floodplains due to the proposed pro-
ject were evaluated and determined to be insignificant.
2. EPA is aware of the soil stability problem at Montesa Park. Recent in-
formation has been received which indicates that soil instability will
not be a problem with the proposed project. For further information, see
the City's report entitled "Foundation Soil Conditions - Montesa Park
Vicinity" prepared by Benny McMillan & Company.
3. Page 6-97 of the Draft SEIS has been changed to reflect this comment.
4. The City's proposed project has been revised to include filtrate, leach-
ate, and surface run-off control therefore, no groundwater contamination
is expected. Further elaboration of this topic is presented In Sections
3.1 and 3.2 of the Final SEIS.
5. EPA agrees that existing and future development surrounding the proposed
facility at Montesa Park could be affected by malodorous upsets at the
facility. The text on page 6-49 of the Draft SEIS has been changed to
reflect this comment.
-------
Memo to Jay Sorenson, Ch:ii rmnn, Citizi-n;- Advisnrv Comn:itlei-
Responses to Comments from James Wiegmann - Concluded
Page No
5-42
6-81
6-39
inr
Tlie UNM Guif Course n.-n-.icpr hns suited that UNM
is not a buver fnr sluii^e fertilir.er at this time.
Reference tn the l!r.]" vtrsi ty as a user should be
de]eted.
6
s is superficial
of any final
stic effects on
n the- rase (if the
r owns or is the
f nuarby properties. I
University of New Mexico who ei th(
beneficiary ni l.inds hoth north .-;;
Montcssa P.irk arcn, potential los.s
revenue can easily be many million
In.sti rution:!] funds which mipht h.i
by these properties will most like-
State Government and thus the taxp
Any unfavorable a Iteration of the
acteristics of ttu- southeast mesa
the citizens of the Albuquerque irt-
significant amounts of futun.- prop
and econom ic op PIT tun i t i cs associ .
ment.
A reduction in the- developab ilitv of the sou then st
mesa might result in further population shift to
the west side of the Rio Grande with consequent in-
creases in public infrastructure expenditures (i.e.,
bridges). In short, economic issues have cither been
ignored or glossed over as unimportant throughout the
Draft SEIS.
It is mentioned that there was a stipulation in 1980
which required the City to irstii'ite the following
conditions at Plant No. 1: (1) Kot vent odorous pases
(2) Discontinue the use of s'udp.o dryinp beds; (3) Re-
move sludge on a cl.-iily basis. Why ,-irt-n't these pnrnm-
eters beinj1 used MS standards in ihe design nf the
proposed f ;ici 1 i ty «it Montessa Park?
7a
7b
8
7a.
7b.
8.
5-42 of the Draft SEIS, the University of New Mexico (UNM) is
s a potential user of the sludge produced during the 1990 design
On page
listed i __
year. This statement was not Intended to imply that UNM is currently a
buyer of the sludge. As was stated in the Draft SEIS, there has been no
docuttentation to-date that the UNM or other entities are willing to
purchase or utilize sludge in the future.
EPA'& evaluation did not determine that drastic effects on land values
would occur due to the proposed project or alternatives. Effects of the
City's currently proposed project are presented in Section 3.2 of this
Final SEIS.
EPA's evaluation did not determine that a gross reduction in the develop-
ability of the Southwest mesa or any other area would occur.
According to the City, these standards are being used for the expansion
of Plant No. 2. Recent revisions to the proposed project include odor
control for gases vented to the atmosphere, deletion of alternatives
considering open air drying, and covered stockpiles for the dried sludge.
Further elaborations on revisions to the proposed project are included in
Section 3.1 of the Final SEIS.
-------
Evelyn Oden
7505 Forsythe, SW
Albuquerque, New Mexico 87105
November 18, 1981
Mr. Clinton B. Spotts
Regional EIS Coordinator
United States Enviroatoental
Protection Agency
Region VI
1201 Elm Street
Dallas, Texas 75270
Responses to Comments from Evelyn Odeo,
Member of the Citizen Advisory Committee
Albuquerque, Rev Mexico (18 November 1981)
The Draft SEIS evaluated and coated a conventional wet air oxidation sys-
tem which achieves 95Z oxidation of organic natter. The Ziapro process
discussed by the CAC during the public participation process Is not a wet
air oxidation process, rather It is a thermal conditioning process coat
achieves approximately 5Z oxidation in organic matter. Conventional wet
air oxidation was screened out for Albuquerque due to high O&M costs,
particularly high energy costs. An evaluation and cost analysis of the
Zimpro thermal conditioning process was conducted based on a request by
the CAC following the Issuance of the Draft SEIS. This information has
been included in Section 3.3 of the Final SEIS.
Dear Mr. Spotts,
In order to adequately evaluate the most feasible method of
disinfection for Albuquerque's municipal sludge, it is essential
that WAPORA reconcile the disparity of costs for wet air oxidation
as given by Zimpro and the City of Albuquerque. Please include the
final cost analysis in the final EIS.
Sincerely,
Evelyn Oden
Member
Citizen's Advisary Committee
cc Jay Sorens9n
Charles Varnell
-------
United States Department of the Inteij5&-|f (&)
NOV 23
ER 81/2170
OFFICE OF THE SECRETARY
Office of Environmental Project Review
Post Office Box 2088
ALBUQUERQUE, NEW MEXICO 87103
& A DIVIS
Responses to Comments from Raymond P. Churan
US Department of the Interior, Office of Environmental Project Review
t or the interior, urtlce or Environmental t
Albuquerque, New Mexico (19 November 1981)
1. Comment noted.
NOV 1 9 1931
Mr. Clinton B. Spotts
Regional EIS Coordinator
U.S. Environmental Protection Agency
1201 Bin Street
Dallas, Texas 75270
Dear Mr. Spotts:
This responds to your September 25, 1981, request for our evaluation and
comments on the Draft Supplement to the Final Environmental Impact State-
ment for Wastewater Treatment Facilities - Sludge Management System,
Albuquerque, New Mexico. The following conoent is provided for your
consideration:
We note that under all sludge management alternatives, there will
be an unavoidable increase in the nutrient load at the Isleta
diversion due to the nutrient level in the effluent. We realize
nutrient load in the effluent is a subject considered in the
Wastewater Treatment Facilities Final Environmental Impact State-
ment and is outside the scope of the supplement; however, we be-
lieve the effects on the Isleta diversion demonstrate the need
for nutrient removal at sewage treatment plants on the Rio
Grande.
We appreciate the opportunity to review this Draft Supplement.
Sincerely yours,
_Jtayoond P. Churan
Regional Environmental Officer
-------
KOV 23
S & A DIVISION
Bruce M. Thomson
600 La Veta NE
Albuquerque, NM 87108
Nov. 19, 1981
Responses to Comments from Dr. Bruce M. Thomson. P.E.
Albuquerque, New Mexico (18 November 1981)
1. Comment noted.
I
CT>
Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency (6ASAF)
1201 Elm Street
Dallas, TX 75270
Dear Mr. Spotts:
To reduce the potential for misunderstanding, 1 am
sending you my contents on the Supplemental Draft Environ-
mental Impact Statement on the Wastewater Treatment
Facilities-Sludge Management System, Albuquerque, NM.
This letter summarizes comments made by me at the Public
Hearing of November 18, 1981.
I first wish to commend the staff of the Water
Resources Department of the City of Albuquerque for con-
ducting an open and thorough public participation program.
Throughout the past 14 months they have shown tremendous
patience and willingness to work with both the Citizens
Advisory Committee and the general public. I am certain
that in reviewing the record, you will find that their
efforts have more than met the Federal requirements for
public participation.
I have reviewed in detail all of the major documents
associated with the proposed sludge management system
including the Facilities Plan (Balloon Report) and the
Supplemental Draft EIS (SDEIS). I believe that in making
a final process selection it should be recognized that
there is a clear mandate from all parties involved,
including the Citizens Advisory Committee, that the waste
sludge should continue to be used in a beneficial manner.
This is most evident in their near unanimous and emphatic
rejection of Dedicated Land Disposal and Land Filling
options discussed in the SDEIS. If this directive is
followed, and I believe it should be, some form of sludge
disinfection will be required under current regulations.
I am familiar with the two most reasonable disinfection
alternatives proposed, composting and irradiation. I have
visited the Sandia Irradiator for Dried Sewage Solids on
a number of occasions, and have in fact actually been inside
-------
I
O^
CO
it (with appropriate monitoring instrumentation I might add)
this past summer when one of the Cs-137 pins was removed for
testing. I believe that either alternative can provide
adequate disinfection if properly design and operated. In
light of my familiarity with the local constraints, and
assuming that the costs are equal, I believe that irradiation
is the most desireable alternative due to the following
factors:
a. ease and simplicity of operation of the irradiator,
b. thoroughness of disinfection is independent of
uncontrollable variables, although composting is
subject to 0 £ M errors, weather conditions, and
temperature variations within the pile,
c. it appears safer for the operators than composting
as it involves little heavy equipment and there is
reduced potential for airborne pathogenic diseases,
d. it does not destroy any of the nutritional value
of the sludge.
In reviewing the SIDSS program, and the proposed application
of this technology to the City's problems, I find it extremely
unlikely that employees of the Water Resources Department
will receive an annual radiation dose above background levels
that is statistically significant. The chances that the
general public would be exposed appears to be several orders
of magnitude less.
There are three areas that do not appear to be adequately
addressed in the SDEIS. The first is the discussion of the
trucking alternatives to the use of pipelines. There should
be quantitative discussion of the negative impacts of this
option to specifically include; the expected potential for
fatal and non-fatal accidents with an included cost to the
local community, and the effects of up to almost SO truck
trips per day on existin roads, again with cost analyses.
The existing raod system in the vicinity of Plant 2 is not,
in my opinion, suitable for this proposed alternative as
the projected traffic will be large trucks loaded to maximum
capacity. Recent findings have implicated this traffic in
excessive wear and destruction of roadways of all designs.
There will certainly be severe negative economic impacts
regardless of the final disposal alternative, and these
should be calculated rigorously.
The second area that I feel should be addressed is an
alternative to Montessa Park for sludge treatment. The
projected capital cost of the pipeline and pumping system
for this alternative is enormous ($1.2 million is the value
determined by Wilson § Co.) with total annualized costs of
$230,000. In addition to the obvious waste of energy and
resources, I have philosophical difficulties with the pump-
age of sludge six Biles to a second treatment facility when
Responses to Comments from Dr. Bruce M. Thomson, P.E. - Continued
2. An evaluation of the impacts of the trucking alternative is included in
the Land Use and Transportation section of the Draft SEIS (Section 6.8)
In Table 6-16. Since the wording used in Table 6-16 was not very
specific, it has been changed in the F-SEIS (Section 5.0). A more
detailed discussion of the impacts associated with trucking, including
the potential increase in accidents, was included on page 6-75 of the
Draft SEIS.
3. The City already owns more than 60 acres of usable property located
immediately north of the plant complex. A portion of this tract will be
used for the Phase II liquid treatment works and certain supporting
facilities, as is outlined in the site development plan in Chapter 1 in
the Balloon Report. However, the City has stated that constructing
sludge handling facilities (other than perhaps mechanical dewatering) at
the plant site is not a meaningful response to either the City's policy
commitment or the "Court Stipulations, mandating best practical technology
to minimize potential for nuisances in or near the plant. In addition,
the shallow water table (approximately 10 feet) at Plant No. 2 could
cause potential safety problems with constructing the irradiator, since
the main structure of the Irradiator will be built underground. A com-
plete site analysis prepared by the City is contained in Appendix E of
this Final SEIS.
-------
-3-
O
vo
undeveloped land is apparently available adjacent to the
plant. My objections to this alternative can be summarized
as:
a. the large capital expenses,
b. the large annual 0 6 M expenses which will
increase with energy cost rises,
c. the potential for failures which will
interrupt the sludge management system.
A more reasonable alternative would be to purchase land near
the existing plant along with additional land to serve as
a buffer zone and could be used for agriculture or park land.
I recognize that there are substantial political and econo-
mic problems associated with this proposal, not the least
of which is the perceived odor problem by nearby residents.
The concept, and associated problems should be addressed in
the SDEIS,.particularly in light of significantly improved
operations and consequent reduction of odors in the past
two years.
The SDEIS bases the comparison of alternatives pri-
marily on economic analyses with brief consideration given
to environmental and other consequences. I am firmly con-
vinced that a major selection criteria should be the ability
of the Water Resources Department to operate and maintain
the system finally selected. As noted above, 0 § M by the
city has substantially improved in recent years, however
there remain constraints which limit the degree of soph-
istication attainable. These include the wage and salary
structure and its effect on the ability to attract and
retain qualified personnel, as well as the available labor
pool. Many examples acrosss the country can be cited of
marvelous high technology treatment facilities with miserable
performance records due to improper operation by unquali-
fied personnel. The irradiation process, for example,
appears to be nearly fool-proof, while other systems con-
sidered require constant attention by skilled operators.
It is unquestionably difficult to quantify 0 $ M capabili-
ties, yet it is important that these potential limitations
be included. Specifically, I suggest that a column be added
to the appropriate matrices summarizing the alternatives
which refers to 0 $ M sophistication required.
I wish to conclude my comments by stating that I have
a fundamental disagreement with the sludge disinfection
requirements promulgated by the USEPA. The City of Albuquerque
and other citys throughout the nation have a long history
of successful application of stabilized sewage sludge on
municipal property with no solid epidemiological evidence
of health problems that I am aware of. I accept the find-
ings of pathogenic organisms in the sludge, however the
present regulations, in my opinion, fail to recognize the
additional disinfection which will occur during drying,
particularly in open-air drying beds, stockpiling, and
Responses to Comments from Dr. Bruce Thomson. P.E. - Concluded
4. Although EPA recognizes the validllty of this statement, the OtX cost
Indicated for each alternative Includes the labor cost that is reflective
of the sophistication of the processes Involved. During the design phase
of this facility an O&M manual which specifies the personnel and training
required Bust be developed by the City and is subject to EPA approval.
It Is noted however, that EPA has no enforcement authority to ensure that
this manual is followed.
5.
Comment noted.
-------
finally spreading on parklands. Furthermore, i believe
that the mode of infection postulated is unlikely. I
do not deny that there are potential hazards, but remain
skeptical that there is a serious problem, and I am con-
vinced that disinfection of sludge is not a cost-effective
solution to the problem.
Thank you for your attention. I look forward to
receiving a copy of the Final Environmental Impact
Statement.
Sincerely yours,
SIGNATURE PAGE. EPA RESPONSE NOT REQUIRED
Bruce M. Thomson, Ph.D., P.E.
Environmental Engineer
cc Water Resources Department
I
^j
O
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Federal Emergency Management Agency
Region VI
Federal Center
Denton, Texas 7620)
November 20, 1981
Cheryl A\» Hoke
Emergency Management Specialist
Natural & Technological Hazards
Division
Mr. Clinton B. Spotts
Regional EIS Coordinator
U.S. Environmental Protection
Agency (6ASAF) Q J? A P 'Uirin.,
101 Elm Street ; ^ & A L/lVlolQN
Dallas, Texas 75270 J .
Dear Mr. Spotts:
The following comments are in response to the Draft Supplemental Environ-
mental Impact Statement dated September 25, 1981, for a sludge management
system for Albuquerque, Bernalillo County, New Mexico.
1. Albuquerque and unincorporated Bernalillo County are partic-
ipating in the National Flood Insurance Program (NFIP), The
current effective flood map for Albuquerque is dated December
4, 1979, and for unincorporated Bernalillo County is dated
January 13, 1981. A recently completed flood insurance study
revising the current flood maps for the project will be avail-
able late in 1981 or early 1982. This preliminary information
should be evaluated for possible impacts on the proposed
project.
2. As mentioned in the DSEIS, portions of the project are within
the 100-year flood plain. For continued eligibility in the
NFIP, Albuquerque and Bernalillo County must ensure that all
.new construction within the 100-year flood plain be built in
compliance with their flood plain management ordinances. This
includes new and replacement sanitary sewerage systems which
must be designed to minimize or eliminate infiltration of
flood waters into the systems and discharges from the systems
into flood waters, and onsite waste disposal systems must be
located to avoid impairment to them or contamination from them
during flooding.
3. Executive Order 11988, Floodplain Management and E.O. 11990,
Protection of Wetlands, direct all federal agencies to avoid
to the extent possible the long and short term impacts associ-
ated with locating in the flood plains or wetlands and to
avoid direct and indirect support of flood plain or wetland
development.
We hope these comments are helpful. Please let us .know if we may be of
further assistance by writing or calling (817) 387-5811, extension 271.
Responses to Comments from Cheryl A, Hoke
Natural & Technological Hazards Division, Federal Emergency Management Agency
Denton, Texas (20 November 1981)
1. The latest available information from the Federal Emergency Management
Agency was used in the Draft SE1S. A copy of the flood insurance study
currently being conducted by the National Flood Insurance Program will
not be available to the public until the summer of 1983 (by phone, Diane
Leathervood, Federal Emergency Management Agency, 13 September 1982).
2. Comment noted.
3. Comment noted.
-------
(404) 262-6649
November 20, 1981
Responses to Comments from Dr. Frank S. Lisella
Environmental Health Services Division, Center for Environmental Health
Atlanta, Georgia (20 November 1981)
--J
NJ
KOM 23 WS1
$,& A DIVISION
Mr. Clinton B. Spotts
Regional EIS Coordinator
U.S. Environmental Protection
Agency (6ASAF)
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
We have reviewed the Draft Supplemental Environmental Impact Statement (EIS)
for the funding of the Step II and Step III Construction Grants for a Sludge
Management System, City of Albuquerque, New Mexico. We are responding on
behalf of the Public Health Service and are offering the following cosments
for your consideration In preparing the final document.
Vectors
It was indicated that excess sludge stockpiles could result in ''mosquitoes and
flies which could spread disease." We believe this issue should be better
clarified. Has this been a continuing problem with any existing excess sludge
stockpiles? The specific mosquito and fly species which have been found
breeding in sludge drying areas and stockpiles and which have the capability
of causing vector-borne disease problems should be identified in the EIS along
with any other public health problems that these vectors might create.
Sludge Quality
The EIS "should provide additional information on the general quality of sludge
generated by the wastewater treatment system and whether it does or could
contain chemical constituents that could be harmful to public health if used
on public lands and parks. Should gardening or wild-food gathering be
prohibited on those lands being benefited with sludge applications?
Sludge Disinfection
We believe the regulatory need for sludge disinfection prior to disposal on
parks and golf courses should be better clarified. According to the EIS, "new
Federal regulations (40 CFR, Part 257.3-6) governing the application of sludge
on land prohibit the continued practice of spreading sludge on parks or golf
courses without disinfection." However, examination of Part 257.3-6(a) and (b)
about disease prevention does not necessarily indicate that sludge applications
on parks or golf courses have to be disinfected.
2a
2b
1. The City currently has no problem with files and mosquitos, nor is EPA
aware of any docuraentable evidence of sludge stockpile vector problems in
New Mexico. However, since problems have occurred (although infre-
quently) elsewhere, it is mentioned in the SKIS.
2a. Testing was conducted on the sludge for metals and other priority pollu-
tants. The results of these tests indicate that the sludge in the samp-
ling described were within the standards published by the Water Quality
Control Commission. All this information supports the position that
sludges produced in Albuquerque conform to all applicable State and
Federal regulations for land application. EPA toxicity testing has also
been conducted and the sludge quality is well within published limits
(see Append!* D of this Final SEIS). It is important to note that
Albuquerque is implementing an industrial pre-treatment program which
will limit heavy metals and toxics in the sludge.
2b. The City only has plans to use sludge on turf grasses in the City parks.
There are no plans now or In the future to grow food crops on land con-
ditioned by the sludge.
3. 40 CFR Part 257 was written to control sludge application to cropland.
Currently, EPA Region 6 is handling sludge applied on non-cropland on a
case by case basis. At the onset of this SEIS, EPA determined that dis-
infection would be required for sludge application on parks for this
project.
-------
Page 2 - Mr. Clinton B. Spotts
Prior disinfection of sludge by ganna ray irradiation (Cesium 137) or other
"Process to Further Seduce Pathogens" (Part 257.3-6 Appendix H B) is required
only when the sludge is to be applied to land or incorporated into soil which
is used to produce crops for direct human consumption within 16 months follow-
ing application or Incorporation. Part 257.3-6(b)(3) states that "if crops
for direct human consumption are not grown within 18 Booths of application or
incorporation, the requirements of paragraphs (b)(l) and (2) of this section
apply." The (b)(O paragraph indicates that the application of any sludge
to land or to soil requires treatment by a "Process to Significantly Reduce
Pathogens." If grazing by animals whose products are used for human consumption
cannot be prevented for at least one month and/or if public access to specific
application areas cannot be controlled for at least 12 months, would treatment
by a "Process to Further Reduce Pathogens" then be required?
Considering the above, an alternative to irradiating sludge and allowing
immediate public access to an application area (aasuBing it meets the other
"Criteria for Classification of Solid Haste Disposal Facilities and Practices"
Part 257.3) would be to control public access. Could access to specific
application areas on the City's parks and golf courses be controlled for at
least a year? Please explain what EPA's legal definition is for controlling
public access. Would the application area have to be fenced or could it be
properly posted and restricted to prevent unsafe public use? The EIS should
indicate if the need to require at least 1 year of public access controls to
the City's application areas when such areas have become properly stabilized
and covered with vegetation is adequately supported by public health studies.
Would trenching or burial of sludge on such lands be feasible and/or environ-
mentally sound?
According to the EIS, sludge Is a valuable resource for the City of Albuquerque
for use on parks and golf courses. While we fully recognize and support the
current EPA regulations for disease prevention aa specifled by 40 CFR Fart
257.3-6, should EPA fund a sludge disinfection progrv so that the City can
continue to use sludge for parks and golf courses vhen other leas expensive
and environmentally sound alternatives exit? If the City wishes to use the
sludge for some special purpose, shouldn't they be responsible for any addi-
tional expenses associated with rendering the sludge suitable for that special
use?
Responses to Comments from Dr. Frank S. Llsella - Continued
4. EPA currently has not obtained a ruling or interpretation from legal
council on the definition of controlling public access. EPA Headquarters
staff have interpreted "controlled access" to mean: (1) using chain-link
fencing in metropolitan areas; and (2) using barbed-wire fencing in
remote, rural areas. Posting is not adequate in either case. The RCRA
was adopted by Congress based upon public health Information justifying
the need for such a law. EPA has not conducted further studies justi-
fying or negating the need for the law. Sludge produced in Albuquerque
would be applied to all parks annually, therefore controlling public
access for one year would result in the virtual exclusion of the public
from all Albuquerque parks. Trenching or burial of sludge in the parks
is not feasible; however, landfilllng (i.e., trenching or burial) Is
feasible and has been evaluated in the SEIS (Alternatives 2A and 2B).
5. The City has made several significant changes to their proposed project,
as described in Section 3.1 of this Final SEIS. The changes have sub-
stantially reduced the estimated cost of the City's proposed project. .4s
indicated in Section 4.3 of this Final SEIS, the City's proposed project
is now the most cost-effective, environmentally-sound alternative.
6. After evaluating all available information, EPA determined it appropriate
to allow a $70/ton credit for the use of sludge as a soil conditioner.
See Section 4.1 of the Final SEIS for further information. The credit
amount is not based upon the variability of quality and marketability of
Albuquerque's sludge. The $707 ton value is specific to the City of
Albuquerque project, and may change for other projects. The City will
pay $70/ton for other material, and in fact, currently pays $225/ton for
Mllogranite. EPA determined that it is appropriate to allow a credit for
sludge and exclude direct and Incorrect costs associated with processes
(i.e., trucking) outside of the immediate process train (i.e., alter-
nating) being evaluated.
Alternatives
Comparing the cost-effectiveness of optimal alternatives, tables were provided
ranking the alternatives with and without credit for utilization of sludge on
public lands. Does the credit amount given account for any differences in the
quality of sludge (presence of pathogens, heavy metals, etc.) and accessibility
to a marketing firm? Would the City of Albuquerque be willing to pay this
credit value of $70/ton if City sludge was unavailable or unsafe to use even
after disinfection? Since the "EIS does not Include an analysis of the costs
or environmental effects associated with sludge hatuMing or management by the
Parks Department" (page 5-32), is it appropriate to include credit benefits
for using sludge in the alternative analyses (Table 5-14) and exclude direct
and indirect costs associated with sludge management and adverse effects?
6
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Page 3 - Mr. Clinton B. Spotts
While we recognize that existing roadways were assumed to be used, please
explain why a shorter truck haul route was not selected to Rio Puerco. Was
any consideration given to the uae of the Rio Bravo Bridge and the same route
used for the pipeline to Rio Puerco? From Figure 5-2, it appears that the
difference between the length of unimproved road to be used In the "Truck
Route to Rio Puerco" and the length of unimproved road that could be used
along the "Pipeline to Rio Puerco" is minor.
We appreciate the opportunity to review this Draft EIS. Please send us one
copy of the final document when it becomes available. Should you have any
questions about our comments above, please call Robert Kay of my staff or
me at FTS 236-6649.
Sincerely yours, \
Responses to comments from Dr. Frank S. Lisella - Concluded
7, According to the City, there is no shorter truck route to Rio Puerco
without necessitating the construction of new roads. The pipeline route
to Rio Puerco crosses open lands and does not follow established road-
ways, therefore this route is not feasible "for trucks. The City selected
the most feasible and costeffective routes available for evaluation.
t_
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
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CITIZENS AGAINST NUCLEAR THREATS
--J
Ln
1O6 GIRARD SE ROOM 121 C
ALBUQUERQUE. NEW MEXICO B7KD6
BOB) 26B-S557 f£C 7
Deceaber3, 1901
A DIVISION
Consents on Environmental Impact Statenent, ?acilities-31ud~e
7'.ana~eaent Sjisten, Albuquerque, II.::. °
Although the 313 recommends the sludge irradiate" i-1- does
not sake a clear and overriding case for the i-ra^iato^. Ilaterial
is presented in a va-^e cad biased manner and all of it is
based on information from city of t icials -and citv an-^oved
consultants who all favor the irradiator. " ""
Ilajor areas dealt with inadequately are:
lie aw metals and che:.-iic°ls
These are an important danger to life but the irrr.iiator would
not ax.-eet these elenents. The EIS tries to show- these n--e not
a ?ro3lea in Albuquerque. But fibres are not renent and" based
on en.renely scanty sampling. To address this area adequately.
tho document ahould tell us v.-hat industries are D-oducin-
heavy netals and chemicals in waste, what pretreatmer.t is --iven
their was-ce now, and in wh-t way their treatment is nonito-ed
j-or adequacy now and will be monitored in the future.
:To up to date _ information is given as to results of tests for
£»* £*+ chenicals run on secondary digesters or dry sludge
beds, ./hat protection does the public have froa these elements
re* tins into ground water or food chain?
Co~p,-.rgtive Costa
stp-i« of the irradiator is to render the slud-e
sterile. o. pa-ho^ens, then it would seem that this could be
.Achieved ct far less cost, as admitted by the EIS, by other
odor problems would be the sane. In the case of the wet air
oxidation Process, the use ex? polymers, an oil urodutt, would
be eliminated. 2he EIS does not indicate the cost of these
polders. And the fact that coapostins would ber 1/3 to 1/2 less
expensive is also not reflected in the charts.
finally, we find no overwhelnin/; case for the potential hazards
o- ,,,-ie use of millions of curies of Cesiuc 137 simply to
s.-ri_ize sludge, with its accorr.pimyiii- complications of a
5 nile pipeline an^. va^.ely described aolar drvin- facilities.
On the contrary, it appears nainly to be a contrived justification
for fie use of an isotope by-product-of the production of
plutoniua for use in nuclear weapons.
Dorelen :\iatin-
Responses to Comments from Dorelen Bunting
Citizens Against Nuclear Threats
Albuquerque, Hew Mexico (3 December 1981)
1. The Draft SEIS did not recommend any alternative or component (e.g.,
Cs-137 irradiator); however, this Final SEIS does indicate which alter-
native EPA proposes to fund.
2. The Albuquerque Industrial Fretreatment Program Development manual sub-
mitted to EPA on 29 June 1981 summarizes testing of the sludge for metals
and other priority pollutant compounds. The data indicate that the
sludges in the sampling described were within the standards published by
the Water Quality Control Commission. This data Is also consistent with
earlier test work on sludge quality, summarized In Appendix C of the
Balloon Report. All this information supports the position that sludges
produced in Albuquerque conform to all applicable State and Federal regu-
lations for land application. EPA toxlclty testing has also been
conducted and the Albuquerque sludge is well within the limits specified
by regulations (see Appendix D). Albuquerque currently Is implementing
an industrial pretreatnent program which was approved by EPA. The
details of this pretreatment program are not within the scope of this
SEIS which is limited to sludge management systems.
3. Cost for conditioning polymers was included in miscellaneous cost for all
appropriate altneratives. The complete costs. Including O&M and capital
cost, for all alternatives were presented in Table 5-13 and 5-14 of the
Draft SEIS. Alternatives IE and IF Include composting. A revised cost-
effectiveness analysis Is presented in Section 3.4 of this Final EIS. It
is noted that the composting alternatives range from 3Z less expensive to
28Z more expensive than the City's proposed project, and not 33Z-SOZ less
expensive.
4. Comment noted.
Thl» i* 100% recycled p»(Mr.
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Cily of ' Ubu(juei'
P.O.BOX 1293 ALBUQUERQUE. NtWMtXICO 87101
MAYOR
arry- E. Kinf
CHIEF
CHIEF
ADMINISTRATIVE OFFICER
Frank A. Kle.nlieni
Dscember 8, 1981
/ffi r= n P" i
ir ? !| !',/ ;cf7T
^ ' Li u Jj [T j ! I
TKANSMITTAI. LETTER. EPA RESPONSE SOT REQUIRED.
Mr. Clinton B- Spotts
Regional £IS Coordinator
USEPA Reg i or. VI
1201 Elra Street
Dallas, TX 75270
Dear Mr. Spotts:
Enclosed please rind comments from Ms. Eileen Grevey Clifford, Chair-
man of the Water Resources Citizen's Advisory Board, regarding the
Draft SE1S document.
Sincerely,
Paul D. Noland, Director
Water Resources Department
PDN:smn
Enc.
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''."^tcr Resources CitJ2en's Advisory Etiard
December, 7, 1981
Responses to Comments from MB. Eileen Gravey Clifford
Chairman, Water Resources Citizen's Advisory Board
Albuquerque, New Mexico (7 December 1981)
1.
Cement noted.
Kr. Paul D. l\oland-, Director
Wattr Resources Department
City of Albuquerque
P.O. Box 1293
Albuquerque, NM 87103
Dtar Mr. Noland:
Thank you for providing relevant information to this committee regarding
Albuquerque's Sewage Sludge Treatment and disposal alternatives including
the City's preferred alternative.
On evaluating the technical and other information provided by the Water
Resources Department, this committee concurs that sevage sludge must be
treated adequately so that it can be utilized as a soil conditioner/
fertilizer on public and private land. The committee feels that re-
cycling sludge as a valuable resource, in addition to solving a sludge
disposal problem, will accomplish monitary savings for the City through
its use on City parks as a soil nutrient.
Realizing some of the inherent safety considerations involved in the
beneficial use of sludge and associated liabilities of the City, the
committee prefers an alternative which can reliably and consistently
render sludge safe for public use.
The technical information provided to this committee on the City's
preferred alternative involving pipeline transport of anaerobically
digested sludge to Montesa Park for dewatering and disinfection via
Canjna-Ray Irradiation before disposal as soil conditioner/fertilizer vas
evaluated by the committee. The following represents a consensus of
the members on this matter.
1. The proposed alternative is consistent with the committee's
view regarding benefitial utilization of sludge. The alter-
native appears to be compatible with today's need for energy
conservation.
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1, The application of 5 rra ri a t ICT pr _ :c-ss in a ec-r. sitive field
such as r^-dicin:- and ctr^r c. r,;-:ur;fcr prpd.icts v.OT°ld =7pcdr
to indicate its reliability in insuring the safety aspects
of benefiting sludge use.
3. The committee recommends that safety aspects in the handling
and use of Cesium-137isotope be carefully evaluated and
appropriate measures taken during design and construction to
insure public health and safety-
Once again, we appreciate the opportunity provided to this committee
for commenting on the City's Sevage Sludge disposal planning. If you
have any questions regarding this letter, we could discuss it during the
next monthly committee meeting.
Sincerely yours,
2
3
Responses to Comments from Ma. Eileen Grayey Clifford - Concluded
2. Comment noted*
3. The safe handling and use of Cs-137 is of prime importance to EPA as
indicated in Section 6.4.3, Section 6.11.3, and Section 10.2 of the Draft
SEIS. The licensing process for operation of the irradiator, which will
be handled by the New Mexico Environmental Improvement Division, will
further assure the safe handling and use of Cs-137.
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Ms Eileen Grevey Clifford, Chairman
Water Resources Citizen's Advisory Board
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Mr. Clinton E. Spotts
Regional E.I.S. Coordinator
U.S.E.P.A.
1301 Elm Street
Dallas, TX 75270
Dear Mr. Spotts:
2800 Charleston, N.E.
Albuquerque, N.M.
December 9, ""fa ,!?/B fi? |]
DIVISION
Re: E.F.A. 906/9-81-003 Draft S.E.I.S.
Albuquerque Sludge Management
System
TRANSMITTAL LETTER. EPA RESPONSE NOT REQUIRED.
The purpose of this letter Is to clarify the position of the Citizens'
Advisory Connittee regarding review and comment on the subject draft. On
November 17, 1981, the C.A.C. members, Mr. Jay Sorenson, Mr. Janes
Wiegman, Mr. Fred Seeblnger, Mr. Gene Martinez, Mr. Stan Read, Mr. Walt
Webster, and Ms. Evelyn Oden. The individual comments of Ms..Rosa Grado
are also included.
The comments Mr. Khera made on November 11, and which he submitted
separately in rebuttal to Mr. Caudill's comments, are not the position of
the Citizens' Advisory Connittee. I hope that I have cleared up any
misunderstanding the E.P.A. may have had regarding the C.A.C. position on
this matter.
Please advise if you have any further concerns.
Sincerely,
JBS/LTC/bb
Jay E./Sorenson, Chairman
Citizens' Advisory Conroittee
cc: A.K. Khera, Water Resources Dept.
C.A.C. Members
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COMJJ.'lb UAH b.L.l.t.
ALbLjQbERQUE SLUDGL MANAGEMENT SYSlUi
,,Ul 1
l-i tjd
Alternate sites which 1 believe shoulc be considered iuciuat LtiJte land
lying immediately east oi 1-25 and north ot the Karler Packii:y Plant
aiio private lanu lying NU oi the curve oi 1-25 where it turrit. IIOLJ N-S
to L-V< just beiore crossing the Kio Grande. A poultry larm occupies
the latter site iit present.
Gene Martinez:
Since the nitrate contamination oi groundwater at Mcuntsin View is of
unknown origin Pnd therefore cannot be separated from the sluogt
disposal problem the nitrate problem should biave been more full)
addressed in the Draft S.E.I.S. Alternate approaches/solutions to this
[cost serious problem should have been included in the Lraft S.E-l.S.
Stan Kead:
The Drait S.E.I.S. is deficient in its consideration of alternate sites
for sludge handling facilities, whether federally controlled, state
owned or controlled, or inprivate ownership. Although the need for
consideration of alternate sites was raised by the C.A.C. six nonths
ago, no alternatives to t-ior.tesa Park Were considered. Possible
alternate sites include lands at Kirtland Air Force Ease, other federal
lanas, trust lanes ot the University of New hexico, other state lands
south oi Tijera.= Arroyo, range lands of the Isleta Pueblo, and private
Isnas of M-l or K-2 (manufacturing) zoning in the County and away from
oost areas of human liabitation.
RESPONSES TO COMMENT'S FROM FRED SEEBINGER, GENE MARTINEZ, STAN READ,
HALT WEBSTER, AND ROSA GEADO, CITIZEN'S ADVISORY COMMITTEE MEMBERS
ALBUQUERQUE, NEW MEXICO (9 DECEMBER 1981)
1. Alternative sites evaluated by the City are included in Appendix E.
2. The Draft SEIS documents the existence of nitrate contamination of
groundwater in the Mountain View community; however, determining
solutions to this existing problem are out-of-scope for this SEIS.
3. Alternative sites evaluated by the City are included in Appendijt E.
4. Since issuance of the Draft SEIS the City has revised their proposed
project to include totally enclosed facilities. Costs for this alter-
ation have been included in Section 3.4 of the Final SEIS. Open storage
and open air drying have been deleted from further consideration as it
was found to be not environmentally sound.
5.
This suggestion merits consideration; however, establishment of such a
committee would best be handled on a local level (city/county) .
I
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Walt Webster:
Tht Dralt S.E.I.S. does not adequately address or consider as an
alternative, if in fact sludge handling facilites are to be located at
tontesa Park; the use of totally enclosed facilities there (including
cost estimates); and the use of no open storage or no open air drying.
The Draft S.E.I.S. does not adequately address or consider as an
alternative the use of an oversight committee, consisting oi
representatives oi Kirtland A.F.B., IWi, and F-A.A. ior purposes oi
Design review and observation of a one year operating period if Montesa
Park is utilized as a site for sludge handling facilities.
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Kosu (Jrfaou:
I
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1. 'Hit S.t.l.^. luiii n^ide L,O mention ui q>eciiic conn.uijLi. IMU.C by
City ii Courity residents objectin;. to a iiicility utilizing
rnuiuictivi- nateri&l in :,luclj'C- ti e:bi as
being incomplete, confusing and uiidocumLntsble: One rei'fon for
tliis concern ij> die "Notice" dial appeals inside tbc Inn-.t cover oi
die tkiiiuia Uib ana tatelle documents reviewed diat ciiscl;'ii;.s any
liability for die completeness, accuracy etc. oi the inlorrcation
proviaeci and the use tlieicoi. A ^fcond reuscxi it tliiit ii- irradator
oi die size proposed utilizing Cesuim has never betn done before
except as described by Sandia from their pilot irr&diator -
citizens object to having their city used as a basis tor diis
experiment. A diird reason is that admittedly (SL Lpcktfman) die
trucks carrying Cesium will be emitting radiation and unknowingly,
persons alongside these vehicles will be exposed. Related is
elgibility addressing public and worker healtii and safety and
.possible radiation - induced healdi effects.
3. The S.E.l.S. also does not address at all psychological eflects on
citizens from the use of a radioactive material in an adnittedly
experimental facility. Citizens, mothers, potential mothers, young
people have expressed to this committee objections to such a
facility using radioactive material and otter feelings that can be
deiiiied as a psychological perspective of a negative nature.
U. I want die S.E.l.S. to completely deiine "Background Radiation",
and to address die discrepancy between their stated level and diat
of die consultant (Kowal). Background Radiation before atmospheric
testing.before uranium mining and milling has been aiiected greatly
towards increased radiation in die atmosphere and water in New
texico.
5. Address die issue tttat irradiated sludge had been proposed to be
used as a feed supplement for livestock and that we have no
guarantee it won't be used as such.
6. I am very concerned that all viable alternatives have net be
explored specifically using die sludge to leise fuel crops.
6
8
9
10
11
Responses to Comments from Citizen's Advisory Committee Members - Concluded
6. Public comments on the Draft SEIS are included in the Final SEIS.
7. See EPA's response to Question No. 6.
8. Psychological effects, both positive and negative, of all the alter-
natives is out-of-scope for the SEIS. Public comments and concerns are
documented in Chapter 6.0 of the Final SEIS.
9. Background radiation Is the naturally occurring radiation In the environ-
ment due to cosmic rays, external terrestrial radiation, and internal
terrestrial radiation. Dr. J.C. Robertson stated the background radia-
tion In Albuquerque was between 250 and 350 mlllirems per year (Mem/
year). Sandla National Laboratories found the background radiation of
Albuquerque to be 200 mrem/year. This difference is not significant and
is attributable to the location of the test. For example, if the test
was conducted In an area surrounded by concrete, the radiation level
would be higher than if the test was conducted in an open area. This
discrepancy would be caused by the radioactive content of the concrete.
10. According to DOE, it is Illegal under Food and Drug Administration
regulations to feed human sewage solids to cattle to be slaughtered for
human consumption. This procedure can only be done for experlnental
purposes. The City's Facilities Plan Amendment has no provision for
utilization of sludge as a feed supplement.
11. See EPA's response to Comment 9d In Section 6.4.
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9 December 1981
Supplemental Draft Environmental Impact Statement, Wastewater TreainiSik. Facilities j
Sludge Management System, Albuquerque, New Mexico UU \
Mr. Clinton 8. Spotts, Regional EIS Coordinator
U.S. Environmental Protection Agency Region VI
1201 Elm Street
Dallas, Texas 75270
DEC 10 "
O P ft niwiomiu
O & M UlvlolUN
1. We thank you for the opportunity to review and comment on the subject docu-
ment. Following are technical comments for specific referenced paragraphs:
a. Paragraphs 1.2, 4.2, 5.5.5, and others discussed open-air drying of
sludge. The alternatives which include open-air drying of sludge do not con-
sider the possibility of creating an acceptable habitat for breeding of insects.
Biodegradable material available in the sludge, coupled with sufficient moisture
(35 to 45 percent solids) and warm temperatures would appear to be a likely
breeding .place for a sufficient number of insects to attract birds. Birds in
close proximity to the airport environment pose an unnecessarily high potential
for bird/aircraft strikes. The question of sludge creating a habitat for insects
at any time of the year should be considered and addressed to a professional
entomologist.
b. Paragraph 1.3 discusses the "no action alternative" of continuing to
use drying beds and sludge lagoons. The objection to the alternative was
discussed in our 1980 BASH report for Kirtland AFB, New Mexico. The main
attraction would be that of waterfowl and other birds to the presence of a water
source in an arid environment.
c. Paragraph 1.2, 1.3, 4.2, 5.5, 5.5.4, and others discuss landfilling of
sludge. Landfill guidelines which should be considered with relation to the
attraction of birds are found in the Code of Federal Regulations, Title 40, Part
257.3-8, which states, "a facility or practice disposing of putrescrible wastes
(solid waste which contains organic matter capable of being decomposed by micro-
organisms and such a character and proportion as to be capable of attracting or
providing food for birds) that may attract birds and which occurs within 10,000
feet of any airport runway used by turbojet aircraft ... shall not pose a bird
hazard (increase in the likelihood of bird/aircraft collision that may cause
damage to the aircraft or injury to its occupants) to aircraft." The proper
question which should be addressed by a professional is whether or not the
sludge placed in a landfill could, at any time of the year, attract birds. If
that possibility exists, then landfilling operations as proposed in the draft
supplemental EIS would be in opposition to the guidelines set forth by the
Federal Aviation Administration (FAA) and the Environmental Protection Agency
(EPA).
3.
RESPONSE TO COMMENTS FROM JOE C. LA FOY, JR.
DEPARTMENT OF THE AIR FORCE
DALLAS, TEXAS (9 December 1981)
The attraction of birds due to open air drying or composting was men-
tioned on page 6-75 of the Draft SEIS. Since the concept of open air
drying currently has been dropped from consideration as being environ-
mentally unacceptable (as explained in Section 4.2 of the Final SEIS),
additional information regarding insect habitat potential is unnecessary.
For this project, the "no action alternative" was addressed per EPA
requirements, but was not considered aa a viable alternative. The Bird
Aircraft Strike Hazard (BASH) report prepared by the US Air Force
expressed concern about the attraction of birds to lagoons at Montesa
Park. Although the City did at one time propose using sludge lagoons as
an interim measure, none of the alternatives for ultimate treatment and
disposal of sludge aa evaluated in the Draft SEIS proposed the use of
lagoons at Montesa Park. At CAC Meeting 17, a member of the Air Force
BASH team expressed concern about the attraction of birds to open air
drying beds. Since issuance of the Draft SEIS, the City has made certain
changes vhich include: (1) deleting open air drying from consideration;
and (2) enclosing all stockpiles. These changes should alleviate
concerns over the attraction of birds to the proposed sludge handling
facilities.
The landfill site evaluated in the Draft SEIS Is approximately 11 miles
(over 60,000 ft) from the Albuquerque Airport, and thus not in conflict
with 40 CFR 257.3-8.
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d. Table 3-1 does not reference two important documents concerning solid
waste disposal facilities and bird/aircraft strikes: (1) Classifying Solid Waste
Disposal Facilities, a Guidance Manual SW-828, March 1980 EPA; (Z) FAA Guidance
Concerning Sanitary Landfills On or Near Airports, 5200.5, 16 October 1974.
Both of these documents discuss in detail the concerns the FAA and EPA have for
facilities or practices which could cause an increase in the potential of BASH
problems.
2. We ask that our comments and concerns be addressed in the final EIS. Should
you have any questions or concerns, our staff point of contact is Mr. Ed Lopez,
(214) 767-2514.
N4*t£ ~ / ,,
JOE C. LA FOY, JR. At Co/pnel, USAF
/thief, Environmental Planning Division
Response to comments from Joe C. La Foy, Jr. - Concluded
4. Table 3-1 on page 3-5 of the Draft SEIS lists Federal regulations and
legislation In lieu of Federal guidelines. However, the comment Is valid
and these Important documents have been added to Chapter 7.0 -
Bibliography in this Final SEIS.
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M -- '')
"t;^ DEPARTMENT OF TH£ AIR
~ ['EC 1 * "HEADQUARTERS ISOCTH - .- )> ..IM_ ^--ACI
v-'V7x^o ^ADIVISJON N""""F°R^t'" '^";^:rL7"' looEc
' DEEV (Ms. Hoe, 4-0950)
' Supplemental Draft Environmental Impact Statement, Wastewater Treatment
Facilities, Sludge Management System, Albuquerque, New Mexico
;' USEPA
Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
Subject document has been reviewed for technical aspects and environmental
impact. Following are technical comments for specific referenced paragraphs:
1. Item 5.2, page 5-8. No action alternative, "Sludge not dried on drying
beds would be stored in lagoons." It is not specifically stated whether the
lagoons would be at Plant 2.
2. Table 5-7. page 5-12. Does not include FAA airfield criteria and
zoning appropriate for airfield environs.
3. Item 5.5.5, Secondary Drying, page 5-28. Bird attraction to insects
breeding in the open air drying process of sludge is not addressed.
4. Composting, Table 6-7, page 6-43. No distance estimates are included
in this section indicating areas which may be affected by significant odor that
could be generated from the sludge.
5. Page 6-73. The first paragraph under "Specific Disposal Sites" refers
to Sandia Military Reservation which no longer exists. The Sandia Military
Reservation merged in 1971 with what is now Kirtland Air Force Base.
6. Page 6-75. The paragraph referring to possible bird strike hazards is
not substantiated by the Bird/Aircraft Strike Hazard Report.
7. Paragraph 6.11.3, page 6-92 and page 6-97. Refer to composting and
stockpiling as attracting mosquitoes and flies. These insects would attract
birds also, but bird attraction is not further addressed.
8. Paragraph 6.12.3, Environmental Consequences of the Action Alternative,
page 6-101. There is no mention of possible bird/aircraft strike hazard.
6.
RESPONSE TO COMMENTS FROM HERBERT C. BOHANNON, JR.
DEPARTMENT OF THE AIR FORCE
ALBUQUERQUE. NEW MEXICO (10 December 1981)
1. The lagoons would be constructed at Plant No. 2B on City property.
However, EPA does not consider "no action" as a viable alternative for
the subject project.
2. Transportation criteria and zoning criteria were considered in Section
6.8 of the Draft SEIS. Pertinent FAA guidelines have been added to
Chapter 7.0 - Bibliography of this Final SEIS.
3. This section simply describes the process, and does not evaluate Che
effects. Bird attraction to open air drying and composting is addressed
in Section 6.8 of the Draft SEIS,
4. Table 6-7 on page 6-43 lists effects that potentially can occur due to
the utilization of various processes. Table 6-9 indicates the signif-
icance of effects actually expected to occur for various alternatives for
the proposed sludge management system. As stated on page 6-49 of the
Draft SEIS, distances can not be given because the odors are dependant
upon the proper functioning of the plant, wind speed and direction, topo-
graphy in the same direction, and atmospheric dispersion at the tiise
odors are occurring.
5. Page 6-73 of the Draft SEIS has been changed to reflect this cc:s>Bent.
See Chapter 5.0 of this Final SEIS.
The report does not appear to document problems associated with conr-
posting facilities. The Bird Aircraft Strike Hazard (BASH) report
prepared by the US Air Force expressed concern about the attraction of
birds to lagoons at Montesa Park. Although the City did at one time
propose using sludge lagoons as an interim measure, none of the alter-
natives for ultimate treatment and disposal of sludge as evaluated in the
Draft SEIS proposed the use of lagoons at Montesa Park. At CAC Meeting
17, a member of the Air Force BASH team expressed concern about the
attraction of birds to open air drying beds. Since issuance of the Draft
SEIS, the City has made certain changes which include: (1) deleting open
air drying from consideration as being not environmentally sound; and (2)
enclosing all stockpiles. These changes should alleviate concerns over
the attraction of birds to the proposed sludge handling facilities.
Pages 6-92 and 6-97 address health effects. Bird attraction is not a
health effect. Bird attraction was addressed under Transportation on
page 6-75 of the Draft SEIS.
8.
Page 6-101 addresses recreation and aesthetics, not transportation.
EPA's response to Comment 7.
See
GLOBA L
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9. B.U Bibliography, page 8-1. The Bird/Aircraft Strike Hazard Report,
June 1980, is not included in the bibliography. This report was prepared in
July 1980 and given to the City of Albuquerque Water Resources Department.
10. The Air Force continues to be concerned with, and opposes any open air
processing, to include drying beds, wet drying beds and any other such system
:onfigurat1on having the potential to attract insects, birds, or cause odor.
9
10
HERBERT C. BOHANNON, JR.
:h, Engrg, Construction A Envmtl Ping Br
Response to comments from Herbert C. Bohannon, Jr. - Concluded
9. This report was not made available to EPA prior to issuance of the Draft
SEIS. The BASH report is referenced in Chapter 7.0 - Bibliography of the
Final SEIS.
10. Open air drying and open stockpiles have been determined environmentally
unsound, and are not included in the Clty'y currently proposed project.
CO
Ln
-------
of*
P.O. BOv 12P3 ALSuOVit RGUL. NLW MtXICO B710.J
CHIEF
ADMINISTRATIVE OFFICER
Frank A. Kie.nfifcnr
DEC 14 '531
& A DIVISION
Responses to Comments from Vern C. Kagen
City of Albuquerque
Albuquerque, New Mexico (11 December 1981)
1. The City has responded to this comment through a letter from Mr. Frank A.
Kleinhenz, Chief Administrative Officer. A copy of this letter is
included in Appendix A of the Final SEIS.
December 11, 1981
I
00
Clinton Spotts, Region IV EIS Coordinator
U.S. Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
Dear Mr. Spotts:
This letter concerns the Draft Supplemental Environmental Impact
Statement (SEIS) on the proposed Sludge Treatment Management System for
Albuquerque.
Your attention is directed toward the following deficiencies in the Draft
Supplement relative to the National Environmental Policy Act, Section
1506.2(d) (possiole conflicts between the proposed action and the
objectives of state and local land use plans, policies and control for
the area); Section 1502.14 (alternatives).
Section 1506.2(d) The proposal analyzed by the Draft SEIS is not in
compliance with tne Albuquerque/Bernalillo County Comprehensive Plan:
The proposalanalyzed bythe draftisbasedupona report(Cityof
Albuquerque, New Mexico, Southside Wastewater Reclamation Plant Number
Two - Phase II Expansion Report) which is described on Draft pages 1-2
as an official facilities plan amendment. The following four issues are
not adequately considered relative to the Comprehensive Plan.
The Draft SEIS does not accurately described the official relationship of
this report. The above referenced SEIS Plan element amendment (Phase II
Expansion Report) has no official relationship to the City/County
Comprehensive Plan. The Phase II Expansion Report has not been locally
adopted as an amendment of the Area-Wide Wastewater Collection and
Treatment Facilities Plan, an element of the Comprehensive Plan.
Amendment of any of the six elements of the Comprehensive Plan requires
approval of the County and City Planning Commissions after public
hearings, and adoption, after further public hearings, by the City
Council and the Board of County Commissioners.
The Draft pages 1-2 also does not accurately describe the official status
of the "principal planning document for wastewater collection and
treatment for the City of Albuquerque and several outlying areas."
-------
Clinton Spotts
Page 2
December 11, 1981
00
The document, correctly identified in the Draft as the Albuquerque
Area-Wide Wastewater Collection and Treatment Facilities Plan was adopted
in May, 1977, by both the City and the County as the fifth of six
elements of the City/County Comprehensive Plan. It is not, therefore, a
free-standing facilities plan.
The proposed project, analyzed by the Draft SEIS, has no official
relationship to the City/County Comprehensive Plan. Section 3-19-11,
W4SA, 1978, requires Planning Commission consideration of the conformance
of specific public works projects to the adopted municipal master plan:
"3-19-11. Legal Status of Master Plan.
A. After a master plan or any part thereof has been approved,
and within the area of the master plan or any part thereof
so approved, the approval of the Planning Commission is
necessary.to construct, authorize, accept, widen, narrow,
remove, extend, relocate, vacate, abandon, acquire or
change the use of any:
(1) park, street or other public way, ground, place or
space;
(2) public building or structure; or
(3) utility, whether publicly or privately owned."
Section 1502.14. The proposal analyzed by the Draft Supplement does not
adequately consider alternative methods of sludge treatment, alternative
sites, nor fully disclose environmental consequences.
The Draft Supplement does not acknowledge that the proposed project is to
be located in an area designated by another City/County Comprehensive
Plan element (Plan for Major Open Space) as public open space "to be used
for passive recreation, maintenance of scenic areas, preservation of
essential resources and other environmental purposes."
These comments are substantive in nature and, therefore, deserve
incorporation in the review record of the Draft; further, these comments
deserve a response from the Agency in the final SEIS as described in
Section 1502.9(b).
Sincerely,
Vern C. Hagen
Associate Director/Planning
VCH:amc
cc: Barbara Stephenson, Legal Department
Carl Rodolph, Municipal Development Department
Larry Caudill, Municipal Development Department
Paul Noland, Water Resources Department
Responses to Comments from Vern C. Hagen - Concluded
2. One new alternative (including thermal conditioning under the disinfec-
tion component) has been Included in the Final SGIS. An analysis of
alternative sites which were considered by the City is presented in
Appendix E of the Final SEIS. The environmental consequences have been
re-evaluated based on data and mitigative measures that recently have
been provided by the City, and are included in Secion 3.2 of the Final
SEIS.
3. The text in the Draft SEIS has been changed. The steps the City will
take to rectify this inconsistency with the Comprehensive Plan are
included in Section 3.1 of the Final SEIS.
-------
STAN READ
(BOD) B42.6O6O
62O ROMA N. W
ALBUQUERQUE. IV M B71O2
December 14, 1981
re
IE, i
DEC 17 ic'<"
S & A DIVISION
Clinton B. Spotts, Regional EIS Coordinator
US Environmental Protection Agency (6ASAF)
1201 Elm St.
Dallas, TX 75270
Attn: Darlene Owsley
Re: DEIS, Albuquerque, NM Sludge Management
System and Public Participation Process
Dear Mr. Spotts:
This letter presents the most fundemental insufficiencies
in the DEIS for this project for inclusion in the comments on
the DEIS and consideration in the Final EIS.
Additionally, the comments of the CAC are included herein
by reference except as they may conflict with the insufficien-
cies specifically cited in this letter.
The DEIS is not sufficient in the following:
1. the DEIS does not contain and the CAC and the public
have never received a design plan, specific in detail, of
the City's preferred alternative;
2. the DEIS does not consider adequately alternative
siting for any disinfection alternative;
3. the DEIS does not include the independent appraisal or
cost analysis of the systems included in the DEIS as
supplied to the EPA and the City in mid-November, 1981;
4. the DEIS does not include an adequate mitigation and
safety analysis of the options or sites;
5. the DEIS does not include a sufficient treatment of the
alternatives to the City's preferred alternative, specifi-
cally electron-beam irradiation and thermal conditioning;
6. the DEIS does not provide documentation of the value of
sludge for land application.
Furthermore, concerning the Public Participation process and
the role of the CAC, I believe that the EPA (Dallas) and the
City were seriously remiss in failing to provide the CAC and
the public with two reports from Priede-Sedgwick before the
December 9, 1981, meeting of the CAC, especially the Priede-
Sedgwick independent evaluation of October 14, 1981. They should
be included in the Final EIS.
Read
RESPONSE TO COMMENTS FROM STAN READ
MEMBER, CITIZEN ADVISORY COMMITTEE
ALBUQUERQUE, NEW MEXICO (14 December 1981)
1. A somewhat more detailed description of the City's currently proposed
project Is given In Section 3.1 of this Final SEIS. Specific design
plans will be developed and approved by EPA prior to issuance of a con-
struction grant.
2. A new analysis of alternative sites, prepared by the City, is included in
Appendix E of this Final SEIS.
3. The Draft SEIS was issued in September 1981. Additional analyses con-
ducted by Priede Sedgwick, Inc. are contained in the public information
depositories established for this project.
4. Mitigation measures included in the City's currently proposed project are
described in Section 3.1 of this Final SEIS. A site analysis is included
in Appendix E.
5. Electron-beam irradiation is explained thoroughly in Appendix 10.3 of the
Draft SEIS. Thermal conditioning is described in Section 3.3 of this
Final SEIS.
6. EPA determinations regarding sludge value are explained in Section 4.1 of
this Final SEIS.
7. EPA provided the reports to the City upon receipt. Both Priede Sedgvlclt
reports are now contained in the public information depositories estab-
lished for this project.
-------
6.6 MAILING LIST FOR FINAL SEIS
Listed in Table 6.3 on the following page are government offices and
public interest groups which will receive a copy of the Final Supplemental
EIS. In addition, members of the Citizen's Advisory Committee and individ-
uals who made oral and/ or written comments on the Draft SEIS will receive a
copy of the final document.
6-89
-------
Table 6-3. Mailing list for the Final SEIS on the proposed City of
Albuquerque sludge management system.
Federal Agencies
Advisory Council on Historic Preservation
Federal Emergency Management Agency
Kirtland AFB
Representative Manuel Lujan
Senator Harrison J. Schmitt
Senator Pete Dominica
US Department of Housing and Urban Development
USDA Soil Conservation Service
US Department of Energy
US Department of Health and Human Services
US Department of Interior (USDOI)
USDOI Fish and Wildlife Service
US Department of Transportation Federal Aviation Administration
State Agencies
Environmental Improvement Division
Office of the Governor
Representative Kiki Saavedra
State Engineers Office
State Historic Preservation Officer
State Planning Office
Public Interest Groups
Citizen Against Nuclear Threat
League of Women Voters
New Mexico Citizens for Clean Air and Water
Sierra Club
Southwest Research and Information Center
Southwest Valley Area Council
6-90
-------
CHAPTER 7
BIBLIOGRAPHY
-------
7.0 BIBLIOGRAPHY
Presented below is the list of references utilized in the preparation
of the Final SEIS, in addition to the ones listed in the Draft SEIS:
CH-M Hill. 1982. Innovative and alternative technology assessment for the
sludge management system. Phase II expansion program. Albuquerque
NM, variously paged.
Federal Aviation Administration. 1974. FAA Guidance concerning sanitary
landfills on or near airports (5200.5). Washington DC, variously
paged.
International Atomic Energy Agency. 1979. Radiation A fact of life.
Vienna Austria, variously paged.
Khera, A.K. 1982. Letter, Ashok Khera, City of Albuquerque Water
Resources Department, to Stephen Romanow, US Environmental Protection
Agency, Region 6, 15 January 1982, 4 p.
Khera, A.K. 1982a. Letter, Ashok K. Khera, City of Albuquerque, to
Darlene Owsley, US Environmental Protection Agency, Region 6, 31 March
1982, 1 p.
Long, G.L., and J. Kent. 1980. Kirtland AFB Bird/Aircraft Strike Hazard
Assistance Report (BASH). Prepared for Department of Air Force,
Tyndall Air Force FL, 4 p.
US Environmental Protection Agency. 1979h. Program requirements memoran-
dum 79-8/identifying expensive projects. Memo from John T. Rhett
to Regional Administrators, 9 May 1979, Washington DC, 10 p.
US Environmental Protection Agency. 1980q. Guidance manual SW-828, Clas-
sifying solid waste disposal facilities. Washington DC, variously
paged.
US Environmental Protection Agency. 1981. Draft supplemental environ-
mental impact statement, wastewater treatment facilities sludge
management system, Albuquerque, New Mexico. Dallas TX, variously
paged.
7-1
-------
APPENDICES
-------
APPENDIX A
SIGNIFICANT
CORRESPONDENCE
ino
-------
RECEIVED OCT 07 JSSi
Department of Energy
Albuquerque Operations Office
P.O. Box 5400
Albuquerque, New Mexico 87115
OCT 5
Ms. Dawn Davenport-Johnson
WAPORA, Inc.
8515 Greenville Avenue, Suite N-205
Dallas, TX 75243
Dear Ms. Davenport-Johnson:
This letter is to clarify Neil Hartwigsen's response to your question
in a recent telephone conversation about the cesium-137 source size for the
proposed Albuquerque sludge irradiator. As you are aware, Appendix E of the
Phase II B expansion plan report estimates a source size of about 5 MCi for
a 25 ton/day facility. Note that this is 25 gross tons per day, independent
of solids content.
In the updated economic analysis furnished by the city of Albuqueruqe
to EPA dated July 2, 1981, a capacity of 29.4 dry tons of sludge per day
at 40% solids is assumed. This translates into 73.5 gross tons. This
capacity would require a source size of about 14.5 MCi which is consistent
with Mr. Hartwigsen's estimate of 15 MCi.
Since required source size is determined by the gross tonnage of s.ludge
to be processed per day, rather than by dry tonnage solids content has a
srrong influence on source s.'.ze. The actual source size for an irradiator
if Albuquerque proceeds with this option, is uncertain at present because
the City has not completed detailed analyses and designs which fix the
solids content of the sludge to be irradiated.
I hope this clarifies Mr. Hartwigsen's response adequately. If you
have further questions, please contact me at 505-846-5236.
Sincerely,
i'vw
W. H. McMullen
Project Manager
Sewage Sludge Irradiation Program
See page 2 for cc:
A-l
-------
-2-
Ms. Davenport-Johnson
cc:
A. K. Khera, Water Resources Dept.
M. L. Kramm, 4540, SNLA
B. D. Zak, 4544, SNLA
J. S. Sivinski, 4545, SNLA
C. C. Hartwigsen, 4544, SNLA
D. Owsley, (6ASA?P) USKPA
A-2
-------
''
Department of Energy v.v
Albuquerque Operations Office ^\. -
-------
-2-
P. Noland
I hope the above has given you a better understanding of DOE plans and
goals. I can't emphasize enough that everything is contingent upon DOE
funding from Congress. The DOE is currently operating under a Continuing
Resolution which severely limits its ability to undertake new commitments.
When this situation is resolved, my staff will contact your staff to discuss
in more detail the plans regarding Albuquerque in FY 82.
If you have any questions regarding this matter, please give me a call.
Dennis L. Krenz
'Director, Energy Research
& Technology Division
cc:
W. C. Remini, NE-320, DOE, HQ
A-4
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COLLEGE.OF AGRICULTURE AND HOME ECONOMICS
DEPARTMENT OF AGRONOMY
Box 3O/Las Cruccs. New Mexico 88003
Telephone (505) 616-3405
December 22, 1981
Mr. W. H. McMullen
Department of Energy
Albuquerque Operations Office
P. 0. Box 5400
Albuquerque, NM 87115
Dear Bill:
At your request I attended a briefing of EPA personnel in Dallas, Texas on
December 21, 1981. Also in attendance were Gary Yeager (SNL), A. K. Khera
(City of Albuquerque) and John Burgh (Camp Dresser and McKee, Inc.). I
gave a brief summary of NMSU's agronomic research and detailed our experi-
ence regarding the Iron (Fe) value of sewage sludge. The following is a
summary of toy presentation for your files.
EPA personnel also shared a copy of a letter from the Soil Conservation
Service (Ray Margo, Jr., State Conservationist) with me and asked for some
clarification of agronomic discussion. As a service to EPA, I have also
addressed these issues.
Iron value of sewage sludge
Iron availability on the calcareous, high pH soils of the southwestern
United States is often very low due to precipitation as insoluble iron
oxides. This extremely limited availability is often manifested in Iron
chlorosis of various crops, ornamentals, and turf grasses. Inorganic Fe
fertilizers are typically ineffectual in correcting Fe deficiencies as the
released Fe ions are quickly precipitated as Insoluble Fe oxides. Com-
plexed Fe forms, on the other hand, either as synthetic Fe chelates or as
natural organic complexes of Fe, are not subject to the same rapid precipi-
tation reactions. Complexed Fe thus remains available for plants If the
complex is stable enough. The most effective synthetic Fe chelate on
severely Fe-deficicnt soils is acknowledged to be FeEDDHA (commercially
marketed by CIBA-GEIGY as Chel 138). Unfortunately. Chel 138 Is very
expensive ( ^ $250/lb Fe), and its use is often restricted to small scale
applications. Greenhouse studies conducted by B. D. McCaslin and Vicente
Lee Rodriguez showed sewage sludge applied at 15 tons/A to give statis-
tically the same yields as 51b Fe/A when the Fe was added as FeEDDIIA. The
available Fe content of Albuquerque sludge Is 166' !ppm. Thus, when 15 tons
of sludge are applied per acre, thn available Fe added is 0.166 Ibs avail-
nble Fc/10 Ibs sludge x 30 x 10Jlbs sludge/A « 4.98 Ib available Fe/A.
Thus, 15 tons of sludge yields essentially the same amount (4.98 Ib) of
A-5
-------
Mr. W. H. McMullen
December 22, 1981
Page two
available Fe as 5 Ib/A of Fe EDDHA. Given this equivalence of action, one
can assign a fertilizer valuci to the sludge equal to that of FeEDDllA. On
a per ton basis: 0.166 lb/10 Ibs x 2 x ^(T lb x $250/lb Fe = $83/ton of
sludge as an economic value of the sludge based only oh the available Fe
content.
One can also calculate a fertilizer value of sludge based on its N and P
contents as follows:
2% N in sludge at $0.30/lb N x 2 x 103lb/ton = $12.00 for N/ton sludge
2.5% P " " " $0.21/lb P x " " " " - 10.00 for P/ton sludge
When the N and P values are added to the Fe value, the sludge Is seen to
have an approximate value of $100/ton.
It is also important to consider recent projections of fertilizer costs in
1985 (Fertilizer Progress, 1981 Vol 12:14). These conservative projec-
tions estimated all fertilizer costs to increase about 2.5 fold from 1980
costs. Thus, by 1985, the sewage product could be worth about $250/ton
based solely on N, P, and Fe elemental composition. We are truly dealing
with a product that is too valuable to throw away.
SCS letter (copy attached)
In paragraph #4 of page one of the letter, SCS personnel suggest that
application of sewage sludge at about 5 ton/A will necessitate additional
watering requirements to meet additional N additions. What they were not
aware of was the fact that the current watering scheme the city uses has
been determined for grass already treated with sewage sludge. I do not
know how much sludge is currently being applied, but suspect that It is
near the Intended 5 ton/A rate. Thus, additional watering is not neces-
sarily needed. These comments also pertain to paragraph J?l on page 2
which suggest that more Irrigation water will move soluble salts to a
greater depth in the profile.
Paragraph #4 on page 2 addresses the value of sludge and compares sludge
to steer manure. This comparison assumes equal nutrient content of the
materials which is generally not true. Steer manure averages only 1.34% N
and 0.53% P compared with Albuquerque sludge at 2% N and 2.5% P. Steer
manure is also much lower In mlcronutricnts especially Fe (0.5%) compared
to sludge (1.5%). Field studies at Artesia showed manure to be much less
effective in promoting sorghum growth than equal rates of sewage sludge.
A-6
-------
Mr. W. H. McMullcn
December 22, 1981
Page three
Bulk manure is also not treated to "further reduce pathogens" and thus
would not be allowed on turf areas. Even the value given "heat-treated"
and bagged steer manure ignores the lower nutritional value of steer
manure. I trust that these comments are helpful and sufficiently clear.
However, if you need additional information, please feel free to contact
me.
Sincerely,
George A. O'Connor
Professor of Soil Chemistry
tb
cc: Gary Yeager
A-7
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Cily of Hbuquerque
P.O. BOX 1293 ALBUQUERQUE, NEW MEXICO 87103
MAYOR
Harry E. Kinney
CHIEF
ADMINISTRATIVE OFFICER
Frank A. Kleinhenz
January 6, 1982
Clinton Spotts, EIS Coordinator
USEPA Region VI
1201 Elm Street
Dallas, Texas 75270
SUBJECT: COMMENTS/DECEMBER 11, 1981 LETTER FROM ALBUQUERQUE PLANNING DIRECTOR
Dear Mr. Spotts:
The purpose of this letter is to detail the City of Albuquerque's position
relative to the draft Supplemental Environmental Impact Statement (SEIS) on
the Phase II Expansion Program Report, and in particular clarify those points
previously raised in the letter from the City's Planning Director, Vern C. Hagen,
dated December 11, 1981.
In the referenced letter Mr. Hagen correctly points out that the Area-Wide
Wastewater Collection and Treatment Facilities Plan is an element of the
Albuquerque/Bernalillo County Comprehensive Plan, and that the Southside Waste-
water Treatment Plant Phase II Expansion Program Report must be officially
adopted through the Planning process before it becomes part of the Comprehensive
Plan.
The timing of the proposed Facilities Plan amendment (Phase II Expansion Report)
could occur in one of two ways: (1) prior to the release of the Final SEIS with
appropriate language stipulating adoption by local governing bodies; or (2) sub-
sequent to the release of the Final SEIS publication with similar stipulations.
Discussions with members of the City and County Commissions in a Study Session
will be held in the immediate future as a prelude to formal introduction of the
Report as an amendment to the Comprehensive Plan's Wastewater Facilities Plan
element.
It must be pointed out that a member of the City Environmental Planning Commission
and a member of the County Planning Commission served as members of the CAC SEIS.
In previous action the City's Environmental Planning Commission (EPC) did approve
rezoning for the Montessa Park Site for a permanent sludge treatment facility,
conditioned on final approval of a site development plan.
Various sludge treatment alternatives, site alternatives, and environmental con-
sequences will be addressed in the Final SEIS through a cooperative effort of the
City's Planning Division, Water Resources Department, the City's consultant (Camp
Dresser & McKee, Inc.) and WAPORA, Inc. These alternatives will be submitted as
part of the total package to the City and County Planning Commissions and their
governing bodies for adoption into their comprehensive plan.
A-8
-------
Mr. Snotts -2- January 6, 1982
The following comments should be included in the content of the Final SEIS:
A. That the Final SEIS acknowledge the status of the Phase II Expansion
Program Report. Specifically, the final sentence on Pages 1-2 would
read as follows:
The final version of this report was completed during January 1981
and was forwarded to EPA as a proposed facilities plan amendment on
January 21, 1981.
This section should further state that relative to the Albuquerque/
Bernalillo County Comprehensive Plan "The City has initiated the re-
view process required to formally amend the Comprehensive Plan's
Facilities Plan element by adopting the Phase II Expansion Program Re-
port, as an amendment." The Report will achieve official status by
adopting it as an amendment of: the Comprehensive Plan.
B. The final SEIS should indicate that:
1. The Phase II Expansion Report must be adopted as an amendment of
the Comprehensive Plan's Wastewater Facilities Plan element. It
must also be adopted by other local governments in the planning
area prior to initiation of the preliminary design phase.
2. The City of Albuquerque will maintain an EIS and SEIS Record
documenting compliance with these stipulations.
Please consider this letter as a supplement to Vern Hagen's letter of December
11, 1981 referenced above.
Thank you for your consideration, and if you have further questions or require
additional information or explanation, the City will respond through my office.
Sincerely,
A. Kleinhenz
Chief Administrative Officer
FAK:PDN:rmm
cc: Carl P. Rodolph, Director,
Terence L. Nighbert, GIF Official, MDD/CIP
Vern C. Hagen, Associate Director/MDD Planning
Paul Noland, Director, WRD
A-9
-------
APPENDIX B
COST-EFFECTIVENESS
ANALYSIS
-------
Cost-effectiveness analysis of optimal alternatives, with a credit (10,740 ton/yr. at $70/ton) given for
utilization of sludge on public parks.
Alters.
1A*
IB*'1'
1C*
ID*
IE*
IF*
1G*
d
-. 1H*
2A<2>
2B
3A
3B
3C
3D
Capitol
Grant Eligible
25,699,100
26,427,100
22,872,600
23,600,600
19,063,500
19,791,500
22,817,500
23,545,500
16,622,200
18,383,400
29,188,700
31,382,700
28,719,300
25,688,200
Cost
Ineligible
0
80,000
0
80,000
0
80,000
0
80,000
0
0
0
165,500
212,500
0
Annual
O&M
17,400
(224,800)
119,300
(122,900)
496,900
204,700
273,800
316,000
770,000
640,200
558,600
103,306
264,900
657,600
PW O&M
(10.2921)
179,100
(2,313,700)
1,227,800
(1,264,900)
5,114,100
2,209,100
2,818,000
3,252,300
7,925,900
6,589,000
5,749,200
1,063,200
2,726,400
676,800
Salvage
Value
2,030,100
4,092,000
597,000
2,659,500
(2,722,900)
(661,000)
523,100
2,585,000
1,785,800
2,601,900
9,475,700
13,103,000
8,084,800
3,893,000
PW
Salvage
Value
(0.2410)
489,300
986,170
14,400
640,900
(656,200)
(159,300)
126,100
623,000
43,000
62,700
228,400
315,800
1,948,500
938,200
Total PW
25,388,900
23,207,200
24,086,000
21,774,800
24,833,800
22,239,900
25,509,400
26,254,800
24,505,100
24,909,700
34,709,500
32,295,600
29,709,700
25,426,800
Total
Annual
Equivalent
(0.0972)
2,467,800
2,255,700
2,341,200
2,116,500
2,413,800
2,161,700
2,479,500
2,552,000
2,381,900
2,421,200
3,373,800
3,139,100
2,887,800
2,471,500
Cost
Per
Ton
230
210
218
197
225
201
231
238
222
225
314
292
269
230
Rank-
ing
8
3
4
1
6
2
10
11
5
7
14
13
12
9
, .Potentially eligible for 85% Federal funding.
'Alternative IB is the City's proposed project.
cost-effective conventional system.
-------
Potential funding of optimal alternatives.
Total Capitol
Capitol
t»
Alternatives
1A*
IB*
1C*
ID*
IE*
IF*
1G*
1H*
2A
2B**
3A**
3B**
3C**
3D**
Cost Eligible
For Funding
25,699,100
26,427,100
22,872,600
23,600,600
19,063,500
19,791,500
22,817,500
23,545,500
16,622,200
18,383,400
29,188,700
31,382,700
28,719,300
25,688,200
EPA Funding
75/85%
21,844,200
22,463,000
19,441,700
20,060,500
16,204,000
16,822,800
19,394,900
20,013,700
12,466,700
12,466,700
12,466,700
12,466,070
12,466,700
12,466,700
State Funding
12.5%
3,212,400
3,303,400
2,859,100
2,950,100
2,382,900
2,473,900
2,852,200
2,943,200
2,077,800
2,077,800
2,077,800
2,077,800
2,077,800
2,077,800
Total Funding
25,056,600
25,766,400
22,300,800
23,010,600
18,586,900
19,296,700
22,247,100
22,956,900
14,544,500
14,544,500
14,544,500
14,544,500
14,544,500
14,544,500
(Local Share) +
Ineligible Funding
642,500
660,700 +
571,800
590,000 +
476,600
494,800 +
570,400
588,600 +
2,077,700
3,838,900
14,644,200
16,838,200 +
14,174,800 +
11,143,700
80,000
80,000
80,000
80,000
165,500
212,500
*Potentially eligible for 85% funding.
**Funding limited by most cost-effective conventional system.
-------
APPENDIX C
REVISED COST
INFORMATION
-------
dim of* llbuquwtanc
P.O. BOX 1293 ALBUOUFHOUl , NLW MLXICO 87103
CHIEF
ADMINISTRATIVE OFFICER
Frank A. KU.'inlM,'M/
March 22, 1982
Mr .. Steven R. Rubin
Project Engineer
Construction Grants
USEPA Region VI
First International Bldg.
1201 Elm Street
Dallas, TX 75270
Subject: Albuquerque Sludge Management System SEIS
Dear Mr. Rubin:
As suggested by Mr. Verne 11 of WAPORA in our most recent meeting in
the Region VI office, we have undertaken a more detailed scrutiny
of costs for the City's preferred system (dewatering, solar drying,
and ultimate resource recovery) and the landfill ing alternative.
Conclusions drawn from this more detailed examination of the components
in these alternatives have led to adjustment of certain costs, which
in the earlier planning-level studies appear to have been excessively
conservative. Following are genera] observations on these items:
Belt Press Dewatering
Earlier estimates were based on providing a two-story structure for the
belt press installation. More detailed engineering evaluation suggests
that a single story structure would in fact be more appropriate for this
design application, irrespective of whether located at the plant or at
Montesa Parki The revised estimates herein reflect the resulting re-
duction in building superstructure costs. Further, discussion with
manufacturers indicates that a washwater reclamation feature of accept-
able performance can be provided as an integral part of the equipment,
with resulting increase in equipment cost of less than ]0 percent. Since
this approach is more cost-effective than providing the separate wash-
water installation previously envisioned, we have deleted the latter in
favor of equipment costs slightly higher to reflect inclusion of this
feature. We have also re-examined the operating and maintenance labor
requirements in light of the foregoing as well as a review with respect
to overall size of the present plant staff. From this review, we have
concluded that we were rather too conservative in estimating labor re-
quirements. Appropriate adjustments have been made in the belt: press
staffing costs. The effect of these combined considerations is to
appreciably reduce the cost for belt press dewatering.
C-l
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continued
Stovct, H. Hub ir,
Pago 2
Horizontal Greenhouse Drying
We have pursued a more refined layout of the greenhouse and covered
sludge stockpile structures. In order to accommodate desirable interior
roadways., but preserve the direct-gain solar area reguired, the areen-
house has been lengthened slightly. The planning studies assumed agricul-
tural type manure spreading equipment to place the belt press cake on the
beds. This has now been replaced by electrically operated equipment for
conveyance of the sludge to and from the beds, and for cake mixina, all
resulting ir. a net savings ir, vehicle investment and energy costs. The
savings and costs in these adjustments are roughly offsetting, and the
overall process cost remains essentially as provided you previously.
However, we are pleased to note that the site plan we are developing
permits all truck loading and other handling operations to be conducted
within the ureenhouse or stockpile buildings, which we think is a further
enhancement from an environmental point, of view.
Landf illir.g
We have reviewed our filter press unit process costs, and have validated
the earlier assumptions and their costs. However, the adjustments in
belt press costs discussed above result in belt pressing now becoming
competitive with filter pressing for ultimate disposal by landfilling.
Since the resulting process train costs for belt pressing or filter
pressing followed by trucking to landfill are guite close ($133 and
$136/ton, respectively), the selection between these two methods would
likely be made or, considerations of ease of operation at the plant, or
bacteriological quality of the sludge deposited in the landfill. The
lime conditioning involved in filter pressing renders the sludge more
inert as regards the potential for bacteriological contamination of ground-
water, and renders it a somewhat more beni.gr, product, in transit across
the city. On the other hand, belt presses require somewhat less opera-
tion and maintenance resources at the plant.
As will be seer, from the enclosures, the results of this more detailed
engineering studv of the most favored alternatives is that the cost of
the City's preferred opt.ion is well within 10 percent of what we -judge
the lowest cost alternative.
As I mentioned ir, our earlier correspondence, wo have developed a con-
ceptual site plan illustrating in general way how the proposed facil-
ities could be positioned on the Montesa Park site. A copy of this
layout is being forwarded under seperate cover for your information.
A corresponding architectural rendering of the facilities is being pre-
pared, and will be furnished to you as soon as completed.
C-2
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continued
Steven H. Rubin
Page 3
We hope the enclosed material is useful, and that you will find it a
contribution to moving the SETS to a successful completion. As you
know, we have already provided a large portion of the additional in-
formation desired by WAPORA to aid them in responding to draft SEIS
comments. In the interim, if we may provide any further explanation
of the enclosures, or in any other way assist you or WAPORA, do not
hesitate to call.
Sincerely yours,
Ashok K. Khera, P.E.
Water Resources Department
AKK/In
Enclosures
cc: James C. Varnell
Paul D. Noland
Walter H. Nickerson
John A. Burgh
Edward C. Stokes
Kenneth C. Adams
Darlene Owsley
Scott Ahlstrom
f I
f/reader 's
C-3
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Table 1
SUMMARY COSTS OF ALTERNATIVES
Process Train Alternative
Cost
o
i
Ranking
1 **
2
3**
4
5
6
7
8
9
Process Composition*
Pipe to MP (21), belt press to 25% (65), open-air dryer to 40%
(51), gamma irradiate (39), to parks (-70)
Pipe to MP (21) belt press to 20% (62), roll press (51), gamma
irradiate (39), covered stockpile ( to parks (-70)
Pipe to MP (21), belt press to 20% (62), compost (99), to parks
(-70)
Pipe to MP (21), belt press to 25% (65), horizontal greenhouse
& stockpile to 40% (59), gamma irradiate (39), to parks (-70)
Belt press to 25% (65), truck to landfill (68)
Filter press to 35% (90), truck to landfill (46)
Pipe to MP (21), belt press to 25% (65), vertical greenhouse &
stockpile to 40% (81), gamma irradiate (39), to parks (-70)
Pipe to Pajarito site (42), inject in OLD scheme (133)
Pipe to Rio Puerco site (66), inject in OLD scheme (119)
& Per
Dry Ton
106
11 T
112
114
133
136
136
175
185
Percent of
Lowest
100
105
106
108
125
128
128
165
175
* Numbers in parentheses are cost, in dollars per dry ton, or respective components.
** Alternatives strongly disapproved by CAC, on environmental and aesthetic considerations.
MP= Montesa Park
-------
Table 2
SUMMARY OF COSTS OF UNIT PROCESSES
18 March 32
FUNCTION
Transport
Dewatering
Drying
Disinfection
Disposal
Miscellaneous
TABLE
No.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
UNIT PROCESS/COMPONENT TON
Pipeline to Montesa Park
Pipeline to Pajarito OLD Site
Pipeline to Rio Puerco OLD Site
Truck Liquid to Montesa Park
Truck Liquid to Pajarito Site
Truck Liquid to Rio Puerco Site
Filter Press (3 to 35% Solids*)
Belt Press (3 to 20% Solids)
Belt Press (3 to 25% Solids)
Open-Air Dryer (25 to 40% Solids)
Roll Press (20 to 40% Solids)
Vertical Greenhouse & Open Stockpile
(25 to 40% Solids)
Electron-beam Irradiation
Gamma-ray Irradiation
Composting
Truck Filter Press Cake to Landfill
Inject Sludge at Pajarito OLD Site
Inject Sludge at Rio Puerco OLD Site
DAF Sludge Thickening
Truck Belt Press Cake to Landfill
Horizontal Greenhouse and Enclosed Stockpile
COST PER
DRY SOLIDS
$21 .40
41.73
65.62
41.20
70.69
81.95
89.97
62.19
55.15
50.89
51.32
81.15
56.21
38.94
99.21
46.11
133.23
118.60
58.63
68.03
58.99
24
(25 to 40% Solids)
Enclosed Stockpile
9.59
* i.e. process input is at 3% solids, process output is 35% solids.
c-5
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18 March 82
Table 10
COST OF BELT PRESS FACILITY TO
DEWATER FROM 3% to 20% SOLIDS
ITEM
Construction Costs:
Building $ 660,000
Belt Presses 1,2-6S,000
Support Systems ... 173,000
Subtotal ... 2,098,000
Contingencies (15%) 3.14,700
Subtotal . 2,.412,700
Field Exploration* , . -0-
Land Acquisition -0-
Design Engineering (6%) . . . 144,800
Engineering During Construction (5%) 120,600
Administration and Legal (4%) . . 96,500
Startup (1.5%) 36,200
Capital Cost 2,810,800
Present Worth of Salvage Values -79,500
(Buildings)
Present Worth of Capital Cost 2,731,300
Annualized Capital Cost 265,400
Fixed Annual O&M Costs:
Labor (5,000 m-h) 49,500
Power (15,600 m-h) 1,100
Variable Annual O&M Costs
to Process 30 TPD:
Labor (9,970 m-h) 98,700
Power (140,400 Kwh) 9,600
Polymer (107,300 Ib) 214,600
Maintenance & Repair Materials 29,000
Annualized O&M Cost 402,500
TOTAL ANNUALIZED COST 667,900
Annual Cost Per Ton Dry Solids $62.19
Included w/drying facilities.
C-6
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18 March" 32
Table 11
COST OF BELT PRESS FACILITY TO
DEWATER FROM 3% to 25% SOLIDS
ITEM
Construction Costs:
Building $ 660,000
Belt Presses 1,510,000
Support Systems 173,000
Subtotal 2,343,000
Contingencies (15%) 351,500
Subtotal 2,69^,500
Field Exploration* . -0-
Land Acquisition -0-
Design Engineering (6%) 161,700
Engineering During Construction (5%) 134,700
Administration & Legal (4%) 107,800
Startup (}.S%) 40,400
Capital Cost 3,139,100
Present Worth of Salvage Values
(Building) -79,500
Present Worth of Capital Cost 3,059,600
Annualized Capital Cost 297,300
Fixed Annual O&M Costs:
Labor (5,000 m-h) . 49,500
Power (15,600 m-h) 1,100
Variable Annual O&M Costs
to Process TPO:
Labor (9,970 m-h) . . 98,700
Power (140,400 Kwh) 9,600
Polymer (107,300 Ib) 214,600
Maintenance & Repair 29,000.
Annualized Q&M Cost 402,500
TOTAL ANNUALIZED COST ..... 699,800
Annual Cost Per Ton Dry Solids $65.15
* Included w/drying facilities
C-7
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18 March 82
Table 23
COST OF HORIZONTAL GREENHOUSE
AND COVERED STOCKPILE
Construction Costs:
Greenhouse (5-60'X 400' bays):
Cast-in-place Concrete . .
Asphalt Paving .
Electrical Fans & Louvers
Structural Steel & Monorails
Glazing
Stockpile (ISO1 X 260' metal bldg)
Foundation
Paving
Shell . .
Sitework ,
Sludge Handling Machines
Sludge Conveyor System
Front End .Loader
Dump Truck .
Subtotal
Contingencies (15%)
Subtotal
Field Exploration
Land Acquisition
Design Engineering (6%)
Engineering During Construction (5%)
Administration & Legal (4%). ....
Startup (1.5%)
Capital Cost
Present Worth of Salvage Values
(Fndn, Structural, Glazing, Sitework)
Present Worth of Vehicle Replacements
(6 2/3 year service life) "
Present Worth of Capital Costs
Annual ized Capital Cost
Fixed Annual O&M Costs:
Labor (5,000 m-h)
Power (15,700 Kwh)
Variable Annual O&M Costs to Process 30 TPD
Labor (11,640 m-h)
Power (268,400 Kwh)
Fuel (4,000 gal diesel)
Maintenance & Repair Materials
Annual O&M Cost
TOTAL ANNUALIZED COST
Annual Cost Per Ton Dry Solids ....
. . $ 473,000
. . 187,000
. . 56,000
. . 858,000
. . 986,000
. . 109,000
. . 73,000
. . 316,000
. . 95,000
. . 120,000
. . 263,000
. . 35,000
. . 50,000
. . 3,621,000
. . 543,200
. . 4,164,000
. . 30,000
. . -0-
. . 249,800
. . 208,200
. . 166,600
. . 62,500
, . . 4,881,100
. . . -683,600
, . . 85,800
. . . 4,283,300
. . . 416,200
. . . 49,500
. . . 1,100
. 115,200
. . . 18,400
7,900
. . . 25,200
. . 217 300
. . 633 500
. . . $58.99
C-8
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18 March 82
Table 24
COST OF ENCLOSED STOCKPILE STRUCTURE
ITEM
Construction Cost:
Civil and Structural $ 277,000
Superstructure 180'X 260' metal building 316,000
Front End Loader 35,000
Dump Truck 50,000
Subtotal 678,000
Contingencies (15%) 101,700
Subtotal 779,700
Field Exploration 10,000
Land Acquisition -0-
Design Engineering (6%) 46,800
Engineering During Construction (5%) 38,900
Administration & Legal (4%) 31,200
Startup (1.5%) 11,700
Capital Cost 918,300
Present Worth of Vehicle Replacements
(6 2/3 year service life) , 85,800
Present Worth of Salvage Values
(Building and Sitework) -71,500
Present Worth of Capital Costs 932,600
Annualized Capital Cost 90,600
Fixed Annual O&M Cost
Labor -0-*
Power (7,300Kwh) 500
Variable Annual O&M Costs to Process 30 TPD
Labor -0-*
Fuel (4,000 gal diesel) 7,900
Maintenance & Repair Materials 4,000
Annual O&M Cost 12,400
TOTAL ANN UAL I ZED COST 103,000
Annual Cost Per Ton Dry Solids $9.59
Stockpile labor costs included in respective
dewatering and drying system costs.
C-9
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APPENDIX D
TOXICITY TEST REPORTS
-------
ilil'llll
\^V / , I.1 i'i A I I'. I I' MM i'Ul II . M /.?. I IM ) ,
Si.-plci;ihcr 9, 10
L ABO R A T 0 R Y R K P 0 R T
V.'nritc Concir.-itor: City of Albmnu-j-ijuo, P.O. Box 1293, Albiiquerquc, N.M. 87J03
Location of Waste. Cc-nuration: Treat.m.-nt Plants //I and 112
Process Producing Waste: Liquid Waste Treatment Facilities
Description of Waste: Waste sludge from drying beds
Approximate Quantity of Waste Produced:
Average Monthly - 5.07 x 10 kilograms
Kaxlr.um Monthly - Data not available
Annual - 6.2 x. 106 kllograins
Parameter(s) being tested: KP (Extraction Procedure) Toxicity Test as
per "Hazardous Waste Manngc.rent System", Federal Re2Jster_, 45 (98),
May .19, 1980.
Samples were collected on 6/25/1980 by David Kersey, Chemist.
The extraction portion of the test was performed by the City of
Albuquerque and shipped to Wilson Laboratories on 17 July 1980 for
chemical analyses.
Analysis portion of 'EP Toxicity Test was completed on 25 July 1980,
according to "Hazardous Waste Management System", FJ2_deral_J?egJ.ste_r,
45 (98); 33127-33128, May 19, 1980.
This waste docs not exhibit the characteristics of EP Toxicity as
defined in and tested according to "Hazardous Waste Management
System", FederalJRejjIstjer, 45 (98), May 19, 1980.
D-l
-------
Metals Analyses were performed according to "Methods for Analysis of Water and Wastes", EPA-600/4-79-020 , on a
Perkin-Elmer 503 Atonic Absorption Spectrophotometer equipped with a flame and graphite furnace. Analysis were
performed by Bruce Fast and Robert Rickard, list of qualifications attached.
Organic compounds were analyzed, according to "Methods for Benzidine, .Chlorinated Organic Compounds, Pentachloro-
.phenol and Pesticides in Water and Wastewater", U.S.E.P.A., September 1978, on a Hewlett-Packard 5710 gas chroma-
tograph equipped with a Ni63 electron capture detection on a 1.5% SP-2250/1.95% SP-2401 Supelcoport 100/120 column
at 185°C with a carrier gas flow of 60 mi/min. Analysis were performed by Clifford Baker and Robert Rickard, list
of qualifications attached.
Analyses Results
O
Analysis
Arsenic
Barium
Chromium
Lead
Mercury
Selenium
Silver
Methoxychlor
Toxaphene
- > **D
2,4,5-TP
EPA Hazardous
Waste Number
DOOS
D009
^f1 o
D013
^O"1 4
n ^ i c
> ^ -.j
D016
D017
Toxicity Limit
(~,g/i )
5.0
100
" r\
5.0
5.0
0.20
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
8007-178
80-0290
ND(C.05)
0.10
ND (0.0005)
0.0006
O.OQ3S
ND(O.OOOl)
XD (0.001)
XD(0.0005)
XD (0.001)
ND (0.001)
ND (0.005)
ND(O.Ol)
XD(0.20)
XD(0.02)
8007-179
80-0291
ND(0.05)
0.075
0.0046
0.0031
0.0085
XD (0.0001)
ND (0.001)
0.0008
ND (0.001)
ND (0.001)
ND(O.OQ5)
XD(O.Ol)
ND(0.20)
XD(0.02)
8007-180
80-0283
0.012
0.14
0.0080
0.0027
0.0038
0.00025
ND(0.003)
0.0014
ND (0.001)
ND (0.001)
ND (0.005)
ND(O.Ol)
ND(0.20)
ND(0.02)
8007-181
80-0284
0.006
0.24
0.0022
0.013
0.0042
O.C035
ND(0.003)
0.0023
XD (0.001)
ND(Q.COl)
XD (0.005)
ND(O.Ol)
ND(0.20)
S3 (0.02)
Polychlorinated Biphenyls XD(O.Ol) XD(O.Ol) ND(O.Ol)
ND denotes none detected. The detection limit of the method is shown in oarentheses.
ND(O.Ol)
WILSON LABORATORIES
Robert L. J^eyer
Chief Chemist
File No. 80-9501
Lab No. 8007-173 through 181
Date: 29 August 1980
-------
APPENDIX E
ALTERNATIVE SITE
ANALYSIS
-------
February 26, 1982
SLUDGE PROCESSING FACILITIES
SITE LOCATION STUDIES
This report is submitted pursuant to the request of WAPORA, Inc. for a
summary of the investigations conducted by the City and its consulting
engineers in search of the most reasonable site for sludge processing
facilities for the period to the year 2000 and beyond. The purpose of
this report is to summarize the previous assessment of the characteristics
of each site which led to formulation of the City's proposal. Various
aspects of wastewater facilities site analysis and selection efforts
persisted throughout the 1975-1981 period. However, information utilized
in this effort was gathered from a wide variety of sources representing
urban planning and other work done over the past 20 years.
METHODOLOGY
The fundamental methodology adopted to identify and successively screen
locations was to (a) select from map study all general tracts possibly
suitable from a topographic and land use point of view; (b) conduct
field reconnaissance; (c) examine access, transportation linkage and
utility services existing or feasible; (d) through consultation with
City Real Property Office staff, prepare a judgment of land availability
and cost; (e) in a preliminary way, consider the annualized cost of
sludge transfer to the site, and (f) contemplate the environmental
aspects of sludge transfer and on-site processing. This approach was
grounded on a review of all relevant published and other information
E-l
-------
which could be obtained, and avoiding unnecessary repeating of data or
analyses presented in the EIS completed for the 1978 Facilities Plan.
During the SEIS public participation process, suggestions for sites over
and above those identified in this planning process were actively sought.
WAPORA and their associated consultants were also urged to suggest sites
for any system facilities that might appear promising during the course
of their work on the_project.
The investigative team began the site selection process by reviewing the
areawide Comprehensive Plan prepared by the Albuquerque/Bernalillo
County Planning Department in 1975. This report assisted in identifying
feasible tracts of land in which, on the surface, the designated land
use did not seem to conflict with the installation of components of the
sludge management system.
Following examination of the Planning Department mapping, the City and
its consulting engineers conducted field reconnaissances of the areas
tentatively identified. Simultaneously, the investigative team thoroughly
reviewed the literature in search of relevant information which may be
beneficial for site analysis and selection.
FACILITIES PLAN AND EIS
The results of these and other efforts undertaken in the early phases of
the site selection process are embodied in the Albuquerque Areawide
E-2
-------
-3-
Wastewater Collection and Treatment Facilities Plan of 1978 (herein re-
ferred to as the Facilities Plan). Volume 2 (Figure 7) of the Facilities
Plan identifies a number of parcels of land distant from and including
Plant No. 2 in connection with alternative siting of new treatment plants,
the development of plant effluent infiltration-percolation schemes, and
proposed irrigation projects using plant effluent. In particular, the
EIS addressed tracts on the Southeast Mesa (basically the tract of state-
owned land located south of Montesa Park), the South Valley including
both treatment plants, and several parcels in the Pajarito area on the
Southwest Mesa. In addition to these primary sites, several locations
considered for potential "satellite" plants, serving relatively isolated
segments of the planned collection system, were identified in the facilities
planning process. These include: the Corrales Plant Site (located
northwest of the City, near the intersections of Coors and Corrales
Roads); the Sandia Heights Plant site (in the Sandia foothills, at
the northeast extremity of the urban area); and the East Mountain Plant
site, in the upper reaches of Tijeras Canyon adjacent to 1-40.
The Phase II Expansion Report (Balloon Report)
Subsequent efforts expanded the array of identified sites. The 1980
Phase II Expansion Program Engineering Report (herein referred to as
The Balloon Report) details siting considerations with regards to land
application. (See pp. 7-111--7-114.) The Balloon Report expands on
the sites documented in the Facilities Plan, presenting other alternatives
which merited investigation. Los Lunas East and West (located south of
E-3
-------
of Isleta Reservation in Valencia County), the West Mesa Airport site
(found on the western-most edge of the City) and Montesa Park (situated
near Tijeras Arroyo, south of the City) were included for review. On-site
field reconnaissance, laboratory soil sample analyses and special reports
were executed and prepared to provide further data for ultimate site
selection.
SITE EVALUATIONS
Whereas the entire siting process extended over a lengthy period of
time and included a review of numerous sites, the following list depicts
the principal sites investigated:
- Kirtland Air Force Base
- Satellite Plant Areas
- Southeast Mesa
- Plant No. 1
- Plant No. 2
- Plant No. 2 Infiltration-Percolation Site
- Pajarito
- Isleta Reservation
- Los Lunas East
- Los-Lunas West
- Volcano Park
- West Mesa Airport
- Rio Puerco
- Montesa Park
E-4
-------
-5-
These sites are indicated on the map provided as Appendix A.
As is apparent, the alternative site investigation was geographically
comprehensive in scope. Although these sites were initally considered
for a variety of wastewater system needs, the City and its consulting
engineers utilized the information, regardless of intent, in the evaluation
of site suitability for sludge handling facilities.
All sites listed above were evaluated for relative strengths and weaknesses.
The standards employed in this regard included:
(1) Technical suitability related to needs associated with
the construction of facilities and/or systems;
(2) Economic issues such as land values, real estate interests
and the proximity of sludge users;
/
(3) Physical realities of each site including distances
from population centers and treatment facilities,
accessibility, terrain and hydrological factors; and
(4) Environmental and Cultural concerns regarding the preservation
of the Albuquerque area's heritage.
Each site was analyzed from these perspectives. Particular attention was
given to site accessibility. Another important variable identified was
the availability of (or feasibility of readily developing) utility
services at each site. Environmental and other characteristics being
equal, a site lacking sewers and sources of water and power was judged
to be less satisfactory for development for a sludge processing system
than one better served by utilities.
The remainder of this report is devoted to reviewing site-by-site the
factors taken into account as the City reached its final selection of
the most suitable site for processing.
E-5
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Kirtland Air Force Base (KAFB) (1)
This site, located generally south of the City, was one of the first
considered. The base is host to a large number of DOD and DOE functions,
including extensive facilities of Sandia National Laboratories. The
primary advantage associated with this site includes its accessibility
to transportation routes and utilities. Roads provide access to nearly
all areas and a rail spur provides rail transportation to the base.
Adequate utilities are available, some being extensions of City services,
and others owned and maintained by the Base.
Disadvantages of the site are those relating to distance and pump lift
requirements. As KAFB is approximately eight to ten miles east of
Plant No. 2 and is elevated about 500 feet above the plant beyond the
Southeast Mesa, considerable pumping would be necessary. In addition,
KAFB officials have indicated that land within the jurisdiction of KAFB
definately is not available as an alternative site. According to the
officials, this is primarily due to the Base's stringent security pre-
cautions and land assets commitments related to national defense research,
KAFB received only two votes (out of 14) in the CAC preference poll
as site for sludge facilities. Therefore, the investigative team deter-
mined that KAFB is an unrealistic site to propose for sludge processing
facilities.
Satellite Plant Areas (2)
The parcels considered in the Facilities Plan for isolated-area treatment
plants were considered, but relatively quickly dismissed as impractical
E-6
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-7-
for centralized sludge handling facilities. These three sites are all 15-
18 miles from Plant No. 2, and far higher in elevation, imposing pro-
hibitive sludge transport costs, even though basic road access is adequate.
In terms of utility provision, power sources are available, but because
these sites are as yet external to the municipal utility service area,
sanitary sewers and city water supplies are not available. The Corrales,
Sandia Heights and East Mountain sites share all these problems, which
led to their elimination from further consideration.
Southeast Mesa (3)
The large tract of land just south and west of Kirtland Air"Force Base
is owned (and managed in trust for UNM) by the State Land Office. The
UNM tract is elevated 370 feet above Plant No. 2 and is located approxi-
mately five miles southeast of the facility. The water table in the area
is relatively deep (350 ft.); however, a ground water nitrate problem has
been detected, the cause of which'is still under technical debate. This
site also demonstrates a relatively high soil pH factor (8.4-8.6) and a
CEC of 6.5-10.1 meq/lOOg. A heterogenous soil type exists on the South-
east Mesa including fine sandy loam soil types typically found on the
valley terraces such as Madurez-Wink and Bluepoint-Kokan associations.
The area is not bisected by roads of any consequence and the nearest
rail line is located about five miles to the west. The Southeast Mesa
area does not have ready access to utilities. As previously noted, the
lack of utilities has serious ramifications when evaluating site suitability,
as capital costs rise significantly.
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If the tract were for lease (and some discussions suggest that it is not),
the cost is estimated at $180/acre/year. The crucial point is the land
is not for sale and further leasing by the City for even the existing
temporary sludge lagoons may not be possible. This reluctance on the
part of the University was clearly reflected in conversations held be-
tween the City and UNM officials. From those interchanges, it appears
that UNM may wish to utilize the land for planned commercial and residential
community development. Since this is the case, it is highly unlikely that
UNM would be interested in getting involved in long-term sludge management
systems. As a result of this reluctance and the lack of site access and
utilities, the Southeast Mesa was omitted from further deliberations.
Plant No. 1 (4)
Within the South Valley, several sites were studied at the beginning of
the site selection process, all of which are depicted in Figure 7,
Volume II of the Facilities Plan. The area enveloping Plant No. 1 is
one of the South Valley sites investigated as a potential location for
sludge processing facilities.
Generally, the plant is situated in a comnrercially zoned area just west
of Second Street S.W. and north of Rio Bravo Blvd. S.W. Whereas the
Plant No. 1 vicinity has the advantages of accessible road and rail ser-
vices and complete utilities, the area was deemed to be unsuitable due
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-9-
to the lack of available land adequate for the buffer zone which would
be mandatory in this odor-sensitized neighborhood. The subsequent
enactment of a court stipulation calls for the closing of Plant No. 1
largely rooted in many years of real or perceived odor nuisances.
Therefore, the stipulation reinforces the previously reached concensus
regarding unsuitability of sites in this general area, for the proposed
purposes. Even though odor control in the sludge facilities will be an
integral part of system design and operation, it was judged impossible
to achieve public acceptance for such a concept at this location, in
spite of such assurances.
Plant No. 2 (5)
Also situated in the South Valley, Plant No. 2 was evaluated as a potential
site for sludge handling facilities. In particular, the investigative
team studied the 60 acre parcel of land located directly north of the
plant complex which the city recently acquired. Advantages of on-site
centralization potentially include lowered treatment costs and ease of
operation. Upon further investigation, however, several disadvantages
emerged which reduced the area's potential for success. One, this part
of the South Valley has a very shallow water table, commonly lying within
5-15 feet of the surface. Due to the shallowness of the alluvial aquifer,
ground water contamination is a potential hazard which must be recognizec
In particular, nitrates, which may be derived from the Tijeras Canyon
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area, are present in small but significant amounts in several areas
in the region. Consequently, concern has been expressed in regards to
constructing facilities which have any potential to heighten an already
prevalent pollution problem.
Secondly, the City's policy commitment to odor containment would be
seriously undermined by an on-site sludge processing facility. Further,
constructing sludge handling facilities at the plant site is not a
meaningful response to the court stipulation which mandates best practical
technology to help reduce nuisances at or near the plant. Noting that
nine of the 14 CAC votes favored sites elsewhere, it is felt that construc-
tion of extensive sludge processing facilities at Plant No. 2 would be
socially and politically unacceptable to the South Valley residents.
Without community support, further legal entanglements and subsequent
construction delays would quickly make an on-site location less cost-
effective. Limited processing, such as mechanical dewatering in enclosed
facilities, is probably viable, however.
Based on the uncertainties of land availability and pollution potential,
coupled with court stipulations, policy commitments and perceived community
response, the vicinity of Plant No. 2 was judged as an unrealistic site
for sludge handling facilities more extensive than dewatering for sub-
sequent landfilling.
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Plant No. 2 Infiltration-Percolation Site (6)
The infiltration-percolation site proposed in the Facilities Plan is
located south of the Mountain View Community, bounded on the east and
west by Broadway Blvd. S.W. and Second Street S.W. respectively. Sit-
uated on the escarpment extending up to the Southeast Mesa, it is of
higher elevation and steeper terrain than the alluvial valley floor.
Most of the area under consideration encompasses valley terraces of Blue-
point-Kokan and Madurez-Wink soils (fine sandy loams). As might be ex-
pected, wind and water erosion present problems for this area. Due
to these characteristics, this site is not as attractive as the others
located in the valley. Further,. much of the area is in productive
agricultural and other uses.
Much of the earlier discussion pertaining to the treatment plants is
applicable to this site as well. Problems exist with regards to ground
water contamination, negative community response and, to a degree, the
uncertain availability of land. Consequently, the area was dropped
from consideration early on in the site selection process.
Pajarito (7)
Situated on the Southwest Mesa, Pajarito lies just north of the Isleta
Reservation. Within Pajarito, three specific localities at varying
heights were examined. Differences in elevation serve as the primary
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distinction among the three sites; one area is low on the mesa, another
is back to the west and is much higher, and the third is an intermediate site.
The general Pajarito area is privately owned. Land values range widely,
estimated at a minimum of $1 ,250/acre to $8,000/acre or more. This
dramatic variation in land prices may be attributed to differences in
road access among the three targeted areas. In terms of transportation,
secondary roads provide access to only a small portion of the site. A
similar access problem is noted in conjunction with municipal utilities,
for none are presently available beyond the margins of this area.
Collectively, the Pajarito sites are approximately 360 feet above Plant
No. 2, have a slight (1-7%) surface slope and would require a pipeline
on the order of 53,000 feet in length. Although Pajarito is the site
closest to Plant No. 2 of all the West Mesa locations considered, it
still is fairly remote (10- miles) from the plant. These site characteristics,
including elevation, topography and distance, would warrant three pumping
stations and a moderate static lift if a location in the area were
developed for sludge handling purposes. This site also exhibits a
heterogeneous soil association in that Madurez-Wink and Pajarito loamy
fine sand constitute its soil profile. Concentrations of nitrates have
been detected in selected wells in the Pajarito area ground water. With
regards to site deterioration, a significant erosion potential exists
in that moderate water and severe wind erosion has been noted. This
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is typical of the West Mesa where high winds disturb the unprotected
and sandy surface soils.
Despite these negative features, the investigative team realized several
benefits to be gained in siting sludge processing facilities at Pajarito.
The relative remoteness of the site from existing community developemnt
is attractive. Plus, the deepest contour in the Middle Rio Grande
Ground Water Basin runs west of and roughly parallel to the fiver, likely
a buried old meander. This results in a southwesterly flow of ground
water to a point somewhat westerly of the present river channel. By
siting a facility at Pajarito, therefore, any leachate from the install-
ation might tend to move away from the City wells located in the more
densely settled.valley area to the east.
Problems of site accessibility, utility services pumping requirements
and erosion potential are recognized, but this site was judged perhaps
workable for a OLD system, and therefore it was retained in the alternative
studies for that purpose.
Isleta Indian Reservation (8)
One of the largest of the 19 Indian Pueblos located in New Mexico both
in area .and population, Isleta is located south of the treatment plant,
at the southerly boundary of Bernalillo County. Isleta land is downstream
from Plant No. 2, and includes portions of the valley at an elevation
approximating that of the Plant. Because of its relatively low elevation
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and reasonable proximity to Plant No. 2, modest pumping requirements
were recognized as a potential advantage of this site. In addition.,
this general area has adequate access by road and rail. Not only is the
area serviced by Interstate 25 and the ATSF railroad line, but also
several secondary and other roads bisect the reservation.
Upon further examination, however, it became apparent that obstacles
exist to siting sludge treatment facilities within the Reservation boundaries
Whereas the City has the legal authority to obtain real estate inside or
outside the City limits, it can not purchase Federal property, Indian
holdings, nor state lands. This is a critical factor, for the City would
prefer to make capital improvements of the sort envisioned on land they
own. This reluctance on the part of the City is partially due to the
great practical difficulty of easement acquisition and subsequent pipe-
line construction on Indian land. Thinking that perhaps the Interstate
25 easement could also be jointly utilized for pipeline passage, the
City contacted the Highway Department, where it was learned that separate
easements must be obtained for such new works, irrespective of whether
physically sited within existing easements. The acquisition of ease-
ments is very difficult to predict, both in regards to cost and time
required, and there is no assurance whatever of eventual success. As
was noted for South Valley sites, another negative factor related to this
site includes the absence of municipal services on the Reservation.
Since services are not extended to the Reservation, resistance to
locating sludge processing facilities at this site may reasonably be
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anticipated.
Based on this knowledge, Isleta Reservation was deemed unrealistic as
a suitable site. Despite the advantages of location and accessibility,
factors contributing to the site's rejection include the lack of
municipal services and City ownership, impracticality of easement
acquisition and the perceived negative community response to the proposed
project.
Los Lunas East (9)
The Los Lunas East site lies immediately south of Isleta Reservation in
Valencia County, approximately two miles west of Interstate 25. Even
though this site is somewhat removed from the Albuquerque population
center, it was initially identified due to its setting in relation to
Plant No. 2. With a slight surface slope, an elevation equal to that of
the plant and a pipeline distance of 77,000 feet, the site would require
(relative to some others) modest pumping investment: two pumping sta-
tions and a relatively small (lOO^feet) lift would be sufficient. Further-
more, the Los Lunas East is situated downstream and to the west of the
Rio Grande River, yet east of the mesa escarpment. As was the case
with Pajarito, the Los Lunas location could potentially minimize the
adverse impact of contamination of valley wells from the facilities due
to the southwesterly trend in flow of the ground water, which is rela-
tively deep (150 *ft) in this area.
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On balance, however, the identified disadvantages outweigh any perceived
advantages in locating facilities at this site. Although access by road
is adequate overall, it is uncertain whether sludge could be pumped via
a pipeline across Isleta Reservation which lies between Los Lunas and
Plant No. 2. As was the case in Isleta Pueblo, questions arise regard-
ing locating facilities in an area which is not serviced by the project
and does not maintain adequate utilities for facility support. Another
factor which must be considered is that Los Lunas East would involve
another political entity (Valencia County) in an already complex situation.
For these reasons, Los Lunas East was judged to be inappropriate for
facility siting.
Los Lunas West (10)
Another privately owned area, Los Lunas West, was also examined for site
suitability. Approximately five miles west of Interstate 25, this site
is located on the mesa overlooking Los Lunas East. Because it is sit-
uated on the mesa, Los Lunas West differs from the eastern site in ele-
vation and pipeline distance. In this regard, Los Lunas West has an ele-
vation difference of approximately 400 feet and would require a 104,000-
foot pipeline from Plant No. 2. Hence, greater pumping requirements
are associated with the westerly site. However, the Los Lunas West site
can likely be purchased at a lower cost ($850/acre) than its eastern
counterpart.
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Similarities are also evident between Los tunas East and West. Both
sites demonstrate comparable pH values and soil associations, with a
slightly higher concentration of fine sand on the mesa. Topography
is similar at each site.
In terms of sludge processing requirements, perhaps the primary advantage
of Los Lunas West is its accessibility via a secondary road and the
Santa Fe railroad line. The advantages, however, are modest in comparison
with the disadvantages associated with this site. All the drawbacks
noted for Los Lunas East also apply to this site, and the very extensive
pumping requirements discourage facility siting in Los Lunas West.
To summarize, from investigations conducted in areas external to Bern-
alillo County, the City determined that these areas are not reasonable
for sludge processing facilities. Various dialogues with EPA and the
CAC led to a general concensus in support of this view.
Volcano Park (H)
The Northwest Mesa, on the western horizon of the City, was also ex-
amined for potential sites. Since Volcano Park was in City ownership
at the start of the project, it was one site on the mesa selected for
investigation. This sparsely settled area incorporates the Indian Petro-
glyph Park and a portion of the area of volcanoes. Volcano Park is about
twelve miles northwest of Plant No. 2 and is at a substantially higher
elevation than the plant; pumping costs could become prohibitive.
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Although this area has a relatively deep water table (it marginally en-
compasses the deeper portions of the Santa Fe Group aquifer ) the
soil structure of Volcano Park is very permeable. Possible ground water
contamination therefore must be recognized when considering the construc-
tion of sludge processing facilities at this site. Other factors deser-
ving recognition include site access and utility provisions. Several
secondary and dirt roads presently traverse Volcano Park. Sanitary
sewer lines and other services are not readily available.
A final consideration of Volcano Park is its historical significance,
a part of which is now preserved in the Indian Petroglyph Park. In
light of past discoveries, it is felt that this site is archeologically
sensitive. Hence, construction activities and an increase in carbon
monoxide levels resulting from plant traffic may prove to be deleterious
to the cultural heritage of the area.
Therefore, due to great distances from Plant No. 2", extreme lift require-
ments, the evidence of soil porosity, transportation difficulties and
cultural ramifications, Volcano Park was viewed as an inappropriate site
for sludge processing facilities.
West Mesa Airport (12)
In addition to Volcano Park, the second site examined on the Northwest
Mesa was the tract of approximately 6400 acres located immediately west
of the volcanoes. Many of the benefits and liabilities associated with
Volcano Park are also evident in the West Mesa Airport site.
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In regards to this site, soil types, water availability and distance
factors were examined and are noted in Table 7-40 of the Balloon Report.
Specifically, it has been estimated that this area is 830 feet above
Plant No. 2 and would require a 94,000 foot pipeline. Based on these
site characteristics, extensive pumping capabilities would clearly be
necessary including six or more pumping stations and considerable pumping
lifts. In addition, despite the site's deep water table, the fine sand
typical of Madurez soils indicates a porous soil with potential for
ground water contamination. Another problem is the severe wind erosion
and moderate water erosion potentials demonstrated at this site.
The City has placed options to purchase this site for a new feeder airport.
Consequently, consideration was given to the possibility of integrating
airport and sludge treatment facilities so that transportation and
municipal service infrastructures could be jointly developed as a part
of the airport project. Greater accessibility and utility convenience,
therefore, made the westerly mesa site appear to be more advantageous
than Volcano Park. However, the other characteristics associated with
the airport site, including great distances from the plant and extensive
pumping requirements, outweigh any perceived gain from facility integration,
Further, timing of airport development is as yet uncertain. Therefore,
it was concluded the area does not appear to offer a reasonable site
for sludge handling facilities.
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Rio Puerco (13)
A tract located along 1-40 on the upper slopes of the Rio Puerco drainage
basin was also examined. Due to its great distance from and height above
the plant, it was judged unsuitable for development for other than a
OLD scheme. This location was retained in the planning studies for that
purpose.
Montesa Park (14)
By far the most favorable location identified for off-site sludge pro-
cessing is Montesa Park, a City-owned parcel of 570 acres near the
Tijeras Arroyo, located about five miles directly east of Plant No. 2.
This is not to say that Montesa Park is without problems. -We feel that
the information presented in the Facilities Plan, the Balloon Report and
materials provided to the CAC illustrate the drawbacks associated with
Montesa Park. The potential disadvantages of Montesa Park noted include
potential soil foundation difficulties, nitrate contamination, BASH
concerns and interference of recreational activities.
Because of structural problems observed at the former detention center
which occupied this site, it was recognized that a soil problem may
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exist at Montesa Park. Consequently, a report was commissioned to
analyze the performance of foundation soils along the Tijeras Arroyo
in the vicinity of Montesa Park. From this analysis it was determined
that the City's proposed project can be built without encountering the
structural problems that were experienced with the detention center,
through proper attention to design. In addition to foundation conditions,
the soils of Montesa Park are susceptible to moderate to severe wind
and water erosion. This is not surprising when one considers that all
the mesa sites (east and west) demonstrate a relatively high degree of
erosion potential.
Another recognized problem of Montesa Park includes nitrate contamination
of the ground water. As has been noted, this problem is prevalent
throughout the Tijeras Canyon/Mountainview region and is of an undeter-
mined origin. In Montesa Park, however, this problem is less of a concern
when one considers the relatively great depth (180- feet) of the water
table and the calcareous and cementitious nature of Montesa Park soils.
Therefore, the site is relatively better protected against accidental
contamination than are some other locations where the water table is
shallower.
With regards to bird aircraft strike hazards (BASH), in spite of the
fact that dried sludge stockpiles have existed at Montesa Park for
numerous years with no evidence of bird infestation, the proposed design
for Montesa Park will take into account these concerns in order to
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prevent potential problems. For example, all open stockpiling as well
as open air drying of sludge have been eliminated from the proposed
project design. Beyond these measures, we do not feel that BASH concerns
are relevant to this situation. In fact, little hard evidence was pre-
sented by the USAF BASH team with regards to bird hazards from this type
of facility.
A special consideration of Montesa Park is that there is a City Parks
motorcycle course immediately to the west of the site, and the hills to
the south of Tijeras Arroyo are sometimes used for hang gliding. The
planning of proposed facilities recognized this recreational use and
the design of facilities will be such as to preserve such use. These
recreational activities should not be impaired by the operation of a
sludge processing system, particularly as all processing operations are
enclosed.
From an engineering point of view, several appealing aspects of this site
were readily apparent. Since Montesa Park is City-owned land, there is
a strong economic advantage, particularly since EPA and the State are
not participating in land acquisition costs for projects of this type.
Also, there are relatively few land owners involved in the abutting tracts
and most of these tracts are publicly owned.
In terms of on-site sludge users, the Forest Service has a long-term
lease from the City for 220 acres of Montesa Park to be used as a tree
nursery. Only 50 to 70 acres of the 570-acre parcel are sufficiently
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flat for construction and are above the 100-year flood plain. Therefore,
the site naturally allows for a liberal buffer area, and the tract is
large enough to serve this purpose to the end of the century and beyond.
Even the most far stretched planning for development (by UNM) indicates
that the area, including about one mile around the facilities, would
remain undeveloped through any conceivable future time.
Pipeline and pumping requirements are also favorable when compared with
any other off-site location. Since Montesa Park is less than five miles
from Plant No. 2, only one pump station external to the plant would be
required. In addition, no pipeline easements of any consequence would
be required to move sludge into the site or remove the sidestream back
to the plant due to the Tijeras Interceptor and its easement.
Site accessibility and utility convenience are other favorable site
factors. There is excellent road access to the area and an easy connec-
tion could be arranged with the nearby KAFB railroad spur, if ever desired
for bulk sludge shipment. Also, a reliable support system exists includ-
ing on-site electric power, gas, water and telephone utilities.
CONCLUSIONS
Based on the investigations and discussion briefly summarized herein,
Montesa Park appears overall the best of a wide variety of locations
considered, for the following principal advantages relative to the
alternatives:
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- Lower costs for site acquisition and development.
- Ability to capitalize on existing facilities for access, and
in-place utility services.
- Environmentally suitable, with proper planning and design.
- Relative proximity to Plant No. 2.
- Liberal buffer areas around the facility.
- Free from the potential of population centers within one mile
for conceivable planning horizon.
Based on the results of our investigation, we feel that our proposed site,
Montesa Park, reflects a sensitive handling of the technical, economic,
geological and environmental considerations relevant to the site selection
E-24
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ALTERNATIVE SLUDGE PROCESSING FACILITIES SITES
ANOOVAL COUNTY
BCMNALILLO COUNTY
WEST MESA
AIRPORT SITE
SANDIA1HEIGHTS
VOLCANO
PARK
EAST
MOUNTAIN
KIRTLAND AIRFORCE BASE
MONTESA PARK
RIO PUERCO
U.N.M. LAND
ISLETA RESERVtfT
IHNALILLO COUNTY
VALENCIA COUNTY
I KIRTLAND AIR FORCE BASE
LOS LUNAS EAST
LOS LUNAS WEST
2 SATELLITE PLANT AREAS' EAST MOUNTAIN, CORRALES.
SANDIA HEIGHTS
3 U.N.M. LAND
4 PLANT NO. I
5 PLANT NO. 2
6 PLANT NO. 2 INFILTRATION-PERCOLATION SITE
7 PAJARITO
8 ISLETA RESERVATION
9 LOS LUNAS EAST
10 LOS LUNAS WEST
II VOLCANO PARK
12 WEST MESA AIRPORT
13 RIO PUERCO
14 MONTESA PARK
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APPENDIX F
PRELIMINARY SLUDGE
SURVEY
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("ily of*
P.O. BOX 1293 Al.BUOUE HOUl. NLW MLXICO 8V103
MAYOR
H.iriy E. Kinni.'v
CHIEF T " "\ iT" '^ ""'
ADMINISTRATIVE OFFICER 1 DJ if; : ^'
Frank A. Kli'inhen? I H j v ' ~
March 12, 1982 HAR jjjj ,953
' ,
''"1!
U
6ES
Mr. Steven R. Rubin
Project Engineer
Construction Grants Branch
Environmental Protection Agency
Region VI
First International Bldg.
1201 Elm St.
Dallas, TX 75270
Subject: Albuquerque Sludge Management System - SEIS
Dear Mr. Rubin:
This is in response to Mr. Romanow's letter of February 3, 1982 relative
to the impact of our potentially being denied the continued use of sludge
as a soil conditioner on City Parks. I understand that the Water Resources
Department staff have had numerous discussions with you regarding this
matter since the February 3rd letter. Therefore, please consider this
as a final "rap up" of matters relative to sludge value.
We feel that the City takes justifiable pride in our excellent parks and
golf courses, and the City is certainly committed to continuing our
historic level of maintenance to preserve these assets for the community.
Should we be denied the opportunity to continue using sludge in the manner
that we have used it so beneficially for so many years, we would of course
take prudent management and budgeting steps to provide the most appropriate
and scientifically sound fertilizer and soil conditioner regimen for the
parks, among the options which remain. However, we do note that our present
consultants join our staff who have many years experience in local r.---rV main-
tenance, in affirming that in fact there is no chemically-based substitute
material known as effective as sludge on these calcareous soils.
We would like to emphasize the fact that it is difficult to equate cost
of substituce chemical fertilizers if in fact no true substitute exists.
For example, at the prevailing price of fertilizer (N-P-K) material,
we would anticipate spending an equivalent of $33/ton of sludge for our
parks and golf courses, if sludge were not available. This figure is
based on the amount of fertilizer required to equal the nitrogen available
in sludge. However, it does not consider the value of all the constituents
in the sludge, particularly the essential micro-nutrients such as iron -
chelnte and zinc. It is conceivable that some of the micro-nutrients
available in sludge may have to be applied to the City parks to preserve
their existing character and appearance. In absence of more scientific
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cor.t ir.ucd
Steven Hubir,
Page 2
studies to identify the typos and rates of these substitute products r.ccded,
we could not provide a reasonable estimate of costs for replacement chemicals
if sludge were not available. Certain inherent values in the use of sludge
on City parks are related to i l.s soil-condi ti oni r.g and water holding
capability. We are not aware of a practical method to assign dollar value
to sludge for these characteristics.
Our Parks personnel have experienced a reduced watering requirement with
sludqc use, though the exact amount of savings cannot be determined from
current records. In any event, considering the fact that our parks and
golf courses utilize almost one million dollars worth of City water you
can see that a modest 10% reduction in watering could translate into great
savings .
As you know, we plan to market about 40% of total design sludge production
at fair market value in an effort to partially offset the cost of sludge
disposal. In order to assess a fair market value for processed sludge,
we conducted a very preliminary telephone market survey. Results of
this survey are summarized in the attached Exhibit 'A'. You will note
that the demand for similar organic fertilizers/soil conditioners just
within the City of Albuquerque far exceeds the marketable quantity of
sludge that we would produce. If you consider demand for such materials
within Bernalillo County and other outlying areas, the sludge quantity
to be marketed is trivia]. Then, when one considers other products
such as milorganite being successfully marketed at prices far in excess
of $200/ton and other far less effective products being marketed at $50-
70/ton (wet tons), we believe that there is a potentially strong market
for processed Albuquerque sludge at prices at or above $70/dry ton on
a wholesale basis and well above $100/dry ton on a retail basis. We have
an excellent Customer Services Division servicing residential accounts that
is fully capable-of handling a retail market. However, whether the City
enters such a retail market is a policy matter that must be evaluted at
a later date. We can certainly market the product on a wholesale basis
to a private enterprise, should we decide not to enter the retail market
in the future.
I hope this letter will clear up the issues and questions raised by EPA
and WAPORA , Inc., regarding sludge value. Please feel free to contact
the Water Resources Department if further information is needed.
S4r.cerely,
-fa,
Frank A . Kle inhrr.i-
Chief Administrative Officer
FAK:ln
/
cc: Paul No]and
Ed Stokes - NMfCJD
A.K. Khera
Join. Burqh - CDM
Scott Ahlstroni _ CH2M HILL
Al Boberg - Parks Dcpt.
\Darlene Owsley - EPA
F-2
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V.irch 1 1 ,
I'HKl.lM IHAKY MAHKKT f.UUVFY OF r.l.UHr.'- VALUK
The purpose of this report is. to sumnar iz.c the preliminary telephone
survey conducted February ?.(> through March 1, ll»f'-2 regardinn the markcl
value and re'ccptivity of slwloc as a soil ferti 1 izer/condi t i oner . A
wide variety of contacts were made ir. Ibis re sport rar.qinc from commer-
cial retail anel who! csal c dist ribul.ors to individual users such as
cemctericr, and Jar.df.rapc e~or.tr actors.
Ii". regards to cemeteries, several caretakers were contacted to deter-
mine interest in and usage of orpar.ic soil sunn J events . One manager
generally displayed little interest, in an oraanic product: primarily
due. to the cemetery's current success with liquid chemical fertilizers.
A concern was also' noted durino this conversation regarding the use
of an organic product which mav emit odors, desnite reassurances to the
contrary. The other caretaker contacted, or, the other hand , demon-
strated a keen interest ir, the City's sludnc product. Presently, a
chemical fertilizer (Nipik) is collectively purchased for three
affiliated cernctr-ries in Alhuaufrquc and Santa Fe . Their combine^
expenditure ir. 19P1 equaled ?./,( ^ol lar/> t or. for approximate 1 v IS tons of
chemical fertiliser. Because tbry appeared to he minimal users, however,
it was realised that cemeteries alone do not justify wide-scale marketino
of City sludge .
Ir. conjunction with the cemeteries, several attempts were made to contact
private golf courses, knowing that ornanic soil SUPD! ements are ^eavilv
applied on the courses' oreens. PltHouph the surveyor was not able to
contact the maintenance personnel of any private course, one mav assume
that their application rates roughly approximate that of the cememteries-
That, being the case, hoth of these consumers would employ a mere frac-
tion of the City's projected quantity of sludge. Therefore, other users
were identified to supplement these potentially minimal market. s. To
this end, the surveyor telephoned a r.umher of commercial outlets and
landscapi no . contractors .
Jr. reference to retail outlets, three major nurseries were contacted.
Wlierea.c, t.wo of the nurseries each sell ten tons of soil fertilizer/
conditioner annually at more than "'.OO dollar/ton, the other doe?, not
carry ar, organic soil supplement. Rather, it pnckac.rs and markets
a brand name product consist ir.o of around-up bark which is ar, inferior
product. r.iiifC it does not contain fertilizer nn^ conditioning properties
and is totally void of essential ficro-nut rier.t .<- that arc pre.scnt ir,
.sludge. The in.inacer of this nurserv indicated thai apnj </ i n-at e- 1 v 20f)0
tons at. Ci(> do'J lar/ Ion is dispensed annually, -'ci'onsl iTil i nr i cc s i 5, right. Ti Viohi
of tlii:.. f'.ict-, the C'ity's sunncstrd cost of 70 do] 1 :\r / ton apf>ears. to
i-c fleet .1 nu'drst market pi'icc on ,i wlinlrs.ilc has is. At t.his wholesale
pjicc, it is he li over) th.it a private cntcrnrisr is assured of an
excel Jcnt ni.ircin (;f profit in retuilinc the product, should the Cily
deride not to enter 1 he retail m
1 r, nt-'dilion Lo retail outlets, the surveyor contacted several wholesale
fcrli 1 i .-.(. r distriliulor;.. In the course of the telephone survey, one
EXHIBIT
F-3
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-2-
mnnager war, very rcrxplivr to pureha.', i r,n< r
from the City. This ir.lcrcst was reciprocated bv the City since he
estimated lhat his firm could easily handle 1000 tons a vrar'at the
role of 120 dollar/ton. It was concluded from this conversation that
potential wholesale customers worthy of further consi deration exist
in Albuquerque.
Another large wholesale operator was contacted wHch does r.ot carrv a
true soil fertilizer/conditioner. Instead, it merchandises a heat -
treated steer manure which is less effective than sludae due to lack of
micro-nutrients. Last year the compar.v oroecsscd nr,-' banned ?OO tons
of the name - brand product and sold it in 50 Ib. sacks at the rate of
60 dollar/ton. As was the case with the other wholesale distributor,
this manager expressed much interest in the rjty's product. In fact,
several years ago he had initialed discussion with the Parks Depart-
ment requesting samples of sludge, however, to date he has r.ot received
any. Based on this demonstrated interest ns well r.f the expressed
market, potential he- vend current levels, this appears to be another
marketing outlet deserving follow-up,
The third distributor contacted is the primary provider in few Mexico
of Milorqanitc , a product nationally distributed by the Milwau'
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-3-
rcalistir to assume Dial an additional 10,OOO tor.s may also be used
in this rcg;ird. This estimate is primarily based on informal dis-
cussion:, held early or, in the planning pha.'.e of this project with
operators of sod farms and dairies located throughout the Albuquerque
area*
Therefore, when one combines commercial and residential users the current.
demand for a product of this iype may well exceed 20,000 tons. Based
on a population of one-half million, including the City and its
surrounding communities, this determined level of current demand appears
to be highly realistic. As the City's product is only 25% of the total
demand, we anticipate that the sale of sludge as a soil fertilizer/
condtioner will be feasible as well as cost-effective. Also lending
support to the City's marketing of sludge, is. the final recommendations
received from the Citizens' Advisory Committee (CAC), where a ten-vote
majority favored sludge recycling* Clearly, the current market capacity
as well as local citizen preference warrants the City's involvement in
an enterprise of this type.
F-5
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Some Typical Quantities of Materials Marketed
in Albuquerque (Partial List)
Contact
// tor,/year
$/ton
Product
Roland
Loeper
Greer, Acres
Albuq. Chemical
Desert Greer,
SW Toro
10
388.
10
2250
1000*
35R
66
120
200
60.
100 225,
*suqgested market.
mi 1 orqani t.c/
Roland Brand
mi 3 orqanite
Ground-up Bark
soil fertilizer/
cor.di tior.cr
Ground-un
Steer manure
miloroanite
F-6
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INDEX
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INDEX
Air quality l_5i 3_14j 3_18j 3_20, 3-21, 4-3
Albuquerque/Bernalillo County Comprehensive Plan 1-3
Alternatives 1-1, !_2, 1-4, 1-7, 1-8, 3-1, 3-22, 3-25
no-action alternative 1-7, 1-8, 3-22
Balloon report 3-10
Biological Resources 1-6, 3-15, 3-21
Cesium 137 Irradiation 1-4, 1-7, 3-5, 3-18, 3-21, 3-22, 4-2
Citizens Advisory Committee 1-9, 3-1, 3-10, 3-25, 6-1, 6-3, 6-5, 6-8, 6-9
6-10, 6-11
Clean Water Act 1-1, 4-1
Composting 1-8
Conditioning 1-4, 3-4, 3-25
Construction grants program ....1-1, 1-2, 4-1, 4-2
Conventional treatment systems 1-1, 1-2, 4-2, 4-3
Coordination 1-9, 6-1
Cost-effectiveness analysis ....1-2, 1-8, 3-1, 3-26, 3-29, 3-30, 4-1, 4-3, 4-4
Cultural resources 1-6, 3-16
Dedicated land disposal 1-8, 3-25
Dewatering 1-4, 3-1, 3-4, 3-21
Disinfection 1-4, 1-8, 3-1, 3-5, 3-22, 3-26
Dissolved air flotation 3-1, 3-4, 3-18
Drying beds 1-3, 1-7, 3-14
Earth resources 1-5, 3-12
Economic resources 1-6, 3-17, 3-21, 4-4
Electron beam ..1-8, 3-22
Endangered and threatened species < 1-6, 3-16
Energy 1-2, 1-6, 3-18, 3-21
Environmental health 1-7, 3-18, 3-21
EPA alternatives 1-1, 4-2, 4-3, 4-4
Erosion 1-5, 3-12, 3-13, 3-19
Facilities plan 1-2, 1-3
1-1
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INDEX (concluded)
Federal Register 1-2
Fugitive dust 1-5, 3-14, 3-18, 3-20
Funding 1-1, 1-2, 1-4, 4-1, 4-2, 4-3
Groundwater quality 1-5, 3-13, 3-18, 3-20
Innovative treatment systems 1-1, 1-2, 1-8, 1-9, 4-2, 4-3
Land application of sludge 1-2, 1-3, 1-4, 1-5, 1-8, 3-1, 3-8, 3-13, 3-22
Land use and values 1-6, 3-16, 3-21
National Environmental Policy Act (NEPA) 1-1
Noise 1-5, 3-14, 3-20
Non-point source pollution 3-13
Odor 1-3, 1-5, 3-8, 3-14, 3-20, 3-26, 4-3, 4-4
Public participation/meetings 1-9, 6-1, 6-3, 6-4, 6-7, 6-9, 6-10
Recreation 1-7, 3-19
Resource conservation/recovery 1-1, 1-2
Sludge, beneficial uses 1-2
Sludge management 1-3, 1-4, 1-5, 3-10, 3-14, 3-29
Sludge stockpiles 3-8, 3-14, 3-18
Sludge value 1-8, 4-1
Socio-economic conditions . 1-6, 3-17, 3-21, 4-4
Soils 1-5, 3-12
Solar greenhouses 1-4, 3-5, 3-14, 3-22, 4-2
Surface water quality 1-5, 3-13, 3-19
Thermal conditioning 3-11 3-25, 3-26
Unavailable impacts 1-71 3-19
1-2
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