-------
PROJECT NO-
CLIENT-
JBushkill EIS
WAPQRA, inc.
Environm*ntBl/En«rgy/Economlc Studies
SHEET-
-OF.
PREPARED BY
JCV
29 April 1980
SUBJECT-
OFFICE-
PUMP STATION # 6_
Dia. = 4"
PUMP STATION ANALYSIS
CHECKED BY.
DATE
Pump Sta:
0 = .004 MGD
V = .5 fps
H Static
470
Qp - .011 MGD
V = .5 fps
430
40r
H Friction = 3000' @
H Misc.
.01 '/.
1'
10'
TDK
51'
0.15
Pump Sta: Capital Cost $27,750 x .0953 =
0 & M
2,645
1,480
Ferce Main: ' 3000' @ $14 /Ft.
0 & M = $42,000 * 50 yrs.
$42,000 x .0953 = 4,003
840
TOTAL ANNUAL COST = $8,968
Yearly Energy Requirement = 189 X TDK(ft.) X FLOW(mgd) X 365 days/yr.
0.75(pump eff.) X 0.85(motor eff.) X 60
= 1804 X 51'
TDH
.004
FLOW
368
KWH/
119
-------
JKOJECT NO.
&
. iLi-.r --
JUJECT _
OFFICE
WAPORA, Inc.
Environm»nt»l/En»r0y/Economlc Studies
PUMP STATION ANALYSIS
PUMP STATION # 9_
Dia. = 4"
JCV
SHEET—__ OF .
PREPARED BY
nnrr 2Q April 1Q80
CHECKED 8V
OATE_
Pump Sta:
Q =
V =
0.017 MGD
fps
0.3
QP
V
0.043
0.8 fps
H Static = 540
H Friction = 3.800'
H Misc.
460
@ 0.12
80'
10'
TDK
Pump Sta: Capital Cost $40,700 x .0953
95'
1.1
3,879
0 & M
2,220
Feree'Main: ' 3.800' @ - 14 "/Ft. = $53,200 x J0953
0 & M = $53,200 * 50 yrs.
5,070
1,064
TOTAL' ANNUAL COST
$12,233
Yearly Energy Requirement = 189 X TDH(ft.) X FLOW(mgd) X 365 days/yr.
0.75(pump eff.) X 0.85(motor eff.) X 60
1804 X 95'
TDK
.017
FLOW
2,913
KWH/y
120
-------
6.0 DESIGN FLOWS
(Average Flow in MGD)
Flow @ F]-°W Compound
Alternate Nazareth To Easton Total
1. Proposed Action - 2.401 2.40 mgd
2. Modified Action - 1.234 1.234 mgd
3. Alt. 9 (MOD) 0.85 0.255 1.105 mgd
IF!OW Value obtained from Eric Hediger
by phone, 27 May 1980
121
-------
Table V-l
EIS ALTERNATIVES
DESIGN POPULATION/AVERAGE DAIL* FLOW (MOD)
Municipality
Platnlield Township
Bushklll Township
Upper Nazareth
Township
A
Nazareth Borough
Palmer Township
Tataay Borough
Scockertouu Borough
Modified EA Pro-
posed Action
2,288/0.165
860/0.041
1.074/0.083
5.843/0.705
634/0.046
1.360/0.107
821/0.067
Alternative 1
1.938/0.128
165/0.010
1.046/0.076
5.843/0.705
90/0.006
1.360/0.102
821/0.065
Alternative 2
1.986/0.127
165/0.010
1.046/0.076
5.843/0.705
90/0.006
1.360/0.102
821/0.065
Alternative 3
2,288/0.185
508/0.026
1.052/0.076
5.843/0.705
435/0.031
1,360/0.102
821/0.065
Alternative 4
1.938/0.141
165/0.010
1.046/0.076
5.843/0.705
435/0.031
1,360/0.102
821/0.065
Alternatives
5 & 9
1.938/0.141
165/0.010
1.046/0.076
5.843/0.705
90^/0.006
1,360/0.102
821/0.065
Alternatives
6 & 10
2.288/0.185
508/0.024
1.074/0.083
5.843/0.705
90/0.006
1.360/0.102
821/0.065
Alternative 7
2.288/0.185
508/0.024
1.074/0.083
5.843/0.705
435/0.031
. 1.360/0.102
821/0.065
Alternative 8
2.288/0.185
508/0.024
1.074/0.083
5.843/0.705
435/0.031
1.360/0.102
821/0.065
TOTAL
11.263/1.092 11.311/1.091 12.307/1.190 11.608/1.130 11.263|
Includes eatlre existing sewered area lor the Nazareth STP.
tKor Alternative 9. Palmer Township: 435/0.031
11.984/1.170 12.329/1.195 12.329/1.195
CM
CM
Source: WAPORA Draft EIS
-------
7-0 PROJECTED AVERAGE ENERGY CONSUMPTION BY RESIDENTIAL DEVELOPMENT, YEAR 2OOO
' (in MJowatt-hours/ye-ar)
Baseline
AFA
HAP A
Al.T. 1
ALT. 2
ALT. 3
ALT. 4
ALT. 5
Al.T. 6
ALT. 7
AI,T. 8
ALT. 9
Al.T. 10
S INKLE FAMILY UNIT DEVELOPMENT
Projected
Energy Consumption
Without Project
(kwh/yr)'
1,185,200,000
Projected
Energy Consumption
With Project
(kwh/yr)
1,773,900,000
1,342,500,000
1,312,400,000
1,309,400,000
1,327,400,000
1,282,100,000
1,218,400,000
1,330,200,000
1,327,200,000
1,327,200,000
1.2J8, 400,000
1,330,200,000
MULTI-FAMILY UNIT DEVELOPMENT2
(apartments, etc.)
Projected
Energy Consumption
Without Protect
(kwh/yr)
200,240,000
Projected
Energy Consumption
With Project
(kwh/yr)
429,200,000
268,740,000
237,790,000
237,790,000
239,990,000
206,100,000
214,320,000
241,900,000
221,650,000
221,650,000
214,320,000
241,900,000
TOTAL DEVF.LOPMENT
(single and multi-family units)
Projected
Energy Consumption
Without Project
(kwh/yr)
1 ,385,400,000
Projected
Energy Consumpi
With Frojerl
(kwh/yr)'
2,203,100,00
1,611,200,00
1,550,200,0(1
1,547,200.00
1,567,400,00
1,488, 200, Of
1 ,432,700,00
1 ,572, 100, Of
1,548 ,900, Of
1 ,548, 900, OC
1,432, 700, Or
1,572, 100, Or
ro
oo
Energy consumption hy single Family units = 528 x 10 BTll/yr (154,600 kwh/yr)
Energy ronsumptlon hy multl-tamlly units = 501 x 10 BTU/yr (146,690 kwh/yr)
Source: Manujij^ tor Evaluating Secondary Impacts o[ Wastewater Treatment Facilities, USEPA 1978.
-------
ESTIMATED LOCAL USER CHARGES
Alternative
Alt. 9 (RBC)
Alt. 9 (OD)
Alt. 9 (MOD) (RBC)
Alt. 9 (MOD) (OD)
Modified Proposed
Action
Proposed Action
Capital
Cost
$11,553,579
$9,413,579
$11,228,395
$9,088,395
$11,143,977
$13,720,337
Local
Share
(25%)
$2,888,395
$2,353,395
$2,807,099
$2,272,099
$2,785,994
$3,430,084
Annual Equiv.
of Local
Share (.0953)
$275,264
$224,279
$267,517
$216,531
$265,505
$326,887
Annual
0 &M
$358,678
$248,678
$345,677
$235,677
$327,476
$582,658
Total Annual
Cost to
Local Citizens
$633,942
$472,957
$613,194
$452,208
$592,981
$909,545
Month]
Cost Pe
Family
% /& . So
/" l£>. 31
'"•**
t 37,5-
\t--> ( rfit, i 'i
CM
^Monthly Cost Per Family
Total Annual Cost
"Families x 12 mths/yr.
(lie 31)
10, is i »a,ffo ***<*
4477
3 -t?
j.o
-------
APPENDIX D-3
ENGINEERING EVALUATION OF DRAFT EIS
(included by reference)
125
-------
Projected Average Electric Power Consumption by Residental Development, Year 2000
(in kilowatt-hours/year)
Baseline
APA
!1APA
ALT. 1
ALT. 2
ALT. 3
ALT. 4
ALT. 5
ALT. 6
ALT. 7
ALT. 8
ALT. 9
ALT. 10
SINGLE FAMILY UNIT DEVELOPMENT1
Projected Projected
Energy Consumption Energy Consumption
Without Project With Project
(kwh/yr) (kwh/yr)
165,570,000
247,810,000
187,550,000
183,340,000
182,920,000
185,440,000
179,110,000
170,210,000
185,830,000
185,410,000
185,410,000
170,210,000
185,830,000
MULTI-FAMILY UNIT DEVELOPMENT2
(apartments , etc . )
Projected Projected
Energy Consumption Energy Consumption
Without- Project With Project
(kwh/yr) (kwh/yr)
23,069,000
49,448,000
30,961,000
27,396,000
27,396,000
27,649,000
23,745,000
24,692,000
27,869,000
25,536,000
25,536,000
24,692,000
27,869,000
TOTAL DEVELOPMENT
(single and multi-family units)
Projected Projected
Energy Consumption Energy Consumption
Without Project With Project
(kwh/yr) (kwh/yr)
188,639,000
297,258,000
218,511,000
210,736,000
210,316,000
213,089,000
202,855,000
194,902,000
213,699,000
210,946,000
210,946,000
194,902,000
213,699,000
<£>
CVJ
1 General electric power consumption by single family detached units (assumes units are electrically-heated) = 21,600 kwh/yr
(Source: Pennsylvania Power and Light Company, 1980).
2 General electric power consumption by multi-family units (i.e., apartments) (assumes units are electrically-heated = 16,900 kwh/yr
(Source: Hylton Enterprises, Inc., 1979 and Pennsylvania Power and Light Company, 1979).
-------
Estimated Electrical Usage (kilowatt-hours/year) for New Residential
Units in Lake Ridge (Sections 12-15)
Woodbridge, Virginia
RATE (Source: Hylton Enterprises, Inc., 1979)
Single Family Detached
Single Family Attached
Apartment Units
21,456 kwh/yr
19,872 kwh/yr
16,800 kwh/yr
PROJECTED MAXIMUM RESIDENTIAL ELECTRICAL CONSUMPTION
TYPE HOUSING
Single Family Attached
Single Family Detached
Garden Apts./Townshouse
Condominums
NEW
UNITS PROPOSED
1,663
983
751
CONSUMPTION
RATE
1,656
1,788
1,400
TOTAL kwh/yr
33,047,136
21,091,248
12,616,800
TOTAL
66,755,184 kwh/yr
Average Daily Use = 2,225,172 kwh/yr
127
-------
APPENDIX D-5
PROCESS ADVANTAGES AND DISADVANTAGES OF
ROTATING BIOLOGICAL CONTACTORS AND OXIDATION DITCHES
Treatment
Alternative
Advantages
Disadvantages
Oxidation Ditches
1. Stable process when
proper sludge manage-
ment is performed.
2. High quality effluent.
3. Predictable process.
1. Icing of aerator
supports and nearby
area must be con-
sidered.
2. Major maintenance
required crane to
remove equipment.
3. Drive units require
higher maintenance
frequency.
4. Requires good operator
skills and routine
monitoring.
5. Sufficient oxygen
supply should be pro-
vided for nitrifica-
tion and pH may need
to be controlled.
6. Only one type of aera-
tion device is applic-
able.
Rotating Biological Media
1. Stable process.
2. Good quality effluent.
3. Simple operation.
4. Low maintenance, as
a general rule.
1. Effluent quality is
not as predictable as
suspended growth process.
2. Heavy load on first cell
may cause odors.
3. Multiple drives of larger
plants afford propor-
tionally higher mainte-
nance requirements.
4. Shaft and drive failures
have been experienced
and require major mainte-
nance.
SOURCE: Design Seminar Handout, Small Wastewater Treatment
Facilities. EPA, 1979
5. Oil leaks from drive
units are common.
6. Larger plants require
more space than equal
size suspended growth
systems.
128
-------
APPENDIX D-6
From Town and Country Sewage Treatment Agricultural Extension Service,
University of Minnesota, Roger E. Machmeier.
Collector systems
Collector systems are used by two
or more property owners jointly own-
ing a soil treatment unit (figure 16).
Individual septic tanks are used for
each home to separate sewage solids.
The effluent generally Hows by
gravity into the collector line to the
main pumping station. Sometimes
additional lift stations are required
along the collector line. The sewage
effluent is pumped to where the soil
is suitable for the installation of a
soil treatment unit, preferably a
drainfield trench system having drop
boxes.
When property owners join to-
gether in a project, competent legal
advice is needed to develop an
agreement on easements for the col-
lector and pressure sewer lines,
mutual ownership of portions of the
sewage treatment system, operation
and maintenance responsibilities for
mutually owned portions, mainte-
nance schedule for individual septic
tanks, assessment of initial costs to
each lot, other uses for (he common
soil treatment area, and similar
questions.
Property owners must agree on
organizational and operational de-
tails before the sewage treatment
system can be designed. Success of
the group system depends on mutual
cooperation and understanding by all
participants as well as proper design,
installation, and maintenance.
The most trouble-free collector
systems are where each residence
has an adequately sized septic tank
based on the values in table 1. Then
the collector line carries only ef-
fluent, and the pipe grades are not
as critical as when the sewer carries
raw sewage. Also, because the solids
have been retained in the septic
tanks, sewage ejector or sewage
grinder pumps are not required.
High-quality submersible sump
pumps, which are relatively
inexpensive, are adequate for the lift
stations and the main pumping
station.
The collector sewage line must be
watertight and strong enough to wiih-
stand any forces placed upon it. Pro-
tect the collector line against freezing.
If soil conditions prohibit burying (he
line deep enough to avoid freezing,
either insulate or provide heat.
The diameter of the collector line
should be at least 4 inches, which is
usually adequate unless more than 25
homes are involved. If more homes
participate, the relative location of
the homes and the pumping tank
determines if a larger diameter col-
lector line is needed.
The collector sewer line must be
watertight so that infiltration or ex-
filtration (leakage) is not greater than
200 gallons per inch of pipe diameter
per mile per clay. To illustrate, a 4-
inch collector 1/2 mile long should
have no more leakage than 400 gal-
lons per day (200 x 4 x 1/2).
Install cleanouts on the colleclor
sewer line. Cleanouts should extend
flush with or above finished grade
and must be located wherever an
individual sewer connects to the col-
lector line or every 100 feet, which-
ever is least. If manhole access is
provided on the collector sewer, the
manholes can be placed farther apart
than 100 feet, depending upon the
type of cleanout equipment.
Table 1. Recommended septic
tank liquid capacities
Number of
bedrooms
2
3
4
5 or 6
7, 8 or 9
Minimum liquid
capacity, gallons3
750
1,000
1,250
1,500
2,000
aLiquid capacity is the tank volume below the
outlet. An additional internal volume equal to
20 percent of the liquid capacity is needed (or
floating scum storage.
Figure 16. A collector sewer system with a common soil treatment unit
PRAINFIEl.D TRENCHES
WITH DROP BOXES v
LOT AND
HOUSES
129
-------
Collector systems (continued)
When raw sewage Hows inlo a
centrally located septic tank, the
sewer tnusl give mean velocities of
not less than 2 feet per second at full
flow. Cleanout or manhole access to
the sewer is important. A local con-
tractor or plumber can help select
sewer line diameters and grades.
The septic tank effluent is col-
lected into a main pumping station.
The pumping tank must be water-
tight. Manhole access must be pro-
vided for cleaning and maintenance.
The manhole cover must be flush
with or above finished grade and se-
cured to prevent unauthorized entry.
To estimate the amount of sewage
flowing in a collector system, classify
each home as type I, II, III, or IV
(table 4). Estimate the sewage flow
from each residence using (able 4.
Add a .Vbedroom type I home for
each platted but undeveloped lot.
Total the flows to determine the es-
timated daily sewage flow for the
collector system.
Pumping tank capacity should in-
clude the pump-out quantity as well
as reserve storage in case of power
failure. A suggested minimum pump-
out quantity is 10 percent of the daily
sewage flow or 200 gallons, which-
ever is greater. A suggested reserve
storage capacity is 25 percent, of the
daily sewage flow or 500 gallons,
whichever is greater. The pumping
Manhole access is necessary for septic lank and pumping tank maintenance. The
manhole cover should be secured to prevent unauthnri/ecl entry
130
-------
Collector systems (continued)
tank capacity also must include the
minimum submergence depth re-
quired for the pumps.
As an example, assume a collector
system is to be designed for 20 homes;
5 are 3-bedroom type F (450 gallons
per day per home, table 4); .10 are 3-
bedroom type II (300 gpd); and 5 are
2-bedroom type III (180 gpd). The
total estimated daily sewage flow is 5
x 450 + 10 x 300 + 5 x 180 = 6150
gallons.
For the 20 homes, the suggested
minimum pump-out quantity would
be 615 gallons (0.10 x 6150); the sug-
gested reserve storage capacity would
be 1040 gallons (0.25 x 6150). A 6-
inch minimum submergence depth
for the pump might be another 250 to
300 gallons, the actual amount de-
pends on tank surface area. Thus, the
suggested pumping tank size is
approximately 2000 gallons. This
volume could be obtained with a
single tank or two or more tanks
connected in series. Tanks in series
must be connected by watertight pipe
at both their tops and bottoms. One
of the tanks must have a vent at least
2 inches in diameter to allow air to
enter and leave the tank during filling
and pumping.
For a group system, always install
dual pumps that operate alternately.
The pump control should have a
warning device to advise of either
pump failure. In addition, a liquid
level warning device must be installed
on a separate electrical circuit to warn
of pump circuit failure.
In a collector system, use electrodes
or mercury switches for pump con-
trols. These allow for easy pump re-
placement and also simple adjust-
ment of pump-out levels if the
number of participants increases.
The pump will have to handle the
maximum inflow rate of sewage to
the pumping station. Sewage dis-
charge data from residences suggest
that the pump should be capable of
pumping at least 25 percent of the
total estimated daily sewage flow in a
1-hour period at a head adequate to
overcome elevation and friction loss.
The minimum pump capacity should
be at least 1,200 gallons per hour. If
the inflow becomes faster than a
single pump can handle, the second
pump will start.
Size the soil treatment unit based on
the percolation rate of the soil and the
estimated total daily sewage flow. For
the example above with 20 homes and
an estimated daily sewage flow of
6150 gallons, assume that a site is
available with a percolation rate of 10
MPI.
From table 4 on page 22, 1.27
square feet of soil treatment area is
required for each gallon of waste per
day. The total required trench bottom
area is 7810 square feet (1.27 x 6150)
if 6 inches of rock are used below (he
distribution pipe. If 12 inches of rock
are used, the trench bottom area can
be reduced by 20 percent to 6260
square feet (0.80 x 7810). This is 2083
lineal feet of 3-foot wide trenches, or
21 trenches each 100 feet long.
The trenches could extend 100 feet
each way from a drop box. Thus, 11
drop boxes would be required and it
would be advisable to install 22
trenches providing a small factor of
safety. If the trenches were spaced 10
feet from center to center, a lawn area
110 feet wide by 200 feet long (1/2
acre) would be needed for the soil
treatment unit.
Place the soil treatment unit as
far as possible from any drinking
water supplies. Sewage tank effluent
can easily be pumped a mile if there
are no natural barriers, such as rivers
and swamps. If an adequate area is
available, space the trenches 10 to 12
feet apart. Use 6 to 12 inches of soil
cover to maximize evapotranspiration
during the summer.
131
-------
Collector systems (concluded)
A collector sewer line for effluent serves these lakoshore cabins Each cabin has its
own septic tank.
Figure 17. Requirements for a holding tank
4" PIPE FOR ACCESS
TO INLET —7
A •&-
HOLDING TANK
rHOUSE
\SEWER
6 CLEANOUT-
PIPE WITH
TIGHT CAP
4" TO 12" OF V
* EARTH COVER
MANHOLE —'
<2O" LEAST DIMENSION)
TANK CAPACITY = 2,000 gallons minimum
or 40O gallons per
bedroom, whichever is
greatest, for other
establishments, 5 times
the daily flow rate.
TANK MUST BE WATERTIGHT
WATER FLOWING INTO SEWAGE
SYSTEM MUST BE METERED
Each member of the group should
own an undivided share of the soil
treatment site. Since grass cover must
be maintained over the trenches, the
treatment site can be used as a play-
ground or picnic area. However, do
not allow heavy vehicles on the drain-
field trenches, and prohibit foot
traffic and snowmobiles on the
trenches in the winter. Establish a
good grass cover, and allow natural
snow accumulation to protect against
winter freezing.
Several collector systems have
been installed in Minnesota, and
more are under construction. It is a
technically sound and economical
alternative for sewage treatment. Col-
lector systems for small groups of
homes can usually solve sewage treat-
ment problems on small lots without
the large expense of municipal
sanitary sewer.
Among group systems installed in
Minnesota, the cost per lot has been
about the same as for adequately
sized individual systems. Costs of
collector lines and the common soil
treatment unit have ranged from $800
to $1,200 per lot, depending on treat-
ment site accessibility, land cost, and
the soil percolation rate (which de-
termines soil treatment unit size).
132
-------
APPENDIX E
LETTERS OF COMMENT ON
THE DRAFT EIS
133
-------
LAW OFFICES
CHARLES S. SMITH
SUITE 6O6
FIRST NATIONAL BANK BUILDING
4TH AND NORTHAMPTON STREETS
EASTON, PENNSYLVANIA I8O42 AREA CODE HIS
CHARLES S. SMITH 253-27IB
CRAIG j. SMITH March 21, 1980
Mr. Jack J. Schramm
Regional Administrator
Region 3
U.S. Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Re: B-LLJSA response to U.S. Protection
Agency Environmental Impact Statement
regarding B-LLJSA Project
Dear Mr. Schramm:
As counsel to B-LLJSA I enclose herewith the B-LLJSA comments
pertaining to the above mentioned draft of the EIS.
You will note that the report consists of comments from the
Authority and Appended technical commentaries from the Authority's
engineers, Gilbert Associates, Inc.
The enclosed report speaks for itself. However, I should like
to emphasis the Authority's deep concern about the erroneous data
and conclusions found throughout the EIS. These pertain to many
different facets of the EIS and effect conclusions on induced growth,
environmental concerns, zoning and municipal flood plain zoning, and
last but not least, costs. The Authority is also deeply concerned
about the fact that although the basic configuration of the project
as originally approved is reaffirmed, with the exception that Bushkill
Township is to be studied further, and Upper Nazareth Township is to
be studied with respect to a tie in with the proposed new Nazareth
plant, the method of transportation of the sewage to the City of
Easton has been recommended to consist primarily of high pressure
lines and nine pumping stations, which contrast with the B-LLJSA1s
proposal of all gravity lines with the exceptions of two pumping
stations. In view of the severe national concern for energy con-
servation, and in view of the fact that this will engender the
necessity for very substantial redesign which will of course delay
the project severely, we urge that the gravity system be reaffirmed.
One final comment. The report recommends that Upper Nazareth Township
which the report concedes has severe pollution problems, be connected
to a proposed Nazareth Treatment Plant which is now privately owned.
Our report sets forth the extreme problems to be encountered in such
a proposal which will not only delay a solution to Upper Nazareth
Township problems for many more years, but will also prevent Upper
Nazareth Township and the Borough of Nazareth from considering any
other alternative. By eliminating the North-South Schoeneck Inter-
134
-------
Mr. Jack J. Schrainm
Page 2
March 21, 1980
ceptor and the East-West segment and substituting a high pressure line
with a pump on Northwood Avenue and eliminating the gravity line on the
Little Bushkill from Plainfield Township to Palmer Township and sub-
stituting a high pressure line with numerous pumps, will mean that if
the Borough of Nazareth were to decide to acquire the present plant,
demolish it and build a new one, this is the only alternative left no
matter what the cost. We submit that by permitting the entire Schoeneck
Interceptor to be built for Upper Nazareth Township this will provide an
alternative in the event that the new plant proposal is never realized.
Further, it provides a means of promptly elevating the present serious
hazardous pollution problems in Upper Nazareth Township, which will
otherwise of necessity be delayed 7 to 8 years before the new plant
problem can be resolved.
Lastly, a P.L. 92-500 grant was awarded the City of Easton to expand
its plant, interceptors and pumps to accommodate the B-LLJSA. To severely
reduce the scope of the B-LLJSA project will engender extremely serious
litigation problems by the Authority and the Easton Area Joint Sewer
Authority with respect to reserve capacity, membership as a part of that
Authority, and with respect to the amount of obligation owned to that
Authority. I think it then becomes apparent that a consideration of a
new plant in Nazareth while at the same time the Easton plant would be
grossly oversized, and no chance of ever being utilized to its capability,
is inconsistent with national concerns for energy conservation and prompt
solutions to existing serious health problems.
Very truly yours,
r,
Charles S. Smith7 L
Solicitor for B-LLJSA
CSS/jaf
Enc.
cc: Mr. Wolfe
Mr. Alan Mead
c/o Gilbert Associates, Inc.
Each Authority member
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BUSHKILL-LOWER LEHIGH JOINT SEWER AUTHORITY
NORTHAMPTON COUNTY. PENNA.
P. O. BOX 400, NAZARETH, PA. 18064
FORWARD
The commentary to the Draft EIS is designed to develop detail
as progression Is made through the document. In review it was
foun<3 that scope of commentary by necessity Is very broad.
Condensed commentary can only be expressed In terms of serious
errors In degree, omissions and resultant Illogical recommen-
dations. A short summary of salient points Is made followed by,
more voluminous Illustrated detail.
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BUSHKILL-LOWER LEHIGH JOINT SEWER AUTHORITY
NORTHAMPTON COUNTY. PENNA.
P. O. BOX 40G, NAZARETH, PA. 18064
OVERALL GENERAL SUMMARY
1. Serious errors with a hie-h derrree of "laenitude (i.e. 100^ to
are present In the Draft Elb. T^ese errors mlslesd the public in
basic understanding of the B-LLJSA Proposed Action and In the
alternatives addressed. The errors encompass floodplsin, Induced
erowth, stream environ^er.t and zonin.? as well as costs. The
conclusions reached and actions recommended are accordingly
effected.
?. Needs of the area were recosrnized 1^ years ago and means of
addresslrip- those needs were Initiated in 1966. The Draft SIS
as-ain confirms the needs with more advanced technology relative
to surface malfunctions. For other than surface malfunctions
(i.e. sub-surface) little or no determination was accomplished
leaving serious questions onen in suspect areas with needs
determination neither confirmed nor denied.
3. The lone standing needs and resultant health hazards are not
being addressed and resolved in an expeditious manner.
k. Environmental conclusions are in part based upon grossly
erroneous stream crossings (29) vs (l?). 1973 Initial planning
vs "B" Submittal and detailed construction drawings apparently
represents the fallacy in -oroducing this vital statistic.
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5. The environmental state of Schoeneck Creek is deplorable,
representing classic indications of pollution. No resolution
of this stream is recommended, in fact recommendations perpetuate
the condition. The Bushkill Creek and Palmer Township unfortu-
nately receive the unresolved results.
6. Induced growth evaluations attributed to the proposed action
in the Draft SIS are not compatible with the existing experience
of local municipalities, both sewered and unsewered. Serious
discrepancies exist and are Illustrated.
7. Ploodplain evaluation in the Draft EIS ignores local ordinances,
federal financing regulations and literal physical character-
istics. This is even more pronounced in consideration of the
Schoeneck Creek.
8. Citizens of Upper Nazaret^ are doomed to high premiums to
resolve need problems due to erroneous and misleading cost
comparisons.
9. Citizens of the Borough of Nazareth are not being Informed of
relative high costs of be in or restricted to a Nazareth Treatment
Plant precluding a well based decision In resolving the existing
serious problems.
10. When usin? established cost data from EPA Manuals, amongst other
data, Nazareth and Upper Nazareth are being directed to pursue
a course which represents a premium of 300 to
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11. wasted additional federal money is recommended in the Draft EIS
to build a second plant at Nazareth where one at Easton is
already designed, funded and built to accommodate the flow.
1?. Federal Energy Directives are ignored in the Draft EIS through
indiscriminate use of pumps, pumn stations and force mains.
1?. Many existing contracts, agreements, resolutions and ordinances
involviner vested interest, local voice in operation, local
voice in control, obligations, responsibilities, highway
occupancy, railroad crossings and extensive rlerhts of way are
being imperiled by the previously noted erroneous recommended
actions and little or no consideration of the extensive delay.
Ik. The Easton Treatment Plant in the Draft EIS is treated as a
mere plant expansion from 5 to 10 MOD with a change in pro-
cessing to RBC. It completely ignores the reconstructed
interceptors to ^2" diameter. It completely ignores the
construction of 2 Inverted.syohons on the Bushkill Creek.
It conroletely ignores a second ecually sized inverted syphon
across the Lehlgh River. It. completely ignores doubling the
size of two large pump stations. Tv^e plant is B mere 6<3% of the
total Easton funded project.
15. The Draft EIS ignores the declined population of Easton and
the agreement which provides less capacity for the city with
some previously existing capacity and all new capacity allocated
to the surrounding municipalities.
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3c;ds cf the study area ere Icr-' stsrdinjr, having- beer, acted upcv.
ir.cs the esrly 196C's. The twentieth anniversary will shortly be
^ocr. us while the hazards still persist. Solutions arid studies
.-,vo rv_". the scsuntlet from 3 multiplicity of iocsl rr.unicipal ar.d
-j"o -municipal treatment sites co reprior^sl ccr.cepts and bsck s,"8lr,,
i'cy sna suburban concepts have beer1, studied. The regional corce'ot
as beer,, ir. nhe past ar.d-a^air. in the Draft Eli, proven to be the
r.oit beneficial to the areas to be served.
. -rte
_.; state, interstate and r.Stier.si agencies have rr.sde vsciilc
itis known, save strong dictates to planning and directed
1/.1S at the scope was studied, "-hese criteria have been dccu-
ed with SPA and represent a history spanning over eight spec
a needs of the study area were recognized with studies
.•'.l^.sted in the early 19oO's. A i;orks Township report was conrplc--:-_ .
• - :...v--i April, 19o3, recom.nendiriT a treatment plsnt on the Bushkil^
*:\ • .•: at 2uckviil. An addencurr. report ^.sted April, 1965 reaffirm---
, township treattr.ent plant. A Calmer T'cvrsship Feasibility Study v;oo
io.."o"_eted in 1965. It recorr.tr.ended to>Jrship treatment plants or tho
5^s'.-.kili Creek and Lehigh -iver. A 1963 ?orks Township report ccr.-
'. 5ored treatrr.ent in Easton.
- -.e rr.id 1960's produced a Corr.T:Onwe5ith of Pennsylvania requireir.ent
,s noted in the Draft SIS knov;n as the Pennsylvania Sewase Facilitic
• ct. This act requires each Tnur.ici-oslity to file a sewer facility
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r>l'vr. '"ho resultant studies 3rd plans t>roduced municipal treat-
,„,-.>-,!-, -ites on the horizon at Belfast, Stockertown, Tats my,
N"• r •-;••:-• th , Palmer and Forks. An example of a treatment site reelirc'"
in V,-ls -oeriod is the Wind C-ax: 3T?. The report is documented in
t;>m. v66 JPC Comprehensive Plan.
Motvr.?lly s concern arose by the late 1960's when viewing sever
o10 ol'^t local sites mainly effecting the Sushkill Creek.
ir'vi^or.mental concern brought about the formation of the Bushki.l 1-
.1'0".7er Lehlrh Joint Sewer BoRr^ in 1966 consistinfr of Ik munici-
palities of the ares involved. This body meticulously selected r?r
ov-.-7<_np:nv.inp" firm (GAI) and s '^?sic feasibility renort was rsroduce^
ir 1970. The Pennsylvania De^^rtment of Health (fore-runner of DSH;
ner f-r. John P. Durr's letter of 3-9-70 emphatically specified s
regional approach to the solution along with the comprehensive
•olan of the Delaware River Basin Commission which as amended
July 31, 1968 states " The use of regional water pollution
control facilities wil be required throughout the Delaware Elver
B3sln ?
Forks r-nd Palmer Townships initiated snd built the initial segments
toward the regional dictates. Both initial projects received
significant federal grants through the Federal Water Pollution
Control Administration (FWPCA) and The Department of Housing and
Urban Development (HUD) for basic regional interceptor or trunk
sewers.
Following all this basic endeavor the Bushkill- Lower Lehigh Joint
S«w°r Authority was formed the l?th o^ June, l^??. Initially it
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was ''ormed. by four municipalities namely Plalnfield and Palmer
Townships alone- with the Borous-hs of Tstamy and Stockertown. The
Authority was expanded with the Addition of Upper Nazareth and
Bushkill Townships by 197^-.
The Authority promptly initiated surveying and engineering of the
interceptor and collector system; in later time to be designated
Phase II. At this point in time Penn DER Parks Division issued a
letter of intent to contract with the Authority. to design and
build an extension of the system into the State Park, following
throusrh on its approved master plan to protect the Bushkiil Creek.
In 197^ the Commonwealth, in view of the even then long standing
requirements, placed the BLLJSA in high priority and in the fundable
area of the Pennsylvania sewer projects priority lists following
similar priority with the Easton project. In addition, a DEfi
construction permit was issued to the Authority with the proviso
of treatment at Egston.
With all basic premises established a public meeting was held at
Ngzgreth Area HierVi School. It was also pertinent to establish and
accomplish a multiple list of contracts and agreements to facili-
tate the premise. These agreements and contracts involved:
1. Treatment at Easton
?. Use of and transport through the regional, already built
Forks-Palmer Bushkill Interceptor
3. Bank loans to accomplish the work, especially in view of
the absence of Phase I & II (i.e. pipeline project)
*K State Park Contract
5. Sewer Extensions
6. Hiptits of '/Jay
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7- Permits - Blasting etc.
8. Highway Occupancy
9. Kailroad Crossings
The agreement or contract with the City of Easton was one of
prime importance. The City of Ess ton had a 5MGD sewer treatment
plant and only needed. *i-KGD capacity. The city therefore would
^i"oceed to expand only if surrounding municipalities paid for all
t'"^ costs. In fact, the agreement illustrates that 100,000 gallons
per day were sold to the surrounding municipalities. The city
retained iJ-MGD for their use. 6MGD is for use of surroundine
communities. The city was not interested in transferring1 their
jrrant to the surrounding municipalities for a second plant since
t>e then existing plant required approximately $2,500,000 in
significant repairs. Studies conducted by BLLJSA showed a 2nd
plant to be a trade off with an expanded Easton Plant. The then
Secretary of DER directed the Authority to participate in the
expansion of the Easton Plant throug-h his January, 1976 letter.
Tv-e inter-municipal agreement then proceeded to completion in
June of 1976. Eleven municipalities including the BLLJSA
communities and the Authority signed the agreement.
The agreement takes into account two adequately sized inverted
syphons crossing- the Bushkill Creek in Easton. It provides for
a U?" diameter interceptor from the inverted syphon to downtown
Easton. It provides for expanding two larsce pumping" stations in
Saston. It provides for doubling the size of the line across the
Lehio-h Blver by installing a second equally sized crossing:. It
provides for increasing the sewage treatment capacity from 5 to
10 MGD.
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An agreement with the Commonwealth of Pennsylvania relative to
the Authority building and maintaining an interceptor sewer
system in the park was cdmpleted in 1977 and signed by the
Governor and eight addition.?! officials. A special act was
massed by the state legislature to accommodate rights of way
in the nark. Money was provided an^ park plans were reviewed
with the Authority and its engineers. Interceptor sewer lines
were carefully reviewed and in cases re-designed to assure
minimum stream crossings and respecting the concerns of the
Jacobsburg Historical Society.
A Forks - Palmer agreement was reached for use of the adequately
sized Bushkill interceptor from Penn Pump Park to the 13th street
stream crossing in Easton.
Bank loans and agreements were Initiated by the Authority to .pay
for the required, work necessary to make the "A" Submittal and to
be in the position of havine- paid bills for fundable work when
"A" approval was received. Provisions were made to fulfill the
Easton Transport and Treatment Agreement. It additionally saved
or. the degree of interest money reouired.. The loans were, and
are, unsecured being based upon the written advice of DER and
EPA that the project was 'fundable.
Some of the more significant requirements' of the previously
noted necessary work were represented by Rights of Way and the
Environmental Assessment.
EPA and DER stated early in 1076 that a Joint EIS by Easton and
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BLLJSA be done. Easton and BLLJSA agreed and produced the
document on file entitled Environmental Assessment for Bushkill-
Lower Lehigh Joint Sewer Authority and the City of Easton,
Northampton County, Pennsylvania. The assessment was depicted
as one of the finest received in E?A Region III.
Extensive rights-of way work was accomplished through the
requirement that necessary sites, easements and rights-of-way
be obtained "not later than the tiTe by which the Grantee requests
a*yoroval to award construction contracts". Over 70$ of approximately
200 rights-of-way have been accomplished. Highway occupancy and
railroad crossing permits are or file.
The Joint Environmental Assessment was filed and in due time a
Negative Declaration NDP - 179? January 3, 1977 which describes
the -projects as follows: "The total -oroject consists of two
individual construction grant orojects. The first is a sewage
cdllectiO'T system With interceptors to serve the member communities
of the Bushkill- Lower Lehigh Joint Sewer Authority. The second is
an extension of the existing City of Eeston sewage treatment plant
(the designation involves a system of interceptors, pump stations,
inverted syphons and sewage treatment plant) to 10 million e-allons
per day to serve the BLLJSA ss well as the existing service area
in and around the City of Saston.
The Joint Environmental Assessment Negative Declaration and Part
"A" Grant Approval w=>s handled Jointly by EPA culminating in January,
1977 with the "A" Approval en^ Authority acceptance. Part "B"
A-ooroval was accordingly initiated by BLLJSA, processed through
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6a
D5H srA culminated in EPA with an ursent teleerrsm to the Authority
notifying it of approval. Ler?l action apr^inst EPA has, since
Se-oteTiber , 197? held in abeyance further processing.
Other than lepral and EIS delays the needs of the area were
^l^yed through ^oi^t proce-rsirr o^ the Environmental Assessment
.-^-1 otroin throup-h waltincr for ? re -evaluation of treatment 3t t'n
Epston plant in considering F.~,C. Total delays which were uncon-
trollable by the BLLJSA st this point exceed* four years.
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7.
II. Liability
The draft EIS Recommended Action (RA) proposes that Bushkill
Township be studied further for future determination as to how best to
serve certain areas of need. It proposes Upper Nazareth Township should
not be connected to the B-LLJSA system at the present time, but its sani-
tary health problems should await a determination of whether the Nazareth
Treatment Company plant and lines are acquired by the Borough of Nazareth
and whether or not a new plant can be built to serve Upper Nazareth Town-
ship. However, the solution to this problem is a part of the RA. ,As to
the balance of the B-LLJSA system, with minor exceptions, it is recommended
to be constructed as B-LLJSA proposed, with sewage being transported to the
Easton Area Joint Sewage Treatment Authority plant for treatment; however,
the means of transporting sewage to this plant does differ radically from
the B-LLJSA proposal. The B-LLJSA proposal to use all gravity lines
except for two (2) pump stations, is discarded in the RA, and in its place
basically all high pressure lines are proposed plus nine (9) pumping
stations. In addition several areas of Plainfield Township, adjacent to
the gravity lines are proposed in the RA for cluster systems rather than
connection to the immediately adjacent approved gravity lines. Finally,
also in Plainfield Township, one very deep line is proposed within the
paved portion of Route #115 instead of the two (2) shallow parallel lines
proposed by B-LLJSA, neither of which would be constructed within the
pavement of Route #115.
The draft EIS RA recommends that the project be returned to
Step II for redesign. Because of the nature of the RA changes in the
B-LLJSA plan, extensive redesign will be required which will require at
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8.
least one (1) year of design alone.
But what are these delays, what are the reasons, what are
the elements that will invoke such a threatening delay to the project?
1. Resolving the questions concerning the disposition of the
privately owned Nazareth Sewage Treatment Company and how best to serve
the citizens of Upper Nazareth Township and how best to solve their
hazardous sanitary sewage problems will take years to accomplish.
The EIS makes it clear that the need for a central collection
system for Upper Nazareth Township has been established. Likewise the
need for a central collection system for the Townships of Plainfield and
Palmer and the Boroughs of Tatamy and Stockertown have been established
in the EIS.
However, the recommendation that a solution to the Nazareth
Sewage Treatment Plant problem be a part of Phase I of the B-LLJSA
amounts
project/to gross misapplication of the, basic purposes underlying NEPA
and 92-500.
Upper Nazareth Township has present serious health hazards as a
result of malfunctioning septic systems and the EIS recognizes this.
There is a present, quick, cost effect means of solving those health pro-
blems, by looking into the B-LLJSA system. It is irresponsible to suggest
that their present and future health needs are inextricably bound to a
new Nazareth Treatment plant. The Borough of Nazareth has not agreed to
buy the old plant or system, has not agreed to build a new plant, has not
acquired any land for such a project, has not appropriated any funds to
buy the old plant, has not designed a new plant, has not applied for a
grant, and has not even held one public meeting on the entire project to
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9.
see how the people of the Borough of Nazareth and the people of Upper
Nazareth Township feel about the idea. A written agreement would have to
be developed between the Borough of Nazareth, Bushkill and Upper Nazareth
Township as to who would pay the costs of such a venture. Experience with
the expansion of the City of Easton Treatment shows that such an agree-
ment would alone take several years to develop.
What happens to the health needs of Upper Nazareth Township
citizens during this time? Is EPA going to accept responsibility for an
epidemic that might break out? Is EPA going to be responsibile for the
great difference in cost to the citizens of Upper Nazareth Township for
hooking up to the B-LLJSA system compared to those of being a hostage to
EPA and the Borough of Nazareth? If it is determined that the cost of a
new Nazareth Treatment Plant is too great, what options have EPA left for
Upper Nazareth and for the residents of the Borough of Nazareth for that
matter.
If the old Nazareth Plant is phased out there would be no
alternative except to build a new plant, which would then be in addition
to the new Easton Area Joint Sewer Authority Treatment Plant and System
already funded and constructed with a P.L. 92-500 grant and with reserved
capacity for the BLL system. That new plant would have to be built,
irrespective of the cost, because, there would be no Schoeneck Interceptor
of B-LLJSA to tie in to, nor could a line be run east from Upper Nazareth
Township to the B-LLJSA line along Route #115, because that line becomes
a high pressure line at Tatamy, and could never accommodate such a quantity
as required by the Borough of Nazareth and Upper Nazareth Township, or even
just Upper Nazareth Township alone.
Therefore, EPA has imposed severe public health problems on Upper
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10.
Nazareth Township in proposing in the draft EIS that the Nazareth
problem be solved as a part of the B-LLJSA system.
2. The draft EIS RA imposes tremendous costs due to loss of
time and inflation, all upon the local share of the costs of the system.
While it may be true the grant eligible portion of construction may be
increased in accordance with bid costs, the local share, not grant eligible
will go sky high. We have already seen a delay of three (3) years since
B-LLJSA received bids. The draft EIS proposal that the project go back
to Step II for redesign will impose another 3-4 years and may be more for
the Nazareth matter to be resolved, redesign, and matters hereafter
discussed. Can any project sustain such delays in todays or tomorrow's
economic conditions of run away inflation and a drying up of market place
funds. Is it stretching the imagination too far to propose it is possible,
in the next year or so - that there may be no market for bond financing?
Are the changes proposed by EPA so clearly necessary and so clearly correct
as to warrant these contingencies?
Given all of these problems, what is EPA's liability for mandating
such time consuming solutions under the circumstances, and are the solutions
recommended in the EIS the only reasonable solutions. Put another way,
bearing in mind the very substantial loss of time due to EPA's voluntary
decision to do an EIS, and the fact it took EPA almost two (2) years to
do a study they told the District Court it would take eight (8) months,
and bearing in mind the serious questions raised concerning the validity
of the data in the EIS and EIS conclusions, is the time consuming
recommendations warranted under all the circumstances?
3. Another element of delay required by the EIS in recommending
the project be returned to Step II is redesign of a large part of the
project, which has been referred to above. In addition, new rights of way
-------
11.
must be negotiated for the cluster systems and also possibly outright
acquisition of land for disposal in these areas. This is very costly
from an engineering and legal standpoint and requires considerable time.
Condemnation may be required. These same elements are involved in designing
a new Nazareth Treatment Plant and acquiring land for the same. Resistance
to condemnation from the owner and adjoining property owners can be
expected.
4. The delays of B-LLJSA going back to Step II would have an
effect with regard to B-LLJSA's written agreement with the Easton Area
Joint Sewage Treatment Authority. It took several years to negotiate
this agreement, and B-LLJSA after great difficulty and perseverance, was
able to obtain capacity reservation and board representation. B-LLJSA
had a commitment to pay its pro rata share of this plant expansion, and
present delays have already resulted in claims by the Easton Area Joint
Sewage Treatment Authority that the B-LLJSA delays have caused hundreds
of thousands of dollars in increased interest charges for plant expansion
financing. Further delays due to the EIS RA would swell these already
significant demands.
Further delays will cause further complications with the Common-
wealth of Pennsylvania, with whom B-LLJSA negotiated a written contract
whereby in return for building lines within Jacobsburg State Park, the
Commonwealth of Pennsylvania has agreed to share certain capital costs for
the Little Bushkill Interceptor, interceptors within the City, and
expansion of the Easton Treatment Plant.
The Bureau of State Parks cut back their immediate requirements
in the Park as a result of the entanglements of B-LLJSA in the EIS, not
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12.
because their needs changed.
5. The delay in the B-LLJSA project has resulted in much
additional cost related to EIS work and public participation. There
was a period of almost one (1) year, after the February, 1978 announcement
in court it would do an eight (8) month study, that EPA refused all
contact with B-LLJSA and its respresentatives. There is substantial cor-
respondence to substantiate this. During this same period private dis-
cussions were held with counsel for plaintiffs in the court action. Time
after time B-LLJSA pleaded for private meetings with EPA in order to
resolve the case, but EPA absolutely refused, even though it recognized
that B-LLJSA could not meet in the presence of the plaintiffs under the
circumstances.
It will be recalled that before the court action was filed by
the plaintiffs, and after EPA had decided to issue, and in fact had pre-
pared a telegraph to B-LLJSA awarding "B Approval", that at the request
of plaintiffs' counsel, EPA agreed unilaterally with him to delay the
issuance of this approval, to grant this counsels stated request for
ten (10) days time to prepare his court papers for an injunction against
EPA.
It is recalled that EPA's court counsel, advised the District
Court in February, 1978, that EPA had decided to do an eight (8) month
study, but Mr. Anderson, of EPA, in a court hearing on February 8, 1979
testified in fact EPA did not decide to do the same until September 25,
1978 some seven (7) months after the court was incorrectly advised.
Further, Mr. Anderson in charge of the EIS for EPA, again stated under
oath at that same hearing that the draft EIS would be completed the second
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13,
week in May, 1978 - some three (3) months hence. Instead it was
issued two (2) years later.
III. Damage
B-LLJSA has suffered severe damages as a result of this delay.
It will incur even greater damages if this project to relegated to Step II.
1. The credibility of B-LLJSA and its engineers, Gilbert/
Commonwealth has been damaged. EPA advised the district court that data
in the Environmental Assessment was deliberately inaccurate. The EIS has
shown this to be absolutely untrue.
2. The EIS used informal, estimating quality data on costs,
and compared this with the actual bids received by B-LLJSA. In addition,
statements as to the fact that Tatamy and Stockertown did not have
flood plain ordinances were not true, they do have these ordinances. This
misstatement on lack of flood zoning control was the basis for deleting
the Little Bushkill Interceptor in favor of high pressure lines and nine
(9) pump stations. Again this is a careless misstatement of fact on
which an erroneous conclusion was enunciated in the EIS. This type of
error on the part of EPA has wrongfully damaged the credibility of the
B-LLJSA in the eyes of the public with whom it must work.
Further, B-LLJSA felt from the beginning, that an EIS was not
required and pleaded to EPA that it be permitted to defend in open cou '-
against the allegation that it was needed. EPA swept aside this plea, and
voluntarily decided unilaterally to prepare an EIS, subjecting B-LLJSA to
three (3) years of delay so far. EPA RA proposes a further delay of an
untold number of years by requiring the project go back to Step II.
B-LLJSA has sufferred financial loses already on account of EPA
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14.
imposed delays.
1. There are numerous grant eligible items for which
application was made, and to which B-LLJSA is entitled, but EPA
deferred payment pending the completion of the EIS.
2. B-LLJSA has been informed by letter from DER that the
Commonwealth of Pennsylvania considered its written agreement with
B-LLJSA null and void because the lines in the Park were not built within
the specified time. Since the State had contracted to pay a percentage
of the capital cost of certain interceptors and the expansion of the
City of Easton Treatment Plant, B-LLJSA has lost these significant sums due
to EPA's incorrect decision to do an EIS and its procrastination in develop-
ing the same, and further B-LLJSA has lost the State as a customer of its
system.
3. B-LLJSA already has incurred financial loses to the Easton
Area Sewage Treatment Authority and will incurr additional loses if the
RA is made a part of the final draft. Also B-LLJSA may lose its voice
as a member of that Authority.
4. B-LLJSA has already acquired about 90 right of ways for its
system. If the RA is adopted, many of these will not be needed, and under
Pennsylvania law it is uncertain whether the Authority can reconvey the
same to the property owners, if not, it will have to pay for them, adding
additional costs to the project. These are not grant eligible.
5. The financial consultants fee may be increased if further
delay is encountered because it already did practically all the work re-
quired for a bond issue in 1977. It has indicated it will press for pay-
ment for work done if further delays are encountered.
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15.
6. Bond counsel has indicated its fee will substantially
increase since in effect there will be two (2) projects, one for which
it already did the work.
7. The same is true of all legal work and administrative work.
8. Redesign will add significantly to local share costs for
engineering.
Finally, there is the prospect of bankruptcy which must be
evaluated. The Authority does not have funds to keep up with interest
payments on bank loans beyond this year. Both banks with whom the B-LLJSA
has outstanding loans, First National Bank of Allentown and Nazareth
National Bank and Trust Company, have stated legal action against B-LLJSA
and all member municipalities will be taken when interest payments cease.
Federal Banking regulations require this action on delinquent loans.
IV. Conclusions
1. The data contained in the EIS and its Appendices is invalid
in many important areas, as set forth in detail under Commentaries on EIS
Deficiencies.
2. The cost of a new Nazareth Treatment Plant was grossly
understated by almost three million dollars.
3. The cost of repaving and rebuilding a part of Route #115
in Plainfield Township was never considered as a cost. It missed the fact
that Tatamy and Stockertown both have flood plain ordinances to curtail
significantly flood plain growth, P. 225 of EIS.
4. It was not aware of the fact that the area to the southeast
of the Schoeneck Interceptor near the Little Bushkill Interceptor already
is sewered by Palmer Township and hence new sewer lines will not have
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16,
significant growth impacts.
5. It failed to even relate the enormously high energy costs
in the RA to the low energy costs of the B-LLJSA system.
6. The cost data on user charges and charges to pay off
B-LLJSA debts under the RA are a mix up of figures, including municipalities
not to be sewered.
7. The text statement that the annual user charge will be
107 is patently untrue even under the RA of the EIS, since a reference
to the table on user charges at P. 237 shows it to be $200.00 a year for
all communities to be sewered.
8. Growth inducement conclusions for BLL Modified Plan are
not consistent with actual growth experience for Palmer and Forks Townships
after sewers were constructed in 1978 and Bushkill Township without sewers
is growing just as fast. In addition, its projection, in the northern part
of Palmer under the BLL modified plan of 5714 new people, 1900 new homes
is inconsistent with past experience in Palmer and inconsistent with the
zoning of Planned Industrial Commercial in that area, the only zoned,
industrial area in the Township.
9. It is incomprehensible to eliminate the Schoeneck Creek
Interceptor and destroy the only other option available to Upper Nazareth
Township and the Borough of Nazareth, if the proposed new Nazareth Treat-
ment Plant concept is rejected by the voters as too costly, while
simultaneously EPA has funded a doubling of capacity in the Easton Area
Sewage Treatment Plant for Nazareth, Upper Nazareth Township and the BLL.
10. EPA's announcement in U.S. District Court of an 8 month $• T\, />V
155
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17.
has so far taken slightly over 2 years and is still not completed. Since
the basis concept, BLL's plan has been accepted in the EIS, except for
Bushkill Township and Upper Nazareth Township, it is illogical to require
additional extensive delays for redesign and reapproval to accommodate
9 energy inefficient pump stations, and a cluster system immediately
adjacent to a gravity line in Plainfield Township, instead of approving an
environmentally sound energy efficient and cost effective system of
gravity lines.
11. In today's unsettled conditions, such a delay may result
in the total abandonment of this project initialed 13 years ago, with a
grant awarded based on an environmental assessment praised by EPA as the
finest Region III ever received.
This would be a grievous commentary, since the pollution needs
for the area and the basic solution concept is approved and confirmed
by the EIS. The deathnell delay will be the result of needless window
dressing changes which totally ignore and defiantly reject an environ-
mentally sound,energy efficient and cost effective gravity system.
156
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Comments From Other Interested Parties
157
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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA FISH COMMISSION
Division of Fisheries
Fisheries Environmental Services Section
Robinson Lane
814/359-2754 Beliefonte, PA 16823
March 5, 1980
Ms. Rochelle Volin
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, PA 19106
Re: Draft EIS, Bushkill-Lower Lehigh
Joint Sewer Authority and Borough
of Nazareth Wastewater Treatment
Facilities, Northampton County, Pa.
Dear Ms. Volin:
The subject draft EIS has been reviewed by the Pennsylvania Fish Commission
staff and attached are our comments on this document.
If it can be demonstrated that there is a need for the degree of sewage
management recommended we concur with the Draft EIS Recommended Action. However,
we do not believe the mitigative measures given for the biotic resources adequate
to give these resources the protection they must have if the high quality fishery
that now exists is not to be seriously damaged.
Sincerely,
Jack G. Miller, Chief
Fisheries Environmental Services Section
JGM:dms
cc: D. Graff
C. Billingsley
T. Hannold
Attachment
158
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COMMENTS OF THE PENNSYLVANIA FISH COMMISSION ON THE
"DRAFT ENVIRONMENTAL IMPACT STATEMENT, BUSHKILL-
LOWER LEHIGH JOINT SEWER AUTHORITY AND BOROUGH OF
NAZARETH WASTEWATER TREATMENT FACILITIES,
NORTHAMPTON COUNTY, PENNSYLVANIA."
Report Prepared by: Jack G. Miller, Chief
Fisheries Environmental Services Section
Pennsylvania Fish Commission
Draft EIS Reviewed by and
Comments Received from: Jack G. Miller, Chief
Fisheries Environmental Services Section
Martin Marcinko, Fisheries Biologist
Fisheries Environmental Services Section
Craig Billingsley
Area Fisheries Manager, Area 5
In reviewing the Draft EIS there remains some doubt as to the necessity for
the amount of construction proposed by either the Modified Applicant's Pro-
posed Action or any of the alternatives given. We are concerned about any
plan which transports sewage more than a minimum distance from its origin
because of the negative groundwater recharge effect of such action. The
placing of collector lines facilitates development and can result in a
greater groundwater withdrawal while at the same time lessening recharge
capabilities.
The EIS appears to adequately describe the effects which the different
actions could have on the aquatic environment concerned, but does not ade-
quately delineate methods to abate or minimize these deleterious impacts.
Discussion of Alternatives
1. No action - While this alternative would not solve existing
problems, proper enforcement by the Sewage Enforcement Officer
or other responsible agent would. The cost would be trans-
ferred from the Federal Government to those creating the prob-
lem. Perhaps the State or some local government entity should
bear part of the cost for allowing the conditions to develop
through improper regulation and/or enforcement.
2. Modified Applicant's Proposed Action - This plan is unaccept-
able for several reasons. There are too many stream crossings,
water from too large an area would be transported too far down-
stream, the route for the interceptor lines could interrupt
spring flows to the stream, and the lines follow the streams
too closely.
Of the remaining alternatives, number 9 is most acceptable for the following
reasons:
159
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-2-
1. Releases much more of the water nearer the place where it
is taken.
2. The lines do not follow the stream channels.
3. The crossings are reduced to six. If proper construction
methods are enforced for the crossings, damage to the
aquatic environment can be minimized and of relative short
duration. Wherever crossings are made the disturbance of
bank vegetation should be minimized and crossings located
so larger trees which provide shade, etc., will not be
disturbed.
Different methods of making stream crossings should be discussed in an attempt
to find a method which will minimize both short and long-term adverse impacts
upon the aquatic environment.
The feasibility of tunneling or jacking interceptor sewer pipe beneath the
stream bed, as suggested in the recommendations, should be studied, but because
of the presence of bed rock at or near stream bottom at some of the crossing
locations would prevent the use of this method.
Mitigative measures which will help insure the continued high water quality of
Bushkill Creek are very important. These should include siltation control,
measures to keep the temperature of the water at desirable levels for salmonids,
and control of land development to help minimize the chances for any form of
pollution entering the stream.
The establishment of a permanent vegetated buffer zone along Bushkill Creek,
especially in the Belfast-Stockerton-Tatamy corridor would help significantly
to lessen degradation due to sewer induced growth. The needed size for such
a buffer zone would require additional studies.
For the Nazareth plant, whether an upgraded STP or the proposed RBC, a method
of dechlorinization should be installed which will insure a maximum of three
parts per billion of chlorine in the effluent to prevent damage to the aquatic
environment of Schoeneck Creek.
In summary, the Pennsylvania Fish Commission is opposed to the Modified Applicant's
Proposed Action and basically supports the EIS recommended Action (Alternate 9,
with slight modifications).
We wish to be kept informed of any action taken on this project.
160
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INCORPORATED
FOR THE ADVANCEMENT OF BUSINESS, INDUSTRY, AND PROFESSIONS IN THE PALMER COMMUNITY
February 14, 1980
United States Environmental
Protection Agency
Region 3
6th & Walnut Streets
Philadelphia, Pa. 19100
Gentlemen: Attention: Ms. Rochelle Volin
The Palmer Township Business, Industrial, and Professional Asso-
ciation is a quasi-public organization incorporated under the
laws of the Commonwealth of Pennsylvania. Our group has been in
the forefront in promoting the growth of business and industry
as means of providing employment opportunity for all of our area
residents.
We take strong exception to the EPA Environmental Impact State-
ment produced for the Bushkill-Lower Lehigh Joinl Sewer Authority
project as it pertains to the area served by the Schoeneck Creek
interceptor in Palmer. Contrary to the report as written, the
area to be served by the Schoeneck Creek inceptor is not zoned
residential but much is zoned commercial-industrial and has been
so zoned for more than seven years.
There presently is a water system constructed and operational
for the area which was funded by an EDA grant to Palmer. With-
out d?velopment, this quarter-million-dollar water system will
stand unused as a monument to a combined federal and local effort
to provide jobs on one hand and negating the process with the
other. The Commonwealth of Pennsylvania through P.I.D.A. pro-
vided funding for in-the-ground utilities for this area and
there presently are areas with dry-capped sewers that had been
mandated in order to facilitate connections to the B-LL system.
That much of the residential area has already been developed
and is in dire need of sewer service since most of it was
developed based on the premise that the B-LL system would be
built.
There are presently business establishments operating on hold-
ing tanks, sand mounds, and other modifications of on-lot systems
due to the poor soil conditions in the area. Many of th^se
problems would now be corrected had the noncontroversial portions
of the B-LL project been permitted to proceed as originally
designed.
61 SUTTON DRIVE / PALMER TOWNSHIP / EASTON, PENNSYLVANIA 18042, (215) 258-7033 253-7191
161
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U.S. EPA - 2 - February 14, 1980
We strongly object to the new concept that a gravity system for
which the engineering has been completed and land acquired to
construct be now scrapped in order to replace it with a forced
main and pumping system. A pump system would be costly to install
expensive to operate, and would use untold amounts of energy which
America can ill-afford to waste on a system that could be better
served by the gravity system already engineered.
We respectfully urge EPA to question the capability of the well-
meaning people who have been charged with the responsibility of
providing alternatives to the original B-LL plan.
In the true interest of solving environmental problems which
should be the first priority of EPA, we urge the immediate
approval of the B-LL plan for Palmer as developed by Gilbert
Associates. It is imperative for the health and welfare of
the area that time not be wasted on studies in an area where
the need is already well-documented and has neeer been the
topic of controversy.
Very truly yours ,
R. Margaret Kennedy
President
SLM
16?
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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
January 30, 1980
Dear Ms. Volin:
Thank you for forwarding a copy of the draft environmental
impact statement on Bushkill-Lower Lehigh Joint Sewer Authority
and Borough of Nazareth Wastewater Treatment Facilities. This
Department has no comment on the Statement.
Since
'Anthopy V. DiSilvestre
Assistant Director (Environmental Programs)
Office o£ Administrative Programs
Ms. Rochelle Volin (3IR61)
EPA, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
163
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Fulmer Poad
RD#3, Box 279B
Nazareth, Pa., 18064
March 20, 1980
Ms. Rochelle Volin
Environmental Impace Branch (31E61)
Environmental Protection Agency
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania, 19106
Dear Ms. Volin:
This letter is written to voice our opposition to the proposed cluster
typ° sewer system to be located in Plainfield Township on property owned and
famed by Kulmer Bros.
Ten years ago we purchased three (j) acres o:' land in Plainfield Township
located alor^g Township Route t09- Two years later we built our house on these
three acres. Our main purpose for buying three acres and building omithis land
was so that we could have a garden, plant fruit trees and also that we would
nor be sur.-ounded by other houses. We were both raised in a rural area and this
is what we wish the surrour.din.K areas adjacent to our property to remain. Just
a wsek ago we were informed of the proposed Cluster Sewer System to be located
within 1/4 mile of our- house plus the fact that wi ~.,h the Installation of this
system approximately ',? new hcuses would be built nearby- We definitely oppose
this action. We wish our area to remain rural.
We understand the-, t. Lhi..-; type system would take approximately 1? to 1i? acres
of our neighbors (Fulmer Bros.) prime farm land. At this point in time we feel
that this type of action if. unnecessary. The EPA is supposedly protecting this
farm land from being developed unnecessarily and we feel with the installation
of any type of large sewer system it only encourages development and growth of ,
population. If this continues there will be no farm land or rural areas Jeft
and without (he farm land who is going to supply us with our food plus raise
crops for the animals which also supply us with a source of food.
What happens to fie land when the system is installed? IK it just condemmed?
Can some still be used for farming? Can trees be planted on it? What about any
offensive odors emitted from the so-called holding tanks? How much? What is
erivolved in installation? Who is required to hook-up? Who must pay the tariff?
There are so many questions that no one can seem to answer.
We feel there might, be problems with individual on*site disposal of sewage,
but why must a whole area be punished for a problem that could possibly have an
alternate solution. Correction of these problem sites could be made by
individuals themselves.
To sum up our feelings: We wish our area to remain rural. We don't want valuable
farmland used for the dumping of sewage. Sewers bring development anddpopulation
growth which in turn increases the services required by our local government and our
TAXES go up arid up.
We appreciate your ti.'ie and possibly you could answer these questions for us.
Thank you.
Sincerely,
164 "W *'TAv.^<.*.<#<£
KI-- K, Mrs. Oer^lr) Roth
-------
COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA HISTORICAL AND MUSEUM COMMISSION
WILLIAM PENN MEMORIAL MUSEUM AND ARCHIVES BUILDING
BOX 1026
HARRISBURQ, PENNSYLVANIA 1712O
March 20, 1980
Mr- Jack J. Schramn
Regional Administrator (III)
Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr- Schramn:
The Office of Historic Preservation has reviewed the
Draft EIS for the Bushkill-Lower Lehigh Joint Sewer Authority
in Northampton, Pennsylvania,, This document recognizes that
the applicant's proposed action could adversely impact arch-
eological resources eligible for the National Register of Historic
Places. Our office will be available for consultation to develop
mitigation proposals for the project.
Please notify us as to the present timetable for the
project. Possible delays can be avoided, if our office is
included at an early point.
Sincerely,
Brenda Barrett
Office of Historic Preservation
cc: Charlene Dwinn,
Advisory Council on Historic Preservation
BB: jek
' RECEIVED
MAR ? i •£.;.-)
JftfATER SUPPLY BRANCH
, c EPA REGION III
1 65
-------
Commonwealth
of
Pennsylvania
GOVERNOR'S OFFICE
OFFICE OF THE BUDGET
P.O. BOX 1323 - HARRISBURG, PA. 17120 - (717) 787-8046
783-3133
RE: ' PSC-SAI# 58001008
APPLICANT:Bushkill-Lower Lehigh Joint
Sewer Authority & Boro of Nazareth
PROJECT: Wastewater Treatment Facilities
LOCATION: Northampton County
Enclosed with this letter please find the comments of the
following State Agencies relative to the project identified above:
DER
Please consider these the comments of the Pennsylvania State
Clearinghouse at this time.
Thank you for your cooperation.
Sincerely,
Anne G. Ketchum
Supervisor
166
United States Environmental Protection Agency
Region III
6th and Walnut Streets
~1
Philadelphia,.PA 191Q6
_J
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
P. 0. Box 2063
Harrisburg, PA 17120
April 3, 1980
SUBJECT: Review and Evaluation of PSCH No.
5-80-01-008
DEIS Bushkill-Lower Lehigh Joint
Sewer Authority and Borough of
Nazareth Wastewater Treatment Facilities
Northampton County
TO: Richard Heiss, Supervisor
Pennsylvania State Clearinghouse
FROM: CLIFFORD L. JONES L\\
Secretary of Environmental Resources
The Department has reviewed the Draft Environmental Impact Statement
for the Bushkill-Lower Lehigh Sewer Project and offers the following comments.
Gravity Conveyance vs. Pumping (Little Bushkill CreekJ
As with most of the major issues surrounding this project, a
positive decision on either alternative cannot be made based on the existing
level of analysis. The Department recommends the following to assist in the
decision-making process.
a. A breakout of the cost-effectiveness analysis for
just the two methods of conveyance.
b. Revised and updated energy comparisons for only
the two methods of conveyance.
c. A re-evaluation of the induced growth impacts recognizing
that it is not that much more difficult to connect to a
pressure system than it is to connect to a gravity system.
Should further analysis show similar initial costs and secondary
growth impacts, the decision will then revolve around the energy issue
favoring gravity conveyance. The Department is not overly concerned about
the environmental impacts of the gravity interceptor construction on the
Little Bushkill Creek since they are short-term and can be mitigated. The
Department is concerned about the long-term secondary growth impacts on the
water quality and natural trout reproduction capability of the creek. If the
initial cost for these alternatives is similar, it must be more clearly shown
that the difference in the secondary growth impacts of a gravity system is
significant enough to offset the increased operation and maintenance costs
of the EIS pumping alternative for the Department to endorse it.
167
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Richard Heiss, Supervisor 2
Nazareth STP
The EIS proposes to replace this inadequate privately-owned plant with
a new facility. Presently, the Department is negotiating a Consent Agreement
regarding the purchase, renovation and operation of the existing Nazareth sewage
treatment plant by the Borough. Controversy over the costs of renovating the
existing plant vs. building a new plant vs. construction of sanitary sewers to
convey sewage from this area to the Eastern plant must be resolved and be compared
to determine the most cost-effective alternative. The present EIS does not
provide convincing evidence that any one alternative should be selected over the
other two.
Dual vs. Single line along Rt. 115
Bushki11-Lower Lehigh's proposal provided parallel gravity sewers
along Rt. 115 because of the topographical difficulties in serving both sides
of the highway with a single line. The recommended EIS action shows only a
single gravity sewer line for this area. Although the Department realizes the
detailed design of the EIS recommendation would occur in Step II, the Department
does not feel that enough information comparing the cost and other differences
between a single gravity and parallel lines was developed in the EIS study to
support this recommendation. An extremely deep interceptor over a long distance
presents very high cost risks. Expensive homeowner connections required by the
single sewer alternative should also be considered.
To avoid further delays over this issue, the Department recommends
resolution in Step II when more detailed site and design information is available.
General Cost Data
Credibility and acceptance of selected alternatives revolve around
credible cost inputs arid clear user charge data. Cost data complaints were
made by representative^ of the Bushkill-Lower Lehigh Joint Sewer Authority on
many aspects of the three major preceding issues. The Department recommends the
various cost inputs be closely scrutinized and revised if necessary.
The EIS consultant for the project should contact Mr. John Wroblewski at
the Reading Office, Wernersville State Hospital, Building #10, Wernersville, PA
19565, Phone: (215) 670-0301, to review these comments.
Other Comments
Sewer lines following stream and crossings should be limited to those
absolutely required.
Permits will be necessary for the utility facilities located in the
100 year floodplain.
The Nazareth Treatment Plant, which was constructed in 1929, operates
on gravity. No electric motors are used in the plant. There is a possibility
that the plant may qualify as a Civil Engineering Historical Site. Mr. Iran
168
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Richard Heiss, Supervisor 3
M. Viest, Chairman of the Historical and Preservation Committee for the Lehigh
Valley Section ASCE should be contacted at 215-694-2579 for information on the
historical value of the existing Nazareth Sewage Treatment Plant.
The Department encourages municipalities along Schoeneck, Little Bushkill
and Bushkill Creeks to establish streamside vegetation buffer zones. Streamside
buffer zones will help reduce floodplain development, minimize water quality
deterioration, protect fish and wildlife, and enhance water-based recreation
opportunities along these streams.
169
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE
CENTER FOR DISEASE CONTROL
ATLANTA, GEORGIA 30333
March 3, 1980
Mr. Jack J. Schramm
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
We have reviewed the Draft Environmental Impact Statement (EIS) for the
proposed construction of the Bushkill-Lower Lehigh Joint Sewer Authority
and Borough of Nazareth Wastewater Treatment Facilities, Northampton
County, Pennsylvania. We are responding on behalf of the Public Health
Service and are offering the following comments for your use in the
preparation of the final EIS.
We recognize that the "Applicant's Proposed Action" will have significant
impacts upon the human environment and believe the "EIS Recommended Action"
(modified Alternative 9) is very desirable from an environmental and
economic standpoint.
With regard to the proposed construction of treatment facilities and sewers,
we are particularly concerned with the induced population growth and con-
struction of dwelling units within flood prone lands. It appears that
certain communities and townships have no or ineffective regulations to
control development in the 100 year flood plain. The potential development
pressure by each alternative in flood prone areas should be described. As
growth increases in the project area, the duration and area of flooding in
the flood prone areas should also increase unless storm retention measures
are incorporated into land development. What assurance does EPA have that
satisfactory ordinances, regulations and technical measures will be devel-
oped and implemented to prevent induced growth and increased flooding in
flood prone areas? Federal agencies are prohibited by Executive Order
11988 to support any activity that directly encourages adverse flood plain
development.
We are also concerned that a satisfactory surveillance program be performed
to monitor and prevent adverse nitrate levels in local public and private
water supplies. In addition, periodic indicator bacteria testing of
water supplies should be performed in those areas having high densities
of onsite waste treatment systems and private wells. Improved building
codes (minimum lot sizes and improved construction and location of wells,
distribution lines, and onsite waste treatment systems) and permit and
170
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Page 2 - Mr. Jack J. Schramm
inspection requirements should help prevent any cross contamination between
water supplies and onsite waste treatment systems.
We appreciate the opportunity to review this draft EIS. Please send us one copy
of the final document when it becomes available.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
171
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R. D. 3, Box 8
N«arrth, PA 18064
393 ROUTE 17
PARAMUS. NEW JERSEY O7652
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GARY NEIL ASTEAK
-— ATTORNEYS AT LAW-
ASSOQATE 726 WALNUT STREET
MILDRED A. MOLINO
EASTON.PENNSYLVANIA 18042
February 21, 1980 215252-0768
215258-2901
Rochelle Volin
Environmental Protection Agency
6th & Walnut Streets
Curtiss Building
Philadelphia, Pennsylvania
RE: EIS - BLLJSA
Dear Ms. Volin:
Bushkill Township is pleased with the draft E.I.S. That is the
virtually unanimous response of its citizens and government. The
Township is pleased first and foremost that the difficult efforts
it prompted to examine alternatives to regional sewage have been
productive.
The E.I.S. shows that the regional interceptors would have ill
served the future sewage need of the Township. At the same time,
the interceptors would have carried untimely and unneeded develop-
ment far into the rural township. By investigating the sewage
needs with an eye towards straightforward, realistic, and
environmentally sound sewage treatment, the Environment Impact
Study has served all citizens in the surrounding area by directing
federal and local dollars toward existing problems. For that the
Township commends EPA.
Secondly, the Township is pleased that the EIS provides a foundation
for sewage planning and .design that has previously not been in place.
Building first on a complete review of the existing community,
public services, recreation, historical site, farm lands, stream and
wild life, the E.I.S. placed present and future sewage needs solidly
within the frame work of the community as a whole. It offers the
Township the broad view and planning support necessary to meet its
needs. In a few narrow areas the Township disagrees with conclusions
drawn from this foundation. The Township will address each of these
areas only briefly.
The Township is still concerned that the past assumptions of need
focused in the Cherry Hill area not distort the true needs pictured
in the Township. Only two of the twenty-one surface malfunctions
investigated by EPA were in the Cherry Hill area, and no pattern or
concentration emerged dispite exhaustive attempts through well
178
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Rochelle Volin February 21, 1980
Environmental Protection Agency Page Two
monitoring, on-site inspections, and other methods to confirm past
suggestions of concentrated needs. The EIS solidly concludes that
such is not the case.
Given the scattered needs of the Township, the precautionary
language on the bottom of Page 104 and the inclusion of Cherry Hill
in Table 111-10 should not suggest that the lower portion of the
Township needs more planning attention than any other part. To do so
repeats the error of past regional planning.
In that connection, the Township repeats its requests for the
location and addresses of confirmed malfunctions throughout the
Township, which the Township requested most recently by letter of
October 19. 1979.
Next, in a related area, the Township believes the E.I.S. section
on soil suitability for waste water treatment overstates soil
limitations by omitting proper explanations of the meaning of the
broad geological data. Particularly Figure III-4 which appears to
adopt the USDA-SCS "severe" soil limitation label throughout most of
the Township. As the Township and its consultants have pointed out
repeatedly including letters of March 9, 1979, March 12, 1979,
June 6, 1979 and earlier workshops, the label cannotes strong or
irreconcilible restrictions precluding on-site systems. That, they
are not.
Those labels are based on soil types and are useful and helpful as
a starting point for broad agronomic or even community planning; they
should not be portrayed as a definite measure of suitability. They
suggest only that indigenous soil conditions be further examined on
site-by-site basis. The Township was of the understanding that EPA
would either include other sewer treatment data in this section, or
properly explain limitations of the labels. (March 12, 1979 letter
to Eric Hediger). Interviews with County Conservation District
Member Ross Kahler on June 11, 1979 and Carl Kislan confirmed that
proper soil investigation and siting allow effective soil treatment
throughout the Township. The suggestion of broad severe limitations
on on-site systems portrayed in Figure III-4 is unjustified.
Regarding several other areas in the E.I.S. the Township offers the
following brief comment. With regard to the cost figures, the
E.I.S. does not clearly set out which Townships and which residents would
bear the various projected user costs calculated in the E.I.S. for each
alternative. Various local planning options and divisions should be
presented with likely costs figures where available. The Township
recognizes that precise costs figures cannot be expected at this first
stage of planning. It does believe that comparison of estimates are
meaningful and that additional clarity would be helpful.
179
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Rochelle Volin February 21, 1980
Environmental Protection Agency Page Three
With regard to the recommended proposed action, the Township believes
that the tremendous savings and costs, induced growth and
environmental damage make it a plan worthy of consideration, where the
original proposed action was not. Moving the interceptors out of the
streambeds was one of the original concerns of the Bushkill Township
residents. Proper sizing and capacity limitations were also formerly
ignored in Regional Planning.
The Township is still very concerned that local cost effective choices
be preserved in the Nazareth and Upper Nazareth areas, the Township's
neighbors to the South. As pointed out in the past, cost comparisons
as set forth in the E.I.S. could continue to skew those comparisons
toward regionalization because treatment costs have not been
included in the original schemes. Particularly in the long term, any
community tied into the regional system must consider the end-of-pipe
costs associated with a decision to transport its wastes out of the
area. The regional concept also means a loss of local autonomy.
The E.I.S. has an obligation to point out and assess those and other
costs important to the local decision making that must follow.
The Township believes that these remaining areas of concern are
the types properly worked out in second stage sewage planning made
possible by the E.I.S. Those remaining questions should not distract
attention from the more general and fundamental questions by the E.I.S.
The Township is anxious to move ahead with the planning, design,
financing, and construction or appropriate facilities, consistent
with the needs and desires of its citizens.
The E.I.S. presents the choices. The most urgent need seems to be
in the Northern most part of the Township, the Rissmiller area.
That area alone is recommended for immediate federal funding under
Phase One. The E.I.S. recommends that homes in that area be served
promptly with cluster systems or a community marsh pond.
Next, the E.I.S. points to the Cherry Hill area in the Southern part
of the Township. The E.I.S. shows no concentrated problem and no need
for Phase One or centralized sewers. It high lights the need for
careful local planning and suggests a program to monitor, repair and
up-grade existing system as necessary within the existing community.
The remainder of the Township is also included within the so called
"small flow" district. For those areas, the E.I.S. points to the
financial and environmental advantages of local waste management
planning to provide service sporadic problems. The Township endorses
these dispersed and innovative alternatives to its sewage needs and
has already begun planning for them.
The E.I.S. leaves open the question of who can best implement these
180
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Rochelle Volin February 21, 1980
Environmental Protection Agency Page Four
now apparent choices. The E.I.S. recognizes that the sewer
authority's engineers, management, and financing methods may not
meet those needs promptly or effectively. The Township agrees. The
Township firmly believes that the sewer authority's past planning,
posture, and attitude show that it could not do so. In those
circumstances, the Township has no alternative but to regain control
of its sewage planning for the future. Accordingly, it has sent a
Notice of Intent to Withdraw from the sewer authority.
In doing so, the Township commits itself to the sewage planning and
recommendations in the E.I.S. and pledges to work with both E.P.A.
and the sewer authority to implement those choices.
Once again, congratulations on a job well done.
\
SUP
~Chairman, Bushkill
owiish^tp Board of Supervisors
.RVISORS
Jane GTlbert, Vice Chairman
William Mo r man
...
Anthony Kaz'makJLtes
Ralph Mfetz'
C-•. '
-4»'
U
. Brent Alderfer,Special Counsel
~ ^ - -1^^. -: V^ u
Gary Neil Xsteak, Solicitor
181
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
CURTIS BUILDING, SIXTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
REG.ON IN MAR 2 5 1980
3CE
Mr. Jack J. Schramm
Regional Administrator
Environmental Protection Agency
Region III
Attn.: Ms. Rochelle Volin
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
This is to inform you that the Draft Environmental Impact Statement
for the Bushkill-Lower Lehigh Joint Sewer Authority and Borough of
Nazareth Wastewater Treatment Facilities has been reviewed and we
have no comments to offer.
Thank you for the opportunity to review this statement.
Sincerely,
/
IN REPLY REFER TO:
/ c*
/ Th " -
Thomas C. Maloney
y^^Regional Administrator
182
AREA OFFICES
3ALTIMORE. MARYLAND - PHILADELPHIA. PENNSYLVANIA • PITTSBURGH. PENNSYLVANIA- RICHMOND. V IR G IN IA . WASH I NG TON . u.
Insuring Offices
Charleston, West Virginia . Wilmington, Delaware
-------
If you have something to say, please send your comments to:
A A
\A
Rochelle Volin (3IR61)
EIS Project Monitor
EIS Preparation Section
U.S. Environmental Protection Agency
Curtis Building
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
/
O.
u
A
«">'
183
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SSS\ United States
If) Department of
Agriculture
Soil
Conservation
Service
P. 0. Box 985
Federal Square Station
Harrisburg, Pennsylvania
17108
March 17, 1980
Mr. Jack J. Schramm
Regional Administrator
Attention: Ms. Rochelle Volin (Mail Code 3IR61)
U. S. Environmental Protection
Agency
Region 3
Sixth & Walnut Streets
Philadelphia, PA 19160
Dear Mr. Schramm:
The Soil Conservation Service has reviewed the December 1979 Draft
Environmental Impact Statement for the Bushkill-Lower Lehigh Joint Sewer
Authority and Borough of Nazareth Waste Water Treatment Facilities,
Northampton County, Pennsylvania. The statement displays a good assess-
ment of the items of concern to the SCS. We do feel that the prime
farmlands were overestimated in the draft. According to the definition
of prime farmlands in the Code of Federal Regulations, Title 7, Chapter
VI, Section 657, 60 percent, rather than 75 percent, of the EIS Service
Area is prime farmland. The land within this 15 percent difference does
not qualify as prime farmland but does qualify as additional farmland of
statewide importance. We appreciate the opportunity to comment on this
project.
Sincerely,
Graham T. Munkittrick
State Conservationist
184
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C C Go LUNGS AND GOAPANY IMC
ISTABLI5 HE D "924
INVESTMENT BANKERS
THE nnr.LiTY BUILDING
PHILADELPHIA, PA. 19109
March 17. 1980
United States Environmental Protection Agency
Region III
6th & Walnut Streets
Philadelphia, PA 19106
Attn: Ms. Rochelle B. Volin, Project Monitor
Gentlemen:
Our firm serves as Investment Bankers to the Bushkill-Lower Lehigh Joint
Sewer Authority (the Authority) located in Northampton County, Pennsylvania.
Our firm received a copy of the Draft Environmental Impact Statement (EIS)
on the proposed construction by the Bushkill-Lower Lehigh Joint Sewer Author-
ity and Borough of Nazareth Wastewater Management Facilities, Northampton
County, Pa. In respect, thereto, we attended a public hearing on February 21,
1980 in the Nazareth Junior High School.
Our firm has attended meetings since such time with representatives of
the Authority and Gilbert Associates, Reading, Pa., Consulting Engineers for
the Authority. It is our understanding that the Authority has submitted to
your office a request to make certain modifications to the EIS Recommended
Action as set forth in Chapter IX of the Draft EIS.
Based upon information provided to us by the Authority and their Con-
sulting Engineers and our analysis in respect thereto, we recommend your
immediate approval of the segmentation as requested by the Authority for the
following reasons:
1. The Authority's segmented proposal is financially feasible at
present. The annual user rental charges would be less than
$300 per year. This is low enough to make the sale of the
Revenue Bonds that provide the private share of the construction
money possible.
2. The Draft EIS of the Environmental Protection Agency (EPA) would
not be financially feasible. This is because the additional
costs engendered by changing to force mains and pumping stations
from gravity flow, and a deeper collector in the road center
185
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U. S. Environmental Protection Agency
-2-
instead of along the sides, could drive the annual user rental charges
over $400, thus raising serious questions as to the financial feasi-
bility of the Project which could prevent the sale of Revenue Bonds
which provide the private share of the construction money.
3. The changes requested would require a redesign of the Project which
could delay the Project at least six months. We estimate that any
prolonged delay will cause the costs to substantially rise because
of inflation. Annual delays have increased construction costs
approximately 12% compounded annually per year to date. This pattern
is expected to accelerate in the future.
4. The Authority is presently obligated to local banks in the amount of
$680,000. Further delays in the approval and construction of the
Sewer System could result in serious financial consequences.
Very truly yours,
C. C. COLLINGS AND COMPANY, INC.
Edward J. Maher
Executive Vice President & Treasurer
EJM/mab
186
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United States Department of the Interior
OFFICE OF THE SECRETARY
15 State Street
Boston, Massachusetts 02109
March 11, 1980
ER-80/89
Mr. Jack J. Schramm
Regional Administrator
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
This responds to your letter of December 28, 1979, requesting our review
and comments on the draft environmental statement for Bushki11-Lower
Lehigh Joint Sewer Authority and Borough of Nazareth Wastewater Treatment
Facilities, Northampton County, Pennsylvania. The Department of the
Interior offers the following comments for your consideration.
Specific Comments
Page 52 - Under Surface Water Uses and Classification, the statement is
made that "The water use classification. . .for Bushkill Creek and
Little Bushkill Creek. . .has not yet been adopted." We believe this
statement and the related material in Appendix E-2 should be revised to
reflect adoption of standards referenced in the Pennsylvania Bulletin,
9(36):3051-3179 dated September 8, 1979.
Summary Comments
The discussion of potential project effects on known historic and
archeological resources appears adequate, and there is some discussion
of plans for "an historic sturctures survey" (page 247). However, we
see no provisions for any further identification and evaluation of
presently unknown archeological resources in the proposed project area
that may be eligible for inclusion in the National Register. This
identification would be especially important in siting decisions for any
planned wastewater treatment facilities. We therefore urge that such a
survey be planned as soon as possible, in consultation with the
Pennsylvania State Historic Preservation Officer, so that EPA may fully
187
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comply with historic preservation mandates under Executive Order 11593
and the National Historic Preservation Act, as amended. The results
should be included in the final environmental statement or in any future
environmental documents prepared for the proposed wastewater treatment
project.
The State Historic Preservation Officer for Pennsylvania is Edward
Weintraub, Executive Director, Pennsylvania Historical and Museum
Commission, P.O. Box 1026, Harrisburg, Pennsylvania 17120
(telephone 717-787-2891).
Sincerely yours,
. ~!
William Patterson
Regional Environmental Officer
188
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Dim pine cofiKran
mm
ALLENTOWN-BETHLEHEM-EASTON. AIRPORT. OovtmnMnt Building
LEHIQH VALLEY, PENNSYLVANIA 18103
March 6, 1980
THOMAS H. UNSER
Chairman
GEORGE R. JENKINS
Vice Chairman
RAYMOND C. GEIGER
Treasurer
HELENE M. WHITAKER
Secretary
JOHN J. COUGHLIN
FRANK FISCHL
I. CVRUS GUTMAN
THOMAS HECKMAN
NELSON W. HEFFELFINGER
NICHOLAS G. KORDOPATIS
STANLEY M. LYSEK
PAUL M. MARCINCIN
WILLIAM F. MOHAN, JR.
FRANK W. MOYER
JEAN A. NELSON
ROBERT S. PHARO
PAUL POLAK
PHILIP R. PORTZ
JOHN S. POSIVAK
WILLIAM A. REMO
CHARLES S. SAEQER
RODNEY K. SCHLAUCH
HENRY J. SCHULTZ
LOUIS F. SEEDS
DEBORAH A. SIEGER
RICHARD L. STAFFIERI
SCOTT R. STONEBACK
ARTHUR L. WIESENBERGER
ROBERT K. YOUNG
LEHIGH COUNTY
DAVID K. BAUSCH
County Executive
SCOTT R. STONEBACK
Chairman, Board
ol Commissioners
NORTHAMPTON COUNTY
MARTIN J. BECHTEL
County Executive
DONALD B. CORRIERE
President, County Council
Ms. Rochelle Volin
Environmental Impact Branch (3IR61)
U.S. Environmental Protection Agency
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
CODE TELEPHONE
215 264-4544
MICHAEL N. KAISER
Executive director
Re
Draft Environmental Impact Statement
Bushkill-Lower Lehigh Sewer Project
Dear Ms. Volin:
The Joint Planning Commission reviewed the above-referenced
draft report at its regular monthly meeting on February 28,
1980. The Commission's comments are outlined below.
1. Gravity Interceptor vs. Force Main
The EIS proposes a major modification to the project
to provide service by a series of force mains and
pumping stations along Tatamy Road rather than by
the proposed gravity interceptor along the Bushkill
Creek. The report presents four reasons for this
change. These four reasons are listed below indi-
vidually, followed by our comments on them.
a) Federal policies oppose direct Federal investment
in flood-prone areas unless there are no possible
alternatives - This is a sound policy as it ap-
plies to public investments which would prone
to flood damages. However, the JPC believes
that it is illogical to apply this policy to
a gravity sewer interceptor which would not
have significant flood damage potential.
b) The interceptor along the Creek would generate
new development in flood plain areas - This
would be a valid concern except that the problem
is' mitigated since all of the municipalities in
the service area have or will have flood plain
zoning provisions. Palmer, Forks, Lower Nazareth
and Plainfield Townships,.as well as the Boroughs
of Stockertown and Tatamy, already have flood
plain regulations meeting the standards of the
National Flood Insurance Program. Bushkill and
Upper Nazareth Townships already have planning
189
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Page Two
Ms. Rochelle Volin
March 6, 1980
programs underway so they will have flood plain
recrulations in the fairly near future. Finally- the
Borough of Nazareth is eligible for the National Flood
Insurance Program so it will have to adopt flooa
plain regulations when its detailed flood study
is prepared. Pennsylvania Act 166, adopted in
1978, requires all flood-prone municipalities to
obtain and maintain eligibility for the flood in-
surance program so this Act will, in effect,
require the municipalities to keep flood plain
zoning in force. I understand that EPA has had
some concern that there is no ironclad guarantee
that such flood plain zoning provisions will re-
main in force. While this is true, we also believe
that there is very little more certain in planning
and zoning given the widespread support for flood
plain zoning and the presence of Act 166.
c) The gravity interceptor would involve more construc-
tion in and across the Creek which would have harmful
impacts on aquatic life - It is true that the stream
crossings and construction near the Creek would have
some adverse impacts on aquatic life. Through proper
construction techniques, these impacts can be mini-
mized and the stream should recover from the unavoid-
able damage over time. This negative short-term
impact needs to be compared with the long-term
negative impacts of the pumping stations including
the high cost of maintenance and the energy use to
operate the stations. On balance, the Commission
believes that the gravity interceptor should be
preferred.
(We would like to note here that we periodically receive
grant applications for projects to construct a gravity
interceptor in order to phase out an existing pumping
station. Almost invariably, applicants support such
applications by outlining problems with the pumping
stations such as odors, frequent malfunctions, and
the high cost of operation and maintenance including
electricity costs.)
d) The gravity interceptor would tend to induce more growth
in the service area - The Commission believes that sewers
do tend to induce growth. If the area is recommended for
190
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Page Three
Ms. Rochelle Volin
March 6, 1980
development, this growth inducement is a positive
impact. If not, it is a negative impact. Our views
on this are outlined in the following section en-
titled Growth Policies. It should also be noted
that it is possible to connect to force mains and
there could well be pressure to expand pumping
stations. Therefore, even the force main proposal
would have some growth impacts.
Based on the above reasoning, the JPC supports the concept
of a gravity sewer interceptor along the Creek rather than
the force main alternative.
2. Growth Policies
The JPC Regional Comprehensive Plan assumed that the B-LL
sewer project would be constructed around 1980. Therefore,
the Plan recommended a substantial amount of development in
this corridor. The question which the EIS is asking is what
the JPC's growth policies would have been for the service
area if we had not assumed that the B-LL sewer system would
be constructed. Answering this question fully would be time
consuming since the assumption was a fundamental basis of
the entire Plan. However, some of our preliminary indica-
tions are outlined below.
a) The JPC would still support urban development in the
general corridor along the Bushkill Creek from the
existing interceptor through Tatamy and Stockertown
to the Village of Belfast in Plainfield Townsip.
Therefore, the growth induced by the sewer in those
areas would be desirable from the JPC Comprehensive
Plan standpoint. This would involve more use of land
including prime farmland in this corridor, but hope-
fully it will reduce the total amount of farmland
converted to urban uses in the region by encouraging
higher densities of development in appropriate areas.
b) We would agree with the idea of deleting the Bushkill
Creek interceptor extension north from Stocerktown
into and beyond Jacobsburg Park. If we had not
assumed that sewer system would be built, these
areas would not have been recommended for urban
development.
c) We agree with the concept of examining alternate
methods of sewage disposal in lightly developed
areas with malfunctioning septic systems instead
191
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Page Four
Ms. Rochelle Volin
March 6, 1980
of an extension of regional sewer systems into those
areas. This comment would apply to portions of the
service area such as Cherry Hill, and the portions
of Plainfield Township north of Belfast. (See, for
example, the relevant policies of the JPC Regional
Comprehensive Plan and the 1978 Interim Update to
the JPC Water Supply and Sewage Facilities Plan.)
d) Our policies concerning growth along the Schoeneck
Creek corridor depend somewhat on what decisions are
eventually made concerning the abandonment or replace-
ment of the Nazareth Sewage Company treatment plant.
If the Nazareth plant is to be phased out and the
Schoeneck Creek inte'rceptor constructed, then our
policies would probably recommend development in
that corridor. If the most cost-effective alterna-
tive turns out to be replacing the treatment plant
at the current site, then we would probably not
recommend development in that Schoeneck Creek
corridor. In this case, we would still recommend
continued urban development in and immediately
adjacent to the Borough of Nazareth.
3 . Other Issues
There are a number of other cost and technical issues which
need to be resolved. These include the question of the dual
or single lines along Route 115, the replacement or abandon-
ment of the Nazareth plant, and serving the Newburg homes
area by a pump station or a gravity sewer along the lower
Schoeneck Creek. We believe that these issues ought to be
resolved by a thorough consideration of the costs and en-
gineering advantage and disadvantages. We don't believe
that growth policies issues are major ones in these con-
siderations .
Please contact the JPC offices if you have any questions concerning
these comments.
Very truly yours,
Allen R. O'Dell
Chief Planner
cc: Mr. Thomas Goldsmith
Attorney Charles Smith Nazareth Sewer Authority
Mr. Lewis Wolfe Nazareth Borough Council
Bushkill Twp. Supervisors Stockertown Borough Council
Plainfield Twp. Supervisors Mr. Joseph McHale
Palmer Twp. Supervisors Mr. Douglas McGuil
Upper Nazareth Twp. Supervisors
192
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R. D. 3, Getz Road
Township Municipal Euildiny
Nazareth, Pennsylvania 18064
March 21, 1980
Ms. Rochelle B. Volin
Project Monitor
Environmental Protection Agency
Region III
Sixth and Walnut: Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Volin:
This letter supplements the oral statement given by our
Township Solicitor, John Molnar, at the recent public hearing
on February 21, 1980. The comments made in this letter arc a
compilation of the various positions and statements made at
public meetings o£ the Board of Supervisors of Plainfield Township.
Our immediate concern lies with the finances of this project,
and we can state this concern in simple terms. We are opposed to
additional costs of inflation, restudy and reengineering of this
project. We will not consent to the progression of this project,
if the citizens of Plainfield Township will have to bear the
responsibility of the past debts of the Bushkil1-Lower Leh.i 'jh JoJ nt
Sewer Authority and also bear the responsibility of increased future
costs of this project.
As our Solicitor stated in the oral statement presented at the
Draft Environmental Impact Statement public hearing, we beli.eve that
the Environmental Protection Agency has acted irresponsibly in this
project, and have been the cause of the delays and the problems that
have been encountered. Therefore, Plainfield Township will be looking
directly toward the Environmental Protection Agency to resolve this
troubled project without any further costs to the citizens of Plainfield
Township.
We are not prepared to discuss the merits of the Draft EnvJ ron-
mental Impact Statement, until the Environmental Protection Agency
explains how it plans to pay the past debts of the Bushkill-Lower
Lehigh Joint Sewer Authority and pay the additional costs of inflation
and redesign of this project.
193
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Ms. Rochelle B. Volin
March 21, 1980
Page Two
In conclusion, wo will not cooperate with the progress of
this project, until the Environmental Protection Agency explains
how and when the past debts and additional costs of this project
will be paid.
Sincerely yours,
PLAINFIELD TOWNSHIP BOARD OF SUPERVISORS
William H. Danner, Chairman
/7
L*->
//John A. Houck, Secretary
Robert F. Tengcs
cc. John Molnar, Esquire
Ricliard T. Rutt, P.E.
Mason Klinger
194
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Ms. Rochelle Volin February 16, 1930
Environmentv.l Impact Branch(31R6l)
U. 3. Environmental Protection Agency
Curtis Building
6th Sc Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Volin,
This letter is to let you know I am essentially in agreement
with your conclusion of EI3 Alternative ,.^9 being the most
suitable for funding. There are, however, some comments I
would like to make which are relative:
1. I would like to re-iterate that the fate of Up^er Ngzareth
Township East Lawn Area is tied inseparably to"the N-zareth
3oro because of economic,social and physical reasons such
as schools, H'.'ICA, community parks,garbage disposal, sports
pEograms, and cooperation of police and'fire departments;
therefore, nothing should deter their collaboration in a
sewage collection and treatment system.
2. I agree with building a new Nazareth Sewage Treatment Plant
and with subsequent continued local treatment. The current
dry winter we are experiencing locally points all the more
to keeping treated water in the area to help the water table.
In addition, the Easton Treatment Plant, according to recent
radio reports are already experiencing sludge removal prob-
lems which might be indicative of future problems. It would
be ironic to send waste to E5ston to treat and have to re-
turn it to the outlying areas for disposal.
3» The need for a collector line as far east as shown on E. Lawn
Rd. (Rt. 191 to Stockertown) may not be necessary and could
eliminate a force main and pumping station. The railroad
track has been razed between Friedensthal Rd. and Rt. 191
and the Hercules Cement Co. is buying the right-of-way ob-
viously to expand their quarry. This would curtail the
development shown on Fig. 111-13, year 2COC as heavy resi-
dential south of East Lawn Rd. and east of 31 ey St.
4o Map 111-23 which shows constraints on development and M-p
111-21 whjach, shows on-site problems indicate unsuitable soil
and a possible malfunction East Lawn Road (Rt. 191 towards
Stcckertown). This possibly might be corrected by up-grad-
ing the on lot systems. ICost of these homes are 50 or more
years old and ..iay never have had proper on lot systems in-
st\lied. There are also drainage problems in this area
caused by improper grading and lack of storm sewers. Correc-
tion of the above problems may negate the need for a collec-
tor line for a large portion of S. Lawn Rd.
(cont.)
195
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5.
6.
February 16, 19^0 (cnntO-
Recent newspaper articles indicate t'-at the proposed Sears
Mall at the intersection of Rts. 24<3 and 33 would rival the
exist in.2 Leh;.;';h Valley hall in size. If this is true, these
concerns should be made a ;::a.rt of the overall pl:in and help
pay their share of the coets»
Since the 313 was no'.; ori -; ' nally performed baf-.re allowing
the prant to the 3LL-JSA and relied on the Gilfert Associates
Feasibility Study, I think the EFA she :.ld earnestly consider
the possibilit-- of helping defray the cost of liabilities of the
various communities to the 3LL-J3A to ;.:ake up for this "oversite". .
I believe there is a lr-.rn;e ar..o'jnt of public distrust of the
3LL-Jsa and therefore question its usefullness to so'lve all of the
sewer problems in question. Specifically I believe a sep-
arate sewer authority should be formed to administer the needs
of the Nazareth Boro-Upper Nazareth Township built-up area.
This was previously recommended by independent studies made by
consultants for these co.
I am enclosing recent newspaper article copies which have a direct
bearing on the draft EI3. Thank you for considering these items.
I hope ohey v;ill prove useful.
Sincerely,
CC: Francis .v'underly
President Of Upper Nazareth
Citizens League
Upper Nazareth Township
Board of Supervisors
c/o Robert Recker
Francis J. Schweitzer
24 3. Eley St.
Nazareth, Pa. I':50o4
(Upp-.er Nazareth Township)
196
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Producing
A T^'y Pure Mi|k
Registered HoTstein Cattle
Grade A A Milk
R. Bernard Merwarth
TimifSftuB. Merwarth
Upstream Farm Corporation, Inc. Robert C Starke
BUSHKILL DRIVER. D. 2, EASTON, PA. 18042
X» / -
<& -f~f- tf
/ .V&r. U*-i., Mf**-f
(I 4-&JI L I
/fP7\ I ff s- /
si*,^' ll/WJW/i>-'r <£*-^ ~v'L
197
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Producing
A Truly Pure Milk
from
Registered Holstein Cattle
Grade AA Milk
Upstream Farm Corporation, Inc.
Merwarth
. Merwarth
Robert C Starke
BUSHKILL DRIVE, R. D. 2, EASTON, PA. 18042
198
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February 22, 1980
Ms. Rochelle Volln
Environmental Impace Branch (31R61)
U.S. Environmental Protection Agency
Curtis Building
6th & Walnut Streets
PhU.udolphla, PA 19106
Dear Ms. Volln:
We attended the Hearing last evening In Nazareth Junior High with various neighbors
from Plalnfleld Township.
We live on Kesslersvllle Road within smelling distance of that one option (open field
spraying) which you said Is no longer viable.
Our Immediate area Is violently opposed to such an option should It ever resurface
again. We consider It a very Indelicate manner to solve the excreta problems of mankind.
We enjoyed the portion we heard and realize that you hove a tough job humoring the various
engineering approaches.
Thank you and good luck.
Sincerely,
V- / ./ £ Vt^'i
\ fl^-t 1-" <- I- ' 7
Robert C. Nagel
Box 371B, R. D. 3
Nazareth, PA 18064
cc : J. RampulLa
199
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Plainfield Township Planning &
Zoning Commission
R. D. 3, Getz Road
Nazareth, Pennsylvania 18064
February 20, 1980
Ms. Rochelle B. Volin
Project Monitor
United States Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 1S106
Dear Ms. Volin:
I have been authorized by the Plainfield Township Planning &
Zoning Commission to correspond with you in regard to the draft
Environmental Impact Statement as prepared for Bushkill-Lower Lehigh
Joint Sewer Authority and Borough of Nazareth Waste Water Treatment
Facilities.
On February 18, 1980, the Plainfield Township Planning & Zoning
Commission passed a Resolution opposing any of the alternatives listed
in the Impact Statement which permits spray irrigation in Plainfield
Township. We are strongly opposed to usage of valuable farmland in
Plainfield Township for spray irrigation. The Plainfield Township
Farmers' Association and adjoining farm owners to the proposed spray
irrigation site are extremely upset with the proposed alternatives.
We trust that no further consideration will be given to spray
irrigation in Plainfield Township.
Sincerely yours,
S / /'
': •. e i f r ff , A t / /<• , / /• „' rf>' ^
Elwood Lieberman, Chairman
Plainfield Township Planning & Zoning Commission
cc. Plainfield Township Board of Supervisors
Ernest Ibarra, Secretary, Plainfield Township Pig. & Zng. Com.
John Molnar, Esquire
Richard T. Rutt, P.E.
Charles Smith, Esquire
Lewis H. Wolfe
Jack J. Schramm
200
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PRESIDENT >Assoc/at/on
KKtblUENT V|C£ PRE5|DENT
Richard D. Lieberman r^ld Mac)<
R.D. ], 3ox 159-B - n ,
P-n Argyl, Pa. ,8072 ^ Argy|/ ^J^
SECRETARY TREASURER
Fay Fulmar
R.D. 3, 9ox 281 ^ Nancy HcAer
Nazareth, Pa. 18064 February 20, 1980 R.D. 3, Box .345
Nazareth, Po. 13064
Ms. Rochelle B. Vol.in
Project Monitor
United States Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Volin:
I am currently the President of the P.lainfield Farmers Fair
Association.
The Plainfieli.l Farmers Fair Association has been holding an
annual Fair at the Plainfield Farmers Grove on Route 191 for over
thirty (30) years. in reviewing the Environmental Impact Statement,
we find that there are a number of alternatives proposed by the
Environmental Protection Agency recommending spray irrigation on
lands adjoining the Plainfield Farmers Fair Association real estate.
The citizens of Plainfield Township and citizens of Northampton
County have enjoyed and looked forward to the holding of this annual
affair. There are approximately 20,000 to 30,000 people who attend
this annual event. We are opposed to having a spray irrigation site
adjoining our Farmers Fair Association real estate. We believe that
a spray irrigation site in the close proximity of our real estate will
have an adverse effect on the Fair.
We are also opposed to the taking of approximately 100 acres of
valuable, farmland for the purpose of spray irrigation.
We recommend that the Environmental Protection Agency dismiss
any thoughts of using farmlcinJ in Plainfield Township for spray
irrigation.
Sincerely yours,
Richard D. Lieberrnan, President
Plainfield Farmers Fair Association
cc. Plainfield Township Board of Supervisors
Ernest Ibarra, Secretary, Plain field Township Pig. & Zruj. Corn.
Jack J- Schrarrrn 2Q1
Lewis H. Wolfe
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FEDERAL EMERGENCY MANAGEMENT AGENCY
FEDERAL INSURANCE AND HAZARD MITIGATION
CURTIS BUILDING, SIXTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
REGION III
IN REPLY REFER TO:
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have adopted flcodplain managaaent ordinances in compliance with Section
6U.3(d) (fonoerly designated lb>10.3(d)) of tiie regulations for the National
Flood Insurance Program. These ordinances lindt and condition, out do not
prohibit totally, development within the one hundred (iuO) year flood plain
as defined by their respective Flood Insurance otuoy. Copies of these
ordinances and studies are available in tne offices of our Insurance and
Division (Curtis Building, koom 7Uo).
/fe appreciate tiie opportunity to reviev; this Unviroiiiiiental Lupact
iitatev.ient. Please feel free to contact us if you have any questions.
bincerely yours,
"Walter P. Pierson
Actiny Director
Insurance and Mitigation Division
203
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LEHIGH UNIVERSITY
Bethlehem, Pennsylvania 18015
Telephone: (215)861-3680
86'-3681
Department of Biology
Williams Hall #31
February 28, 1980
Ms. Rochelle Volin (3IR61)
United States Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Ms. Volin:
Enclosed please find my comments on the Draft Environmental Impact
Statement on the Bushkill -Lower Lehigh Joint Sewer Authority Project. I
presented most of this statement at the February 21st hearing at the
Nazareth Junior High School. Hopefully these comments will be helpful
to you in the preparation of the Final Impact Statement. I hope that you
will be able to conduct more bacterial tests in order to ascertain the
cause of coliform bacteria pollution in the creek and nitrate contamination
of the wells.
Thank you for your time and consideration.
Sincerely yours ,
Patricia T. Bradt, Ph.D.
Adjunct Assistant Professor
PTB:ams
204
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Comments on the Draft Environmental Impact Statement on
Bushkill Lower Lehigh Joint Sewer Authority
by
Patricia T. Bradt, Ph.D.
February 21, 1980
Good evening. My name is Dr. Patricia Bradt and I live in Palmer Township
at 10 Ivy Court, Easton. I guess I can represent the inactive Bushkill Watershed
Association, but I would rather represent myself, a concerned biologist. I have
taught biology at both Lafayette and Lehigh and am currently doing research at
Lehigh.
I have conducted several long term studies on the biology and water/quality
of the Bushkill Creek and am continuing these studies. I documented my work on
the stream at the January 1979 public hearings. My purpose tonight is to address
the draft environmental impact statement prepared by EPA and Wapora. I have
spent hours pouring over the 597 pages and I feel that I have not yet grasped
the entire subject.
In deciding the best method of solving the human waste disposal problems
in the upper portions of the Bushkill drainage basin, it is imperative that the
water quality in the Bushkill Creek and its tributaries be preserved or even
better - improved over the present quality. Only by preserving or improving
the existing water quality, will the future of the Bushkill Creek as a reproducing
trout stream be insured. The DEIS considers water quality in the stream as a
high priority and I am very pleased with that part of the statement. In addition
both the placing of sewage effluent on the land and the prevention of water loss
from the drainage basin are two ecologically sound recommended actions. Ideally
the nutrients in sewage effluent should be returned to the land where they can
fertilize land plants rather than put into the water where they only fertilize
algae. Unfortunately there are problems with land disposal of effluents i.e.,
heavy metals build up and virus survival. If land disposal is selected the
effluent must be free of heavy metals and pathogenic viruses. The cost of the
land under consideration for land application may be prohibitive. The retaining
of water in the drainage basin - by cluster systems and by land disposal - will
insure adequate recharge of the ground water. A minimum of water should be
exported from the drainage basin via centralized sewage to the Easton treatment
plant.
I have many comments and questions which I will submit in formal form for
the Final Environmental Impact Statement. I will briefly summarize my questions.
I. Will the land disposal, cluster systems and other sewage treatments
quarantee that there will be no problems with nitrates in ground water and coli-
forms in the creek from these systems? The DEIS mentions mitigation - how do we
know these mitigation methods will prevent further ground water and surface
water contamination? What are the guarantees?
II. I am pleased that the areas of route 115 in Belfast, Stockertown and
Tatamy have a high priority for sewers. The need is these areas is well
documented.
205
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2.
III. Jacobsburg State Park has been removed from consideration for waste
disposal. Originally Jacobsburg was to have many overnight camping facilities
and would not open until sanitary sewers were completed. Obviously the state has
revised its plans for Jacobsburg. Does the state plan not to have any sewage
treatment for the park? What are the plans?
IV. One of the key issues is the issue of malfunctioning septic systems
and deteriorating water quality. If this is a key issue, I think more work
should have been done on the identification of the.type of bacterial pollution
in the stream. Are the bacteria from humans or domestic animals? In order to
identify more precisely the source of the bacteria, more fecal coliform and fecal
streptococcus samples should be taken - over many months - not just over a few
days. No valid conclusions can be drawn from a few days of sampling! Bacterial
sampling should be done during high water, low water and at high water temperatures
Because of the infrequent sampling for fecal coliform and fecal streptococcus,
I am not convinced that it is agricultural runoff and not septic tanks and sewage
plant effluents that are contributing both bacteria and nutrients (nitrates and
orthophosphate) to the stream. I question the data from which these conclusions
are drawn. With all the money spent on this impact statement I think more
attention should have been given to determining more definitely the source of
bacterial and nutrients inputs to the stream and ground water. If it is
agricultural runoff causing the problems, perhaps all this waste water treatment
will not significantly improve and protect water quality in the stream and wells.
There are studies wh/ich can be done to pinpoint sources of nitrogen and bacteria
and I strongly urge that these studies be done.
V. Nitrates in both ground water and surface water are a cause for concern.
I think we should take a long hard look at both the Wind Gap and Nazareth sewage
treatment plants as a potential source of nitrate in both ground and surface
water.
I am concerned about the nitrate content of ground water in the limestone
areas and urge that this problem be addressed. Ninety-six percent of the wells
sampled were in Bushkill Township - what about the limestone area wells? Some
testing we did in 1976-77 indicated that the limestone springs may be a source of
nitrates.
VI. I must question the statement that nutrients in the stream are decreasing
My two long term studies (16 months each) indicate at least a doubling of nitrate
and orthophosphate from 1973 to 1977. These determinations were taken in the
exact same place and cover about 60 chemical analyses.
There should be no more sewage effluents discharged to the stream and I am
pleased that the DEIS agrees. Nutrient input into the stream must be curtailed.
I hope that whichever alternative is chosen, the nutrients entering the stream
will be drastically reduced. The future of the stream is at stake.
VII. The DEIS has given top priority to the preservation of agricultural
lands. I heartily agree with this priority! The annual loss of farmland in the
United States is enormous and with the increasing shortage of food, arable land
is a valuable resource for both the United States and the world.
206
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3.
VIII. The Nazareth sewage plant obviously has problems and is contributing
to the deterioration of both the Schoeneck and the mainstream Bushkill. We have
been studying the Schoeneck and very recently recorded very high fecal coliform,
ammonia, nitrite, nitrate and orthophosphate levels - the highest I have ever
recorded in the drainage basin! The Schoeneck contribures up to 25% of the flow
of the Bushkill and as such injects a large load of bacteria and nutrients to
the Bushkill.
Even with a new treatment plant at Nazareth there will still be nutrient
input into the stream. Perhaps nutrient removal should be considered if we really
want to preserve the Bushkill and improve the Schoeneck.
IX. The biological survey has several problems. In the case of the plants,
the Jacobsburg survey omits many plants found in the park - such as trout lily,
Jack-in-the-pulpit, dwarf ginseng, butterfly weed and many ferns and mosses. I
have had students do studies there and have also taken classes there on field trips
In the fish survey the fairly common Johnny Darter, Etheostoma nigrum, was
omitted. The invertebrate survey is apparently complete.
The American toad's name is Bufo americanus, not Bufo terrestris as stated
in the DEIS. Bufo terrestris is found only south of the Mason Dixon Line.
Other changes in the biota list are as follows:
Plant Species in Jacobsburg Park:
There are many species of mosses and liverworts in the Park, also
many species of fern not mentioned. I enclose a list of flowering plants
(Angiospermae) found in the Park during a student survey in 1975.
In conclusion, the preservation of the Bushkill Creek as a stream supporting
reproducing trout must be insured. The pollution of both ground water and surface
streams from bacteria and nutrients must be prevented. The stream is still re-
covering from the stress of the rechanneling in the late 1960's.
The solving of the waste problems in the northern part of the drainage basin
must be compatible with the future health of the stream. The Bushkill Creek does
not need any further stress, both point and nonpoint discharges must be reduced.
Trout habitat is rapidly disappearing from the northeast. Whatever alternative
is selected, let us be assured that the valuable natural resource, trout habitat
in the Bushkill Creek, is preserved for future generations. Thank you.
207
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F & M ASSOCIATES, INC.
INDUSTRIAL
Consulting Civil Engineers MUNICIPALS
Frank W. Moyer, P. E. 1132 Hamilfon Sfreet
John C. Paris!, P. E. Allentown, Penna. 18101
Donald J. Shurilla, P. E. ph°ne 215 432-4531
David B. Nuss, P. E.
Douglas H. Gordon, P. E.
Monroe W. Frey, R. A.
Peter P. Brungard, Jr., R. S
John s. Heiny, R. S. February 7, 1980
U. S. Environmental Protection Agency
Region III
6th & Walnut Street
Philadelphia, Pa. 19106
Atn: Rochelle B. Volin
3IR61
Re: Draft Environmental Impact Statement
Bushkill-Lower Lehigh
Joint Sewer Authority and Borough of Nazareth
Dear Ms. Volin:
I have received a draft of the EIS for the referenced project
and offer the following comments in regards to the effects on the
Borough of Nazareth.
I agree with the conclusion that EIS Alternative 9 with slight
modification is the best alternative and feel the Borough of Nazareth
will concur with that selection.
I also concur in the elimination of the Schoeneck Creek inter-
ceptor and the replacement of the Nazareth Treatment Plant. This
is consistent with the conclusions reached in our previous reports
the the Borough of Nazareth.
I also note the comment in the EIS that if the Nazareth Sewerage
Company becomes publicly owned, the owners may apply to EPA for Step
I and subsequent grants for planning, design and construction of
wastewater facilities. There is even a clause that the owners may
enter into an agreement with the Bushkill-Lower Lehigh Joint Sewer
Authority to amend the existing application to include funds for
necessary Step I planning effort. Since the purchase of the Nazareth
Sewerage Company by the Borough of Nazareth is imminent, we anticipate
this is the procedure they would follow.
208
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In summary, I concur with the scope of the EIS and look
forward to the utilization of the selected Alternative to provide
the proper wastewater management.
John C. Parisi, P.E.
cc: Nazareth Borough Municipal Authority (5)
ccL Conrad C. Shimer, Esq.
cc: Alfred S. Pierce, Esq.
cc : Thomas Coughlin
209
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PLAINFIELD TOWNSHIP TAXPAYERS ASSOCIATION
Box 164
Wind Gap, Pa. 18091
Ms. Rochelle Volin (3IR60)
U.S. Environmental Protection Agency
Curtis Building
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
We wish to thank Ms. Rochelle Volin and her fellow workers
in the E.P.A. for the in depth study which resulted in the
draft envrionmental impact statement for the BLL project.
Our thanks also to Eric Hediger and the planners, geologists
demographers and associates from Wapona, Inc., who contributed
so greatly to this study.
It was very gratifying to find that all of this work found the
BLL proposal completely unacceptable for the variety of reasons
outlined in the E.I.S.
The one area in which we think additional information would
have been desirable, is in identifying the potential and
confirmed malfunctions with names and addresses. I will point
out the reasons for this a bit later.
We attended our last Supervisors meeting and pointed out to them that
after wasting all this time, to say nothing of the thousands of
dollars they have expended on the BLL project, all that has been
achieved is an unacceptable BLL plan. In view of this fact we
cannot condone any plan involving the BLL. If the recommended
action were taken all of the people from our Township who would
be forced to use it would not only be paying for a massive sewer
system which we do not need, but they would also find themselves
captive payees to amortize the enormous debt BLL has run up with
bank loans.
In order to preclude this we have suggested to our Supervisors
that they cut any additional losses and pull out of the BLL
project entirely.
We have always recognized the fact that there are some
problem areas in the Township, and urged our Supervisors to
solve them by embracing a waste water management concept as
210
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Ms. Rochelle Volin February 21, 1980
U.S. Environmental Protection Agency Page TWO
enunciated in the E.I.S. Incidentally we made this same
recommendation to our Supervisors several years ago.
As part, of this waste water management plan we think the problems
in the southern end of the Township could also be addressed and
solved, hence the earlier request for identification of
malfunctions so that the new Board could begin with the known
problem areas first.
Rochelle, I am now retired and if necessary you may reach me
on my home phone 1-215-863-4422.
Thank you again for all your hard work, and an excellent job.
Sincerely yours ,
'
JOSEFH 7. DORNER
211
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PRESIDENT >Assoc/at/on
B- L j V: .. , VICE PRESIDENT
Kichard D. Lieberman rv,^^U M~,-L
R.D. I, Box 159-B Donald Mock
Pen Argyl, Pa. 18072 R;^ '
Pen Argyl, Pa. 18072
TREASURER
Fay Fulmer . ,.
R D 3 Box 281 Nancy Hower
Nazareth, Pa. 18064 February 20, 1980 R.D. 3, Box 345
Nazoreth, Pa. 18064
Ms. Rochelle B. Volin
Project Monitor
United States Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Ms. Volin:
I am currently the President of the Plainfield Farmers Fair
Association.
The Plainfield Farmers Fair Association has been holding an
annual Fair at the Plainfield Farmers Grove on Route 191 for over
thirty (30) years. In reviewing the Environmental Impact Statement,
we find that there are a number of alternatives proposed by the
Environmental Protection Agency recommending spray irrigation on
lands adjoining the Plainfield Farmers Fair Association real estate.
The citizens of Plainfield Township and citizens of Northampton
County have enjoyed and looked forward to the holding of this annual
affair. There are approximately 20,000 to 30,000 people who attend
this annual event. We are opposed to having a spray irrigation site
adjoining our Farmers Fair Association real estate. We believe that
a spray irrigation site in the close proximity of our real estate v/ill
have an adverse effect on the Fair.
We are also opposed to the taking of approximately 100 acres of
valuable farmland for the purpose of spray irrigation.
We recommend that the Environmental Protection Agency dismiss
any thoughts of using farmland in Plainfield Township for spray
irrigation.
Sincerely yours,
Richard D. Lieberman, President
Plainfield Farmers Fair Association
cc. Plainfield Township Board of Supervisors
Ernest Ibarra, Secretary, Plainfield Township Pig. & Zng. Com.
Jack J. Schramm
Lewis H. Wolfe 212
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APPENDIX F
TRANSCRIPT (COPY) OF
PUBLIC HEARING ON DRAFT EIS,
21 February 1980
(Included by Reference)
213
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