United States
Environmental Protection
Agency
Region 3
6th and Walnut Streets
Philadelphia, PA 19106
August 1980
Final Environmental
Impact Statement
Bushkill-Lower Lehigh
Joint Sewer Authority
and Borough of Nazareth
Wastewater Treatment
Facilities
Northampton County, PA.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                        REGION 111
                 GTH AND WALNUT STREETS
            PHILADELPHIA, PENNSYLVANIA 19106
                                                                  JUL  '.  81S80
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement (EIS)  prepared
by the U.S. Environmental Protection Agency (EPA)  on the proposed construction
of Federally funded wastewater management facilities for the Bushkill-Lower
Lehigh Joint Sewer Authority and Borough of Nazareth, Northampton County,
Pennsylvania.

I wish to thank the applicant for the assistance provided to EPA's staff
during this EIS process.  In addition, I wish to commend the performance of
each Township and Borough representative for the guidance they provided EPA
throughout this decision-making endeavor.  Finally,  I want to especially
recognize the strong commitment of local citizens  throughout the study.  Their
participation has contributed to the development of  responsive solutions to
sewage needs of the area.

This Final EIS is being issued pursuant to the National Environmental Policy
Act of 1969, the Clean Water Act of 1977, and regulations promulgated by this
Agency (40 CFR, Part 6, November 6, 1979).  Comments or inquiries concerning
this EIS should be submitted to the attention of Ms. Rochelle Volin (3IR61) at
the above address by October 5, 1980.

The Final EIS has determined that the Applicant's  Proposed Action is  unaccept-
able for Federal funding due to its potential to cause significant adverse
environmental impacts.  The preferred project (Alternative 9)consists of
conveyance of flows from portions of Plainfield Township, Stockertown and
Tatamy Boroughs, and Palmer Township to the Existing Easton sewage treatment
plant; conveyance of flows from Upper Nazareth Township and the Borough of
Nazareth to a new sewage treatment plant in Nazareth Township:   the use of
multi-family filter fields (cluster systems) in portions of Plainfield and
Bushkill Townships and individual on-site systems  throughout the rest of the
service area.  This action complies with the President's energy conservation
directive by minimizing the total energy demand of the service area and
minimizing construction in streams thus decreasing potential adverse  impacts
to a popular local trout stream.

A public meeting regarding the Final EIS will be held on September 18, 1980,
at 7:30 p.m., in the Nazareth Junior High School.   Both the public and representa-
tives of organizations are encouraged to attend and  express their comments and
opinions on the Final EIS.


 Sincerely  Vours,
          Jl
 JAck
 Regional Administrator
           V
 Enclosure

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                            FINAL ENVIRONMENTAL  IMPACT  STATEMENT
                                                 on
                                    BUSHKILL-LOWER LEHIGH JOINT
                               SEWER AUTHORITY AND BOROUGH OF NAZARETH
                                   WASTEWATER TREATMENT FACILITIES
                                  NORTHAMPTON COUNTY, PENNSYLVANIA
                                            Prepared by:
                                 US ENVIRONMENTAL  PROTECTION AGENCY
                                             REGION III
                                     PHILADELPHIA, PENNSYLVANIA

                                 Rochelle B.  Volin, Project Monitor

                                  Prepared with  the Assistance of:
                                            WAPORA, Inc.
                                           Washington  DC
                                  Eric M.  Hediger, Project Manager
Type of Action:
  Legislative (
  Administrative
X )

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LIST OF PREPARERS           This Environmental Impact Statement was prepared by the US Environmental
                            Protection Agency (EPA), Region III, Philadelphia, Pennsylvania, with
                            assistance from WAPORA, Inc.

                            Key personnel from EPA include:

                            Rochelle B. Volin                   Project Monitor

                            Contributors from WAPORA were:

                            Eric M. Hediger                     Project Manager
                            E. Clark Boli                       Senior Project Advisor
                            Gerald 0. Peters, Jr.               Technical Advisor
                            James C. Varnell, P.E.              Senior Environmental Engineer
                            J. P. Singh, P.E.                   Senior Environmental Engineer
                            Nowzar Dinyarian                    Associate Environmental Engineer
                            Henri D. Bartholomot                Assistant Environmental Engineer
                            Wu-Seng Lung, Ph.D., P.E.           Senior Water Quality Scientist
                            J. Ross Pilling, II                 Associate Environmental Planner
                            Wesley R. Horner                    Associate Socioeconomist
                            Melissa J. Wieland                  Graphics Specialist
                            Teresa F. McCue                     Quality Control Specialist

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EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY
Applicant
conclusions of
Final EIS
Draft EIS
EIS issues
This Final Environmental  Impact Statement (EIS)  has  been  prepared  by  US
Environmental  Protection  Agency (EPA)  Region  III.   It concerns  the Bushkill-
Lower Lehigh Joint Sewer  Authority's  proposed plan  to construct a  regional
collection system to serve the wastewater management needs  of the  following
municipalities1  in Northampton County,  Pennsylvania:
                            •  Bushkill Township
                            •  Upper Nazareth Township
                            •  Nazareth Borough
                            •  Plainfield Township
                                          •   Stockertown  Borough
                                          •   Tatamy  Borough
                                          t   Palmer  Township.
The Bushkill-Lower Lehigh Joint Sewer Authority  (B-LLJSA)-has  requested  the
participation of EPA in the funding of this  plan,  hereafter  referred  to  as
the Applicant's Proposed Action (APA), under the Construction  Grants  Program.
In most cases, the conclusions of the Final  EIS  confirm  those  of  its  predeces-
sor, the Draft EIS.  Major findings are listed below.

•  The APA does not represent an appropriate strategy  to  serve the waste-
   water management needs of the seven municipalities  listed abovel based on
   considerations of the need (as defined  by the Construction  Grants  Program)
   for sewerage facilities, its induced growth potential,  and  its impacts
   (via the Bushkill Interceptor) on the naturally reporducing trout  fishery
   of Bushkill Creek.

a  The Modified Applicant's Proposed Action  (MAPA)  is  not  an acceptable  waste-
   water management plan for funding under the Construction Grants Program
   on the basis of need (as defined above),  cost-effectiveness, induced  growth
   potential, and impact on the naturally  reproducing  trout fishery of Bushkill
   Creek.

•   EIS Alternative  9 is  determined  to be the most cost-effective and environ-
    mentally  acceptable approach  to  serve the documented wastewater  management
    needs of  the  EIS Phase  I Service Area.   Therefore,  it has been selected as
    the EIS Recommended Action.   Growth induced by this alternative  is reasonable,
    and associated secondary impacts are not excessive.  Trout production and
    recreational  areas along Bushkill Creek downstream from Tatamy Borough
    would not be  disturbed  by construction  activities as would be the case if
    the MAPA  were built.  The alternative involves  the replacement of the
    existing  Nazareth sewage treatment plant (STP)  with a new treatment facility
    and the construction  of pump  stations and force mains to avoid the install-
    ation of  gravity sewers in the floodplain of Bushkill Creek.

EPA published the Draft  EIS during December 1979.   The primary purposes of this
document were to review  and analyze the B-LLJSA's application for EPA funding
of  the APA and to develop  and evaluate alternatives in view of the  public issues
surrounding  the  project.   These  issues include (see Section I.C., Draft EIS):

    Need documentation
   Cost-effectiveness2
    Induced growth and secondary  impacts
   Groundwater supplies
   Public participation.
                            ^These municipal ties are known collectively as the EIS Service Area.

                            2EPA's review of the cost-effectiveness of the APA and the development of
                             potentially cost-effective alternatives was conducted under the precept
                             that cost-effective wastewater management plans minimize the total cost
                             of water pollution control to the public.

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documentation of
need by EPA
wastewater management
approaches for Phase I
and Phase II areas
ten EIS alternatives
MAPA
purposes of Final EIS
In response to the first issue, EPA devoted a substantial  effort to document
existing water quality problems and potential public health hazards that are
associated directly with malfunctioning on-site wastewater management systems
in the EIS Service Area.  This effort included an aerial  survey and field
investigation of residential  areas, sampling of streams and wells for pol-
lution indicators, and interviews with municipal  sewage enforcement officers
and other local health officials.  EPA concluded that an immediate need
for sewers or other off-site facilities exists in the following communities:
the Belfast-Edelman area, east Pen Argyl,  and Rasleytown in Plainfield
Township; Rismiller in Bushkill Township;  Stockertown Borough; Tatamy
Borough;'Nazareth Borough; suburban areas  and Christian Springs in Upper
Nazareth Township; and the Newburg Homes  subdivision in Palmer Township.
The following areas that were proposed to  be sewered by the Applicant do not
have documented needs for off-site wastewater management facilities:
Jacobsburg State Park and Cherry Hill  in  Bushkill  Township; Route 115 north
of Belfast in Plainfield Township; and the sparsely populated Northern Cor-
ridor of Palmer Township (with the exception of Newburg Homes).

The results of the needs documentation effort were integral to the develop-
ment of cost-effective, alternative wastewater management approaches  for
areas with immediate need for off-site facilities  (Phase I areas)  and for
areas in which limited wastewater management problems can be solved best by
on-site system replacement or rehabilitation (Phase II areas).  Technologies
that might reduce project costs or minimize adverse impacts (excessive
induced growth, diminished groundwater suppl ies,  etc.), while still  solving
existing problems, were examined first.  Four categories  of alternative
technologies — flow reduction, low-cost  sewers,  decentralization, and land
application -- were considered.  In addition, several specific areawide
alternatives to the APA were developed, combining  the alternative technolo-
gies into complete wastewater management  systems  that would meet the  needs
of the EIS Service Area.

A total of ten alternatives and a "no-action" plan were developed by  EPA and
the public during the EIS process.  Five of these  alternatives proposed the
use of the up-graded and expanded Easton STP, and  four alternatives involved
the upgrading and expanding,  or replacement,  of the existing Nazareth STP.

In order to compare the APA to feasible alternatives developed in this EIS
with respect to costs and environmental impacts,  certain basic assumptions
used by the Applicant in the design of the APA were modified to comply with
those used in the design of the alternatives.  These assumptions pertained
to wastewater flow per capita, areas to be sewered, and design (final) year
of the project.J  This plan is referred to as the  MAPA.

The primary purposes of this Final EIS are to respond to  all  substantive public
and Agency comments on the Draft EIS and  to present new,  or revised,  informa-
tion that has been made available, or was  developed, since the Draft  EIS was
published.   Modifications to some of the  information contained in the Draft EIS
have been required as a result of changing conditions in the EIS Service Area
or because of public comments.

Major public comments received on the Draft EIS include the following:
                            3Under the MAPA, wastewater flow per capita is 60 gallons for residential
                             areas and 70 gallons for residential/commercial areas; the northern ex-
                             tension of the Bushkill Interceptor (through Jacobsburg State Park) is
                             removed, and the design year is 2000.  With the exception of these design
                             parameters, the MAPA is identical to the APA.

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evaluation of
Alternatives
significant decision
factors
need for project
segmental
cost-effectiveness
analysis
9  zoning ordinances that prevent development in floodplains

9  unit prices for sewerage components

9  costs of the Nazareth plant

9  the Boston treatment plant

9  gravity sewer versus force main/pump stations

9  induced growth estimates and impacts

9  energy requirements.

The evaluation of alternatives focuses  on the MAPA and  EIS  Alternative  9
because the MAPA is a redesign of the APA,  which is the subject  of  this EIS,
and because Alternative 9 is the Draft  EIS  Recommended  Action.   Two  versions
of Alternative 9 with slightly different engineering designs  have been
included in this final evaluation:

•  Alternative 9 (RBC)   a new rotating biological  contactor  treatment  plant  to
   replace the existing Nazareth STP; the wastewater conveyance  system  re-
   quires nine pump stations.  This version was  ultimately  dropped  from
   further consideration due to higher  costs and energy impacts.

•  Alternative 9 (Modified; OP)   a new oxidation ditch (OD)  treatment
   facility to replace the existing Nazareth STP; the wastewater conveyance
   system requires six pump stations.  This version is  hereinafter  referred
   to as Alternative 9.

The selection of Alternative 9 over the MAPA as  the Final EIS Recommended
Action is based on significant decision factors  re-evaluated  since  the
publication of the Draft EIS including  the  need  for the project, cost-
effectiveness, energy (electric power)  requirements, and induced growth
potential.  Their significance was highlighted during the public comment
period, which terminated 24 March 1980.

EPA considers Alternative 9 to be an acceptable  wastewater  management plan
from the standpoint of needs documentation.  This alternative serves only
those areas where documented on-site system problems exist.  The entire
capacity of the Schoeneck Interceptor under the  MAPA does not justify Federal
funding under the provisions of EPA's Construction Grants Program.   EPA would
fund only interceptor capacity to serve the existing wastewater  management
needs of Nazareth Borough, Christian Springs and suburban areas  (East Lawn)
in Upper Nazareth Township, Newburg Homes in Palmer Township, and  a reasonable
rate of growth.

A  segmental cost-effectiveness analysis, independent of the  alternatives cost-
effectiveness analysis, was  performed.    It  compared  sewage treatment by a new
Nazareth STP, conveyance  to  the Easton STP  by a  gravity interceptor, and
conveyance to the  Easton  STP  by a force  main/pump  station  system.    Flows
originate at  the Nazareth STP  and end  at the Penn  Pump manhole.  A  new
Nazareth STP  is less  expensive than  a  gravity interceptor  along Schoeneck
Creek; the cost savings are  equivalent to  approximately $0.70/month/family.
A  comparison  of wastewater conveyance  by gravity sewer and by a force  main/
pump station  system  (Tatamy  Borough  to Penn Pump  Park manhole) also was
performed.  The pressurized  conveyance along Tatamy  Road is  only slightly
more expensive than  gravity  conveyance along Bushkill  Creek.  The  difference
in cost between the  two conveyance methods  is equivalent to  $0.15/month/family.
This represents the  cost  of  insuring the preservation  of the trout  fishery in
Bushkill Creek, as well as other  recreational activities.

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energy requirements
•induced growth
final EIS
Recommended Action
fund-ing of EIS
Recommended Act-ion
final public meeting
In view of significant public concern expressed during the Draft EIS comment
period that EPA recommend a wastewater management plan that complies with the
President's energy conservation directives, EPA considers it necessary to
present a realistic energy evaluation of the MAPA and its EIS Alternatives.
This evaluation includes energy consumption by project-associated residents
as well as by project-associated wastewater conveyance and treatment compo-
nents -- the Second Street pump station and Delaware Drive pump station in
Easton and the Easton STP.  These additional  facilities are essential to the
implementation of any alternative involving wastewater conveyance to the
Easton STP, and should be considered in the comprehensive energy evaluation.
Electric'power requirements of the MAPA are five times larger than those of
Alternative 9 on the basis of the following comprehensive energy budget:
                            B-LLJSA/EIS Service Area-associated
                            wastewater conveyance and treatment
                            components

                            Electric  power consumption by induced
                            residential development @ 21,600 kwh/
                            yr for  single family homes and
                            16,900  kwh/yr for multi-family homes

                            Total estimated energy requirements
                                                MAPA
                                              (kwh/yr)

                                               723,860
                                            29,872,000
                                            30,595,860
Alternative 9
   (kwh/yr)

     461,004
   6,263,000
   6,724,004
Implementation of the MAPA would induce the construction of approximately five
times the number of dwelling units (1,515 units)  beyond the baseline than
would be the case under Alternative 9 (311  units).   These estimates of induced
growth include development that could occur in the  designated 100-year flood-
plains of streams in Stockertown Borough and Tatamy Borough.  Recently adopted
floodplain management ordinances for these  municipalities limit and condition,
but do not prohibit, development in the 100-year floodplain.

The Applicant's proposed action is neither  cost-effective nor environmentally
acceptable and is therefore, not eligible for Federal  funding.  Alternative 9
has been determined to be the most cost-effective wastewater management plan,
with a total present worth cost of $10.0 million.  The MAPA, with a total
present worth cost of $12.2 million, is $2.2 millionr(22%) more costly than
Alternative 9 and is not acceptable for Federal  financial assistance.

The responsibility for final decision-making on funding eligibility rests with
the EPA Regional  Administrator.  Following  the close of the 30 day comment period
on the Final EIS, EPA will prepare a formal Record  of Decision, which will be
distributed to the public.  'This Record will  set forth the conclusions of the
EIS process, the  decisions made by EPA on funding of the EIS Recommended Action,
and the actions by the Applicant that are eligible  for Federal funding.

A public information meeting to discuss the recommendations presented in the
Final  EIS will be held in the EIS Service Area during the comment period on
this document.  The site of the meeting will  be the Nazareth Junior High School.
The date and time of the meeting are announced on the cover letter of this
document.

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            Summary of beneficial environmental impacts  of alternative wastewater management  plans evaluated  in
Beneficial
Environmental Impact
(by Environmental Category)
Earth Resources
1. Preservation of prime
agricultural land
Water Resources
1. Improvement in quality
of Schoeneck Creek
below existing Nazareth
STP
2. Recharge of groundwater
resources
3. Reduction in ground-
water quality problems
resulting from
malfunctioning on-lot
sewage disposal systems
Socioeconomic Conditions
1. Increase in long-term
employment in EIS
Service Area
Type of Impact
Primary
ST2 LT3


•






Secondary
ST2 LT3
•



•

• •


Probability of
Impact Occurrence
High Moderate Low
•

•

t

•
•

MAPA


X



XX
XX

Alternatives
123456789 10,
XX XX X X

XXXXXXXXXX

XX XX XX XX X X XX X X X

xxxxxxxxxxx


1 "XX" denotes very significant impacts; "X" denotes less significant impacts;  a dot  (•)  indicates that a type, or level, of impact is expected
  to occur.

2 ST = Short term
 LT = Long term

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Adverse
Environmental Impact
(.by Environmental Category)
Earth Resources
1. Conversion of prime
agricultural land to
developed uses
2. Inducement for develop-
ment on steep slopes,
with subsequent erosion
of soils
3. Inducement for develop-
ment in flood-prone
areas^
4. Disruption and erosion
of soils as a result of
project construction
Water Resources
1. Sedimentation of surface
channels during project
construction
2. Reduction in Schoeneck
Creek flow induced
by elimination of
Nazareth STP discharge
3. Potential to disrupt
groundwater movement
patterns and stream
hydraulics
4. Potential reduction in
water quality through
sewer system malfunctions
Type of Impact
Primary
ST2 LT3











•



•


•



0



•


Secondary
ST2 LT3

t


•



•




















Probability of
Impact Occurrence
High Moderate Low

•


•



•


•



•


0



•



•


MAPA

X


X



XX


XX



XX


X



XX



X


Alternatives
123456789 10

X


X XXX



XXXXXXXXXX


XXXXXXXXXX






X X X X XX










  "XX denotes very significant impacts; "X" denotes less significant  impacts;  a  dot  (•)  indicates that a type, or level, of imapct is expected
  to occur.
2ST = Short term
  LT = Long term
^Except  in flood-prone areas where development is specifically prohibited by  municipal ordinance.

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Summary of adverse impacts (continued).
Adverse
Environmental Impact
(by Environmental Category)
Biotic Resources
1. Disruption of wild trout
habitat
2. Loss or disturbance of
wetlands through induced
development
3. Loss or disruption of
wildlife habitats
Land Use
1. Inducement for conversion
of undeveloped land to
developed areas
2. Increase in residential
density and changes in
community character
Population
1. Project-induced growth to
exceed baseline population
in year 2000
2. Financial burden on resi-
dents imposed by estimated
local user charges
3. Expenditure of public
funds for sewerage needs
not documented
Public Services
1 . Induced need for school
desk space in excess of
baseline requirements
Type of Impact
Primary
ST2 LT3

• •




•












•


•






Secondary
ST2 LT3

• •

•


•


•


•



•









t


Probability of
Impact Occurrence
High Moderate Low

t




•


•


•



i


•


•



t


MAPA

XX




XX


X


X



XX





X



X


Alternatives
123456789 10



X


X


XXXX XXX X


XXXX XXX X



XXXX XXX X


X X


X XXX X



XXXX XXX X



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Summary of adverse impacts (concluded).
Adverse
Environmental Impact
(by Environmental Category)
Public Services (continued)
2. Induced need for police
and fire protection in
excess of baseline
requirements
3. Increased traffic volumes
to require region-wide
highway improvements
4. Induced need for more
extensive or improved
recreational resources
" Energy
1 . Increased consumption of
energy by wastewater
management system
components (kwh/yr)
Type of Impact
Primary
ST2 LT3












• •



Secondary
ST2 LT3

•



•


•



• •



Probability of
Impact Occurrence
High Moderate Low

•



•


•



•



MAPA

X



X


X







Alternatives
123456789 10

XXXX XXX X



XXXX XXX X


XXXX XXX X



XX XX X X X X XX X X X




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                                                                                                       Page

TALLE OF  CONTENTS       List of Tables                                                               xvii
                           List of Figures                                                              xvii
                           List of Acronyms and Abbreviations                                            xix
                           Introduction                                                                  xxi


                           Chapter I:  Public Participation                                                1


                           Chapter II:  Summary of Draft EIS                                               7

                           A.  Background                                                                  7
                           B.  EIS Assumptions -                                                           7
                           C.  Alternatives                                                               10
                           D.  Draft EIS Conclusion                                                       10
                           E.  Draft EIS Recommendation                                                   10


                           Chapter III:  Evaluation of Alternatives                                       13

                           A.  Existing Environment                                                       13
                           B.  Applicant's Proposed Action and Impacts                                    14
                           C.  Alternatives                                                               22
                           D.  Impacts                                                                    28


                           Chapter IV:  Comparison of Alternatives                                        35
                                                  s-

                           A.  Modified Applicant's Proposed Action                                       35
                           B.  Alternative 9                                                              36


                           Chapter V:  Conclusions and Recommendations                                    41
                                                          .j
                           A.  Description of £he Final EIS Recommended Action                            41
                           B.  Impacts and Mitigative Measures of the Final EIS                           46
                               Recommended Action
                            Chapter VI:  Implementation of Final EIS Recommended Action                    53

                            A.  Bushkill Creek Watershed                                                   53
                            B.  Schoeneck Creek Watershed                                                  53
                            C.  Small Flows District                                                       53


                            Chapter VII:  Public and Agency Comments on Draft EIS                          55

                            A.  Issue:  Need for Project                                                   57
                            B.  Issue:  Water Quality                                                      59
                            C.  Issue:  Land Use                                                           61
                            D.  Issue:  Alternatives                                                       62
                            E.  Issue:  Induced Growth                                                     71
                            F.  Issue:  Energy                                                             73
                                                       xv

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APPENDICES                  APPENDIX
                            A        Draft EIS included by reference                                        75
                            B        Recreation and wastewater management plans for Jacobsburg              77
                                    State Park
                            C-l      Induced growth potential in 100-year floodplains of Stocker-           82
                                    town Borough and Tatamy Borough
                            C-2      Induced growth associated with substitution of gravity sewer           83
                                    for pump stations/force main in Palmer Township, year 2000
                            C-3      Induced dwelling units for alternate wastewater management             84
                                    plans, year 2000
                            C-4      Sewer-induced growth in EIS Service Area                               85
                            D-l      Summary of additional  construction costs associated with APA           90
                            D-2      Energy analysis of APA, MAPA,  and EIS alternatives                      94
                            D-3      Engineering evaluation of Draft EIS included  by reference            125
                            D-4      Electric power consumption by  residential  development,  year 2000     126
                            D-5      Advantages and disadvantages of oxidation  ditches and rotating       128
                                    biological contactors
                            D-6      Design, operation, and maintenance of cluster systems                129
                            E        Letters of comment on  Draft EIS                                      133
                            F        Transcript (copy) of public hearing on Draft  EIS, 21  February  1980    213
                                                      xvl

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                                                                                                          Page
LlST OF TABLES             III-l    Updated cost summary of APA                                           19
                           III-2    Estimated local user charges ($) associated                           19
                                    with APA
                           III-3    Significant financial burden and displacement                         20
                                    pressure associated with APA
                           III-4    Expansion costs for Second Street pump station,                       20
                                    Delaware Drive pump station, and Easton STP that
                                    should be added to APA costs
                           III-5    Revised energy budget for APA                                         21
                           III-6    Total estimated energy requirements of APA                            22
                           III-7    Segmental cost-effectiveness analysis of                              26
                                    Alternates A, B, and C and Alternates D and E
                           III-8    Cost-effectiveness analysis of the APA, MAPA,                         29
                                    and Alternative 9
                           III-9    Estimated local user charges for the APA, MAPA, and                   30
                                    four versions of Alternative 9
                           111-10   Dwelling units induced under MAPA and EIS Alternative 9               31
                           III-ll   Financial burden and displacement pressure associated                 32
                                    with MAPA and Alternative 9
                           111-12   Revised energy budget for MAPA:  conveyance and                       33
                                    treatment systems
                           111-13   Energy budget for Alternative 9 (Modified; OD):                       33
                                    conveyance and treatment systems
                           111-14   Total estimated energy requirements for the MAPA                      38
                                    and Alternative 9 (Modified; OD) in the year 2000
                           IV-1     Significant factors considered in the selection of                    38
                                    the Final EIS Recommended Action
                           VII-1    Comparison of B-LLJSA and EIS construction costs for                  67
                                    sewers, stream crossings, and manholes
LlST OF FIGURES            1        Location of the EIS Service Area in Northampton
                                    County, Pennsylvania
                           2        Municipalities in the EIS Service Area
                           II-l     Applicant's Proposed Action
                           III-l    Applicant's proposed stream crossing (manhole
                                    210 to manhole 211) approximately 1 mile below
                                    Tatamy Borough
                           III-2    Applicant's proposed stream crossing (manhole 219                     14
                                    to manhole 220) approximately 1.5 miles below
                                    Tatamy Borough
                           III-3    Location of stream crossings associated with the                      15
                                    APA, MAPA and EIS Alternative 9 (Modified)
                           III-4    Forks Township Interceptor (east side of Bushkill                     17
                                    Creek)
                           III-5    Forks Township Interceptor (east side of Bushkill                     17
                                    Creek)
                           III-6    Subareas associated with segmented cost-effectiveness                 23
                                    analysis
                           III-7    Pump stations associated with EIS Alternative 9                       25
                                    modified conveyance system
                           IV-1     Nazareth oxidation ditch sewage treatment plant                       37
                                    (revised)
                           V-l      Final EIS  recommended action                                          43
                           V-2      Capital costs, present worth, and estimated user                      44
                                    charges associated with APA, MAPA, and four
                                    versions of Alternative 9
                                                         xv 1

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LIST OF ACRONYMS
AND ABBREVIATIONS
APA
B-LLJSA
BOD
DER
EA

EIS
EPA
EPIC
FM
GAI
gpm
i/a
JPC
kwh/yr
LF
LT
MAPA
mgd
Mg/1
MOD

N/A
OD
O&M
PS
PSI
PVC
RBC
ROW
SCS
SFD
STP
ST
ST/SAS
Applicant's Proposed Action
Bushki11-Lower Lehigh Joint Sewer Authority (the Applicant)
Biochemical oxygen demand
Pennsylvania Department of Environmental  Resources
Environmental Assessment for Bushki 11-Lower Lehigh Joint
Sewer Authority and City of Easton (GAI,  1976)
Environmental Impact Statement
United States Environmental Protection Agency (Region  III)
Environmental Photographic Interpretation Center
Force main
Gilbert Associates, Inc.
Gallons per minute
Innovative/alternative
Lehigh-Northampton Counties Joint Planning Commission
Kilowatt-hours per year
Linear  feet
Long term  (impacts)
Modified Applicant's Proposed Action
Million gallons per day
Milligrams per litre
Modified (refers to wastewater conveyance system comprising 6 pump
stations)
Not applicable
Oxidation  ditch sewage treatment plant
Operation  and maintenance  (costs)
Pump  station
Pounds per square inch
Polyvinyl  chloride
Rotating biological contactor sewage treatment plant
Right of way
US Department of Agriculture, Soil Conservation Service
Small Flows District
Sewage treatment plant
Short term (impacts)
Septic tank/soil adsorption system
               xix

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INTRODUCTION

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INTRODUCTION               Tn1s Final Environmental  Impact Statement (EIS)  has been  prepared  by the
                             US Environmental Protection Agency, Region III  (EPA).   It addresses  the
                             availability of Federal  funding for the construction of wastewater manage-
                             ment fac-jntl-es as proposec] by the Bushkill-Lower Lehigh  Joint  Sewer
                  ,           Authority (B-LLJSA), representing the following  municipalities  of
mmwpaiee under         Northampton County, Pennsylvania (Figures 1  and  2):  Bushkill Township,
    ^                        Plainfield Township, Upper Nazareth Township, Stockertown Borough, Tatamy
                             Borough, and Palmer Township.  These municipalities are charter  members  of
                             the B-LLJSA.  Although not a member of the B-LLJSA, Nazareth  Borough has
                             been included in this study because wastewater  conveyance and treatment
                             capacity for its approximately 5,700 residents  was provided  in  the Applicant's
                             Proposed Action (APA).

                             The application was submitted by the B-LLJSA for financial  assistance to
                             resolve the existing wastewater management problems of its  participating
                             municipalities.  The cost for the project as proposed  by  the  Applicant  is
                             estimated to cost $16,800,0,00 in 1980 dollars.

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 PENNSYLVANIA
         PHILADELPHIA
                                                                                                      •H
                                                                                                      •H
                                                                                    MILES
Figure  1.   Location of the EIS Service  Area in Northampton County,  Pennsylvania.

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FIGURE 2   MUNICIPALITIES  IN  THE EIS  SERVICE
——SERVICE AREA BOUNDARY
	MUNICIPAL BOUNDARY

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CHAPTER I
Public Participation
                       4UU

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CHAPTER  I:
PUBLIC PARTICIPATION
public participation
methods
chronology of
public participation
activities
The participation of the public has been sought continuously throughout the
preparation of this EIS,  Suggestions and criticisms generated by local, state,
and Federal agencies, citizen associations, private concerns,  and individual
citizens have been given full consideration in the following EIS processes:

•  Documentation of need for sewerage facilities
•  Development of alternative wastewater management strategies
•  Assessment of environmental, economic, and social impacts
t  Selection and implementation of an EIS Recommended Action.

Public participation methods utilized during preparation of the EIS included
newsletters, public information meetings, workshops, interviews, and telephone
contacts.  These techniques insured involvement with as many citizens as
possible at critical EIS decision points.

A chronology of EIS public participation activities is listed  below:
8 November 1978
15 December 1978
18 December 1978
20 December 1978
January 1979
17 January 1979
28 February 1979
9 March 1979
April 1979
25 April 1979
14 June 1979
29 August 1979
18 September 1979
September 1979
24 September 1979
11 October 1979

18 December 1979
December 1979
January 1980
7 February 1980
21 February 1980
24 March 1980
March 1980
3 April 1980
7 April 1980

22 May 1980
18 July 1980
August 1980
August 1980
September 1980
Preparation of EIS begins
Notice of Intent to prepare an EIS issued by EPA
Meeting with B-LLJSA
Meeting with Plainfield Township Taxpayers Association
EPA pamphlet discussing EIS published in newspaper
EIS Public Information Meeting No. 1
Meeting with Bushkill  Township
Meeting with Bushkill  Township
EIS Newsletter distributed
EIS Public Information Meeting No. 2
EIS Workshop No. 1
EIS Workshop No. 2
EIS Workshop No. 3
EIS Newsletter distributed
EIS Public Information Meeting No. 3
Meetings with Nazareth Borough, B-LLJSA, and Palmer
  Township
Meeting with B-LLJSA and Bushkill  Township
Draft EIS published and distributed
Summary-of-Draft-EIS pamphlet distributed
Meeting with B-LLJSA
Public Hearing on Draft EIS
End of public comment period on Draft EIS
EIS Newsletter distributed
Meeting with B-LLJSA
Meeting with B-LLJSA,  Palmer Township, and Congressman
  Donald Ritter
Meeting with B-LLJSA
Meeting with B-LLJSA and Nazareth Borough
Final  EIS published and distributed
Summary of Final EIS pamphlet distributed
EIS Public Information Meeting No. 4
                            The  remainder  of  this  chapter  identifies  the  agencies, elected officials,
                            media,  citizens groups,  libraries,  and citizens which are on the EIS mailing
                            list.

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                                        EIS MAILING LIST
 FEDERAL AGENCIES

 Advisory  Council on Historic
   Preservation
 Council on  Environmental
   Quality

 Federal Emergency Management
   Agency
 National  Agricultural Lands
   Study

 National  Environmental  Health
   Association
 US Bureau of Prisons

 US Department of Agriculture
     Forest  Service
     Soil  Conservation Service
 US Department of Commerce
     Office  of Environmental
       Affairs
 US Department of Defense
 US Department of Energy

 US Department of Helath, Educa-
   tion and  Welfare
 US Department of Housing and
   Urban Development
 US Department of the Interior
     Bureau  of Outdoor Recrea-
       tion
     Fish  and Wildlife Service
        National Water  Resource
          Analysis Group/Eastern
          Land Use Team
     National Park Service
     Heritage Conservation and
       Recreation Service

 US  Department of Justice
     E. MacTroutman, Esquire
     Ronald H. Gluck, Esquire
     Robert N. de Luca,   Esquire
     Robert S. Forester,  Esquire

 US  Department of Transportation
     Federal  Highway Administra-
      tion
    Marine Environmental Pro-
      tection Division
US Department of Treasury

US General Services  Administra-
  tion

Water Resources  Council
 PENNSYLVANIA  STATE AGENCIES

 Department of Agriculture

 Department of Commerce
 Department of Community Affairs

 Department of Environmental
  Resources
    Bureau of Air Quality and
      Noise Control
    Bureau of Community Environ-
      mental  Control
    Bureau of Occupational
      Health
    Bureau of Radiological
      Health
    Bureau of Solid Waste
      Management
    Bureau of State Forestry
    Bureau of State Parks
    Bureau of Topographic and
      Geological Survey
    Bureau of Water Environ-
      mental  Resources
    Bureau of Water Quality
      Management
    Coordinator for Environ-
      mental  Protection &
      Regulation
    Division  of Solid Waste
      Management
    Division  of Water Supply
      & Sewerage
    Environmental Hearing Board
    Regional  Director, Reading
      Region
    Sewage Facilities Consul-
      tant
    State Conservation Commis-
      sion

 Department of Health

 Department of Transportation
 Environmental Hearing Board
 Fish Commission

 Game Commission

 Historical and Museum Commission
 State Clearinghouse
LOCAL AGENCIES

Blue Mountain Consolidated
  Water Company
LOCAL AGENCIES  (continued)

Bushki11-Lower  Lehigh Joint
  Sewer Authority

Bushkill Township
    Board of Supervisors
    Engineer
    Planning Commission
    Secretary-Treasurer
    Solicitor

City of Easton
    Mayor
    Area Joint  Sewer Authority
    Suburban Water Authority

Delaware River  Basin Commission

Joint Planning  Commission,
  Lehigh-Northarnpton Couties
Nazareth Sewerage Company

Nazareth Borough
    Council
    Engineer
    Mayor
    Secretary
    Solicitor
    Treasurer
Northampton County Conserva-
    tion District

Palmer Tonwship
    Board of Supervisors
    Engineer
    Planning Commission
    Secretary
    Solicitor
Plainfield Township
    Board of Supervisors
    Engineer
    Planning Commission
    Secretary-Treasurer
    Solicitor

Stockertown Borough
    Council
    Mayor
    Planning Commission
    Secretary
    Solicitor
    Treasurer
Tatamy Borough
    Council
    Mayor
    Planning Commission
    Secretary
    Solicitor
    Treasurer

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 LOCAL AGENCIES  (continued)
MEDIA (continued)
CITIZENS GROUPS
 Upper  Nazareth Township
     Board  of  Supervisors
     Engineer
     Planning  Commission
     Solicitor
     Treasurer
 ELECTED  OFFICIALS

 Honorable  Richard  Thornburgh,
  •Governor of  Pennsylvania
 Honorable  H. John  Heinz,  III,
   United States  Senator

 Honorable  Richard  S.  Schweiker,
   United States  Senator

 Honorable  Donald T.  Ritter,
   United States  House of  Repre-
     sentatives

 Honorable  Jeannette  D. Reibman,
   Senate of Pennsylvania, Easton

 Honorable  George J.  Kanuck,
   Pennsylvania House  of Repre-
     sentatives,  Bethlehem

 Honorable  Russell  Kowalyskyn,
   Pennsylvania House  of Repre-
     sentatives,  Northampton

 Honorable  James  P. Ritter,
   Pennsylvania House  of Repre-
     sentatives

 Honorable  Michael  J.  Schweder,
   Pennsylvania House  of Repre-
     sentatives,  Bethlehem
 Honorable  Edmund J. Sieminski,
  Pennsylvania House  of Repre-
     sentatives,  Easton

 Honorable Joseph R. Zeller,
  Pennsylvania House  of Repre-
     sentatives,  Emmaus

 Honorable Kurt D. Zwikl,
  Pennsylvania House of Repre-
    sentatives, Allentown
MEDIA

Newspapers
    Allentown Morning Call
    Bulletin
    Easton Express
    Emmaus & Allentown Times
    Evening Chronicle
    Globe Times
Newspapers (continued)
    Herald
    Home News
    Nazareth Key
    News
    Northampton Times
    Town Topic
Radio
    WEEX   AM
    WEST   AM
    WEZV   FM
    WGPA   AM
    WJRH   FM
    WLEV   FM
    WQQQ   FM

Television
    WLVT   TV
CITIZENS GROUPS

Air Pollution Control Associa-
  tion, Pittsburgh PA
America the Beautiful Fund,
  Washington DC

Appalachian Mountain Club,
  Easton PA

Audubon Naturalist Society of
  the Central Atlantic States,
  Inc. , Washington DC

Brandywine River Conservancy,
  Chaddsford PA

Bushkill Anglers Chapter,
  Trout Unlimited, Nazareth PA

Bushkill Watershed Association,
  Easton PA

Bushkill Township Concerned
  Citizens Committee,
  Nazareth PA

Citizens' Advisory Council to
  the Pennsylvania Department
  of Environmental Resources,
  Harrisburg PA

Citizens Environmental Task
  Force, Pittsburg PA

Concerned Laymen for Environ-
  mental Action Now  (CLEAN),
  Hellertown PA

Cooks Creek Watershed,
  Hellertown PA

Environmental Defense Fund,
  Washington DC
Environmental  Defense Fund,
  Washington DC
Group Against Smog and Pollution
  (GASP), Pittsburgh PA
Leagure of Women Voters of PA,
  Philadelphia PA
  Easton PA
Lehigh Valley Conservancy,
  Bethlehem PA

Monocacy Creek Watershed
  Association, Bethlehem PA

National Parks and Conservation
  Association, Washington DC

Natural Resources Defense
  Council, Inc., Washington DC

PA Forestry Association,
  Mechanicsburg PA

PA Horticultural Society,
  Philadelphia PA

PA Lung Association,
  Hershey PA

PA Roadside Council, Inc.,
  Philadelphia PA
PA State Fish and Game Protec-
  tive Association, Philadelphia
  PA

Plainfield Township Taxpayers
  Association, Wind Gap PA
Rachel Carson Trust for the
  Living Environment,
  Washington DC

Saucon Creek Watershed Associa-
  tion, Hellertown PA

Sierra Club
    PA Chapter, Philadelphia  Pa
    PA Chapter, Pittsburgh PA
    Governor Pinchot Group,
      Mohuton PA
    Southerwestern Group,
      Pittsburgh PA

Trout Unlimited, Indiana  PA

Upper Nazareth  Citizens League,
  Nazareth PA

Water  Pollution Control Asso-
  ciation, Washington  DC

Wilderness Society,
  Washington DC

The Wildlife Society,
  Washington DC

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LIBRARIES

Easton Area Public Library

Lafayette College Library

Mary Meuser Memorial Library

Nazareth Memorial Library
Northampton County Area
  Community College Library


CITIZENS

Ms. Betty Abel
Mr. Robert Achenbach
Mr. Elwood Acherman
Ms. Mary Ann Achweitzer
Ms. Claire Adamson
Mr. Bernie Agner
Mr. William Agnew
Ms. Ruth Anderson
Mr. Sherwood Ashenfolder
Mr. Edwin Averback
Mr. L. R. Barlich
Mr. Paul Beahn, Jr.
Mr. Frederick C. Benfield
Ms. Joan Benter
Mr. John S. Bert
Mr. Dennis Bickirt
Mr. Wayne Billings
Mr. Lester Blean
Mr. Paul Bohlander
Mr. David Boskirk
Mr. Jeffrey C. Bosserman
Mr. R. Botrowsky
Dr. P. T. Bradt
Mr. Peter D. Bringham
Mr. Andrew W. Brock
Mr. Donald Burley
Ms. Virginia Buskird
Ms. He!da Buss
Mr. Sidney R. Butler
Mr. Joseph Butz
Mr. K. N. Butz
Mr. Warren R. Buzzard
Mr. & Mrs. Richard Cartright
Mr. Luke F. Chelnis
Mr. Gregory Chrin
Mr. Jim Claire
Mrs. B. H. Cohen
Mr. Edward S. Cole
Mr. Mr. Harold Coleman
Mr. & Mrs. Edward Colleflower
Mr. John J.  Correll
Mr. Gerald Crabtree
Ms. Carol Crane
Mr. Delbert Grossman
Mr. Maynard Crouse
Ms. Ellie Cyr
Mr. Sammual  Damofre
Mr. Pete E.  Deni
Mr. John H.  Hetiveiler
Mr. Reg Dewalt
CITIZENS (continued)

Mr- Franklin D. Dieter
Mr. Cosmo DiGerlando
Mr. Dominic DiGerlando
Mr. Joseph J. Danner
Ms. Marge Darker
Mr. Joseph Dorner
Mr. J. Michael Dowd
Mr. & Mrs. Rookant Doyle
Ms. Frances T. Dreisback
Mr. John P. Durr
Mr. J. Easton
Mr. Vergil Easton
Ms. Margaret Edis
Mr. Dick Ehlert
Mr. R. A. Elbe
Mr. Richard Englet
Ms. Anna Erdie
Mr. Matthew Erdiep
Mr. Dominic Fararo
Mr. John Feack
Mr. Raymond Fennel
Mr. Frank Ferguson
Mr. John Ferrette
Mr. John Filonge
Mr. Larry Finnegan
Mr. Donald J. Fischl
Mr. James T. Fish
Mr. Robert Fisher
Mr. Keith Fling
Mr. Robert Fostenbader
Mr. Allan Frantle
Mr. Francis Franusiszen
Mr. F- Fraunfieder
Mr. & Mrs. Joseph Frey
Mr. Roger B. Frey
Mr. Joseph Frisch
Mr. Joseph M. Fruhman
Mr. Paul Fundarish
Mr. Woodrow W. Fuls
Mr. Wesley Garr
Mr. Dwight 0. Gelser
Mr. & Mrs. Quentin Gilbert
Mr. James Godisha
Mr. John E. Godsker
Mr. Russell S. Gordon
Ms. Ellen Gradwokl
Mr. Lee Graver
Mr. David Grayson
Mr. Stephen Greyus
Mr. Dennis A. Grube
Mr. John Gruff
Mr. John T. Guiffre
Mr. Gordon Habrial
Mr. & Mrs. John Hale
Mr. Joseph M. Hale
Mr. Charles Holm
Mr. Terry Hannold
Mrs. Esther Harris
Mr. William Heard
Mr. Michael Heberling
Mr. Thomas Heckman
Mr. J. E. Heller
CITIZENS (continued)

Ms. Catherine M. Herkman
Mr. Thomas C. Herkman
Mr. Edward C. Hess, Assoc.
Mr. J. H. Hildenhand
Ms. Margarit Hill
Mr. & Mrs. Joseph Hopper
Mr. Joseph Hopple
Mr. Lee House
Mr. Fred Houser
Mr. & Mrs. George T. Hower
Ms. Nancy Hower
Mr. Ronald & Arthur Hower
Mr. Joseph Hull
Ms. Ricki Hurwitz
Mr. Charles Janec
Mr. Lawrence P. Janett
Mr. R. Jarrow
Ms. Barbara Jeninko
Mr. Michael Jones
Ms. E. Joan Johnson
Ms. Louise Johnson
Ms. T. W. Johnson
Mr. Harold S. Kahler, Sr.
Mr. Tony Kagmakeis
Mr. & Mrs. D. G. Kamback
Mr. Ronald Kaviah
Mr. Tony Kazmakites
Mr. Milton Kelchner
Mr. George Kelchner
Mr. & Mrs. Ben Kehler
Ms. Hilda Keppel
Mr. & Mrs. David Kern
Mr. Kermit Kessler
Mr. Willard J. Kickline
Mr. Lester Kilbanks
Mr. William Kilpatrick, Sr.
Mr. & Mrs. Richard King
Mr. Harry Kirchgassner
Mr. Carl Kislan
Mr. Elwood Kocher, Jr.
Ms. Sherry A. Koehler
Mr. William Konkel
Ms. Linda J. Kortz
Mr. Stanley S. Kratze
Mr. & Mrs. Lester Kratzer
Mr. Kenneth Kromer
Ms. Diane Kullman
Mr. Stephen Lakatos
Mr. Alfred Lankics
Mr. Karl Lausehack
Mr. James Lee
Mr. Harvey F. Leedwig
Mr. Richard S. Lerback
Mr. Sherwood Lessig
Ms. Nancy Lieberman
Mr. Kermit G. Lilly
Mr. Joseph A. Lopresti
Mr. & Mrs. Stephen Lukaez
Mr. James E. Lutz
Mr. R. Lynn
Mr. Robert L. Lynn
Mr. & Mrs. David Mack

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CITIZENS (continued)
CITIZENS (continued)
CITIZENS (continued)
Mr. Glenn D. Macker
Ms. Evelyn Mann
Mr. S. L. Makart
Ms. Anna Mann
Mrs. Mary Manning
Mr. Randolf Markovitz
Mr. Don McCabe
Mr. Alan B. McFall
Mr. Ulin MeGill
Mr. Thomas McGrass
Mrs. Mary J. McHan
Mr. Henry R. Mebus
Mr. George C. Meiser
Mr. R. Bernard Merwarth
Mr. Ed Messanlehner
Mr. Raymond Messinger
Mr. Vernon L. Messinger
Mr. Ralph Z. Metz
Mr. & Mrs. Tim Meyer
Mr. Floyd Michael
Mr. & Mrs. Henry Milrus
Mr. Lawrence Monaghan
Mr. John Moore
Mr. M. Morin
Mr. William B. Morman
Mr. Robert J. Muglone
Mr. & Mrs. Bob Nagel
Mr. Russel H. Naubold
Mr. & Mrs. Gregory Neff
Mr. Michael D. Neiser
Mr. Joseph Nemeth
Mr. Raymond Nenette
Mr. & Mrs. Dennis Newhad
Mr. Frank J. Nikles
Mr. Tom O'Brien
Mr. George Odenwelder
Mr. John A. O'Hagen
Mr. A. J. Oplinger
Mr. Howard J. Overholt
Mr. Joseph Pail
Mr. & Mrs. Joseph Papuak
Mr. Wayne Parry
Mr. Phillip C. Parsons
Mr. Vincent Paukovitch
Mr. Robert Peters
Mr. Ralph Pidcock
Mr. George D. Plowman
Mr. Joseph Pompom'
Mr. Martin Ponist
Mr. Ben Presby
Mr. Dale W. Prinkey
Mr. Walter C. Quier
Mr. & Mrs. S. P. Raisner
Mr. Donald A. Ramaley
Mr. Nicholas Rampulla
Mr- Gary Rapp
Mr. Robert Rapp
Mr. & Mrs. Claude Rathe
Mr. William D. Raumsey
Mr. Donald Raymes
Mr. & Mrs. Earl A. Reade           Mr.
Mr. John W. Reed                   Mr.
Mr. Clayton T. Reese               Mr.
Mr. William Remaly                 Mr.
Mrs. Paul D. Repohen               Mr.
Mr. Dale Resmiller                 Mr.
Mr. Frank Ressler                  Mr.
Mr. Conrad M. Rice                 Ms.
Mr. Robert A. Richard              Mr.
Mr. Harry Richebacher              Mrs
Mr. H. Riefenstahl                 Mr.
Mr. Robert Robert                  Mr.
Ms. Elaine Rodger                  Mr.
Mr. Ronald Rodger                  Ms.
Mr. Arthur Safass                  Mr.
Mr. Joseph Saftman                 Mr.
Mr. Ernest Safgent                 Mr.
Ms. Maryann Sargent                Mr.
Mr. Charles Scabo                  Ms.
Mr. David T. Schell                Ms.
Mr. V. Schirvon                    Mr.
Mr. Daniel Schneck                 Mr.
Mr. Francis J. Schweitzer          Mr.
Mr. Arthur Siefasr                 Ms.
Mr. R. S. Serifass                 Mr.
Mr. & Mrs. Douglas Seyfried        Mr.
Mr. John Shaddle                   Mr.
Ms. Claude Shappelle               Mrs
Mr. Joanne Sherman                 Mr.
Mr. Robert P. Shively              Mr.
Mr. Stephen Shockos                Ms.
Mr. Carl Shmitz                    Mr.
Mr. & Mrs. George W. Shook         Mr.
Mr. & Mrs. Lester Shook            Mr.
Mr. Harold E. Simons               Mr.
Mr. & Mrs. Peter H. Slavish
Mrs. Claire K. Smith
Ms. Darvine Smith
Mr. & Mrs. Roy Smith
Mr. R. W. Smith
Ms. Shirley M. Smith
Mr. William G. Smith
Ms. Patricia Snyder
Mr. William Spafford
Mr. & Mrs. Sparrow
Mr. Charles Spohn
Ms. Carol Sprague
Mr. & Mrs. Allen Stahl
Mr. F. E. Stannard
Mr. Robert Starke
Mr. Douglas T. Stechl
Mr. Wayne M. Steinmetz
Mr. & Mrs. Richard Stine
Mr. A. Stirba, III
Ms. Mary L. Stracko
Mr. Donald Strockoz
Mr. Leo Suprye
Mr. & Mrs. Thomas Sutter
Mr. R. Tenges
Mr. D. L. Thew
    E. J. Trinkley
    & Mrs. Conrad Tripy
    James Unger
    Robert Vanon
    Karl K. Vinger
    Charles F. Voda
    Dale Wade
    Barbara Wagner
    D. D. Wallers
   ,  Jeanette Walters
    Russell Wambold
    Edward Warmbald
    Harold G. Warner
    Michele C. Warner
    Rick Warner
    Mil lard Weave
    Ed Welchner
    Martin M. Wenfield
    Jan Werkheiser
    Evelyn Werkheizer
    Edward A. Werner
    Melvin 0. Werner
    Donald White
    Maureen White
    John Wikles
    Ed Wilchner
    Dale R. Williamson
   .  Ann Woehrle
    Joseph J. Worner
    Francis Wunderly
    Jane Yeakel
    M. A. Yeakel
    Ronald M. Yeakel
    Robert A. Young
    Grant Zilena

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CHAPTER II
Summary of Draft EIS

-------
CHAPTER  II:   SUMMARY
OF DRAFT  EIS
 BACKGROUND
 EIS  ASSUMPTIONS
 Assumption  1
 action being  studied
 Assumption  2
 EIS Service Area
 Assumption  3
 Nazareth Borough
 Assumption  4
 status  of ownership;
 Nazareth wastewater
 collection  and treat-
 ment facilities
 Assumption  5
 purpose  of EIS
This chapter briefly summarizes the Draft EIS (Appendix A).

A.  In 1976, the BLLJSA submitted an application for Federal  financial
    assistance for the construction of wastewater management  facilities
    to the Pennsylvania Department of Environmental  Resources  and
    subsequently to the EPA.  This application requested money to construct
    a collection system which would convey wastewater from the Boroughs of
    Stockertown and Tatamy, Plainfield, Upper Nazareth, Bushkill  and  Palmer
    Townships and Jacobsburg State Park to the Easton Sewage  Treatment  Plant.
    The plan also proposed to eventually abandon the Nazareth  Sewage  Treat-
    ment Plant and redirect wastewater flows from the already  sewered
    Borough of Nazareth and portions of Upper Nazareth to the  Easton  Plant.
    EPA announced its decision, in December  1978, to prepare  an  Environ-
    mental Impact Statement on the proposed plan prior to any  final action
    concerning the application for Federal money.

B.  Several key assumptions/factors influenced the preparation of the Draft
    E'IS.  The assumptions were formulated to define the scope  of  the  EIS
    and to improve the public's understanding of the Federal  decision-making
    process.  These assumptions have also been determined to  be valid for
    the Final EIS.

    •  The Draft EIS addressed the actions proposed by the B-LLJSA [waste-
       water collection and transport facilities), but not the expansion
       of the Easton Treatment Plant and its enlarged interceptor and pump
       station system.  These facilities were constructed under a separate
       EPA grant; however, the estimated B-LLJSA local share  of the capital
       costs associated with the Easton construction, $1.3 million, is
       addressed in the Draft EIS.

    •  The EIS Service Area includes the B-LLJSA Service Area  (Bushkill
       Township, Plainfield Township, Upper Nazareth Township, Palmer
       Township (unsewered portion only), Stockertown Borough, and Tatamy
       Borough) and Nazareth Borough (see Figure   2).  It is  different
       from the area proposed to be served by the Applicant (see  Figure II-l).

    t  Nazareth Borough was included in the EIS Service area  for  three
       reasons.  First, the privately-owned Nazareth sewage treatment plant
       (STP), which serves most residents in the Borough has  required up-
       grading and expansion for several years.  Second, a significant
       number of citizens throughout the EIS Service Area believe that  the
       Nazareth STP. if upgraded, could offer a cost-effective means  of
       wastewater treatment.  This belief stems from the STP's central
       location in the EIS Service Area and from the public assumption  that
       selected STP facilities can be conserved.  Third, even though  Nazareth
       Borough is not a member of the B-LLJSA, the Applicant  has  provided
       capacity in its conveyance system for wastewater flows  generated by
       Nazareth Borough under the assumption that the STP eventually  wil'l  be
       abandoned.

    •  The purchase of the privately-owned Nazareth sewage collection and
       treatment facilities by Nazareth Borough was considered imminent.  This
       assumption was based on conversations with representatives of  Nazareth
       Borough and the Pennsylvania Department of Environmental Resources  (DER)
       Nazareth Borough is listed on the State priority list for  Federal
       construction grant funds (Pennsylvania Bulletin, Volume 9, No. 8,
       24 February 1979) with a rank of 70.

    •  The primary purposes of the Draft EIS were to develop alternative
       wastewater management plans, to evaluate them in comparison to the
       Applicant's proposed plan, and to recommend the plan that  is  environ-
       mentally sound and represents the most cost-effective use  of Federal
       funds.  Although the Draft EIS incorporated the necessary concepts,

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FIGURE II- I   APPLICANT'S PROPOSED ACTION
— —SERVICE AREA BOUNDARY
11H AREA SERVED BY PROPOSED SEWER

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Assumption 6
alternatives approach
Assumption 7
design and costing
Assumption 8
documentation of need
Assumption 9
Jaoobsburg State Park
Assumption 10
Modified Applicant's
Proposed Action
Assumption 11
costs
Assumption 12
user charges
   guidelines, and regulations sought in approved wastewater management
   facilities plans, it does not constitute a facilities plan by itself.

•  Both centralized and decentralized wastewater management approaches
   were evaluated.  These approaches incorporated innovative and alter-
   native technologies, where possible, in accordance with the provisions
   of the Clean Water Act of 1977 and other applicable EPA guidance and
   regulations.

•  The preliminary design and costing of wastewater management alterna-
   tives were completed under the assumption that an EIS recommended
   action would have to be returned to the Applicant for Step II design
   work unless the APA was the recommended action.1   Step II design,
   which involves detailed on-site investigations, engineering, and cost-
   ing, is outside the scope of a typical  EIS.  The Applicant, in order
   to receive Federal funds, must conform with the requirements of EPA's
   Construction Grants Program.

•  Federal funding of the APA, or of any alternative, is contingent on
   the documentation of need for improved wastewater management facili-
   ties.  Need is defined when at least one of the following conditions
   exists:  standing pools of septic tank effluent or raw domestic
   sewage, sewage in basements from inoperable sewage disposal systems,
   or measured contamination of private wells or surface waters by sewage
   disposal systems.  Unsuitable site conditions, including high ground-
   water, rapidly or slowly permeable soils, or solution channels, are
   not sufficient documentation by themselves.  Two levels of need were
   identified in the Draft EIS.  "Phase I" areas demonstrated an immediate
   need for off-site wastewater management facilities, whereas low density
   "Phase II" areas only required improved on-site facilities.

t  Future recreational plans for the 1,170-acre Jacobsburg State Park in
   Bushkill Township have been modified.   The planned development of
   a 300-site camping area, a swimming complex, and a 94-acre lake have
   been terminated in response to public complaints that such facilities
   would be detrimental to the Park's environmental  and historic resources.
   Instead, the Bureau intends to provide small-scale recreational  op-
   portunities at the Park (see Appendix B).

•  The APA, by itself, cannot be compared directly to the other alterna-
   tives due to differences in design year, estimated wastewater flows
   per person, and service area configuration.  The Modified Applicant's
   Proposed Action (MAPA) was developed to overcome these dissimilarities.

•  The costs of the alternatives do not represent absolute construction
   costs of systems.  Locally obtained estimates of unit costs for sewerage
   facilities have been applied uniformly to all wastewater management
   plans evaluated in the EIS.  The focus of the costing effort was on the
   internal comparability of the MAPA and of the EIS alternatives.

•  User charges include the following items:  debt service (repayment of
   principal  and interest to cover the after-grant share of capital costs),
   operation and maintenance costs, ajid an annual reserve fund assumed to
   equal  20% of the annual debt service amount.  The charges do not include
   front-foot assessments and are not in the true sense "user charges"
   because they are not based on actual construction costs.  They are,
   instead, indexes of economic impact and financial burden.
                             Detailed design and costing of the APA were completed in 1977.

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 Assumption  13
 population  projeat-ions
 Assumption  14
 development in floodplains
      •   Estimates of future population associated with wastewater
          management alternatives were based on the municipal population
          projections developed by the Lehigh-Northampton Counties Joint
          Planning Commission (JPC) in '1973.  The "baseline future" population
          projections for each municipality in the EIS Service Area are
          identical to JPC's 1973 figures.

      •   Future development was not assumed to be prohibited in designated
          floodplains of municipalities with enacted floodplain management
          ordinances unless such ordinances specifically prohibited flood-
          plain development.  The codified limiting, or conditioning, of
          development in the floodplain is not considered equivalent to the
          prohibition of such development.
 ALTERNATIVES
 DRAFT  EIS
 CONCLUSIONS
DRAFT EIS
RECOMMENDATIONS
C.   In response to public concern over such issues as need documentation,
     cost-effectiveness, water quality and induced growth, EPA developed
     eleven alternatives to the Applicant's proposed action.  On site system
     problems were identified from field investigations of aerial photography,
     groundwater quality, surface water quality, and soil suitability for
     wastewater disposal/treatment.  Alternatives included various combinations
     of stream discharge, land application and decentralized schemes.

D.   After extensive study and analysis, EPA determined that the BLLJSA's
     proposed plan was unacceptable for Federal funding due to the following:

     •  potential for loss of agricultural  land
     •  potential for loss of valuable trout habitat
     •  other alternatives exist  which do not have significant adverse
       impacts

The  need for centralized wastewater collection and treatment facilities was
assessed compared to the need to alleviate existing water quality or public
health problems.  The absence of documented water quality problems for the
areas listed below suggested that centralized treatment and/or increased
sewer service for these areas were not required.

    •  Plainfield Township north of T609 on Route 115 and Route 191  between
       Belfast Junction and Edelman
    t  Jacobsburg State Park
    •  The vicinity of Cherry Hill, Bushkill Township

An existing need for improved facilities was identified in the following areas:

       Belfast area of Plainfield Township
       Stockertown Borough
       Tatamy Borough
       Rasleytown
       an area east of Pen Argyl Borough (Plainfield Township)
       Rismil'ler (Bushkill  Township)
       Christian Springs (Upper Nazareth Township)

E.  Major elements of the plan recommended in the Draft EIS for Federal  funding
    are:

    •  wastewater generated in the corridor running from the Belfast Area
       through Tatamy Borough, and the Newburg Homes area of Palmer
       Township would be conveyed to the Easton Plant for treatment.
                                                    10

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    •  wastewater flows  from the  existing  Nazareth  Plant Service  area  as well
       as those from the East Lawn vicinity  of Upper  Nazareth  Township could
       be treated at a new plant  adjacent  to the  existing  Nazareth  Plant
       which would be abandoned

    •  sparsely developed segments along Route 115  north of  the gravity sewer
       and communities of east Pen Argyl and Rasleytown (Plainfield Township)
       and Rismiller (Bushkill Township) would be served by  small collection
       systems and multi-family area fields  (cluster  systems).

    •  the remainder of the area  not served  by a  centralized collection
       system would remain an individual on-lot treatment  systems.

The estimated cost for this project was $11,800,000 in         dollars.  It was
calculated that yearly charges to users of the system would  equal about $110
per household.  Additional charges amounting to about $70  per  household were
calculated to cover previous costs incurred  by the  Applicant.
                         tl

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CHAPTER
Evaluation of Alternatives

j
-t,
i
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1
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              X  ' /
              lv!r H /

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CHAPTER  III:
EVALUATION OF
ALTERNATIVES
Comments and new information received during the Draft EIS  public  comment
period were incorporated into the EIS process.   This  chapter  indicates  the
new information and illustrates the subsequent  evaluation of  alternatives.
EXISTING ENVIRONMENT
 Inventory of Prime
 Agricultural Land
 60%, not 75%, of EIS
 Service Area in prime
 agricultural lands
 Recently Adopted
 Floodplain Develop-
 ment  Regulations
Plainfield Township

Stockertown Borough and
Tatamy Borough
 A.   The descriptions of the existing environment in the Draft EIS with
      regard to prime agricultural land, floodplain zoning, and recreation
      are updated in this section.  These modifications largely represent
      new information that was not available, or that was in the process
      of being generated, during the preparation of the Draft EIS.

      1.   It was stated on page 45 of the Draft EIS that the Northampton
           County District Soil  Conservation Service (SCS) was in  the
           process of delineating prime agricultural  lands based on the
           1977 guidelines.  Furthermore, it was noted that under  the new
           guidelines, the Comly (CmB) soil  series and the Clarksburg (C1B)
           soil series would no longer be considered prime agricultural
           lands.  The net effect of these changes is that an estimated 60%,
           rather than 75%, of the EIS Service Area is classified as prime
           agricultural  land (By letter, Mr. Graham T. Munkittrick, US
           Department of Agriculture  (USDA)-SCS, 17 March 1980).  This
           reduction in  the amount of prime agricultural land is scattered
           evenly throughout the EIS Service Area.  Another change in the
           inventory of  Class I and Class II soils (Figure III-6, Draft EIS)
           is  that the soils on which Newburg Homes (Palmer Township) was
           developed are no longer considered prime agricultural lands; the
           construction  of homes has foreclosed agricultural opportunities
            (By telephone, Mr. John Bert, District Soil Conservationist,
           USDA-SCS, 16  April 1980).

      2.   The Draft EIS (page 225) indicated that a number of municipalities
           in  the EIS Service Area do not have zoning ordinances that pro-
           hibit development in flood-prone areas.  This statement was based
           on  EPA's interviews with municipal government officials, including
           planners and zoning officials, during the period from December
           1978 through July 1979.  Plainfield Township, Stockertown Borough,
           Tatamy Borough, Upper Nazareth Township, and Nazareth Borough did
           not have prohibitive floodplain development ordinances.

           Three of the five previously identified municipalities recently
           have amended or adopted floodplain regulations.  They are:

           •   Stockertown Borough (Ordinance No. 164)   adopted 6 August 1979
           0   Tatamy Borough (Ordinance No.  110)   adopted 5 November 1979
           •   Plainfield Township   amended 10 January 1980.

           These new floodplain regulations are based on Flooci Insurance
           Studies that were prepared by the Federal Insurance Administration
           during the summer of 1979.  With its zoning ordinance amended,
           Plainfield Township now prohibits development in the 100-year flood-
           plain.  The referenced floodplain management regulations for Stocker-
           town Borough and Tatamy Borough "limit and condition, but do not
           prohibit totally, development within the 100-year floodplain as
           defined by their respective Flood Insurance Studies" (By letter,
           Mr. Walter Pierson, Acting Director, Insurance & Mitigation
           Division, Federal Emergency Management Agency, 10 March 1980).
Nazareth Borough
Upper Nazareth Township
           Nazareth Borough and Upper Nazareth Township still have not adopted
           floodplain ordinances.  The Joint Planning Commission, Lehigh-

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                                      Northampton  Counties,  reported that these municipalities soon would
                                      have  ordinances  that will  meet the requirements of the National
                                      Flood Insurance  Program as well  as the Pennsylvania Floodplain
                                      Management Act  (By letter, Mr. Allen O'Dell, 6 March 1980).  The
                                      above requirements stipulate that structures must be floodproofed
                                      or  elevated  above  flood levels;  they do not prohibit development
                                      in  floodplain areas.
APPLICANT'S PROPOSED
ACTION AND IMPACTS

Stream Crossings
nwriber of stream
crossings
Modifications have been made to the description and cost of the APA as
stated in the Draft EIS.  As a result, the impacts have changed.

1.   The Draft EIS stated that the APA would require the construction
     of 29 stream crossings, six of which would involve the boring, or
     jacking, of sewer pipe beneath the streambedJ  The remainder of the
     stream crossings were to involve the construction of cofferdams and
     excavation (including rock blasting where necessary) of the stream
     bottom.   Subsequent discussions with the B-LLJSA and its engineer
     during the Draft EIS public comment period necessitate the following
     revisions:

     •   Inspection of the B-LLJSA plot plans  and  bid sheets indicated
         that only 19 stream crossings were proposed to be bid for con-
         struction .  The B-LLJSA informed EPA that  three stream crossings
         in Jacobsburg State Park could be eliminated from the APA
         because of objections voiced by the Pennsylvania Fish Commission,
         The revised number of stream crossings (16) by channel is as
         follows:  three on Bushkill Creek, one on  a tributary to Bush-
         kill  Creek, six on Little Bushkill Creek,  and six on Schoeneck
         Creek.  The Applicant's engineer indicated that it might be
         possible to eliminate one or two more crossings on Schoeneck
         Creek, but the value in doing so is questionable; no stream
         crossings can be eliminated on Little Bushkill Creek [By letter,
         Mr. Hans Meinig, Jr., Gilbert Associates,  Inc. (GAI), 11 April
         1980].  Photographs of two of the Applicant's proposed stream
         crossings on Bushkill Creek are included as Figures III-l and
         III-2.  The revised locations of all stream crossings proposed
         for the APA are shown in Figure III-3.
                        Figure III-l

                        Applicant's proposed stream crossing
                        (manhole 210 to manhole 211) approxi-
                        mately 1 mile below Tatamy Borough.
                                        Figure  III-2
                                        Applicant's proposed stream crossii
                                        (manhole 219 to manhole 220) appr®
                                        mately  1.5 miles below Tatamy Boroi
                            Drawings 06-6796 D-601-008 and 06-6796 D-601-009  (dated  1974,  revised 1977).

                           'Drawings 06-6796 C-601-012 through C-601-019.
                                                    14

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FIGURE 111-3  LOCATION OF STREAM CROSSINGS ASSOCIATED WITH
             THE  APA. MAPA AND EIS ALTERNATIVE 9 (MODIFIED)
-- SERVICE AREA BOUNDARY

  0 APA

 f ELIMINATED UNDER MAPA

  0 EIS ALTERNATIVE 9 (MODIFIED)

    AREA WHERE SPRINGS ARE KNOWN TO EXIST

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types of stream crossings
effect of stream crossing
revisions on aquatic biota
 wild trout population
None of the stream crossings under the APA will  require boring
or jacking of sewer pipe beneath stream bottoms  as previously
proposed by the Applicant.   Instead, all  crossings will be
constructed via cofferdam installation and excavation of stream
bottoms according to procedures prescribed by the Pennsylvania
Department of Environmental  Resources (DER) and  the Pennsylvania
Fish Commission (By telephone, Mr.  Hans Meinig,  Jr., GAI, 17
April 1980).   According to the Applicant's engineer, jacking of
sewer pipe reportedly would  require too much construction time
in comparison to open trench excavation.

The Pennsylvania Fish Commission has described Bushkill Creek as
"one of the better, if not the best, trout streams in eastern
Pennsylvania and as such must be protected" (By  letter, Mr.  Jack
Miller, Chief, Fisheries Environmental Services, Pennsylvania
Fish Commission, to Mr. Robert Blanco, Chief, Water Planning Branch,
EPA, 15 February 1977).  As  stated in the Draft  EIS, this creek
supports an intensive trout  sport fishery.  From May through
August 1978, the Pennsylvania Fish Commission counted a total of
1,651 anglers along Bushkill Creek for a  distance of approximately
2.3 miles downstream from Tatamy Borough.3  During L980, the fishing
pressure on Bushkill Creek has increased  despite a reduction by
8,000 fish in the number of  stocked brown trout  due to shortages of
the  species in the State.  This intensive fishing pressure,  which
is attributed to current economic conditions that keep anglers
close to their homes, is projected to increase in the near future.

Stocking is conducted to supplement the wild trout population.
The Pennsylvania Fish Commission estimates that  the number of
naturally reproduced trout (mostly brown  trout,  Salmo trutta)
in Bushkill Creek is high, with an average density of 250 trout
per 100 meters^ (By telephone, Mr.  Terry  Hannold, Waterways  Patrol-
man, Pennsylvania Fish Commission, 2 June 1980).  In their 1979
inventory of the "Fish for Fun" Area, the Pennsylvania Fish  Com-
mission captured brown trout, measuring 3 to 16  inches in length,
and rainbow trout  (Salmo gairdnerii), measuring 11 to 13 inches.
As stated in the Draft EIS,  the livelihood of the trout fishery
downstream from Tatamy Borough is dependent on the underground
springs known to exist in the vicinity of the Borough and at
the confluence of Schoeneck  Creek and Bushkill Creek (see Fiqure
III-3).

The Applicant, in its detailed design of the sixteen stream
crossings that are associated with the APA, has  incorporated a
number of measures that will minimize damage to  the aquatic
environment.   The adverse impacts expected from  the construction
of the stream crossings, as  well as the structural and non-struc-
tural measures recommended by the Applicant to mitigate these
impacts, are summarized briefly below (By letter, Mr. Hans Meinig,
Jr., GAI, 11  April 1980).
adverse impacts and
mitigative measures
recommended by Applicant
   Erosion of stream banks
   and siltation of surface
   water channels during sewer
   installation .
Mitigative Measures

Streams will be crossed in two
stages with water being diverted
(by sand bags) to one side while
sewer pipe is being installed
on the other.
                             Includes the  "Fish for  Fun" Area.

                            ^Equivalent to approximately 4,000 naturally reproduced trout per mile.

                                                  16

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                                                         Mitigative Measures
                      •  Disruption of trout
                         spawning habitat.
                         Diversion of spring flow
                         away from the creek by
                         gravel-filled trench and
                         interception of ground-
                         water.
                      •  Hydraulic erosion  around
                         sanitary sewage pipeline.
          Use of silt retention  basins
          during construction.

          Follow soil  erosion and sedi-
          mentation control  specifica-
          tions per Pennsylvania Fish
          Commission and  DER rules and
          regulations.

          Obtain Section  404 permits
          from US Army  Corps of  Engin-
          eers prior to construction.

       •  Make stream crossings  during
          time period  recommended by the
          Pennsylvania  Fish  Commission.

       •  Install concrete curtain walls
          (seepage stops) approximately
          every 1,000 feet in areas where
          there is concern that  ground-
          water will follow  trench line
          and be diverted away from the
          adjacent stream.

       •  Encase stream crossings in
          concrete.
                      If proper construction methods are enforced, the adverse primary
                      impacts can be expected  to be of relatively short duration.   The
                      Applicant cites the  construction of the Forks Township Inter-
                      ceptor on the east side  of Bushkill Creek (Figures III-4 and
                      111-5) 12 years ago  as testimony to the fact that a gravity
Figure III-4

Forks Township  Interceptor
                                                      *  :f^&.^
                                                      , * •  v      J* «w * ' V k(',Z-. "*
                                                      §*;*5£
                                                  ;•*  SS    '
      T%V4     -•&*•«
          "B*«-'--s7!:
                  > -- •
s&^^*«^^--r\> ^ *•
».>-»:-. *?54fe vi/.\:J >v •,  •,*£"
    Figure II1-5
    Forks Township Interceptor
                                17

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 potential for spring/
channel diversion
under APA
 corridor  study
 recommended
 potential for
 additional stream
 crossings
 Prime  Agricultural
 Land Conversion Under
 APA
 Induced  Growth
 Revisions  Under APA
 Costs  of APA
   interceptor along lower Bushkill  Creek will  not affect adversely
   this high-quality aquatic environment.  The construction of
   stream crossings in limestone areas, involving the blasting
   of bedrock, must proceed with caution, because this activity
   could divert surface water and groundwater flow away from the
   stream.  The short- and long-term potentials for such diver-
   sion in the B-LLJSA Service Area exist along Schoeneck Creek,
   atong Little Bushkill Creek in the Stockertown area, and along
   Bushkill Creek downstream from Tatamy.  Construction of sewer
   pipe adjacent to Bushkill  Creek downstream from Tatamy and along
   Little Bushkill  Creek should be permitted only after a detailed
   corridor study is completed.  A qualified geologist and biologist,
   in collaboration with the Applicant's engineer, should determine
   the potential  for spring and channel  diversion and habitat
   disruption.

   Development pressures in the future  may result in  the construc-
   tion of stream crossings in addition  to those proposed for
   B-LLJSA project  start-up.   The establishment of a  permanently
   vegetated  buffer zone adjacent to streams, in which construction
   of any kind would be controlled strictly, may reduce the impacts
   of future  sewerage construction and  non-point pollution.  The
   width of this  zone would be determined during the  corridor study
   discussed  above.

In accordance with  the reduction in  the  inventory of  classified
prime agricultural  land in the EIS Service Area (see  Section III.A.I),
the amount of prime agricultural land converted to residential/
commercial/industrial  uses under the APA is  an  estimated 3,200
acres.  This  is less than the amount of converted acreage reported
in the Draft  EIS (3,735 acres) and is approximately double the
amount of prime agricultural  land that  would be converted to non-
agricultural  uses without the project.

Induced dwelling unit and population estimates  for Stockertown
Borough and Tatamy  Borough under the APA have been revised upward
to reflect the fact that floodplain  management  ordinances recently
adopted by these municipalities limit and condition,  but do not
prohibit, development in flood-prone areas (see Section III.A.2).
Under the assumption that development could  be induced legally in
flood-prone areas,  the revised total induced growth figures for
Stockertown and Tatamy under the APA are:

•  Stockertown Borough =  115 dwelling  units (350 persons)
«  Tatamy Borough      =  252 dwelling  units (756 persons).

This assumption was applied to the MAPA and  the other alternatives.
The derivation of the induced dwelling  units (22 for  Stockertown
Borough, 68 for Tatamy Borough) in the  100-year floodplain for
those alternatives  is included in Appendix C-l.

The capital,  operation and maintenance,  and  present worth costs,
as well  as the salvage value of the APA, as  stated in the Draft
EIS, have been updated to reflect more realistic unit costs.  The
updated cost  summary of the APA is presented in Table III-l.  The
unit costs were adapted from the B-LLJSA project bid sheets and
do not reflect the comparatively low unit costs that were used to
estimate the  construction costs of the APA in the Draft EIS.  The
latter unit costs were obtained from engineer contractor firms
located in the greater Easton area and were used in the costing
of all wastewater management plans evaluated in the Draft EIS.
This universal use of- local unit costs ensured comparability among
                                                   ia

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                                            all of  the plans.    The data contained  in the  B-LLJSA project  bid
                                            sheets  represented  the actual 1977 costs for which  the APA would
                                            be constructed.   These detailed  and "realistic" costs were not
                                            applied universally to all  alternatives  in the Draft EIS  because
                                            the site conditions and detailed design  upon which  they were based
                                            were  not commensurate with  the site conditions and  preliminary
                                            designs upon  which  the alternatives were based.
updated aost summary
of APA
Table III-l.   Updated cost summary of APA ($).
                                           Capital
                                            Cost

                                         13.720,337
            Annual
             O&H

            413,985
 Present
  Worth
   O&M
(10.4919)

4,343,489
 Salvage
  Value

4,929,040
Present
 Worth
Salvage
 Value
                                                Total
                                                Present
                                                Worth
                                                                                            (1,244,583)    16,819,243
  Total
  Annual
Equivalent
 (0.0953)

1,602,8/4
                                            The effect  of the  updated  capital  costs  on estimated local  user
                                            charges for the APA is illustrated in  Table  III-2.
estimated  looal user
charges of APA
Table III-2.   Estimated  local  user  charges  associated with  APA  ($),
                                               Capital
                                                Cost

                                              13,720,337
  Local
  Share
  (25%)

3,430,084
                             Annual
                            Equivalent
                             of Local
                              Share
                             (0.0953)

                             326,887
                  Annual
                    O&M

                  413,985
                   Total
                   Annual
                  Cost  to
                   Local
                  Citizens

                  740,872
                 Monthly
                 Cost Per
                 Family6.7

               $13.20-22.40
                                            The monthly  cost  per family for  use of the APA system, $13.20 to
                                            $22.40, represents  an estimated  annual  user  charge  of $158 to $269.
                                            These  estimates contrast  with the Draft EIS  estimated annual user
                                            charge for  the APA of $160.  The calculation of  the user  charge  is
                                            based  on local capital  costs being paid through  the use  of a 30-year
                                            bond  at 7-1/8% interest rate.

                                            The  significant financial burden^ and displacement  pressure^ associated
                                            with  the revised  costs  of the APA, listed  in Table  III-3, have  been
                                  The APA cannot be compared  legitimately with the EIS alternatives,  based on significant differences
                                  in design parameters and Service Area configurations.  The development of the MAPA allows a direct
                                  comparison between the concept of the APA and its ten  EIS alternatives.

                                  This Information is presented for comparative purposes only.  Actual user charges may vary with
                                  prevailing bond rates and market conditions.

                                  7Monthly cost per family = No TFami1?eTx\2°mo/yr; approximately 2,756 families without Nazareth

                                  and 4,677 families with Nazareth (year 1978). The Environmental Assessment (EA), page 1-23, states
                                  that the estimated connected (APA) population Includes Nazareth Borough.
                                  Q
                                  A project is likely to place "significant financial burden" on users when user charges equal or
                                  exceed the following criteria developed by the Federal government (The White House Rural Development
                                  Initiative 1970):  1.54 of  median household incomes are less  than $6,000; 2.0% of median household
                                  Incomes are between $6,000  and $10,000; and when 2.5%  of median household incomes are greater than
                                  $10,000.

                                  "Displacement pressure" is  the economic pressure associated with user charges, which are high enough
                                  to cause lower income families to move. It is measured by determining the number of households
                                  having user charges in excess of 5% of their annual income.
                                                            19

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                                      estimated  under two  scenarios.   The first scenario assumes a B-LLJSA
                                      Service  Area  population  that includes  Nazareth Borough (population
                                      5,763, year 1978).   The  second  scenario assumes that Nazareth Borough
                                      is  not connected to  the  sewer system.


                                      Table III-3.   Significant  financial  burden and displacement pressure
                                      associated with APA.

                                                                 Significant
                                      Annual User                  Financial                Displacement
                                       Charge                     Burden                   Pressure

                                         $158]?                     10-15%                     5-10%
                                         $269"                     20-25%                     5-10%


Additional Construction          5.    The APA  costs  presented  in the  Draft EIS and in Table III-l are
Costs Associated with APA             those associated with wastewater conveyance facilities in the B-LLJSA
                                      Service  Area  proper.  They do not include the expansion (i.e., con-
                                      struction) of two pump stations in Easton (Second Street and Delaware
                                      Drive pump stations) and the upgrading/expansion of the Easton STP,
                                      both of  which  are prerequisites to satisfy the purpose for which the
                                      APA was  intended: transport of wastewater generated in the B-LLJSA
                                      Service  Area  to the  Easton STP  for treatment.   During the comment
                                      period on  the  Draft  EIS, the B-LLJSA indicated that a deficiency of
                                      the EIS  was the lack of  consideration  of the reconstruction of these
                                      and other  conveyance facilities (interceptors and inverted siphons)
                                      in  the evaluation of the APA and alternative wastewater management
                                      plans.   Costs  that should  be added to  the cost of the APA are pre-
                                      sented in  Table III-4.   These were not included in the cost-effec-
                                      tiveness analysis for the  APA in either the Draft EIS or in Table
                                      III-l because  they are not costs associated with construction of
                                      proposed facilities  in the Applicant's Service Area.  The expansion
                                      of  the Easton  STP and two  pump  stations is preceding under a
                                      separate EPA  grant.  However, these costs are essential to the opera-
                                      tion of  the APA and, therefore, should be considered in addition to
                                      those presented in Table III-l.12  Costs for the reconstruction of
                                      interceptors  and inverted  siphons, which also are essential to the
                                      operation  of  the APA, are  not included in Table  III-4; therefore, the
                                      costs  in that table  are  considered conservative.  This reconstruction
                                      occurred under the Easton  Federal grant mentioned earlier.
                                      Table III-4.   Expansion  costs for the  Second Street pump station,
                                      Delaware Drive pump  station, and Easton STP that should be added to
                                      APA costs.12

                                      Expansion  of  Second  Street Pump Station (B-LLJSA portion)  = $  249,429
                                      Expansion  of  Delaware Drive Pump Station (B-LLJSA portion) =    191,040
                                      Expansion  of  Easton  STP  (B-LLJSA portion)                  =  ] ,592,200
                                          Total Additional Construction Costs                   = $2,032,669
                                          Total Additional Capital Costs (@ 127%)               = $2,581,490

                                      Backup calculations  for  these costs are presented in Appendix D-l-
                             Besed on 1978 B-LLJSA estimated connected  population  including Nazareth
                             Borough (EA, p.  1-23, 1976).

                             Based on 1978 B-LLJSA estimated connected  population  excluding Nazareth
                             Borough (EA, 1976).

                           12
                             These additional costs represent only the  B-LLJSA  portion  of  facilities
                             expansion.  B-LLJSA design flow    2.4mgd  (By telephone, Mr.  Lewis  Wolfe,
                             Manager Consultant, B-LLJSA, 9 May  1980).

                                                   20

-------
 Energy  Requirements
 of APA
The Draft EIS estimate of energy requirements associated with the
APA, 5,950 kilowatt-hours per year (kwh/yr) was based on the proposed
wastewater conveyance facilities in the B-LLJSA Service Area.
The only energy-consumptive conveyance facilities in the B-LLJSA
Service Area proper are the proposed Jacobsburg State Park and
Edelman pump stations, with design flows13 of 600 gallons per
minute (gpm) and 180 gpm, respectively (By letter, Mr.  Hans Meinig,
Jr., GAI, 19 May 1980).

Re-evaluation of the APA's energy requirements revealed three
problems with the Draft EIS estimate of 5,950 kwh/yr:

•  The energy requirements of the two pump stations in  the B-LLJSA
   Service Area were underestimated

•  The energy requirements associated with wastewater conveyance
   and treatment facilities that were essential  to the  operation
   of the APA were not included

•  The energy consumption by residential  developments induced by
   the APA was not measured.

The revised energy budget for the proposed Jacobsburg State Park and
Edelman pump stations is 139,991 kwh/yr.   The energy requirements for
the B-LLJSA portion of the expanded Second Street and Delaware Drive
pump stations and Easton STP total 1,365,850 kwh/yr.   The energy re-
quirements directly associated with the operation of the wastewater
management system proposed for the B-LLJSA Service Area are shown in
Table III-5.  Backup data for this table  are in Appendix D-2.
revised energy require-
ments of APA 'a technical
components
                                       Table III-5.   Revised energy  budget  for  APA.
                                            Conveyance

                                            1.    Jacobsburg  State  Park  Pump  Station
                                            2.    Edelman  Pump  Station
                                            3.    Second Street Pump  Station  (B-LLJSA  portion)
                                            4.    Delaware Drive Pump Station (B-LLJSA portion)

                                            Treatment

                                            Easton  STP  (B-LLJSA portion)

                                            TOTAL
                                                             7,938
                                                           132,053
                                                           194,832
                                                           437,290
                                                           733.728

                                                         1,505,841
                                      A  comprehensive  evaluation of  the energy requirements  of  the APA  and
                                      its  alternatives should  include an  estimate of  the energy (electric
                                      power)  consumed  by  residential development associated  with  the  project
                                      under construction.  This comprehensive approach  to  estimating  the
                                      energy  budgets for  the APA and its  EIS alternatives  was precipitated
                                      by the  significant   public criticism  of the Draft EIS  for recommending
                                      the  implementation  of an alternative  that required 93  times the amount
                                      of energy required  by the APA.  It  is emphasized  that  the Draft EIS
                                      energy  evaluation of alternative wastewater management plans considered
                            13
                              Design peak flows.
                                                    21

-------
                                      only the  sewerage  system components in the B-LLJSA and EIS Service
                                      Areas.  Given  the  public emphasis on implementing a Federally
                                      funded  wastewater  management plan that complies with the President's
                                      energy  conservation  directives..  EPA believed it necessary to present
                                      a  realistic  energy evaluation1^  Of the APA and its alternatives in
                                      this EIS  --  one  that includes energy consumption by project-associated
                                      residents as well  as project-associated design components.

electric power oonsump-               The  estimated  average electric power consumption by residential
tion by residential                   development15  that is associated with the APA in the year 2000 is
development under APA                 as follows:  247,810,000 kwh/yr  for single family dwelling units
                                      and  49,488,000 kwh/yr for multi-family dwelling units; total electric
                                      power consumption  by residential  development is 297.2 million kwh/yr.

                                      Projected electric power consumption by residential development with-
                                      out  the APA  is as  follows:   165,570,000 kwh/yr for single family
                                      dwelling  units and 23,069,000 kwh/yr for multi-family units; total
                                      electric  power consumption  by residential  development is 188.6 million
                                      kwh/yr.

                                      Assuming  that  energy requirements of the conveyance and treatment
                                      systems in Table III-5 remain constant over the 20-year project
total energy requirements             planning  period, the total  energy requirements of the APA are those
of APA                                included  in  Table  III-6.


                                      Table III-6.   Total  estimated energy requirements of APA.

                                      B-LLJSA-associated wasteawter conveyance and       1,505,841 kwh/yr
                                      treatment components

                                      Total electric power consumption  by residential  108,619,000 kwh/yr
                                      development  induced1" by APA

                                      Total estimated  energy requirements of APA       110,124,841 kwh/yr


ALTERNATIVES                C.    A detailed review of  the  design  and costing of the wastewater management
                                 plans under  study during  the EIS process is embodied in the "Engineering
                                 Evaluation of  the Bushkill  Draft EIS"  (Appendix D-3).  Key tasks1? under-
                                 taken during this evaluation included:

                                 •  An assessment  of the conveyance systems presented in the Draft EIS
                                    that incorporated  the  use of  force  mains and pump stations

                                 •  Segmental cost-effectiveness  analysis comparing a total of five
                                    alternative wastewater conveyance  and treatment options for two
                            14
                              This evaluation does not include the electric power requirements of project-
                              associated commercial  and industrial development.
                            15
                              Electric power consumption by single family detached units   21,600 kwh/yr;
                              Electric power consumption by multi-family units = 16,900 kwh/yr.

                              Project electric power consumption by development with APA minus projected
                              electric power consumption by development without APA (see Appendix D-4).

                              While these tasks involve a more detailed approach to evaluating the EIS al-
                              ternatives in light of critical  public comment and input received on their
                              design, cost, reliability, and,energy requirements, EPA has not departed from
                              its commitment to conduct such analysis within the framework of the Agency's
                              Construction Grants Program guidelines and regulations for Step I-level
                              projects.

                                                   22

-------
    ana Subarea 1
    oooo Subarea 1

    ••• Subarea 2
    • ••• Subarea 2
         Gravity  interceptor
         Force  main  - pump
          stations
         Gravity  interceptor
         Force  main  - pump
          stations
                            OOOOOOOOOOOOOOOOOOnnnooo
NEWBURG
 HOMES
                                                                PENN
                                                                PUMP
                                                                PARK
Figure  III-6.  Subareas associated with  segmented cost-effectiveness  analysis.
                                    23

-------
Assessment of Pressurized
Wastewater Conveyance
Systems
Alternative 9 (Modified)
Segmental Cost-Effective-
ness Analysis
Alternate A
Alternate B
   subareas in the EIS Service Area.  The first subarea extends from
   the exsting Nazareth STP to the connection point with the Forks
   Township/Bushkill  interceptor at Penn Pump Park in Palmer Township
   (hereafter referred to as Penn Pump Park).  The second subarea
   extends from the southeast corner of Tatamy Borough at Bushkill
   Creek to Penn Pump Park.  The two subareas are illustrated in
   Figure III-6.

•  A reanalysis of the Draft EIS design and cost for the Nazareth RBC
   STP

•  A review of the cost-effectiveness analysis presented in the Draft
   EIS, focusing on the APA, MAPA, and Draft EIS Alternative 9.

1.   As assessment was made of the pump stations that were proposed for
     Alternative 9, the Draft EIS Recommended Action, because of critical
     public comments  on the selection of a pressurized wastewater convey-
     ance system.  No major discrepancies were found.

     For the force mains associated with pump stations (PSs) #1 and #4,
     it was determined that the pressurized piping could be replaced by
     gravity sewers for a moderate distance, resulting in a more econom-
     ical design (see Section III.D.2).  Pump stations #3, #4, #7. and
     #8 involved successive lifting or pumping of sewage.  A study was
     made of the Tatamy Borough/Stockertown Borough area to see if a more
     economical conveyance system was possible.   The use of a gravity
     sewer along the  right-of-way (ROW) of the Lehigh Valley Railroad
     between Stockertown Borough and Tatamy Borough would permit the
     elimination of PSs #4, #7, and #8, but would require enlargement
     of PS #3.18  The enlarged PS #3 is termed PS #3 (Modified),  and the
     conveyance system design using only six pump stations in lieu of
     nine is referred to as Alternative 9 (Modified).  The substitution
     of a gravity sewer system for these three PSs reduced the energy
     requirement of the conveyance system as presented for Draft EIS
     Alternative 9 by nearly 50%.

2.   A segmental cost-effectiveness analysis was made, which was totally
     independent of the analyses performed during the preparation of the
     Draft EIS.  The  study was conducted to determine the most cost-
     effective method to convey and to treat sewage generated in two of
     the subareas in  the EIS Service Area.

     Subarea 1 comprises Nazareth Borough, Upper Nazareth Township, and
     Newburg Homes in Palmer Township (see Figure III-6).  Three alter-
     nates were developed for this area:

     •  Alternate A features a sewage treatment plant to handle waste-
        water flows from Nazareth Borough and Upper Nazareth Township.
        Four treatment plant options were analyzed:  (a) a RBC plant
        with Lamella  Settlers (see Appendix D-3), (b) an RBC plant with
        a conventional final clarifier, (c) a conventional activated
        sludge (AS) plant, and (d) an OD plant.   Newburg Homes is served
        by pump station/force main and gravity sewer to Penn Pump Park.

     t  Alternate B includes gravity sewers along Schoeneck Creek serving
        Nazareth Borough and Upper Nazareth Township, and gravity sewers
        serving Newburg Homes.
                              This railroad ROW is  the same one through which the B-LLJSA proposed to con-
                              struct interceptors  under the APA.

-------
FIGURE IH-7 PUMP STATIONS ASSOCIATED WITH EIS ALTERNATIVE 9
                       MODIFIED CONVEYANCE SYSTEM
    SERVICE AREA BOUNDARY
    PUMP STATIONS INCLUDED IN MODIFIED
       CONVEYANCE SYSTEM
    PUMP STATIONS ELIMINATED UNDER
       MODIFIED CONVEYANCE SYSTEM

-------
 Alternate C
 Alternate D



 Alternate E
 t  Alternate C features a pump station/force main system,  con-
    structed along public roads, to serve Nazareth Borough,  Upper
    Nazareth Township, and Newburg Homes.

 Subarea 2 comprises the area between southeastern Tatamy Borough
 at Bushkill Creek and Penn Pump Park.  Two alternates were  developed
 for this area.

 •  Alternate D would convey all sewage generated north of Tatamy
    Borough to Penn Pump Park by gravity sewer along Bushkill Creek

 •  Alternate E would convey all sewage generated north of Tatamy
    Borough by means of a pump station/force main system down
    Tatamy Road to Penn Pump Park.

 Separate cost-effectiveness analyses that compare Alternates A,  B,
 and C,  and Alternates D and E have been developed (see Table III-7).
                                       Table  III-7.   Cost-effectiveness  analysis  of Alternates A, B, and C,
                                       and Alternates  D  and  E.
Alternate
Schoeneck Creek Watershed
Aa
Ab
Ac
Ad
B
C
(RBC/L5)
(RBC/CONV)
(AS)
(OD)
(Gravity)
(FM/PS)
Lower Bushkill Creek
Watershed
D
E
(Rushkill Creek
Gravity System)
(Tatamy Road
FM/PS System)
Capital
Cost

$3,491,913
3,551,913
2,521,913
1,492,913
1,760,000
1,714,694

$ 740,913
790,575
Annual
O&M

$145
149
165
57
81
101

$ 4
9

,620
,620
.620
,620
,480
,071

,150
,691
Present
Worth
O&M
(10.4919)

$1,527,830
1,569,798
1,737,669
604,543
854,880
1,060,427

$ 43,511
101,677
Salvage
Value

$ 996,939
1,046,939
776,939
486,939
700,000
461,327

$ 295,698
234,250
Present
Worth
Salvage
(0.2525)

($251
( 264
( 19fi
( 122
( 176
( 116

($ 74
( 59

,727)
,352)
,177)
,952)
,750)
,485)

,664)
,148)
lotal
Present
Worth

$4,768
4,857
4,063
1,974
2,438
2,658

$ 709
833

,016
,359
,405
,504
,130
,636

,790
,104
Total
Annual
Equivalent
(0.0953)

$454,39?
462, 906
387,243
188,170
232,354
253,368

$ 67,643
79,395
                                                  r^'rnlnnnln.c0"^^^6 ^ IJ1!"1™ a^owable expenditures to keep the system
                                                                                  j. 2Q yegrg flre no£ included.
Comparison of
Subarea 1
Alternates
Comparing Alternates Aa and B is equivalent  to  comparing Alter-
native 9 (Draft EIS recommended alternative)  and  the  MAPA with
respect to serving the western portion of  the EIS Service Area.
The comparison indicates a gravity sewer  (Alternate B)  is less
expensive than a treatment plant at Nazareth  (Alternate Aa).
The additional expense of the treatment plant is  calculated as
follows:

((capital $ Alternate Aa   capital $ Alternate  B) x  (25% local
share capital $) x discount factor) +  (annual O&M $ Alternate Aa
annual O&M $ Alternate B)) -= number of families x 12  month/year.
                                                    26

-------
Comparison of
Subarea 2
Alternates
extra monthly east to
avoid Buahkill Creek
     (($3,491,913 - $1.760.000) (2.5) (.0953)) + ($145,620 - $81,480)
                      3,754 families x 12 month/year

                                     = $2.34/month per family.

     Alternate Ad -- treatment of wastewater via an OD plant -- however,
     is the least expensive option.  Using the preceding formula, it
     is estimated that an OD plant represents a savings of $0.67/month
     per family over the gravity sewer (Alternate B).

     The comparison of Alternate D (gravity system from Tatamy Borough
     to Penn Pump Park) and Alternate E (force main/pump station system
     from Tatamy Borough to Penn Pump Park) also is shown in Table III-6.
     The total annual equivalent cost of Alternate E is $11,752 more than for
     Alternate D.  Therefore, it would cost $11,762/year for a conveyance
     system that would avoid a State-proclaimed trout stream -- Bushkill Creek

     There are 11,263 persons, or approximately 3,754 families, in the
     EIS Phase I Service Area that would pay the cost.  On a monthly
     sewer bill basis, the added cost for avoiding Bushkill Creek down-
     stream from Tatamy Borough would be:

     ((capital $ Alternate E   capital $ Alternate D) x (25% local
     share capital $) x discount factor) + (annual O&M $ Alternate E
     annual O&M $ Alternate D)) T number of families x 12 month/year.

                                                        U54)
(($790,575 - $740,913) (.25) (.0953)) + ($9,691  -
             3,754 families x 12 month/year

                              $0.15 month per family.

The additional capital cost to EPA, through the  75% Construction
Grant Program, would be:

             ($790,575.,-  $750,913) (.75)   $37,247.
Cost-Effectiveness
Analysis
focus
     The additional capital cost to the B-LLJSA would be:

                      ($790,575   $750,913) (.25)   $9,916

3.    The review of the Draft EIS cost analysis focused on the APA, MAPA,
     and Draft EIS Alternative 9 for the following reasons:

     •  The APA is the subject of this EIS
     a  The MAPA is a redesign of that action             ,.g
     •  Alternative 9 is the Draft EIS Recommended Action.'

     The costs associated with the above alternatives have been updated to
     reflect more realistic unit costs.  The units costs used to revise
     these wastewater management plans were adapted from actual bid data
     upon which the original costs of the APA were based.  The rationale
     behind using relatively lower unit costs during the costing of the
     Draft EIS alternatives is identical to the one given for use of these
     unit costs in the costing of the APA for the Draft EIS (see page
     18    of this EIS).
                             19.
                               Two  types  of wastewater treatment facilities  were considered to meet the needs
                               of the  Nazareth  STP  Service  Area  under Alternative 9.   Combination with the
                               modified conveyance  system (Section  III.C.I)  results  in four versions of
                               Alternative  9.

-------
Draft EIS costs too low
Alternative 9 RBC plant
Alternative 9 OD plant
local user charges
          The present worth costs  of all  the alternatives reported in the Draft
          EIS consistently were found to  be approximately 10% to 22%  lower
          in relation to present worth costs based on construction bid costs.
          However,  the cost ranking of the alternatives,  as determined by the
          cost-effectiveness analysis, remains valid.   The revised cost-effec-
          tiveness  analysis is  presented  in Table III-8.

          Alternative 9 (RBC) has  incorporated the use of conventional treat-
          ment components (preliminary treatment and primary clarifiers) to
          a greater extent than was the case in Draft EIS Alternative 9, which
          recommended the use of several  innovative/alternative (i/a) tech-
          nologies  (wire screen in lieu of conventional  preliminary treatment/
          primary clarification).   Alternative 9 (Modified; RBC) further incor-
          porates the modified  conveyance system (six pump stations) that was
          discussed in Section  III.C.I.  Outside of these modifications, the
          remainder of Phase I  is  served  as reported in  the Draft EIS under
          both scenarios.

          The least costly alternate treatment facility  to replace the existing
          Nazareth  STP is an OD plant.  It can achieve the same effluent quality
          as the previously proposed RBC  plant -- 10 mg/1 BOD, 15 mg/1 suspended
          solids, and 2 mg N/l  ammonia.  These levels are well within the
          effluent  standards set by DER for discharge to  Schoeneck Creek --
          20 mg/1 BOD, 25 mg/1  suspended  solids, and 3 mg N/l ammonia.  Except
          for the substituted treatment scheme to meet the needs of the Nazareth
          STP Service Area, Alternative 9 (OD) is identical to Draft EIS Alter-
          native 9  in configuration.  Alternative 9 (Modified; OD) includes the
          modified  conveyance system described in Section III.C.I.

          Estimated local user  charges for the APA, MAPA, and the four versions
          of Alternative 9 are  presented  in Table III-9.   This information is
          presented for comparative purposes only.  Actual user charges, once
          a system  is operable, would depend on prevailing bond rates, bond
          life, and other market conditions.
IMPACTS
Conversion of Prime
Agricultural Land
Under MAPA and
Alternative 9
secondary -impacts
Induced Growth Under
MAPA and EIS Alter-
native 9
D.   New or revised impacts associated with the implementation of the MAPA and
     EIS Alternative 9 (including its four versions) are discussed in this section
     in light of modifications  described in Sections III.A, B, and C.  As stated
     previously, the impacts associated with the APA cannot be compared to those
     associated with the EIS alternatives because of dissimilar design assump-
     tions and service area configuration.  The MAPA serves as a redesign of
     the APA that can be compared directly to the EIS Alternatives.

     1.   Implementation of the MAPA would induce the conversion of  14% more
          prime agricultural land to residential/commercial/industrial uses
          than would occur without its implementation.   Implementation of EIS
          Alternative 9 would induce the conversion of less than 1%  more prime
          agricultural land to developed uses than would occur without its
          implementation.  These estimates account for the reduction  in the
          amount of classified prime agricultural land in  the EIS  Service Area
          (Section III.A.I).

     2.   The revised numbers of dwelling units  induced  by implementation of
          either the MAPA or Alternative 9 are presented in Table  111-10.  Revi-
          sions have been required as a result of the adoption  by  Stockertown
          Borough and Tatamy Borough of floodplain management ordinances which
          limit and condition, but do not prohibit, development in the 100-year
          floodplain.  Further revisions of  induced growth estimates under
          Alternative 9 have been made to reflect the substitution of gravity
          sewers for force main/pump stations at two locations  in  the EIS Service
          Area:
                                                    28

-------
Table III-8.  Cost-effectiveness analysis of APA, MAPA, and four versions of Alternative 9.
      Alternative
 Capital
   Cost
Annual
  0&M1
 Present
  Worth
   O&M
(10.4919}
Salvage
 Value
Present
 Worth
Salvage
(0.2525)
 Total
Present
 Worth
  Total
  Annual
Equivalent
 (0.0953)
Applicant's Proposed
 Action (APA)

Modified Applicant's
 Proposed Action (MAPA)

Alternative 9 (RBC)
Alternative 9 (Mod;  RBC)
Alternative 9 (OD)
Alternative 9 (Mod; OD)
13,720,337   413,985     4,343,489   4,929,040  (1,244,583)  16,819,243   1,602,874


11,143,977   194,212     2,037,653   3,994,280  (1,008,556)  12,173,074   1,160,094


11,553,579   238,934     2,506,872   3,565,566    (900,305)  13,160,146   1,254,162


11,228,395   233,863     2,453,667   3,513,166    (887,074)  12,794,988   1,219,362


 9,553,489   150,934     1,583,584   3,055,566    (771,530)  10,365,543     987,836


 9,229,575   145,863     1,530,380   3,003,166    (758,299)  10,001,656'    953,168
1
 The values in this column represent the minimum expenditures necessary to keep  the corresponding system
 operating.  Replacement costs for system components, such as gravity sewers and force mains  that  have
 service lives of more than 20 years were not included.  Preferred O&M costs,  which reflect replacement
 costs for all components, are presented in Appendix D-3.  Regardless, the relative  rank of the alternatives
 does not change.

-------
    Table  III-9.   Estimated local  user charges for the APA, MAPA, and four versions of Alternative 9.
Alternative
Alternative 9 (RBC)
Alternative 9 (OD)
Alternative 9 (Mod; RBC)
Alternative 9 (Mod; OD)
Modified Applicant's
Proposed Action
Applicant's Proposed Action
(without Nazareth)
(with Nazareth)
Capital
Cost
$ 11,553,579
9,553,489
11,228,395
9,229,575
11,143,977
13,720,337
13,720,337
Local Share
(25%)
$ 2,888,395
2,388,372
2,807,099
2,307,394
2,785,994
3,430,084
3,430,084
Annual
Equivalent
of Local
Share (0.0953)
$ 275,264
227,612
267,517
219,895
265,505
326,887
326,887
Annual O&M1
$ 238,934
150,934
233,863
145,863
194,212
413,985
413,985
Total Annual
Cost to ?
Local Citizens
$ 514,198
378,546
501 ,380
365,758
459,717
740,872
740,872
Annual Cost
Per
Family
$140.88
103.68
137.40
100.20
126.00
268.80
158.40
Monthly
Cost Per
Family2
$ 11.74
8.64
11.45
8.35
10.50
22.40
13.20
                                                                                                                                                o
                                                                                                                                                CO
 These values represent the minimum expenditures  necessary to  keep  a  system
 operating.   They are not the recommended amounts.   Replacement  costs for
 system components, such as gravity sewers and pressure  pipes  that  have  ser-
 vice lives  of more than 20 years,  were not included.  O&M costs  in Appendix
 D-3 reflect replacement costs for  all  components.

o
 This information is presented for  comparative purposes  only.  Actual  user
 charges may vary with prevailing bond  rates,  bond  life, and market conditions.
       ALT.
        9
       MPA
APA (without Nazareth)
APA (with Nazareth)
NO. OF FAMILIES
     3,650

     3,650

     2,756

     4,677

-------
substitution of gravity
sewers for force mains/
pump stations
Palmer Township develop-
ment induced by gravity
sewer under Alternative 9
   •  Northwood Avenue from its intersection with Van Buren Road east
      to Penn Pump Park (Palmer Township)

   •  Tatamy Road approximately 2,000 feet south of its intersection
      with Stocker Mill Road south through its intersection with
      Northwood Avenue east (on Northwood Avenue) to Penn Pump Park
      (Palmer Township).

   Under the assumption that gravity sewers induce more growth than
   force main/pump station sytsems (see Appendix C-2), Palmer Town-
   ship20 Was allocated an additional 192 dwelling units (592 persons)
   in addition to the Draft EIS induced growth rate estimate of zero
   (under Alternative 9).  The derivation of these revised estimates
   of induced growth in Palmer Township under Alternative 9 is included
   in Appendix C-2.  The revised estimates of induced growth for all
   alternatives are listed in Appendix C-3.
                                      Table 111-10.   Dwelling units induced under MAPA and  EIS  Alternative  9.
Municipality
Bushkill
Nazareth
Palmer
Plainfield
Stockertown
Tatamy
Upper Nazareth
TOTALS
MAPA
S*
0
0
395
128
115
252
158
1,048
M*
0
0
395
32
0
0
40
467
Alternative 9
S*
0
0
96
25
47
47
0
215
M*
0
0
96
0
0
0
0
96
                                         S   single family units

                                         M   multi-family units
Surface Water  Quality
Impacts
3.    Induced growth revisions for Alternative 9 that were described in
     Section III.D.2 result in the consumption of 90 more acres of land
     than the 16 acres estimated in the Draft EIS.  This increase is
     relatively insignificant in terms of non-point source pollution,
     particularly stormwater runoff from potential development.  There-
     fore, the revised induced growth for Alternative 9 still  is not
     expected to affect water quality adversely in terms of dissolved
     oxygen, bacteria, and phosphorus.
                            20
                              Portion  of Palmer  Township  currently  not  sewered.
                                                    31

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Impacts on Aquatic
Environment
Tatamy-Penn Pump Park
corridor' study
five stream crossings
under Alternative 9
(Modified)
Economic Impacts of MAPA
and Alternative 9
There are 16 stream crossings associated with the MAPA  (Figure
III-3).  Like the APA, all of them would involve the temporary
diversion of stream flow and excavation (blasting where necessary)
of the streambed for pipe installation.  The primary impacts and
mitigative measures related to the construction of these stream
crossings are identical to those described for the APA  in Section
III.B.I.  A study of the Tatamy-Penn Pump Park corridor by a
geologist and a biologist, in concert with the Applicant's engineer,
is recommended for the MAPA as well as the APA, because both waste-
water management plans involve the construction of interceptors
through limestone soils and through areas where springs are known
to exist.  There is the potential for spring diversion and/or stream
diversion to occur as a result of sewer construction which involves
blasting of hard rock to facilitate pipe installation.  Blasting
may possibly enlarge or close up solution channels, thereby altering
groundwater flow.

There would be five stream crossings (none on Bushkill Creek down-
stream from Tatamy Borough) under Alternative 9 (Modified); one
less than under Draft EIS Alternative 9.  Adverse impacts that are
associated with these five crossings would be minimal and of
relatively short duration.  Following the acquisition of Section
404 permits from the US Army Corps of Engineers, all  crossings would
have to be made according to stipulations prescribed by the
Pennsylvania DER and Pennsylvania Fish Commission.  A corridor study
(Tatamy Borough to Penn Pump Park) is not recommended for Alternative
9 because wastewater conveyance is by a system of force mains and
pump stations down public roads, not by gravity sewer along Bushkill
Creek.

The potential for future stream crossings is minimal  under Alter-
native 9.  Residential areas in the vicinity of Nazareth Borough,
Stockertown Borough, and Tatamy Borough are practically at develop-
ment capacity.  Future connections would be made to force mains and
pump stations, which generally are located away from streams.

The financial burden and displacement pressure (see footnotes 8 and
9, page 19. related to the MAPA and four versions of Alternative 9
are presented in Table III-ll.
                                      Table  III-ll.   Financial  burden  and  displacement pressure associated
                                      with MAPA and  Alternative 9.
                                      Alternative

                                      Alternative 9 (RBC)
                                      Alternative 9 (OD)
                                      Alternative 9 (Mod.;  RBC)
                                      Alternative 9 (Mod.;  OD)
                                      Modified  Applicant's
                                       Proposed Action
                           Annual User
                            Charge  ($)

                              141
                              104
                              137
                              100
                              126
 Financial
Burden (%)

   10-15
    5-10
   10-15
    5-10
   10-15
Displacement
Pressure  (%j

    5-10
    1-5
    5-10
    1-5
    5-10
Energy Requirments of
MAPA and Alternative 9
The energy requirements of the MAPA, like the APA,  have  been  updated
to account for the expansion of the Second Street and  Delaware Drive
pump stations as well as the Easton STP.  As indicated in  Sections
III.B.3 and III.B.4, the expansion of these facilities is  essential
                                                   32

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                                      to  the  operation  of  any  alternative  involving  the  conveyance  of
                                      wastewater  from the  B-LLJSA  area  to  the  Easton  STP.   Updated  MAPA
                                      energy  requirements  also include  a modified  energy budget  for the
                                      Edelman pump  station and an  estimate of  energy  consumption by
                                      residential development  (Section  III.B.6)  induced  by  the MAPA.
                                      The energy  requirements  directly  associated  with the  operation of
                                      the wastewater management system  under the MAPA (Phase  I area only)
                                      are listed  in Table  111-12.
conveyance  and treatment
system energy  requirements
of MAPA
        Table  111-12.
        posed  Action:

        A.   Conveyance
                                                     Revised  energy  budget  for  Modified  Applicant's  Pro-
                                                     conveyance and  treatment systems.
             1.    Edelman  Pump  Station                                  14,576
             2.    Second  Street Pump  Station  (modified  B-LLJSA  flow)   100,176
             3.    Delaware Drive Pump Station  (modified B-LLJSA flow)  224,840
                                           Treatment

                                           1.    Easton STP (modified  B-LLJSA portion)
                                           2.    Cluster Systems
                                                                                          TOTAL
                                                                      377,258
                                                                        7,010

                                                                      723,860
electric power consumption
by residential development
under MAPA
conveyance and treatment
system energy requirements
under Alternative 9
        Backup data for all  energy evaluations performed during the prepara-
        tion of the EIS are  included in Appendix D-2.

        The estimated average electric power demand by residential  development
        associated with the  MAPA in the year 2000 is as follows:21   187,550,000
        kwh/yr for single family dwelling units and 30,961,000 kwh/yr for multi-
        family dwelling units; total electric power consumption by residential
        development is 218.5 million kwh/yr."

        The energy requirements of Alternative 9 (Modified; OD) were examined
        because this version of Alternative 9 was the least costly of all
        considered (see Table III-8).  The analysis also includes energy demand
        by expanded conveyance and treatment facilities outside the EIS Service
        Area.  The requirements are shown in Table 111-13.
conveyance and treatment
system energy requirements
under Alternative 9
        Table 111-13.  Energy budget for Alternative 9 (Modified; OD):
        veyance and treatment systems.

        A.    Conveyance                                               ]<
                                                                                                      con-
                                           1.    EIS Service Area Pump Stations (see Appendix D-2)   91,592
                                           2.    Second Street Pump Station (EIS Service Area flow)  20,701
                                           3.    Delaware Drive Pump Station (EIS Service Area flow) 46,462
                                                                                                          23
                            21

                            22
                            23
See footnote 15, page III-ll.

Energy consumption by residential development includes both baseline
and project-induced development  (see Appendix D-4).

Equivalent to electric power consumed by four single family dwelling
units @ 21,600 kwh/yr per dwelling unit.
                                                   .3.3

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                            Table 111-13 (continued).

                            B.    Treatment

                                 1.    Nazareth STP (OD)
                                 2.    Easton STP (EIS  Service Area flow)
                                 3.    Cluster Systems
                                                                            TOTAL:
                                                             215,900
                                                              77,959
                                                               8,390

                                                             461,004
el&etv-le power consump-
tion by residential
development under
Alternative 9
total energy require-
ments of MAPA and
Alternative 9
Electric power consumption by residential development associated with Alter-
native 9 in the year 2000 is as follows:24  170,210,000 kwh/yr for single
family dwelling units and 24,692,000 kwh/yr for multi-family dwelling units;
total electric power consumption by residential development is 194.9 million
kwh/yr.

The estimated total energy requirements of the MAPA and Alternative 9 (Modi-
fied; OD) in the year 2000 are presented in Table 111-14.  It is assumed
that energy requirements of the conveyance and treatment systems included
in this table remain constant over EPA's 20-year project planning period.
                            Table 111-14.   Total  estimated energy requirements of the MAPA and
                            Alternative 9  (Modified;  OD)  in the  year 2000.
                            Essential  wastewater conveyance  and
                            treatment  components

                            Total  electric  power consumption by
                            induced*^  residential  development
                                           MAPA
                                         (kwh/yr)

                                           723,860


                                        29,872,000
Alternative 9
(Modified;  OD)
    (kwh/yr)

     461,004


    6,263,000
                            Total  estimated  energy  requirements      30,595,860
                                                                 6,724,004
                           24

                           25
  See footnote 15,  page 30;  footnote 22, page 41.

  Project  energy  consumption by development with MAPA or Alternative 9
  (Modified;  OD)  minus  project energy consumption by development without
  MAPA  or  Alternative 9 (Modified;  OD).   See Appendix D-4.       	

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CHAPTER IV
Comparison of Alternatives

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 .CHAPTER  IV:
  COMPARISON
  OF
  ALTERNATIVES
MODIFIED APPLICANT'S
PROPOSED ACTION
Significant factors that were considered by EPA in  the  final  selection  of an
appropriate wastewater management plan for the EIS  Service Area  are presented
in this chapter.   Because the APA provides sewerage to  areas  for which  there
is not sufficiently documented need,  the EIS focuses on the MAPA and EIS
Alternative 9.  This  process  included consideration of several key factors.


•  Need for the project:  Which wastewater management plan, the  MAPA or Alter-
   native 9, represents the best solution to existing documentable problems
   associated with on-site disposal/treatment systems in the  EIS Service Area
   (see Assumption 8, page II-3)?  In the absence of existing wastewater
   management needs, business development needs are not fundable under EPA's
   Construction Grants Program.

t  Cost-effectiveness:  The selected plan must minimize the cost of water
   pollution control to the public -- Federal taxpayers as well  as sewerage
   system users -- and to the natural environment.

t  Energy (electric power) requirements:  The EPA-recommended plan should
   minimize energy consumption by project-associated residents as well  as
   project-associated wastewater conveyance and treatment components.

•  Degree of induced growth:  The selected plan should  provide for a reasonable
   rate of growth beyond existing wastewater management needs in the interest  of
   floodplain protection (see Assumption 15, page 10),  water  quality,  preser-
  vation of open space and prime agricultural land, and maintenance of the
   quality of existing public services.

t  Aquatic environment:  The intrinsic value of Bushkill Creek as a high quality
   stream capable of supporting a naturally-reproducing trout population should
   be weighed carefully in selecting the most appropriate wastewater management
   plan.  Springs, which are essential to the continued presence of a  large
   wild trout population, are an important element in this decision.

0  Wastewater management:  What are the operation and maintenance requirements
   (including staffing) of the selected wastewater management plan?

•  Engineering:  Although not determinative in the selection  of an appropriate
   wastewater management plan, consideration should be  given  to  Step II require-
   ments and their effect on the timing of the project  given  the immediate
   needs of the Service Area.

A.   As described on page 166 of the Draft EIS, the MAPA is similar to the APA
     in concept but is different in terms of design year, estimated wastewater
     flows per person, and service area configuration.' It provides for cen-
     tralized collection of wastewater in the Belfast-Edelman area of  Plainfield
     Township, the Cherry Hill area of Bushkill Township, Stockertown  Borough
     Tatamy Borough, the East Lawn area of Upper Nazareth Township, and the
     Northern Corridor of Palmer Township.  Capacity for wastewater generated
     in the Nazareth STP Service Area is provided by the Applicant's proposed
     Schoeneck Interceptor.  Wastewater collected in Phase I  communities listed
     above is conveyed, predominantly by gravity flow,  to the upgraded and
     expanded Easton STP for treatment.  Under the MAPA, cluster systems are
     provided in the following communities:  east Pen Argyl and Rasleytown
     (Plainfield Township), Rismiller (Bushkill Township), a.nd Christian Springs
     (Upper Nazareth Township).  The MAPA's design flow of 1.234 million gallons
     per day (mgd) was estimated on the basis of a year 2000 service population
     and on the following per capita flows:  60 gallons per capita per day (gpcd)
     for residential areas and 70 gpcd for residential/commercial areas.  A
     small waste flows district would be organized to manage the on-site systems
     in the outlying Phase II areas.

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ALTERNATIVE 9               B.  Under EIS Alternative 9,1  Phase I  area wastewater management needs  are
                                served by two STPs and twe'lve cluster systems.   A new oxidation ditch
                                (OD) treatment plant (0.85 mgd) replaces  the existing Nazareth STP  (see
                                Figure IV-1), serving Nazareth Borough and the  presently sewered East
                                Lawn area of Upper Nazareth Township.  Residents in the Belfast-Edelman
                                communities of Plainfield Township,  Stockertown Borough, and Tatamy
                                Borough are served by the Easton STP (0.26 mgd).  Wastewater conveyance
                                is achieved by a combination of gravity sewers  and six pump stations
                                (including force main).  Cluster systems  serve  the same communities
                                served by cluster systems under the  MAPA  as well as other low-density
                                areas north of Belfast in Plainfield Township.   Outlying Phase II areas
                                are served by new or rehabilitated on-site systems.

                                Note that the exact location of the  new OD treatment facilities would
                                be determined by Nazareth Borough  officials during additional  Step  I
                                efforts.   Locations of these facilities,  illustrated in Figure  IV-I
                                are only approximate.

                                The advantages and disadvantages of  the MAPA and of Alternative 9
                                are summarized in Table IV-1.  Data  presented in this table were screened
                                in the selection of the EIS Recommended Action,  which is described  in
                                Chapter V.
                             The components of Alternative  9  are  described in  detail  in Appendix  D-6.
                             The version of this  Alternative  utilizing an  RBC  plant was eliminated
                             from further evaluation due to higher costs.

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   Legend:

  1.  preliminary treatment
  2.  oxidation ditch
  3.  clarifier
  4.  chlorine contact chamber
  5.  chlorine storage bldg.
  6.  dechlorinator
  7.  sludge storage
  8.  sludge loading platform
     (contract hauling)
  9.  administration bldg.
 10.  laboratory
lla.  outfall
lib.  alternate outfall
 12.  sludge return pump
      Proposed treatment units
  "j Existing units
                                                      ALTERNATIVE
                                                    OF OXIDATION DITCH
                                                  TRICKLING
                                                     ILTER
                                                                                                    DISCHARGE
                                                                       SLUDG
                                                                      LAGOON
DOSING
  SIPHON
                                                       TRICKLING
                                                     5     FILTER
                                                        CONTROL BUILDING
                                                              CHLORINATOR
                                                                    SLUDGE PUMP1
                                                                  SETTLING TANK
                                                                                                  AERATION
                                                                                                    PONO
                           FLOOD
                        PROTECTION
                           DIKE
                                                           AERATION
                                                             POND
                                                 NAZARETH
                                                                           .SLUDGE
                                                                           ^LAGOON
                                                                                               AERATION
                                                                                                 POND
Figure IV-1.
(revised).
Nazareth oxidation ditch sewage treatment plant

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TabTe IV-1 .   Significant -factors to be considered in selection o-f Final EIS R.
                                                                             Lecommended Ac~ti on .
                       MAPA
       Advantages
    Disadvantages
                  NEED FOR PROJECT
                          •  Entire  capacity  of
                             Schoeneck Interceptor
                             is  not  justified for
                             Federal funding under
                             EPA Construction
                             Grants  Program.   EPA
                             would fund  only  ca-
                             pacity  for  Nazareth
                             Borough, Upper
                             Nazareth Township,
                             Newburg Homes,
                             (Palmer Township),
                             and a  reasonable
                             rate of growth.
                 COST-EFFECTIVENESS
                           • Ranks second;  22%
                             less cost-effective
                             than Alternative 9
                             with total  present
                             worth of $12.2
                             million".
                 ENERGY REQUIREMENTS
 i Requires one pump
   station (14,576 kwh/yr).
• Requires over 1.6
  times as much energy
  as Alternative 9
  for essential  waste-
  water conveyance
  treatment facilities,
                           • Induced residential
                             development requires
                             5 times as much elec-
                             tric power as Alter-
                             native 92.


                           • Total requirements
                             (year 2000)= 5 times
                             as much as Alterna-
                             tive 9.
                                                                                       Alternative 9
       Advantages
       Disadvantages
                                                                                                                      NEED FOR PROJECT
                                                                              Serves only those
                                                                              areas whore document-
                                                                              able need exists
                                                                              (Phase I).
                                                                                          COST-EFFECTIVENESS
                                                                           • Ranks first, with
                                                                             total present worth
                                                                             of $10.0 million.
                                                                                          ENERGY REQUIREMENTS
• Essential wastewater
  conveyance and treat-
  ment facilities1
  require 461,004 kwh/yr.

• Induced residential
  development requires
  6,263,000 kwh/yr.2

• Total requirements
  (year 2000) =
  6,725,004 kwh/yr.
• Requires six pump
  stations (91,592
  kwh/yr).
 ^Facilities include pump stations in B-LLJSA/EIS Service Area,  Delaware  Drive/Second Street Pump Stations, and Easton STP  (MAPA/EIS flow).

 ^Does not include electric power requirements of residential  development without  project.

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Table IV-1.  Significant factors to be considered  in selection of Final EIS Recommended Action  (continued).
                       MAPA
        Advantages
      Disadvantages
                         I	
                  INDUCED GROWTH
 • Would provide capacity
   for commercial and
   industrial development
   in Palmer Township.
                AQUATIC E
                            Would  induce  construc-
                            tion of approximately
                            5  times more  dwelling
                            units  (1,515  units)
                            beyond baseline than
                            Alternative 9
                            Zoning challenges could
                            be initiated.
WIRONMENT

   Involves  construction
   of  16  stream  crossings,
   two  of which  are  down-
   stream from Tatamy
   Borough in the  "brown
   trout  nursery and prob-
   able spawning area."
   Blasting  and  excavation
   in this area  may  dis-
   rupt channel hydraulics.

•  Sewers  parallel  streams,
   increasing the potential
   for  streambank  erosion,
   and  non-point pollution
   of streams.
                                                                                         Alternative 9
Advantages
Disadvantages
                                                                                             INDUCED GROWTH
                                                                              • Would induce construc-
                                                                                tion of 311  dwelling
                                                                                units beyond  baseline

                                                                              • Growth would continue
                                                                                along recent past
                                                                                trends.

                                                                              • Relative less
                                                                                development pressure
                                                                                on Palmer Township
                                                                                RA zoning district.
                     Would  limit  growth  in
                     PIC  zoning district
                     in  Palmer Township.
                                                                                                                     AQUATIC ENVIRONMENT
                                                                                                        t  Involves construction
                                                                                                          of 5  stream cross-
                                                                                                          ings;  relatively less
                                                                                                          disruption  of  stream
                                                                                                          habitat than MAPA.

                                                                                                        •  Sewers parallel roads
                                                                                                          as much as  possible
                                                                                                          to avoid  siltation
                                                                                                          of streams  during
                                                                                                          construction and nor-
                                                                                                          point  source pollu-
                                                                                                          tion as a result of
                                                                                                          construction.

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Table IV-1.   Significant factors to be considered in selection of Final  EIS Recommended Action.(concluded).
                       MAPA
       Advantages
Disadvantages
               WASTEWATER MANAGEMENT
                          • Wastewater management
                            system is relatively
                            simple, consisting of
                            collection and con-
                            veyance (but no treat-
                            ment) facilities
                            in B-LLJSA Service
                            Area proper; therefore
                            wastewater management
                            staffing requirements
                            are relatively minor.
                    ENGINEERING
 • Requires relatively
   less Step II (de-
   tailed) design than
   Alternative 9.
                                                                                   Alternative 9
Advantages
Disadvantages
                                                                                     WASTEWATER MANAGEMENT
                                                                       • See Appendix D-5 for
                                                                         advantages of ODs.
                   •  See  Appendix  D-5  for
                     disadvantages of  ODs.

                   *  Wastewater management
                     system  1s more complex
                     than MAPA; therefore,
                     staffing requirements
                     are  relatively more
                     complex than  those
                     associated with MAPA.
                                                                                         ENGINEERING
                                                                                                •  Requires  relatively
                                                                                                  more  Step II  (de-
                                                                                                  tailed) design  than
                                                                                                  MAPA.
                                                                                                                            c
                                                                                                                            -3

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CHAPTER V
Conclusions And Recommendations

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CHAPTER V:
CONCLUSIONS
AND
RECOMMENDATIONS
DESCRIPTION  OF  THE
FINAL EIS  RECOMMENDED
ACTION
Bushkill  Creek
Watershed   Phase  I
The Final EIS has found that the B-LLJSA's proposed action (APA)  as  well  as  the
Modified Applicant's Proposed Action (MAPA)  and ten of the alternatives  developed
in the EIS are neither cost-effective nor environmentally acceptable.  Therefore,
these are not acceptable for Federal funding under EPA's  Construction  Grants
Program.  An alternative wastewater management scheme, EIS Alternative 9  (Figure
V-l) is acceptable for funding.   This alternative plan was determined  to  be  the
most cost-effective (Figure V-2) and environmentally acceptable approach  to  serve
the documented wastewater management needs of the EIS Phase I  Service  Area
(Figure V-2).  Growth induced by this alternative is reasonable,  and associated
secondary impacts are not excessive.  The total energy requirements  of the plan,
including those of its wastewater conveyance and treatment components, as well
as its induced residential population are less than for the MAPA.  Trout  pro-
duction and recreational areas along Bushkill  Creek downstream from  Tatamy
Borough would not be disturbed by construction activities as would be  the case
if the MAPA were built.

A.  This section describes the EIS Recommended Action as  it would serve both
    Phase I areas (i.e., community need areas  which require off-site facilities)
    and Phase II areas (i.e., need areas which require only improved on-site
    facilities).

    1. Under the modified conveyance system^  (See Section III.C.I) the
       Bushkill Creek watershed  is served predominantly by gravity sewers
       (See Figure V-l).  Gravity interceptors will  serve the  following
       areas:  School  Road, Route 115 from its intersection with  T609
       south of Stockertown Borough, LR48040,  and Route 191  from  its
       intersection with LR48040 south to Belfast Junction.  A pump  station
       and force main will transport wastewater flows from Edelman along
       Route 191 to a point just above its intersection with LR48040.  The
       gravity interceptor then  will parallel  the main artery  through
       Stockertown Borough and Tatamy Borough  until  it reaches  PS #3
       (MOD) southeast of Tatamy Borough.  From PS #3 (MOD), wastewater
       generated in the Bushkill Creek watershed is transported under
       pressure along Tatamy Road until  a point approximately  one-third
       of a mile above Northwood Avenue.  From this point, all  sewage  flows
       by gravity to the Penn Pump Park manhole.   Flows will be treated at
       the upgraded and expanded Easton sewage treatment  plant.

       The sparsely developed segments along Route 115 north of the  gravity
       sewer and the communities of east Pen Argyl and Rasleytown (Plain-
       field Township) and Rismiller (Bushkill Township)  will  be  served by
       small collection systems  and multi-family filter fields (cluster
       systems).  If geohydrolic site analyses do not confirm  SCS soils
       ratings for indicated sites, other sites should be sought  or  marsh/
       pond systems should be considered.
                              modified conveyance system includes six pump stations within the EIS
                          Service Area, instead of nine as presented in the Draft EIS.
                                                 41

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«-
 FIGURE V-l  FINAL EIS RECOMMENDED ACTION

 — — SERVICE ARE* BOUNDARY

  6  APPROXIMATE LOCATION OF CLUSTER SYSTEM
          TREATMENT SITE
^-— PUMP STATION/FORCE MAIN  .
___ 6RAVITT SEWER
 	r- DIRECTION OF WASTEWATER FLOW

 |    | NAZARETH STP SERVICE AREA

    ^J AREA SERVED IY SMALL FLOWS DISTRICT*
            •EXCEPT FOM CLUSTER SYSTEM SERVICE AREAS

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Figure V-2.  Capital  costs, present worth, and estimated user cnarges associated
with APA, MAPA, and four versions of Alternative 9.
                                      1980S x 1,000,000
9
APA
MAPA
ALT.9(RBC)
ALT 9
MOD. (RBC)
ALT.9(OD)
*ALT.9
MOD.(OD)
S
APA
MAPA
ALT.9(RBC)
ALT. 9
MOD.(RBC)
ALT.9(OD)
+ALT.9
MOD. (OD)

APA A1
APA Bz
MAPA
ALT. 9 (RBC)
ALT. 9
MOD.(RBC)
ALT.9(OD)
*ALT.9
MOD.(OD)
10 II 12 13 14
ill'1
-. frn.... ffr „, -, ,.v.^% '-•*•. f ""*%"$%' W *• f "• *?; tfjjjffik
*•''',''",',"- ' ' r< /ij?% 13.7
'' ' II. 1
•C •* ;
JII.5
11.2
9.4 TOTAL CAPITAL COSTS
J PHASE 1
'•
1980S x 1,000,000
> 10 II 12 13 14 15 16 17
I'll1 1 — ' — -, 	 a '
TFpv>.v>y»»»$p»"»>»!i$!gg*>>tyV">- \ -™^ - 	 i 	 -- 	 -•••- -;-'..T '
'- - ' l ' 16.8
,„ ^ Zi4, ,. 	 .-, - 	 -*-„ 	 y
' '; 12.2
"* " ' 13.4
* , ..,, ,, ; '2.8
' I 10.4 TOTAL PRESENT WORTH
	 **•***•*« l""™1 PHASE 1
\ 10.0
1980 S/YR/HOUSEHOLO
100 120 140 160 180 200 220 240 260 280
IIA'IIJIIAI'II'LIJ1
] 269
,-,f^,fttmci.n 	 mrmilll ,,m 	 gil 	 	 	 	 	 jj
158
/, 
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 Schoeneck Creek
 Watershed   Phase  I
 Schoeneck Interceptor not
 justified on basis of Con-
 struction Grants program
 needs definition
 expanded Nazareth STP
 Service  Area

 flewburg  Homes
2.
 facilities planning
total Phase  I area flow
With the exception of need areas contiguous to the existing Nazareth
STP Service Area, Christian Springs (Upper Nazareth Township), and
Newburg Homes  (Palmer Township), wastewater management needs in the
Schoeneck Creek watershed are related to the collection system and
treatment plant presently owned by the Nazareth Sewerage Company.
On-site system problems in adjacent areas, Newburg Homes and Chris-
tian Springs, are not of sufficient importance to justify a new inter-
ceptor that would follow almost the entire length of Schoeneck Creek.
The disposition of the Nazareth Sewerage Company's wastewater facili-
ties has proven to be a decisive factor in wastewater management
planning for the watershed (see Assumptions 3 and 4, page 7).

Under the EIS Recommended Action, a combination of gravity intercep-
tors and pump station/force main systems will  serve Nazareth Borough,
Upper Nazareth Township citizens currently connected to the Nazareth
collection and treatment system, and the East Lawn area (Upper Naza-
reth Township).  Wastewater flows from Newburg Homes should be trans-
ported along Northwood Avenue to Penn Pump Park via a combination  of
pump station/force mains and gravity sewers.

The purchase of the privately owned Nazareth  STP by Nazareth Bor-
ough has been discussed for several years.   Since Nazareth Borough
has not yet purchased the Nazareth collection system system and has not
applied for Construction Grant funds to remedy its needs (see Appen-
dix H-2, Draft EIS), EPA cannot make a grant  decision for specific
construction activities.  In April  1980, however, Nazareth Borough
and the Pennsylvania DER discussed measures which could be taken
immediately to assess the suitability of or to rehabilitate the
Nazareth collection system (By telephone, John Parisi, F & M Asso-
ciated, Inc., representing Nazareth Borough,  25 April 1980.)

If the facilities of the Nazareth Sewerage  Company become publicly
owned, the owners may apply to EPA for Step I  and subsequent grants
for planning, design and construction of wastewater facilities.  The
Facilities Planning Area boundaries and recommended scope of the
Facilities Plan are discussed in Section V.C  of this EIS.   Alterna-
tively, the owners may enter into an agreement with the B-LLJSA to
amend the existing Application to include funds for the necessary
new Step I planning effort.

A detailed, site-specific survey should be conducted of on-site
system problems in Christian Springs as well  as in the unsewered,
developed portions of the Nazareth Borough-Upper Nazareth Township
urban area.  The results of this site-specific survey should
determine whether on-site, or small scale off-site, facilities
will best resolve existing needs.  Total average Phase I area waste-
water flows ot the Easton STP under the EIS Recommended Action equal
225,000 gallons per day.
Phase II
3.   Needs documentation studies conducted in support of this EIS
     revealed surface malfunctions of individual on-site systems and
     localized elevation of nitrate concentrations in groundwater that
     may be attributable to on-site systems.  The responsible munici-
     palities should investigate these problems and require appropriate
     remedies.

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EIS Recommended Action
Cost Summary
IMPACTS AND MITIGATIVE
MEASURES OF THE FINAL
EIS RECOMMENDED ACTION
4.
     Federal funding to assist the municipalities  and,  if  necessary,  to
     augment the efforts of their Sewage Enforcement  Officers  (SEOs)  is
     available if grant requirements discussed  in  Section  V.C.3 are met.
     Topics related to the management of individual and small-scale
     facilities are discussed in Section V.C, including authority for
     management, local decisions that should be made  when  developing
     a management entity, functions that the entity could  provide, and
     steps involved in implementing a management program.

     The EIS Recommended Action has been estimated to cost (in  1980
     dollars) :
     Total Capital Cost

     Federal share of capital cost
     State share of capital cost
     Local share of capital cost

     Present Worth Cost

     Estimated Annual User Charge
       Per Household
                                                                                             $ 9,229,575

                                                                                               6,922,181
                                                                                                       0
                                                                                               2,307,394

                                                                                             $10,001,656

                                                                                             $       100
Environmental, economic, and social impacts associated with Alternative 9
along with appropriate measures to mitigate and minimize them, are
summarized in the section.
                                    Impact

                                 AIR QUALITY

                                 •  Temporary air quality contaminant
                                    emissions, including total  suspended
                                    particles (dust,  smoke)  and gases
                                    (from construction  equipment and
                                    interrupted traffic) will  have in-
                                    significant effects on residential
                                    areas during sewerage construction
                                    and  no effects during construction
                                    of an OD  STP.
                                 •   Odor  impacts  from  operation  of an
                                    OD  plant  and  cluster  systems are
                                    minimal.
                                •   Secondary  air  quality  impacts  are
                                    minimal.
                                            Mitigative Measures
                                         «  Controlled speed of construction
                                            vehicles.

                                         •  Periodic spraying of roads and
                                            construction debris with water
                                            to control dust.

                                         •  Assistance by a traffic officer
                                            at potentially congested road
                                            intersections "in Stockertown
                                            Borough and Tatamy Borough during
                                            sewer construction.  '

                                         •  Proper maintenance of OD plant.

                                         •  Proper construction and mainte-
                                            nance of cluster systems (pump
                                            septic tanks every 3 years).

                                         •  N/A
                                 NOISE

                                 •  Noise from construction of sewers,
                                    force mains, and pump stations
                                    (without use of explosives) may
                                         •  Sewerage facilities construction,
                                            involving excavation and blasting.
                                            should be limited to the hours
                                                46

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                                        Mitlgative  Measures
NOISE (continued)

   cause adverse public reaction as
   much as 2,000 feet from a con-
   struction site.   Blasting may
   cause extreme short-term annoyance
   for up to 2,000 feet from the
   source.
  between 8 a.m. and 4 p.m.  Use of
  blast mats and burial  of primacord
  during demolition work may be
  necessary.
SOILS
   Soil erosion, with resulting
   sedimentation and nutrient
   transport, during construction
   of on-site systems, cluster
   systems, sewers, OD plant, new
   roads, and housing.
t  Compliance with provisions of
   Soil Erosion and Sedimentation
   Control  Act.

•  Require  individual  plan approval
   for construction on steep slopes
   and adopt performance standards
   with specific slope-density
   provisions.

i  Proper placement, hauling, back-
   filling, and mulching of soil
   during sewer construction (see
   mitigation measures specified by
   the Northampton County Conserva-
   tion District in Section VII.4.b,
   Draft EIS).
PRIME AGRICULTURAL LANDS

•  The amount of undeveloped
   (including prime agricultural)
   land that would be converted
   to residential/commercial/
   industrial uses under the EIS
   Recommended Action is 1,393
   acres.  This is only 13 acres
   more than the conversion that
   is estimated to occur without
   the project (1,380 acres).
o  N/A
GROUNDWATER

t  Blasting or rock drilling that
   may be required during construc-
   tion of the new OD STP (includ-
   ing clarifiers) may have
   potential  adverse effects on
   local  groundwater hydrology by
   altering paths of groundwater
   flow to Schoeneck Creek (see
   Section VII.A.6.a, Draft EIS).
•  A detailed geological investiga-
   tion of the OD plant site should
   be conducted to locate limestone
   outcrops  or formations that
   may necessitate  blasting during
    construction.
                 47

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   Wastewater recharge from on-site
   systems and cluster systems is
   projected to be approximately
   1 mgd.  Wastewater that is
   presently recharging groundwater
   supplies in Belfast (Plainfield
   Township), Stockertown Borough,
   and Tatamy Borough (0.30 mgd)
   would be exported to the Easton
   STP under the EIS Recommended
   Action.  The sources of water for
   these communities lie outside the
   EIS Service Area in another ground-
   water drainage basin.  Therefore,
   there are no local adverse effects
   on groundwater supplies asso-
   ciated with wastewater conveyance
   to Easton under the EIS Recom-
   mended Action.  This conveyance
   may lower local water table ele-
   vations along Route 115 in
   Plainfield Township, which would
   be a beneficial impact.  The
   conveyance of wastewater to the
   OD treatment plant also would
   have no impact on local ground-
   water supplies because the sources
   of water for communities served
   by the plant are also outside the
   EIS Service Area.

   The potential exists for local-
   ized nitrate standard violations
   in private wells throughout
   Bushkill Township and Plainfield
   Township.  This potential  will
   increase as densities of wells
   and on-site wastewater management
   systems increase.
   Mitigative Measures

   •  N/A
   Establishment of a surveillance
   program that includes routine
   monitoring of the performance
   of on-site systems and ground-
   water quality.
SURFACE WATER

•  The construction and operation
   of the new OD treatment facility
   will have a favorable impact on
   the water quality of Schoeneck
   Creek and Bushkill Creek.   With
   proper maintenance, the plant
   will continuously attain the
   effluent limitations set for
   BOD, suspended solids, and
   ammonia.

•  Erosion and sedimentation due
   to the construction of sewerage
   facilities and the OD treatment
   plant may be significant if not
   properly controlled (see Sec-
   tion VII.A.4.b of the Draft EIS).
•  N/A
•  Compliance with provisions of
   Soil Erosion  and  Sedimentation
   Control Act.

t.  Mitigative measures recommended
   on pages  16 and 17. of the Final
                   48

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   Impact

SURFACE WATER (continued)
•  Stormwater effects on water
   quality are minimal as a result of
   the projected induced growth in
   the EIS Service Area.  However,
   erosion and the resultant sedi-
   mentation due to changes in land
   use may be significant and may
   increase the sediment level in
   Bushkill Creek.
   Mitigative Measures
   EIS  should  be  followed  closely.
   Construction of  sewers  through
   streams  must be  in  accordance
   with Section 404 of the Clean
   Water Act  (see Section
   II.A.9.a,  Draft  EIS).

•  Proper control of erosion and
   sedimentation  is necessary
   during the construction period
   of sewage  treatment upgrading
   and  development  of the  growth
   area.

•  Establishment  of permanent
   vegetation buffers along
   Schoeneck  Creek.  Little
   Bushkill,  and  particularly
   Bushkill Creek,  may reduce
   sediment and  non-point  source
   pollution  loads  to these streams.
FLOOD-PRONE AREAS

•  The potential for development in
   flood-prone areas exists in
   Stockertown Borough and Tatamy
   Borough where ordinances do not
   prohibit such development.  This
   potential is not increasing in
   Bushkill Township (no sewers  ,
   provided).
•  Construction of flood control
   facilities including Stormwater
   detention ponds, vegetated
   drainage swales, and temporary
   water storage areas on building
   roofs (see Section VII.A.8.b,
   Draft EIS).

t  Establishment of permanent
   vegetated buffer zones to en-
   compass flood-prone areas ad-
   jacent to Bushkill Creek.   These
   buffer zones, which also could
   serve as parks or recreational
   areas, would preclude development
   in the floodplain (see Section
   VII.A.9.b, Draft EIS).
BIOTIC RESOURCES

t  Discharges of properly treated
   effluent (0.85 mgd) from the OD
   treatment plant may benefit
   aquatic life in Schoeneck Creek
   by augmenting channel flow during
   summer periods of low flow.

•  The construction of five inter-
   ceptor stream crossings may
   adversely affect stream quality
   via siltation.  (Figure III-3;
   also see Section VII.A.9.a,
   Draft EIS).
•  N/A
•  See Section VII.A.9.b, Draft
   EIS.

t  Compliance with provisions of
   Section 404, Clean Water Act,
   administered  in the Service
                49

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                                            Mitigative Measures
BIOTIC RESOURCES (continued)
   Potential  for sewer-induced growth
   in flood-prone areas in Stockertown
   Borough and Tatamy Borough is accom-
   panied by potential  for stream
   conditions to become degraded with
   respect to temperature, dissolved
   oxygen, transparency, nutrient, and
   bottom habitat.  If uncontrolled,
   streamside development may degrade
   Bushkill Creek, which is a high
   quality stream that supports a cold
   water (trout) fishery.
   Area by the Philadelphia
   District, US Army Corps of
   Engineers.

   See Section VII.A.9.b, Draft
   EIS.
HUMAN ENVIRONMENT

•  Population growth would be induced
   above basline by 927 persons.   This
   represents a 3.4% increase.

•  Land use impacts would be minimal
   because only 69 acres of land  in
   addition to that anticipated under
   baseline conditions would occur.
   Development density would increase
   as some municipal ordinances pro-
   vide for density bonuses where
   sewer and water service exists.

•  The induced dwelling unit growth
   would amount to 311 units.  The
   character of housing mix may be
   altered by the addition of some
   new multi-unit development.

•  The user charge of $100 per house-
   hold per year has the potential of
   placing a financial burden of
   5% to 10% of the Service Area popu-
   lation which could result in 1% to
   5% of the population being forced
   to move from their homes.

•  Public services such as health
   facilities, public safety, water
   supply, electricity, solid waste,
   and transportation will have
   minimal impacts.

•  No direct impacts are anticipated
   on known archaeological sites,
   historic sites, or structures.
   N/A
•  N/A
•  N/A
•  Loans or grants could be
   secured by the management
   authority from the Farmers
   Home Administration of the US
   Department of Labor, Economic
   Development Administration.
•  N/A
•  Degree of impact to be deter-
   mined following a detailed
   archaeological survey of EIS
   Sewer Survey Area.
i  As this alternative induced a         •  N/A
   minimal amount of population growth,
                 50

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   Impact                                   Mitigative Measures

HUMAN ENVIRONMENT (continued)

   additional recreation acreage
   will not be required in excess
   of defined baseline needs.


ENERGY (ELECTRIC POWER)

•  Electric power requirements of           •   N/A
   six pump stations in EIS Service
   Area   91,592 kilowatt-hours/
   year  (equivalent to average
   electric power consumed by four
   single family homes in one year).
   An  additional 215,900 kwh/yr are
   required  by the Nazareth  OD STP;
   cluster systems will consume
   8,390 kwh/yr.  A comprehensive
   energy evaluation of this
   alternative would also include
   electric  power consumed by:
   (1) conveyance and  treatment
   facilities outside  the EIS
   Service Area  (essential to
   treatment of  flows  from Belfast-
   Edelman (Plainfield Township),
   Stockertown Borough, Tatamy
   Borough,  and  Newburg Homes
   (Palmer Township) and (2) in-
   duced residential development.
   These energy  requirements equal
   145,122 kwh/yr and  6,263,000
   kwh/yr, respectively.  Total
   estimated energy requirements
   of  this alternative = 6,724,004
   kwh/yr.
                    51

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CHAPTER VI
Implementation of the Final EIS Recommended Action
P^^   dpW-
                    rt


&


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CHAPTER VI:
IMPLEMENTATION  OF THE
EIS  RECOMMENDED ACTION
Suggested procedures  for the  implementation of the wastewater management
facilities recommended  in this Final EIS are discussed in this chapter.
Bushkill Creek
Watershed   Phase I
Phase I staffing
requirements
Schoeneck  Creek
Watershed  -  Phase  I
      Phase I facilities recommended to serve parts of Plainfield Township,
      Bushkill Township, Stockertown Borough, and Tatamy Borough include
      both conventional and decentralized, alternative facilities.  The
      conventional facilities would presumably be designed, constructed,
      and operated by the B-LLJSA using standard engineering, management,
      and financing methods.  Easements previously not acquired for sewers
      and power sources at pump stations will have to be obtained.

      Inspection  and maintenance of the two pump stations in the Bushkill
      Creek watershed would require 40% commitment of a full-time two-
      person  B-LLJSA maintenance crew  (the remaining 60% of their time
      would be spent on the four pump  stations in the Schoeneck Creek
      watershed).  Alarms installed in the pump stations could alert the
      crew to any operational problems, thereby facilitating the mainte-
      nance effort on these systems.   These same two persons periodically
      could check the sewers for leaks, cracks, and other problems.

      Design, construction, and operation of the cluster systems in
      Plainfield  Township and Bushkill Township also could be coordinated
      through the B-LLJSA, although existing agreements with the Townships
      may not cover this responsibility.  This point may require nego-
      tiation between the B-LLJSA and  the Townships.  Design of these
      facilities  will require different engineering skills than those
      required for conventional facilities.  The responsible party should
      insure  that their employees or consultants have appropriate
      capabilities.  Operations personnel should be trained in the mainte-
      nance of small wastewater management systems.

      Since the designs of the conventional and alternative facilities
      differ  from those previously proposed, the B-LLJSA may apply for a
      Step II grant for preparing designs and specifications.

      Nazareth Borough has been negotiating purchase of Nazareth Sewerage
      Company's facilities with the company for the past five years.
      Nazareth Borough also has been given a rating of 70 on the
      Pennsylvania DER Construction Grants priority list.  These facts
      indicate that the facilities may become publicly owned, and an
      application for Federal funding  may be made.  Assuming this will
      occur,  the  Borough should prepare a Plan of Study and apply for
      a  Step  I grant to be followed by Step II and Step III applications.
      (If the cost for Step III construction is estimated in the Facilities
      Plan to be  less than $2 million, the project may be eligible for
      a  combined  Step II and Step III  grant per 40 CFR 35.909).
lall Flows District
lase II
Cv   Designation of parts of the EIS Service Area as having immediate
     need for off-site treatment, the Phase I area,  does not reduce the
     importance of dealing effectively and quickly with the scattered,
     improperly functioning on-site systems elsewhere.   Proceeding with
     solutions for the Phase I areas should not detract from efforts to
     achieve long-term sanitation and water quality  objectives  in the
     remainder of the EIS Service Area.

     The Clean Water Act of 1977 provides  economic incentives to improve
     rural  wastewater management by making repair and upgrading of on-
     site systems eligible for 85% Federal grants.  Facilities  Planning
     for rural  wastewater management is  eligible for 75% Federal grants.
                                                     53

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                                       Immediate needs in the Phase II area might be most expeditiously
                                       met without grant processes by inspections and enforcement  actions
                                       conducted by SEOs and by owner funding of appropriate repairs.
                                       Long-term sanitation and water quality objectives could also be
                                       met without grant processes.  This could be achieved first  by adop-
                                       tion of local ordinances to require monitoring and periodic inspec-
                                       tion of on-site systems and to allow access to individual on-site
                                       systems for inspection and maintenance.  It could also be achieved
                                       by sufficient appropriations for additional skilled personnel to
                                       carry out the inspection, monitoring, and maintenance.  For the
                                       reason that this additional effort has not traditionally been
                                       provided here or elsewhere, costs and manpower cannot be accurately
                                       estimated.  A rough estimate of the costs is $30 per household per
                                       year.  For the approximately 3,000 unsewered residences in  the Phase
                                       II areas, this would provide an annual budget of $90,000 per year,
                                       $30,000 of which could go to septic tank pumping (each tank pumped
                                       once every three years) and $60,000 per year for professional salaries
                                       (full-time sanitarian at $18,000 per year, half-time soil scientist
                                       at $13,000 per year, and one-quarter time geohydrologist at $7,000
                                       per year), clerical support (secretary at $12,000 per year) and office
                                       space, laboratory analyses, supplies, and transportation ($10,000 per
                                       year).  Other combinations of fees and attendant services are
                                       feasible.  Services provided could be:

                                       •  Lot inspection and resident interview every three years  to detect
                                          problems with surface malfunctions and plumbing backups  and to
                                          educate residents in the proper use of their systems

                                       •  Periodic well water sampling from properly constructed wells in
                                          representative locations

                                       •  Emergency septic tank pumping

                                       o  Routine septic tank pumping once every three years

                                       t  Professional consultation and design recommendations for problem
                                          systems.

                                       These services would supplement the present regulatory functions of
                                       municipal SEOs.

                                       The benefits of applying for Federal and State grant assistance to
                                       initiate such a program can be seen as:

                                       •  Initial planning, site analysis of existing problems and develop-
                                          ment of the management structure would be completed in an orderly
                                          manner and at relatively low costs to the municipalities

benefits of EPA-funded                 •  Repair and replacement of malfunctioning systems would cost the
Phase II program                          homeowner a fraction of the total cost (applies only to  homes
                                          built before December 1977)

                                       •  Public participation requirements would insure citizen input to
                                          the development of the management structure.

                                       On the other hand, complying with Construction Grants regulations
                                       would result in a lead time during which existing problems  could
                                       continue unabated.

                                       To provide additional  information on Construction Grants regulations
                                       for funding of Phase II, 40 CFR 35.918 "Individual Systems" is
                                       reproduced in Appendix A-2 of the Draft EIS.
                                                       54

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CHAPTER VII
Public and Agency Comments On Draft EIS
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CHAPTER VII:
PUBLIC AND  AGENCY
COMMENTS ON
DRAFT EIS
Substantive public and agency comments were received on  the  Draft  EIS.
They have been compiled and summarized in this chapter.   Only those  comments
that were offered through testimony at the public hearing on the Draft  EIS
and through written correspondence, which are essential  to the EIS decision-
making process, are responded to herein.   The comments  and appropriate  re-
sponses are organized by selected Draft EIS_s ub ject areas_, including:

   Need for the project
   Water quality
   Land use
   Design and cost of the Alternatives
   Induced growth
   Energy
                          Citizens and agencies that offered
                          listed  below:

                              Name

                          •   Brenda  Barrett
                                  substantive comments on the Draft EIS are
                           •   Patricia T.  Bradt


                           •   Wilmer  Clewell,  Resident

                           •   William H.  Danner,  Chairman;
                              John  A.  Houck,  Secretary;
                              Robert  F. Tenges

                           •   H.  Robert Daws,  Chairman

                           •   Joseph  DiGerlando,  Chairman;
                              Jane  Gilbert, Vice-Chairman;
                              WilIiam Morman;
                              Anthony Kazmakites;
                              Ralph Metz;
                              R.  Brent Alderfer,  Special
                               Counsel
                              Gary  Neil Asteak,  Solicitor

                           •   Joseph  T. Dorner

                           •   J.  Michael  Dowd,  Executive
                               Vice-President

                           t   Clifford L.  Jones,  Secretary


                           •   R.  Margaret Kennedy,  President

                           •   William P.  Kunkle,  Resident

                           •   Elwood  Lieberman,  Chairman
                           •  Richard D.  Lieberman,
                               President
                                  Office of Historic Preservation
                                  Pennsylvania Historical & Museum Commission

                                  Lehigh University
                                  Department of Biology

                                  Plainfield Township

                                  Plainfield Township Board of Supervisors
                                   Palmer Township Board of Supervisors

                                   Bushkill Township Board of Supervisors
                                   Plainfield Township Taxpayers Association

                                   Easton Area Chamber of Commerce


                                   Pennsylvania Department of Environmental
                                    Resources

                                   BIP  Inc.

                                   Plainfield Township

                                   Plainfield Township Planning and Zoning
                                    Commission

                                   Plainfield Farmers Fair Association
                                                   55

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   Name
Agency
•  Frank S. Lisella, Ph.D.,
   Chief
•  Edward J. Maher, Executive
    Vice President and
    Treasurer

•  Thomas C. Maloney, Regional
    Administrator

•  Bernard Merwarth

•  Jack G. Miller, Chief


•  John Molnar, Solicitor

t  Graham T. Munkittrick


•  Allen R. O'Dell, Chief
    Planner

•  William Patterson, Regional
    Environmental  Officer

t  Walter P. Pierson, Acting
    Director

•  Elaine Q. Rodger,  Resident

•  Mr. & Mrs. Gerald  Roth,
    Residents

•  Rodney W. Schreck, Resident

•  Francis J. Schweitzer

•  Charles S. Smith,  Attorney

•  Patty Sparrow,  Resident

•  Mr. & Mrs. Allen Stahl,
    Residents

•  Wayne A. Steinmetz, Resident

•  Donald E. Walters
Environmental Affairs Group
US Department of Health, Education and
 Welfare
Public Health Service

C. C. Collins & Company, Inc.
US Department of Housing and Urban
 Development

Upstream Farm Corporation, Inc.

Fisheries Environmental Services Section
Pennsylvania Fish Commission

Plainfield Township

US Department of Agriculture
Soil  Conservation Service

Joint Planning Commission
Lehigh-Northampton Counties

US Department of Interior
Insurance & Mitigation Division,
Federal Emergency Management Agency

Plainfield Township

Plainfield Township


Plainfield Township

Upper Nazareth Township

Bushki 11-Lower Lehigh Joint Sewer Authority

Plainfield Township

Palmer Township


Plainfield Township

Board of Directors,
Palmer Township Industrial and Professional
 Association
All letters or comments on the Draft EIS are included in Appendix D-l; a copy
of the transcript of the public hearing is included in Appendix D-2.
                            56

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ISSUE:
NEED FOR PROJECT

Comment 1
Jaeobsburg State Park
Response 1
 Jacobsburg  State Park has  been  removed  from consideration  for waste  disposal.
 Obviously,  the State has  revised its  recreation  plans  for  the Park.   What
 are the  State's wastewater management plans for  the future?   [Bradt]

 The Pennsylvania Department of  Environmental  Resources (DER), Division of
 Outdoor  Recreation,  has removed Jacobsburg State Park  from any consideration
 of centralized sewerage service in response to changes made  in long-range
 recreation  plans.   Plans  that formerly  called for the  construction of
 swimming and camping facilities were  abandoned by DER  in the face of sub-
 stantial opposition  from  local  citizens.   When DER agreed  not to  provide
 overnight camping  facilities, in response  to  public claims that such facil-
 ities would harm local  environmental  and archaeological  resources, it was
 determined  by the  Department that connection  to  the proposed B-LLJSA system
 would not be necessary  (By telephone, Mr.  George Fogg, Chief, Division of
 Outdoor  Recreation,  DER,  27 May 1980).

 Current  recreation plans  call for the provision  of facilities to  support
 hiking,  cross-country skiing, nature  and historic interpretation,  and
 picnicking.  Limited wastewater management needs will  be served by comfort
 stations with on-site disposal.  The  Department's position regarding
 recreation  and waste disposal plans for Jacobsburg State Park is  documented
 in Appendix B.
Comment 2
definition of need
Response 2
 In  order to qualify for  EPA grant  funding  for  sewage  conveyance and treatment
 systems, the EPA regulations require  a  substantiation of  "need."  This gen-
 erally means establishing  that existing on-lot treatment  systems are mal-
 functioning, causing surface or groundwater  pollution,  and that it 1s more
 cost-effective to centralize treatment  than  to attempt  to continue on-lot
 treatment.   [B-LLJSA]

 The documentation of need  under EPA's Construction  Grants Program has nothing
 to  do  with  the cost-effectiveness  of  centralized versus decentralized treat-
 ment.   Federal  subsidy of  sewerage facilities  construction is awarded only if
 there  are documentable water quality  or public health problems associated with
 inoperable  wastewater management facilities  that can  be corrected through
 such construction.   Need is defined in  EIS Assumption #8, page 9.
Comment 3
names and addresses
of residents with
confirmed malfunctions
needed
Response 3
 The names and addresses of residents  determined  by EPA during  the  needs
 documentation process to have confirmed malfunctioning on-site wastewater
 management systems should have been included in  the Draft EIS.  Such  infor-
 mation would facilitate municipal  wastewater management planning by identi-
 fying known problem areas which must  receive priority over other areas.
 [Morman,  Dorner,  DiGerlando]

In the interest of privacy, EPA does not publish in an EIS the names and
addresses of residents determined to have confirmed malfunctions.  General
locations of on-site system malfunctions are shown in Figure 111-21, Draft
EIS.  However, the exact locations of malfunctions photographed and field-
inspected by EPA's Environmental Photographic Interpretation Center (EPIC)
can be requested from EPA's Project Monitor at the following address:

                      Ms. Rochelle B.  Volin, Project Monitor
                      EIS Preparation Section
                      US Environmental Protection Agency,
                        Region  III
                      Sixth and Walnut Streets
                      Philadelphia, Pennsylvania  19106
                      215/597-8335.
                                                  57

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Comment 4
needs determination
•in suspect areas is
unresolved
Response 4
The locations of malfunctions verified by the Pennsylvania DER, and  included
in the EIS, are a matter of public record.

For other than surface on-site system malfunctions, little ortno determination
of need was made in tne Draft EIS.  This leaves serious questions open in
suspect areas with needs determination neither confirmed nor denied.  [B-LLJSA]

As described on page 99 of the Draft EIS, there are three types of problems
or malfunctions associated with on-site sewage treatment systems that are
recognized in the Technical Manual for Sewage Enforcement Officers (Pennsylvania
DER 1975).  These include surface malfunctions, back-up malfunctions,1 and
water table malfunctions.   Tne comment focuses on the  latter two types of
problems.

Information regarding the extent of back-up malfunctions in the EIS  Service
Area was sought from municipal sewage enforcement officers (SEOs) who are most
familiar with the performance of local on-site systems.  Sewage system back-
ups, along with surface malfunctions, were reported in the Belfast area of
Plainfield Township (see Figure 111-21, Draft'EIS).  These problems  have been
found to be most cost-effectively corrected via centralized sewerage.

EPA's determination of the extent of water table malfunctions during prepara-
tion of the EIS comprised the following tasks:
                                 Task

                            1.   Interviews with Northampton
                                 County sanitarian and super-
                                 vising sanitarian.

                            2.   Interviews with municipal
                                 SEOs and engineers, including
                                 tours of their jurisdictions.

                            3.   Review DER reports  of bacter-
                                 iological quality of private
                                 wells.

                            4.   Well sampling program (June
                                 1979).
                            5.   Interviews with local  plumbers.
                                       Obtain general perspective on wastewater
                                       management needs in EIS Service Area.
                                       To document location of groundwater
                                       quality problems associated with
                                       on-site sewage treatment systems.

                                       To identify location of wells potentially
                                       contaminated by on-site sewage treatment
                                       systems.

                                       To measure groundwater quality in areas
                                       suspected of having water table malfunc-
                                       tions.  Included analysis for nitrates ,d
                                       and indicator bacteria.

                                       To survey the number of chlorinators in-
                                       stalled in private water supply systems.
                            The results of these tasks do not indicate that on-site sewage treatment systems
                            are causing widespread groundwater pollution sufficient enough to justify the
                            construction of EPA-funded sewers.  Individual groundwater quality problems
                            (excessive nitrate levels) were limited.  They were found (June 1979) to be remote
                            from densely populated areas where wastewater management needs can be met
                            by centralized sewerage.  EPA believes that individual groundwater quality
                            problems which are identified can be corrected through localized solutions
                            within the framework of the Small Flows District (pages 274-275 of the Draft EIS).
                            At least one "suspect area,"3 Cherry Hill in Bushkill Township, was determined
                             Sewage backing up into house plumbing presenting use of sanitary facilities.
                            ?
                            "Effluent passing  to  the water table without adequate treatment.

                             Includes areas with  shallow depths to bedrock or groundwater.
                                                             58

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                           by EPA to have no measurable groundwater quality problems.  Three wells in this
                           community, which is located just above the Bushkill-Upper Nazareth Township
                           boundary, were found to have no water quality problems, based upon analysis of
                           nitrates, bacteria, chlorides, and total dissolved solids.  Nitrate levels
                           ranged from 0.4 to 1.4 rng/1 as N, which are well within safe drinking water
                           standards.  The US Public Health Service has determined "safe" drinking water
                           to contain no more than 10 mg/1 as N.

                           In sum,  EPA does not agree with the comment.  Adequate determination of the
                           extent of back-up and water table malfunctions was made during the EIS process.
                           The need of "suspect areas" for improved wastewater management facilities was
                           evaluated with due-caution.  Problems, other than surface malfunctions, were
                           not always deemed correctable via centralized sewerage facilities.  Localized
                           water table malfunctions can be corrected through the on-site system design,
                           construction, and maintenance provisions of the Small Flows District program.
ISSUE:
WATER QUALITY

Comment 1
oonoern over chlorine
concentration in
effluent
Response  1
Concern is expressed over residual  chlorine in Schoeneck Creek as a result
of effluent disinfection bv chlorination .at an upgraded Nazareth sewage
treatment plant (Alternatives 5 and 6), or the new RBC plant (Alternatives
9 and 10).  Treatment processes must achieve an effluent quality of a maximum
of 3 parts per billion (0.003 mg/1) chlorine.   [Miller]

Chlorination at the RBC treatment plant would produce an effluent with a
chlorine residual  of 0.01 mg/1.  After dechlorination, the residual chloride
concentration would be practically zero or below the detection limit.  With
the stream flow in Schoeneck Creek to provide additional dilution, the resi-
dual chlorine level should certainly be below the 0.003 mg/1 level specified
in the EPA red book for protection of the aquatic environment.  No chlorine
residual would result from the operation of the EIS Recommended Action:
Alternative 9.
Comment 2
source of  bacteria
and length of sample
period questioned
Response  2
More work should have been devoted in the Draft EIS to the identification
of different types of bacterial pollution in Bushkill Creek (and its tribu-
taries).  What is the source of the bacteria -- human waste or domestic
animals?  The Draft EIS conclusions about the source of bacteria in the
Bushkill Creek watershed are invalid because they are based on only 2 days
of sampling.  [Bradt]

The stream  sampling survey  (June  1979) was one of four programs undertaken
during  the  preparation  of the  Draft  EIS  to document the need for improved waste-
water management facilities  in the EIS Service Area.  It was not intended
to be a comprehensive water  quality  survey.  Such a  survey was unnecessary
in light of the availability of water quality data collected over a 7-year
period  (see Appendix E-3, Draft EIS).  Rather, its purpose was to comple-
ment the results of the most determinative needs documentation program--
EPA's remote sensing (via aerial  photography) and ground-checking of on-site
system surface malfunctions  throughout the EIS Service Area.  The remote
sensing/ground-checking program was  completed by the Agency's Environmental
Photographic Interpretation  Center (EPIC) in March 1979.  Needs documentation
data gathered by EPIC were determinative because they enabled EPA to pinpoint
the locations of on-site system failures.

Bacteriological  data was collected to address the question of whether the
sources of bacteria were human or non-human.   The technique selected was
analysis of both fecal  coliform and fecal streptococci.   Fecal coliform
bacteria are found in the intestines of all  warm-blooded animals but are
                                                   59

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Comment 3
STPs as nutrient sources
Response 3
 Comment 4
 decrease -in nutrients
 questioned

 Response 4
especially numerous in the human digestive  tract.   Fecal  streptococci  are
similarly numerous in the intentines of many  domestic  animals.   A  ratio  of
fecal coliform to fecal streptococci, therefore, may  indicate whether  the
dominant source is human or animal..  The  technique  provides  clear  results
only when the ratio is very high (human)  or very low  (animal).   Intermediate
values of the ratio are not decisive.

Ratios calculated from the June 1979 survey samples were  intermediate  but
generally closer to the low end of the range.  The  results,  therefore, are
inconclusive but suggest that non-human sources predominate.  Given this
information, and the much more specific data  from the  remote sensing/ground-
checking program, follow-up stream surveys  using the  bacteria ratio were not
conducted.


Both the Wind Gap and Nazareth sewage treatment plants  (STPs) are  potential
sources of nitrate in ground and surface waters that should  be examined
carefully.  [Bradt]

All of the available water quality data that  were analyzed during  the  prepara-
tion of the Draft EIS indicate no significant increase  in the concentrations
of nitrate nitrogen in Little Bushkill Creek  and Schoeneck Creek as a  result
of wastewater discharge from the Uind Gap and Nazareth  STP's, respectively.
However, a more pronounced increase in nitrate level  in Schoeneck  Creek and
Bushkill Creek would be expected as a result  of the nitrification  processes
at the new, or upgraded, Nazareth treatment plant.

This increase of nitrate concentration in  the receiving water would reach
approximately 7  mg/1  of nitrate nitrogen in Schoeneck Creek and 5 mg/1  in
Bushkill Creek under 7-day,  10-year low flow conditions.  This calculation
is based on a simple material  balance considering nitrate as a. conservative
substance in the short stretch of the receiving stream.  The calculated
nitrate levels,  although considered conservatively high, are less than  the
drinking water standard of 10 mg/1  nitrate nitrogen.  Therefore, nitrate
nitrogen in the surface water should not be a cause for concern; the need
for nitrogen removal  as part of any new treatment scheme for the Nazareth
STP does not appear to be warranted.


The Draft EIS states that nutrients in Bushkill Creek are decreasing.   This
statement is questioned in view of two long-term studies that indicate  a
doubling of nitrate and orthophosphate from 1973 to 1977.  [Bradt]

Comparison of nutrient data does show that orthophosphate, nitrate, and
ammonia levels along Bushkill  Creek generally decrease from  1972 and 1973
to 1979 during the summer months (see Appendices E-3, E-4, and E-9, Draft
EIS).

For example, the orthophosphate concentration in the summers of  1972 and
1973 ranged from 0.02 mg P/l to about 0.8 mg  P/l in Bushkill Creek  (Appen-
dices E-3 and E-4, Draft EIS).  During the  summer of  1979, the ortho-
phosphate levels ranged from 0.01 mg P/l to less than 0.2 mg P/l (Appendix
E-9, Draft EIS).  Ammonia nitrogen levels in  1972 and 1973 ranged  from
0.1 mg N/l to 0.5 mg N/l (Appendices E-3 and  E-4, Draft EIS).  On  the
other hand, EPA's 1979 survey shows that the  average ammonia nitrogen
concentration is 0.1  mg N/l  (Appendix E-9,  Draft EISJ.  Nitrate  levels
in Bushkill Creek in 1972 and 1973 were as  high as  12 mg  N/l, with most
of the measurements above 5 mg N/l  (Appendices E-3  and  E-4,  Draft  EIS;.
During the summer of 1979, nitrate concentrations were  all less  than
5 ng N/l along the Creek (Appendix E-9, Draft EIS).
                                               60

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Comment 5
limestone area wells
not sampled

Response 5
Ninety-six  percent of the wells sampled during the preparation of the Draft
EIS were in Bushkill Township -- what about the limestone area wells?  [Bradt]

The sampling of 27 domestic wells for water quality during June 1979 was
conducted on a strictly volunteer basis.  Ninety-six percent of the volun-
teers who wished to have their wells sampled were residents of Bushkill
Township.  The remaining 4% lived in Plainfield Township.

Many of the residents of the limestone areas (Nazareth Borough, Upper Nazareth
Township, Tatamy Borough, and Stockertown Borough) are connected to the Blue
Mountain Consolidated Water Company's water supply system and, therefore, do
not have private on-site wells.
Comment 6
Alternative 9
perpetuates deplorable
conditions -in
Schoeneck Creek

Response 6
The environmental state of Schoeneck Creek is deplorable, representing
classic indications of pollution.  No resolution of this stream pollu-
tion is recommended.  In fact, recommendations perpetuate the condition.
Bushkill Creek and Palmer Township unfortunately receive the unresolved
results.  [B-LLJSA]

Elimination of the four sewage bypasses at the existing Nazareth sewage treat-
ment plant would  significantly improve the quality of Schoeneck Creek.  The
upgrading and expansion of treatment facilities at the plant, proposed under
the EIS Alternative 9, would not only eliminate the  direct raw waste-
water discharges  (bypasses) to Schoeneck Creek, but also would achieve an
effluent quality  well within the discharge limitations prescribed by DER of
20 mg/1 BOD, 25 mg/1  suspended solids, and 3 mg/1 ammonia nitrogen.  These
discharge limitations must be met on a monthly average basis.  With proper
design, operation, and maintenance,  either the  RBC plant or  the OD  plant would
achieve an effluent quality on a daily average basis that is better than that
prescribed by DER.
Comment 7
Bushkill Creek needs
protection from future
stress
Response  7
Trout  habitat  is  rapidly disappearing from the northeast.  The preservation of
Bushkill Creek as a stream supporting reproducing trout must be insured.  The
pollution  of groundwater and surface water from bacteria and nutrients must be
prevented.  The stream  is still recovering from the stress of its rechanneling
in the  late 1960s.  Bushkill Creek does not need any further stress from point
and non-point discharges.  [Bradt]

Comment noted.  The protection of Bushkill Creek's naturally reproducing trout
habitat over the  life of the project precipitated the planning of a force main/
pump station system along Tatamy Road.  On the average, this system would be
separated  from Bushkill Creek by a distance of approximately one-half mile.
This minimizes siltation during project construction, and reduces non-point
source  pollution  after  construction by concentrating sewer-induced development
away from  the  Creek.
ISSUE:
LAND USE

Comment 1
Northern Corridor, not
zoned residential

Response 1
Contrary to what is stated in the Draft EIS, the area to be served by the
Schoeneck Creek interceptor  (under the APA) Is not zoned residential but
commercial-industrial.  [Kennedy, Daws, Walters].

The Draft EIS did not state that the northern, currently unsewered, part
of Palmer Township is zoned residential.  The zoning map on page 177,
Draft EIS Appendices, illustrated the existence of three different zoning
districts in this portion of the Township in the EIS Service Area.  They
include:
                                                 61

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                            t  R-l  -  low density  residential
                            •  RA     rural agricultural
                            «  PIC    planned  industrial-commercial.

                            The R-l  district is bounded by Northwood Avenue, Schoeneck  Creek,  and  Bushkill
                            Creek and permits residential development at a density of one dwelling unit
                            per 20,000 square feet.  The RA district in the northwestern and northeastern
                            parts of the Township has agriculture as its major land use.  The  primary
                            permitted use in this district, defined in the Palmer Township Zoning Ordi-
                            nance (Chapter 55), is single-family dwellings on lots of not less than
                            30,000 square feet.

                            The PIC zone is bounded by Route 33, Tatamy Road, Northwood Avenue, and
                            Schoeneck Creek; its purpose is to provide sufficient space to meet regional
                            needs for large-site commercial and industrial developments.  A special excep-
                            tion use permitted in this district is home occupation, the major existing
                            land use, along with agriculture.  The Code of the Township of Palmer, Chapter
                            36A, Planned Residential Development, encourages innovative residential devel-
                            opment within the PIC district.  Under a curative amendment, the Brenton
                            Village subdivision currently  proposes 358 townhouse units  on 54 acres in
                            the PIC area.   It is anticipated that if sewer service capacity were
                            introduced into this area with the limited amount of commercial and industrial
                            subdivision proposals on record, additional curative amendments, downzoning,
                            and resultant residential development would occur.

                            An R-2, medium-density residential district lies immediately south of North-
                            wood Avenue, on the southern border of the EIS Service Area.  It is added to
                            the list of zoning districts addressed in the EIS because modifications in
                            the conveyance system along Tatamy Road near Penn Pump Park could induce
                            development within its boundary.

                            In sum, the EIS has addressed areas that have been zoned residential as well
                            as areas which, though zoned either RA or PIC, can legitimately support
                            single family or multi-family housing.
Comment 2
•prime agricultural
land overstated
Response 2
The estimated amount of prime agricultural land in the EIS Service Area
has been overstated by approximately 15% in the Draft EIS.   [Munkittrick]

Comment noted.  See appropriate revisions in Sections III.A.I,  III.B.2, and
III.D.I of the Final EIS.
Comment 3
JPC would agree with
partial deletion of
Bushkill interceptor
from B-LLJSA project

Response 3
The Joint Planning Commission, Lehigh-Northampton Counties  (JPC) would agree
with the ElS-deletion of the Bushkill Creek interceptor extension north from
Stockertown into and beyond Jacobsburg State Park.  If the  Commission had
not assumed that the B-LLJSA sewer project would be built,  these areas would
not have been recommended for urban development.  [O'Dell]

Comment noted'.
ISSUE:
ALTERNATIVES

Comment 1
opposition to spray
irrigation in
Plainfield Township
Several citizens of Plainfield Township, including farm owners and local
government representatives, are opposed to the concept and  implementation of
spray irrigation on valuable farmland.  On 18 February 1980, the  Plainfield
Township Planning and Zoning Commission passed a resolution opposing any of
the alternatives presented in the Draft EIS involving a spray irrigation
system in Plainfield Tonwship.  [R. Lieberman, E. Lieberman, Nagel]
                                                   62

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Response  1:
None of the five alternatives involving the use of spray irrigation systems in
the Draft EIS were determined to be cost-effective approaches to meeting the
w'astewater management needs of Plainfield Township or of any other municipality
in the EIS Service Area.  The present-worth costs of all spray irrigation al-
ternatives were too high to be recommended and funded by EPA for implementation
(even with the 115% cost preference given innovative and alternative technolo-
gies).  The well-documented advantages of spray irrigation systems across the
nation, as well as their potential advantages in the EIS Service Area, justified
the development and evaluation of spray irrigation alternatives in the Draft EIS.
These advantages include the recycling of water and nutrients for productive
(crop) uses, low consumption of chemicals, low generation of sludge, preserva-
tion of large open-space areas with potential for multiple recreational  use
during non-irrigation seasons, and lower operating costs than other systems with
the equivalent degree of treatment.
Comment 2:
water quality protection
guarantees

Response 2:
What are the guarantees that land application systems, cluster systems, and other
sewage treatment facilities will protect the surface water and groundwater from
nitrate and bacterial contamination?  [Bradt]

If properly designed, constructed, operated, and maintained, these wastewater
management systems will protect the local water resources from nutrient and
bacterial contamination.  Land application (spray irrigation) systems, providing
the equivalent of tertiary treatment, were not recommended for implementation in
the EIS Service Area on the basis of the cost-effectiveness analysis (see above).
Bacterial and nutrient contamination of surface water from new treatment plants
serving the Nazareth Service Area should be insignificant if these facilities
are constructed and operated in compliance with standards set by the Pennsylvania
DER.

Detailed hydrogeologic investigations of any recommended cluster system (commu-
nity drainfield) sites must be conducted before an assessment of the reliability
of these systems can be made.  These site investigations, which include detailed
soils mapping, permeability tests, test borings, in-situ hydraulic testing, and
as necessary, laboratory hydraulic testing , will be required prior to approval
and installation of the systems.  Key requirements for maximizing the reliability
of cluster systems with regard to water quality protection include:

•  Well-planned and -executed site analysis

•  Measurement of and designing with the natural assimilative capacity of
   local soil and groundwater resources

•  Provision of adequate community supervision of the installation, opera-
   tion, and maintenance of the cluster systems.

The preliminary design of cluster treatment systems in the Draft EIS focused on
providing system components that mitigate the potential for nutrient and
bacterial contamination of groundwater and, ultimately, surface water.  These
components .(for each system) are:

•  Common septic tank (minimum 3,000 gallons)

•  Dosing pump to control septic tank effluent flow to drainfields  and
   insure effluent distribution to be the entire drainfield.

•  Alternate drainfield area as backup and to allow resting of the primary
   drainfield.

Suggested procedures and criteria for designing community drainfield  systems
that may be followed during Step II design efforts were included in Appendix
L-l of the Draft EIS.  These procedures alone will not guarantee water
                                                  63

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Comment 3
gravity sewer leaks vs.
pressure sewer leaks
Response 3
 quality protection.   As indicated above, qualified supervision of installa-
 tion,  operation,  and maintenance of cluster systems will significantly reduce
 the potential  for water quality contamination by sewage-associated bacteria
 and nutrients.


 When comparing  a  gravity interceptor to a pressure interceptor, considering
 breaks, cracks, etc., it is pertinent to note that a gravity interceptor
 leaks  inward (i.e.,  into the line), whereas a pressure line leaks outward
 causing pollution of a given area.   The fact that a gravity line leaks inward
 is illustrated  by EPA regulations requiring infiltration/inflow studies and
 remedies.   [Wolfe]

 Exception  must  be taken to the comment, because gravity lines can leak into
 the surrounding soil, depending on  the hydraulic pressure and/or soil mois-
 ture content.   In a  very dry soil,  wastewater may leak directly because of
 faulty joints,  root  intrusion, illegal connections, etc.  Gravity line leaks
 are difficult  to  detect, difficult  to locate, and in the case of deep gravity
 lines, expensive  to  repair.  Another symptom of a gravity line leak is the
 flowing of extraneous water into the sewer.  The first indication of a severe
 infiltration/inflow  problem in a gravity sewer system is usually an overflow-
 ing manhole.  Raw sewage has been known to spill into Little Lehigh Creek
 after manholes  overflowed (By telephone, Mr. Fred Mussel, Waterways Patrolman,
 Pennsylvania Fish Commission, 3 June 1980).

 Force mains are constructed of pressure pipe that results in few joint fail-
 ures and no root  intrusion.  Leaks  in force mains are quickly suspected due
 to drop in pressure  and increased pumping time.   Because force mains are
 constructed close to the surface, leaks are easily located and inexpensively
 repaired.   As  with any sewage collection and treatment system, it is hoped
 that a B-LLJSA  system will be maintained properly and thus will not leak.
Comment 4
limit sewer along/
across streams
Response 4
 Sewer lines that parallel  and cross streams should be limited to those abso-
 lutely required.  [Jones]

 Comment noted.   The EIS  Recommended Action (Alternative 9) eliminates the
 gravity sewers  along Schoeneck Creek and Bushkill Creek.
Comment 5
soil 'Limitations for
on-site systems over-
stated

Response 5
 The Draft EIS overstates the soil  limitations for on-site wastewater treat-
 ment systems (see Figure  III-4)  through the use of broad geological data.
 This suggests unjustifiably that  there are irreconcilable soil restrictions
 which preclude the use of such systems.  [DiGerlando]

 The discussion and illustration in the Draft EIS of soil limitations for
 on-site wastewater management in  the Service Area explicitly states (pages
 38 and 29) that such limitations  -- slight, moderate, and severe -- apply
 only to standard or conventional  septic tank-soil absorption systems
'(ST/SAS).  They do not apply to alternate effluent disposal systems includ-
 ing elevated sand mounds, sand-lined trenches and beds, oversize areas, and
 shallow placement areas.  Therefore, the EIS does not suggest that the use
 of all on-site systems is precluded in areas, such as Cherry Hill, where the
 soils are reported to have severe limitations for standard ST/SAS.  The
 Draft EIS concluded that the Cherry Hill vicinity could be served best by _
 both rehabilitated standard ST/SAS, where feasible, and by alternate on-site
 systems under the Phase II wastewater management scheme (see page 161 of the
 Draft EIS).  It is emphasized that the use of alternate systems is restricted
 to those areas where local site conditions are appropriate to the technology.
 The suitability of soil, slope, and area for on-site treatment will be
 determined during the detailed design phase of this project  (Step II).
                                               64

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Comment 6
relationship of East
Laum area to Nazareth
Borough
Response 6
 Tne fate of the Upper Nazareth Township East Lawn area is tied inseparably to
 Nazareth Borough because of economic,  social, and physical  reasons such
 as  schools, the YMCA, community parks, garbage disposal,  sports programs,  and
 cooperation of police and fire departments.   Therefore, nothing should  deter
 their collaboration in a sewage collection and treatment  system.   [Schweitzer]

 Comment noted.   This phenomenon underlies EPA's development of Alternatives
 5,  6, 9, and 10 -- all of which involve the treatment of  East Lawn area sewage
 flows at a new or upgraded/expanded Nazareth sewage treatment system.   It  was
 also an important consideration in the selection of the  EIS Recommended Action
 (Alternative 9).
 Comment 7
 aost of new BBC-type
 Nazareth STP grossly
 understated
 Response 7
Comment 8

inadequate  discussion
of Easton wastewater
management  system
expansion
Response  8
 The cost of a new Nazareth STP (RBC plant)  was grossly understated  by almost
 $3 million.  [B-LLJSA]


 The total capital expenditure associated with constructing  a new RBC plant to
 replace the existing Nazareth STP has been  revised from $1.32 million to
 $2.94 million.   The $1.62 million increase  in capital  costs for  the Nazareth
 RBC plant is attributed principally to:   (1)  the substitution of conventional,
 more costly wastewater treatment facilities (for example,  preliminary treat-
 ment and primary clarifiers) for innovative/alternative, less costly facilities
 (for example, wire screens); (2) recosting  of the RBC component; (3) addi-
 tional excavation and backfilling costs; (4)  provision for  additional  yard
 piping; and (5) increased effluent disinfection costs.  Components  of the
 $2.94 million (capital) RBC plant are illustrated in Figure IV-1.   A detailed
 breakdown of revised RBC treatment plant component costs is furnished in
 Section 4.3.2 of the "Engineering Evaluation  of the Draft  EIS" (Appendix  D-3).

 In the Draft EIS, the Easton STP is presented as a mere plant expansion from
 5 million gallons per day  (mgd) to 10 mgd capacity with a change in processing
 from trickling filters  to  rotating biological  discs.  The EIS completely
 ignores the construction of other sewerage facilities which are essential
 to the operation  of the expanded and upgraded Easton STP.  Such construc-
 tion includes the doubling in size of two large pump stations, the emplace-
ment of two inverted siphons on Bushkill  Creek in addition to one across
 the Lehigh  River, and the  enlargement of interceptors to 42 inches in diameter.
 [B-LLJSA]

The Easton wastewater management facilities referenced in the comment were
not at issue in the Draft  EIS because they were constructed under an EPA
grant to the City of Easton, not to the B-LLJSA (see Assumption 1, page 7).
 EPA, in this EIS, has focused on wastewater management facilities in the
B-LLJSA which are planned  in the Environmental Assessment (1976), designed
per the B-LLJSA's detailed drawings and plot plans, and costed per con-
struction bid sheets submitted to EPA by the Applicant in 1977.  These
data, which were reviewed  and analyzed by EPA, do not themselves include
the Easton wastewater management facilities.

The local share (after  Federal grants) of the capital costs associated with
the expansion/upgrading of the Easton STP and the enlargement of sewage
transport facilities in Easton -- $1.3 million -- was estimated in the
Draft EIS as part of an overall B-LLJSA project cost (pages 125 and 239 of
the Draft EIS).  This overall B-LLJSA project cost, which must be borne
entirely by local government, was estimated to be $2.2 million.  The charge
that would be levied on B-LLJSA system users in order  to retire the $2.2
million debt was estimated to be $70 per household per year.   It is clear
                                                65

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Comment 9
segmental cost-
effectiveness
required
I 
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management plans evaluated  in  the  Draft EIS have been  discussed (see Sections
III.B.4  and III.D.3).

A comparison  of unit costs  used  by the  Applicant to determine  B-LLJSA project
construction  costs and by EPA  to determine construction costs  for the APA,
MAPA, and  ten alternatives  in  the  Draft EIS is presented  in  Table VI-1.   The
table focuses on several sewerage  components (gravity  sewer, force main, etc.)
which are  common to all wastewater management plans evaluated  in  the EIS.  The
construction  bids received  by  the  B-LLJSA in the second quarter of 1977 were
inflated  in the EIS to values  representing conditions  in  the third quarter of
1977 --  the period during which  EPA costed the APA, MAPA, and  EIS alternatives.
While B-LLJSA and EIS unit  costs  (3rd Q '79} appear to be similar, it is
important to note that they reflect two different levels  of  design detail.
The Applicant's costs are based  on detailed survey of  proposed sewer routes.
They also  include coverage  for construction activities required to overcome
unpredictable site conditions  (rock blasting, highway  pavement replacement,
utility  adjustment, etc.).   Unit costs  in typical EISs are not based on detailed
survey of sewer routes and  do  not  include local contingencies  such as blasting,
etc.  Typical unit costs from  the  greater Easton area were applied uniformly
to all wastewater management plans evaluated in the Draft EIS, including the APA,
thereby  insuring comparability among the plans.  For further discussion, see
Section  III.B.4.

During preparation of the Final  EIS, new cost information for  the APA,  MAPA, and
EIS ALternative 9 was developed  using unit costs adapted  from  B-LLJSA bid sheets.
All wastewater management plans were recosted using the same unit costs.  Revised
unit costs now include provision for local construction contingencies,  such as
highway  pavement replacement,  blasting, etc.  Although this  level  of effort is
outside  of the scope of a typical  EIS,  EPA developed this new  cost information
in response to local and state concerns.


 Table VII-1.  Comparison of B-LLJSA  and  EIS  construction  costs  for sewers,
 stream crossings,  and manholes.
Item
8" gravity sewer
10" gravity sewer
12" gravity sewer
15" gravity sewer
18" gravity sewer
21" gravity sewer
24" gravity sewer
30" gravity sewer
6" force main
8" force main
B-LLJSA
Units
$/ft Contract 1
Contracts 4, 5, 6
$/ft Contract 1
Contract 2
Contract 3
Contract 4,5,6
$/ft Contract 1
Contract 3
$/ft Contract 1
Contract 2
$/ft Contract 2
$/ft Contract 2
Contract 3
$/ft Contract 2
Contract 3
$/ft Contract 2
$/ft Contract 1
$/ft Contract 1
2nd Q '77'
$16.94
20.66
16.42
24.75
20.22
29.97
18.57
18.73
20.55
27.96
33.09
38.85
25.57
37.16
28.93
48.36
15.60
18.00
3rd Q '792
$21.45
26.20
20.82
3K38
25.64
38.00
23.55
23.75
26.11
35.45
41.96
49.26
32.42
47.12
36.68
61.32
19.78
22.82
EIS
3rd Q '793
$19
21
24
28
34
4S
60
110
12
14
   Weighted average of unit costs from "Part B Submittal" sheets.  (ERA Form 5780-1B), dated
   26 August 1977; low-bidder construction costs included therein are dated Hay 1977.

   ^Low-bidder construction costs have been inflated to September 1979 costs -- period in which
   APA, MAPA, and EIS Alternatives were costed -- for the sake of comparability.  Source for
   3rd Q '79 figures:  "Construction Cost Indexes," 4th Quarter 1979, USEPA, Office of Water
   Program Operations.

   3These figures were used to cost the APA, MAPA, and EIS Alternatives 1 to 10 in September
   1979.
                          67

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                            Table  VII-1.  Comparison of B-LLJSA and  EIS  construction costs  (continued).
Item
stream crossing



manhole (MH)



















B-LLJSA
Units
$/each:
Contract 1
Contract 2
Contract 3
$/each:
Contract 1 :
MH walls
MH bases
MH frames/ covers
Additional cost

Contract 2:
MH walls (41 dia.)
MH walls (51 dia.)
MH bases
MH frames/covers
Additional cost

Contract 3:
MH walls
MH bases
MH frames/covers
Additional cost

2nd Q '771

2,500-5,000
6,000-21,000
3,700-8,300


56.00
350.00
170.00
70.00
646.00

40.00
55.00
320.00
150.00
110.00
675.00

30.00
100.00
100.00
50.00
280.00
3rd Q '792

3,170-6,340
7,608-26,628
4,692-10,524






819.00






856.00





355.00
EIS
3rd Q '793

5,800


A
700


















                                 This is an average cost for a manhole.  It includes costs for manhole walls, bases, frames,
                                 covers, and additional cost for ensuring water tightness, but does not include manhole drop
                                 connections.
Comment 11
JPC agrees with decen-
tralized wastewater
management for lew-
density areas suah as
Cherry Hill
Response 11
JPC agrees with  the  concept of examining alternate methods  of sewage disposal
in lightly developed areas  with malfunctioning septic  systems instead of
extending a regional  sewer  system into these areas.  This  comment would apply
to portions of the EIS  Service Area such as Cherry Hill, and the portions of
Plainfield Township  north of Belfast.  [O'Dell]

Comment noted.
Comment 12
floodplain regulations
need to be observed in
siting new Nazareth STP
Response 12
The floodplain  regulations set by the Delaware River  Basin  Commission and
Pennsylvania DER  should be reviewed before a new Nazareth STP is located.
These regulations  do  not allow any construction in  the  "flood way" and
require that any  wastewater treatment plant or pump station in the "flood-
plain" be operable under 100-year flood conditions.

EPA believes that the new treatment plant should be located outside of the
designated 100-year floodplain.   However, the exact location of the new treat-
ment facilities would be determined by local officials  during the preparation
of a Step I facilities plan for Nazareth Borough.

The EIS has considered both the cost of building a  new  STP  outside of the
100-year floodplain li-e., cost of new land) and the  cost  of flood proofing
a new STP at approximately the same location as the existing Nazareth STP
through construction  of a flood protection berm (dike)  and  an outfall line
(see Figure IV-2).   If the local officials choose to  locate the new plant
                                                    68

-------
management plans evaluated  in  the Draft EIS have been  discussed (see Sections
III.B.4  and III.D.3).

A comparison  of unit costs used  by  the  Applicant to determine  B-LLJSA project
construction  costs and by EPA  to determine construction costs  for the APA,
MAPA, and  ten alternatives in  the Draft EIS is presented  in  Table VI-1.   The
table focuses on several sewerage components (gravity  sewer, force main, etc.)
which are  common to all wastewater  management plans evaluated  in  the EIS.  The
construction  bids received by  the B-LLJSA in the second quarter of 1977  were
inflated in the EIS to values  representing conditions  in  the third quarter of
1977 --  the period during which  EPA costed the APA, MAPA, and  EIS alternatives.
While B-LLJSA and EIS unit costs (3rd Q '79) appear to be similar, it is
important  to  note that they reflect two different levels  of  design detail.
The Applicant's costs are based  on  detailed survey of  proposed sewer routes.
They also  include coverage for construction activities required to overcome
unpredictable site conditions  (rock blasting, highway  pavement replacement,
utility  adjustment, etc.).  Unit costs  in typical EISs are not based on  detailed
survey of  sewer routes and do  not include local contingencies  such as blasting,
etc.  Typical unit costs from  the greater Easton area were applied uniformly
to all wastewater management plans  evaluated in the Draft EIS, including the APA,
thereby  insuring comparability among the plans.  For further discussion, see
Section  III.B.4.

During preparation of the Final  EIS, new cost information for  the APA, MAPA, and
EIS ALternative 9 was developed  using unit costs adapted  from  B-LLJSA bid sheets.
All wastewater management plans  were recosted using the same unit costs.  Revised
unit costs now include provision for local construction contingencies, such as
highway  pavement replacement,  blasting, etc.  Although this  level  of effort is
outside  of the scope of a typical EIS,  EPA developed this new  cost information
in response to local and state concerns.
 Table VII-1. Comparison of B-LLJSA and EIS  construction costs for sewers,
 stream crossings,  and manholes.
Item
8" gravity sewer
10" gravity sewer
12" gravity sewer
15" gravity sewer
18" gravity sewer
21" gravity sewer
24" gravity sewer
30" gravity sewer
6" force main
8" force main
B-LLJSA
Units
$/ft Contract 1
Contracts 4, 5, 6
$/ft Contract 1
Contract 2
Contract 3
Contract 4,5,6
$/ft Contract 1
Contract 3
$/ft Contract 1
Contract 2
$/ft Contract 2
$/ft Contract 2
Contract 3
$/ft Contract 2
Contract 3
$/ft Contract 2
$/ft Contract 1
$/ft Contract 1
2nd Q '771
$16.94
20.66
16.42
24.75
20.22
29.97
18.57
18.73
20.59
27.96
33.09
38.85
25.57
37.16
28.93
48.36
15.60
18.00
3rd Q '792
$21.4.5
26.20
20.82
3K38
25.64
38.00
23.55
23.75
26.11
35.45
41.96
49.26
32.42
47.12
36.68
61.32
19.78
22.82
EIS
3rd Q '793
$19
21
24
28
34
4S
60
110
12
14
   Weighted average of unit costs from "Part B Submittal" sheets.  (EP,A Form 5780-1B), dated
    26 August 1977; low-bidder construction costs included therein  are dated May 1977.

   ^Low-bidder construction costs have been inflated to September 1979 costs -- period in which
    APA, MAPA, and EIS Alternatives were costed -- for the sake of  comparability.  Source for
    3rd Q '79 figures:  "Construction Cost Indexes," 4th Quarter 1979, USEPA, Office of Water
    Program Operations.
    1979.
        figures were used to cost the APA, MAPA, and EIS Alternatives 1 to 10 in September
                          67

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                            Table VII-1.  Comparison of B-LLJSA and  EIS  construction costs (continued).
Item
stream crossing



manhole (MH)




















B-LLJSA
Units
$/each:
Contract 1
Contract 2
Contract 3
$/each:
Contract 1 :
MH walls
MH bases
MH frames/covers
Additional cost

Contract 2:
MH walls (41 dia.)
MH walls (51 dia.)
MH bases
MH frames/covers
Additional cost

Contract 3:
MH walls
MH bases
MH frames/covers
Additional cost


2nd Q '7?1

2,500-5,000
6,000-21,000
3,700-8,300


56.00
350.00
170.00
70.00
646.00

40.00
55.00
320.00
150.00
110.00
675.00

30.00
100.00
100.00
50.00
280.00

3rd Q '792

3,170-6,340
7,608-26,628
4,692-10,524






819.00






856.00





EIS
3rd Q '7g3

5,800


/
700*







1
i








355.00
i.
                                 This is an average cost for a manhole.  It includes costs for manhole walls, bases, frames,
                                 covers, and additional cost for ensuring water tightness, but does not include manhole drop
                                 connections.
Comment 11
JPC agrees with decen-
tralized wastewater
management for lew-
density areas suah as
Cherry Hill
Response 11
JPC agrees with the  concept  of examining alternate methods  of sewage disposal
in lightly developed areas with malfunctioning septic  systems instead of
extending a regional  sewer system into these areas.  This comment would apply
to portions of the EIS  Service Area such as Cherry Hill, and  the portions of
Plainfield Township  north-of Belfast.   [O'Dell]

Comment noted.
Comment 12
floodplain regulations
need to be observed in
siting new Nazareth STP
Response 12
Tne floodplain  regulations  set by the Delaware River  Basin  Commission and
Pennsylvania DER  should  be  reviewed before a new Nazareth STP is located.
These regulations  do  not allow any construction in  the  "flood way" and
require that any wastewater treatment plant or pump station in the "flood-
plain" be operable under 100-year flood conditions.

EPA believes that  the new treatment plant should be located outside of the
designated 100-year floodplain.   However, the exact location of the new treat-
ment facilities would be determined by local officials  during the preparation
of a Step I facilities plan for Nazareth Borough.

The EIS has considered both the cost of building a  new  STP  outside of the
100-year floodplain (i.e.,  cost of new land) and the  cost of flood proofing
a new STP at approximately  the same location as the existing Nazareth STP
through construction  of  a flood protection berm  (dike)  and  an outfall line
(see Figure IV-2).  If the  local  officials choose to  locate the new plant
                                                    68

-------
Comment  13
varying  peak factors
should be used in
sizing interceptors
Response 13
                            outside of the floodplain, then $120,000   is  added to the rest of the plant
                            components to cover the purchase of  land.   If the existing site is used,
                            a floodproofing dike and new outfall  line  can be constructed for $70,000.
                            This cost would be substituted for the  land cost if the existing site is
                            retained.9
When sizing interceptor  sewers,  varying peak factors, according to  load condi-
tions, should be used  instead  of an assumed constant peaking factor of 2.5.


The variability of wastewater  flows in the Service Area under any wastewater
management plan has  been accounted for in the estimation of average daily
flow.  Average daily flows  for individual communities in the Service  Area
are determined, on the basis of  several conditions,  including type  of
housing,  age  of  system,  and amount of  commercial  and/or industrial  develop-
ment in the community.   A peak factor of 2.5, which is well-documented in  the
literature, is then  applied to the variable average daily flow to determine
the size  (diameter)  of an interceptor or outfall sewer.  It is not  necessary
to provide for additional flow variability given the relatively low quantities
of commercial and industrial flow generated in the Service Area.

Peak daily flow factors  for interceptor or outfall sewers are recommended  to
be 2.5 by several authorities  including the following:
                            1.
                            2.
     "The Federal  government has set minimum average design flows at 75  gpcd.
     On this  basis,  laterals are designed for a peaking factor of 4.0, and
     outfall  sewers  are  designed for a peaking factor of 2.5."

     Source:   Metcalf &  Eddy, Inc.   Wastewater Engineering.  McGraw-Hill  Book
               Co,  New York  NY,   782 p,

     "Laterals and minor sewers  shall be designed, when flowing full, assuming
     flows equivalent to 4 times the average daily per capital flow.  Main
     trunck,  interceptor, and outfall sewers shall be designed to convey
     expected peak flow  equivalent to 2.5 times the average daily per capital
     flow."
                                 Source:  Texas  Department of Health.
                                          TDOH.  Austin  TX.   63 p.
                                            Design Criteria for Sewerage  Systems.
  In 1971, the Nazareth  STP  had  an  assessed value of $6,000 per acre, baser* on
  its designation as  "commercial  property" (By telephone, Roslyn Kahler, NCCD, from
  Colar-Trumble, Inc., 23 April  1980).   This land value has been inflated to
  reflect 1980 economic  conditions.

  The calculations below present  the  costs associated with (a) floodproofing of
  the plant site and  (b) construction of an outfall  line.

             (a)   Flood protection berra (dike):
                  Length   1,200 ft.
                  Area     (50 + 20)

                  Volume =  1-2003
                                                                 35Qft.


                                                               15.556 cy.
                                              Embankment Cost:  Dec. 79/Mar 75  3,140/2,128   1.48 factor

                                                         1.48 x $2.50/cy. x 15,556 cy.  $58,000.
                                         (b)   Outfall pipe:
                                              12" pipe @ $32.81/ft. x 250'
                                         TOTAL:  Floodproofing and outfall   $66,203
                                                                     $0.07 million
                                                    69

-------
                            3.    Page 20-2 of the ten States standards presents a graph which suggests
                                 using a peak factor of 3.0 when the design population is 10,000 persons.
                                 However, the ten states standards make no distinction in peak flows for
                                 laterals or interceptors.
Comment 14
Route 225:  dual
versus single sewer

Response 14
The placement of a deep sewer in the center of Route 115, as proposed in the
EIS Recommended Action, instead of along the sides of the road raises serious
questions as to the financial feasibility of the project.  [Maher]

EPA agrees with the Pennsylvania DER's recommendation that the issue of dual
sewer versus single sewer along Route 115 (including the depth of a single
sewer) would be more appropriately resolved during Step  II of  this  project
when more detailed site and design information is available  (By letter,
Clifford Jones, Secretary, Pennsylvania DER, 3 April 1980).  In its resolu-
tion of this issue during Step II, the Applicant could consider the feasibility
of multiple house-to-sewer connections (to minimize road cuts) and the feasi-
bility of boring house-to-sewer connections beneath the roadway (to eliminate
road cuts).  A typical  single sewer serving Route 115 is illustrated below.
                                                                                  (NOT TO SCALE)
Comment 15
opposition to oluetev
systems in Plainfield
Township
Response 15
Figure VI-1.  Typical sanitary sewer service  (single sewer).


We oppose the prospect of cluster-type sewer  systems in Plainfield Township.
We wish our area to remain rural and do not want sewage pumped to valuable
farmland.  Sewers induce development which, in turn, overtax our public
services and fiscal resources.  The following questions regarding cluster
systems need to be addressed:  What odor and  water quality  problems are asso-
ciated with cluster systems?  Can normal farming operations (planting, grazing,
plowing, etc.) be conducted over a cluster system?  What  are the land  (area)
requirements of a cluster system?  How is land acquired for a cluster  system?
Is it just condemned?  [Roth, Sparrow, Schreck]

EPA's development of decentralized wastewater management  alternatives  which
propose the use of cluster (community) treatment systems  was pursued in the
interest of preserving rural farmland and cost-effectively  solving the waste-
water management problems of remote areas.  Cluster systems for small  groups
of homes can usually meet the sewage treatment needs of small lots without
the large expense of a municipal or regional  sanitary  sewer.  For community
systems installed in Minnesota, the cost per  lot has been approximately the
same as for adequately sized on-site treatment systems (Machmeier 1977).

The number of homes to be served by a cluster system is usually decided by
local government officials during Step II.  Therefore, reserve capacity of
these systems, and hence induced development, can be controlled.
                                                      70

-------
                           The water quality considerations associated with cluster sytsems were dis-
                           cussed on page63 .   Odor problems associated with community treatment
                           systems are no greater than those associated with on-site systems.  Because
                           the cluster systems proposed in the EIS involve the use of one large septic
                           tank, instead of individual septic tanks, to serve individual homes, any
                           odor problems are minimized.  Proper maintenance of the septic tank, includ-
                           ing pump-out of solids as required, should eliminate odor problems.  The
                           provision of a dosing pump  (to insure distribution of septic tank effluent
                           to the entire drainfield) and an alternate drainfield (to allow resting of
                           the primary drainfield) are also measures proposed by EPA which should
                           prevent clogging of the cluster system's drainfield component and, hence,
                           any odor problems.

                           Typical farm operations, including the planting of trees, the grazing of
                           domestic animals,-and the driving of heavy vehicles, should not be permitted
                           over cluster treatment systems under any weather conditions.

                           The land area requirements  for a cluster system designed in the EIS to serve
                           approximately 20 homes is typically less than four acres.  The size of the
                           cluster system soil treatment units is based on the percolation rate of the
                           soil and the estimated total daily sewage flow.

                           Land for cluster systems can be acquired through purchase or other coopera-
                           tive agreement between land owners and the local municipality, or through
                           the power of eminent domain if it is established that the acquisition of
                           such land is in the best interest of all citizens in the municipality.  Ease-
                           ments may be required for cluster system maintenance operations.  Design,
                           operation, and maintenance  of cluster systems (Machmeier 1976) are discussed
                           in Appendix D-6.
 ISSUE:
 INDUCED GROWTH

 Comment 1
justification  of
economic transport
 distance

 Response 1
Explain the rationale behind an economic transport distance of 4,800
feet--the distance from an interceptor that a subdivision developer would
find economically justifiable to build a trunk sewer serving a new 100-
house development [B-LLJSA].

The estimation of an "economic transport distance" was presented to indicate the
amount of land area "opened up" to new development by the installation of new
sewers.  The actual number of 4,800 feet is hypothetical because it is based on
an assumption which, in fact, will vary considerably from one developer to
another and from one site to another.  The exercise is based on a very real
economic factor, however.  A developer makes decisions to buy land and build on
it depending on how much profit he expects to make.  His profit depends on his
cost to build and the price people are willing to pay.  While sewerage costs
are only a part of the cost to build, they can be exhorbitant.  Consider the
builder who wants to'develop 100 lots at the foot of Blue Mountain.  His cost
for sewerage includes hook-up fees, facilities which he must build in any case,
i.e., house sewers and collector sewers on his properties, and facilities which
depend on his development's distance to a public sewer.  Under present conditions,
he would have to build his own sewer to Easton or to an adequate sewage treatment
plant, both of which would probably increase his total cost to build above the
price people are willing to pay.

On the other hand, if public sewers are present at the boundary of his proposed
development, his sewerage cost is at an absolute minimum.  He has no extra trans-
port cost and no new treatment, pi ant costs.

In between the two extremes,  there fs a maximum incremental cost (marginal cost)
that a developer could profitably pay for sewage transport.  The marginal cost
will be determined by all of his other costs, his expected sale price, and his
desired profit.  In order to illustrate the constraint that this marginal cost
                                                     71

-------
                            places on the location of new developments relative to a  proposed  sewer system,
                            a marginal  cost of $1,000 per lot ($100,000 for 100 lots) was  assumed  and con-
                            verted to the length (4,800 feet).

                            Many factors could increase or decrease the economic transport distance for any
                            given parcel of land, or any developer's specific proposal.  The analysis,
                            however, is felt to be conservative (we expect the marginal cost to be higher
                            than $1,000 in many parts of the EIS Service Area), and it serves  the  purpose for
                            which it was intended:  to relate the configuration of new, publicly funded sewers
                            to the land area that could be developed because of public sewer availability.
Comment 2
force main versus
gravity system

Response 2
A reassessment of induced growth is needed  in view  of  the  fact  that it  is not
that much more difficult to connect to a pressure system than  it  is to  connect
to a gravity system.  [Jones]

This comment can be addressed through a consideration  of costs  requires to serve
single households or residential subdivisions with  sewer service  by tying into
gravity sewers or force mains.  For serving a single family  residence,  the cost
of tying into a force main is approximately 500% more  expensive than tying into
a gravity sewer.  This means that single unit structures will not develop along
Tatamy Road (location of force main) as will occur  adjacent  to  a  gravity sewer
along/in Bushkill Creek.  Planned multi-unit facilities could develop along
Tatamy Road.  However, the multi-unit facilities must  be occupied rather simul-
taneously.  Otherwise, what does the person who buys the first  house do for
sewer service while waiting on the sale of  199 houses  and  activation of the lift
station?  With a force main along Tatamy Road, cluster development along Bushkill
Creek will be limited if not non-existent.  The 3,500  linear feet of force main
required to serve cluster developments along Bushkill  Creek  would cost  an addi-
tional $70,000 to $90,000.

Cost of Serving One Household

a.   Gravity Sewer:  The cost here consists of a property  owner paying
     for his house lateral (4" PVC) and a tap fee.  The developer or
     municipality will pay for a 6" x 8" tee at the sewer  main, approxi-
     mately 30' of 6" service lateral, and  1/2 of a 4" x 6"  wye.   The cost
     involved would be:
                                 6" x 8" tee:
                                 6" service:
                                 1/2 (4" x 6") wye:
                                 4" house lateral:
                                 Tap fee:
                                 1 @ $75: each
                                 30' @ $15/foot
                                 1 @ $17 each
                                 50' 
-------
                           Cost of Serving a 200-Home Subdivision

                           a.   Gravity Sewer:  The developer must pay for the 8" street laterals,
                                which will involve about 80 L.F. per lot.  The cost of the house
                                tie-in is also involved.  The costs would be:
                           b.
                                200 homes @ $992 each

                                8" lateral:  $28/L.F. x
                             80 L.F. x 200 homes
                              2 sides of street
                                             TOTAL
$198,400.00

 224,000.00

$422,400.00
     Force Main:  To tie into a force main, the developer will  build the
     above gravity system.  Then a lift station would pump into the force
     main.  The costs would be:
                                Gravity system  (above)
                                200 x 350 gpd =0.07 mgd LS
                                0'.07 x 694 x 50' TDH/1,000
                                  F = 2.4
                                     Cost
                                                                        TOTAL
$422,400.00


  48,100.00

$470,500.00
Comment  3
adoption of new
floodplain oTdinances
Response  3
To update the Draft EIS:  Plainfield Township recently has amended its
zoning ordinance by adopting a new floodplain zone.  Tne prohibition of
development now is applicable within the 100-year floodplain area defined
by the Federal Insurance Administration's Flood Insurance Study for Plain-
field Township.  In addition, both Stockertown Borough and Tatamy Borough
have adopted floodplain management ordinances in compliance with Section
60.3(d) of the National Flood Insurance Program.  These ordinances limit
and condition, but do not prohibit totally, development in the 100-year
floodplain as defined by their respective Flood Insurance Studies.
[Pierson]

Comment noted.

See Sections III,B.3 for a discussion of how municipal induced
growth estimates under the APA, MAPA, and Alternative 9 are affected by  ^
these new ordinances.
Comment 4
EIS overstates APA
growth
Response 4
 Differences  in  induced  growth  estimates  between  the APA  and Alternative  9
 are  significantly overstated  in  the  Draft  EIS.   [B-LLJSA]

 See  Appendix C-4.
 ISSUE:
 ENERGY

 Comment 1
 Alternative 9 consumes
 400 times more energy
 than APA

 Response 1
 The  Draft EIS Recommended Action (Alternative 9)  will  consume 400 times
 more electric power than the proposed B-LLJSA conveyance system.   [Smith]



 The  table on page 196 of the Draft EIS indicates  that the estimated energy
 consumed by the B-LLJSA conveyance system (the Applicant's Proposed Action)
 would be 5,950 kilowatt-hours per year (kwh/yr).   The energy consumed by
 Alternative 9 would be 552,490 kwh/yr.  Thus, the Draft EIS Recommended
 Action appears to consume 93 times more electric  power than the APA.  The
 energy budget of the APA has been revised, however, to 139,991 kwh/yr (see
 Appendix D-2  Final EIS), or approximately one-fourth of the energy required
 by the Draft EIS Recommended Action.  It is noted that these comparisons
 are based on energy requirements of wastewater conveyance and treatment
                                                    73

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Comment 2
Alternative 9 consumes
too much energy to be
EIS Recommended Action

Response 2
components within the immediate B-LLJSA and EIS Service Areas.   When  energy
set aside in the Easton system and energy utilization  by  induced development
are added into the analysis, Alternative 9 consumes considerably less energy
than the APA or MAPA (see Response 2).

The excessively high energy requirements of EIS Alternative  9 do not  justify
its selection over the APA as the EIS recommended wastewater management plan.
This is particularly true in view of the President's directive  to conserve
energy.  [B-LLJSA, Kennedy, Merwarth]

The energy evaluation of wastewater management plans presented  in the Draft
EIS (page 196) considered only the electric power requirements  of wastewater
conveyance and/or treatment facilities in the immediate B-LLJSA and EIS Ser-
vice Areas.  Any facilities that were essential to the implementation of these
plans and that were located outside of the B-LLJSA and EIS Service Areas proper
were omitted purposely from the energy evaluation simply  because they were not
to be constructed under the B-LLJSA grant in question.  In view of the sub-
stantial public support for implementing a Federally funded  wastewater manage-
ment plan which complies with the President's energy conservation directives,
EPA has taken a more comprehensive approach in the Final  EIS to assessing the
energy needs of the APA, MAPA, and Alternative 9 (modified version).   This
approach includes the evaluations of:

•  The energy requirements of the B-LLJSA and EIS Service Area  (Phase I)
   portions of the expanded Second Street pump station, Delaware Drive
   pump station, and Easton STP.  The expansion of these  facilities is essen-
   tial to the operation of any wastewater management system involving use of
   the expanded and upgraded Easton STP

t  The energy requirements of the residential development (single family and
   multi-family homes) induced by the construction of the APA,  MAPA,  and
   Alternative 9.

The revised energy budgets (kwh/yr) for the APA, MAPA, and Alternative 9
are as  follows:
                            B-LLJSA/EIS Service Area
                            associated wastewater
                            conveyance and treatment
                            components
                              APA
                           (kwh/yr)

                           1,505,841
                            Electric power consump-  108,619,000
                            tion by induced resi-
                            dential development @
                            21,600 kwh/yr for single
                            family homes and 16,900
                            kwh/yr for multi-family
                            homes
   MAPA
 (kwh/yr)

   723,860
                                          29,872,000
Alternative 9
	(kwh/yr)

     461,004
                    6,263,000
                            Total  estimated energy
                            requirements
                         110,124,841
30,595,860
    6,724,004
                            The revised APA energy budget is discussed in Section  III.B.4 of the
                            Final  EIS, and the revised energy budgets for the MAPA and Alternative 9
                            are in Section III.D.5.   Detailed energy analyses are  included  in Appen-
                            dix D-2.
                                                   74

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APPENDIXES


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                                        APPENDIX  A
DRAFT ENVIRONMENTAL IMPACT STATEMENT
      (included by reference)
      75

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                                       APPENDIX R
RECREATION AND WASTEWATER MANAGEMENT PLANS
        FOR JACOBSBURG STATE PARK
                  77

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                                                               APPENDIX  B
                    DEPARTMENT OF ENVIRONMENTAL RESOURCES  June  2,  1980
                                                             Refer to:   RM-P-R
                                                             717-787-6674
        P. O. SOX 1 «67

HARRISBURG. PENNSYLVANIA  17120
Mr. Eric Hediger
Wapora, Inc.
6900 Wisconsin Avenue
Chevy Chase, Maryland  20015

Dear Mr. Hediger:

          Enclosed are copies of two letters that state the Department's
position regarding development at Jacobsburg State Park.
          If you have any further questions, please do not hesitate  to
call me.
                                     Sincerely,
                                     George E/Fogg, Chief
                                     Division of Outdoor
Enclosures:   (2) Letters
                              78

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                                                                  In  reply refer to

                                                                        2348:1

                                 March  30,  1979
J. arsas Pilling  III,  Associate
  Envirorzsiitai  Plar.ncr
l.'AFORA, Inc.
6900 Wiico-oain Avenue, N.W.
Washington, D. C.   20C15

Dear Mr.  Pilling!

           Tfcia is  in raspon*« to your  latter oT y.irch 7, 1079, ccncerniag th«
Dcpartr^r.it' a  proposed development  at Jacobabur", State. Park.

           Sinca  the January 1U7C tolacon bacvecn M3. Judith Ludiagton of your
office ar.d Mr. Larry S'uarar of our otaf £ ,  the construction scheduling of the
waatevntar faciliciea and budget coo»tr*inc« h^ve r.a
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                                                                   tn  T'sply raf«r ta
                                                                          ffil-X
                                                                       £5 43i1C
                               April 16,  I!i7'
  of »'-ic  Tovnahi?
  Board of Suvcrvtaoru
iuaf'illl  Towuhi?
10; J n Pallor RoaJ
'ii'lusi Op,  Pennsylvania  13001
Deur !ir.

           TM.3  ia  ia rcapoaaa  to your Icttar of jUrch 30, 1979,  concarning
tha Dtsr-artrssivt1 :i propott'jd ii«TalopB*Bat
           1: is  t.'.\-i i^cenC  of  tin* D«purt-Mrt c ?  E^.vtrw'.r.-r.ial  aa*oyTcsa  to
          utvftlor.-s-'AS if lew density rBcre*ei:7T-.,U  f*.:ilitl«c vhieh will
            tito historic azul DAtutiil ajipuctj »f ta*  c'aik.  V« .fill proviso
            *i»r hli-iiit;, crm»4 country ukiin-.:, :• ituvs xrJ. 't :»corlc inttr-
 z.taiiu-*, Jiui pl.^-icl-iiii';.   1'ha n«cc-3-ja?7 7"nii-^ t u: co-..'.'c'rt
 cait3  uro inaCi
                 'ii  of Jtiaya  La tha conetrjccic-;i of  '/iatc-./ata
ai:d  budget cor.acr.iiita, v-a Hav* Taprc-ftrusBiv.i .iovel-: '"ir.r.t ;  il  tho Tori;.   f.:a
lou  ^ir.sity facilicifij vtll  La utiliifcd until  r.'.:iv.  -i.-.I-iftcu'.I.-.j  cf wajcew»t»r
ficilltios iia.:  bcur. -zlirt'laa.  ..'.c ca«; ili«,  uc -.-111 rcvl?v  tb-i lUatar  ?Lt3
of  rha T.trk. ana i-rc^m fund a in c^-.r  capital :^:-j-;^i tor  *y-c dsrirn  o^  my
        G^jCfro !".  I'o •.,-•, CiicJ  of tho Clviflon of Outaocr
ht 771 y  ;o Kccit r'itli you to  review t'.ie pla.-.j AC '/cur  co
cor.ca^:ad ,1; ?p^r;.->--lv\r\ia  Dcpurt-.ont of  l.nviror; ..-.r.t-vl '
                                    171""   ' 7 ' 7 \ ~i " ™~,
                                  \  * I 1 ^ j )  \ / * j f I ., (
                                                                           I la a-v
                                                                           P.  0.
                                 Slrcarnly.
                                  Lirr?rn L.

                                     80

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                         APPENDIX C
INDUCED GROWTH
             81

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                                                                                      APPENDIX C-l
                       INDUCED GROWTH POTENTIAL IN 100-YEAR FLOODPLAINS OF
                       STOCKERTOWN  BOROUGH AND TATAMY  BOROUGH,  YEAR 2000
                                  (APA, MAPA, All Alternatives)
                     I.     Planimetric  Measurement of Undeveloped Areas
                           A.    Stockertown  Borough
Use
Residential
Industrial
Commercial
Open Space
Acreage
6 acres
5 acres
6 acres
15 acres
Zone
R-l
1-1
C-2
P-0
                                               12,000 ft.
                                                                 Population
                                                                     67
Residential
Residential
Total
 1  acre
17  acres
18  acres
B.   Tatamy Borough
        R-2
        R-l
 7,800 ft.'
12,000 ft.'
 6
62
68
 18
184
202
             "NOTE:  Recently adopted floodplain management ordinances do not prohibit
                     degelopment in 100-year floodplain.
                                         82

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                                                                APPENDIX C-2
INDUCED GROWTH ASSOCIATED WITH SUBSTITUTION OF GRAVITY SEWER
 FOR FORCE MAIN/PUMP STATION IN PALMER TOWNSHIP,  YEAR 2000
                      (Alternative  9)
      Palmer Township
      A.    Northwood Avenue
           1.   R-I;  20,000 ft.2 lots  -  22  existing  units
                24.7 acres - 10 developed acres    14.6  acres
                14.6 acres * 20,000 ft.2  = 32  units
                32 units x 3.08 persons/du  99  people

           2.   G-2;  12,000ft.2 lots    110 existing units
                63.57 acres - 30.3 developed acres =  33.Z7 acres
                33.27 acres * 12,000 ft.2 lots = 121  units
                121  units x 3.08 persons/du    373 persons

      B.    Tataniy Road
           1.   R-I;  20,000 ft.2 lots  -  53  existing  units
                42.38 acres   24.33 developed  acres = 18 acres
                18 acres * 20,000 ft.2  lots    39 units
                39 units x 3.08 people/du   120  people
      C.    Total  induced growth  Alternatives  5  and  9
           1.    Population       -   592
           2.    Dwelling Units   -   192
           3.    Acres            -    66
                       83

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                                             DWELLING UNITS INDUCED BY ALTERNATE WASTEWATER MANAGEMENT PLANS, YEAR 2000
                                                                                                                                          APPENDIX C-3
Municipalities
Bushkill
Nazareth
Palmer*
Plain-field
Stockertown
Tatamy
Upper Nazareth
TOTAL
•Single(l)/Multi(2)
Family
Dwelling Unit
1-
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1980 Existing
Dwelling Units
1,355
50
1 ,580
658
45
0
1,565
165
207
60
270
74
1,228
120
6,250
1,127
Baseline APA MAPA
1 ,876 901 0
140 00 0
1,553 00 0
643 00 0
115 925 395
0 924 395
2,070 1,816 128
252 454 32
209 115 115
60 0 0
336 252 252
98 0 0
1,507 730 158
172 183 40
7,666 4,769 1,048
1,365 1,561 467
EIS Alternative
1234 5&9 6&10 7 8
00 36 00000
00000000
00000000
00000000
177 177 177 0 96 177 0 0
178 178 178 0 96 178 0 0
151 132 212 132 25 424 424 424
38 38 53 0 0 106 106 106
115 115 115 115 47 115 115 115
00000000
252 252 252 252 47 252 252 252
00000000
158 158 158 158 0 0 158 158
40 40 40 40 0 0 40 40
853 834 950 657 215 968 949 949
. 256 256 271 40 96 284 146 146
Units within the proposed Service Area

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                                                                                        APPENDIX C-4
                           SEWERS    INDUCED  GROWTH  IN  EIS  SERVICE  AREA


 The basic assumption  in the induced growth analysis is that sewers provide an inducement for growth
 due to excess  capacity resulting from engineering and regulatory constraints on minimum pipe size
 diameters (in  many instances, DER requires a minimum interceptor pipe size of eight inches regardless
 of flow).  This  analysis will further define the growth inducement data found in Appendix G-20,
 Draft EIS as well as further published documentation of the inducement effects sewers have in
 conjunction wtih market forces operative in this study area.  Additionally, engineering economics of
 the differential effects of gravity versus force main growth inducement will be demonstrated.

 The Draft EIS  reported different amounts of growth that would be associated with the introduction of
 various wastewater collection and treatment facilities in the Service Area.  Table B-l shows the
 total year 2000  population projected by municipality for the original design of the APA, the MAPA,
 EIS Alternative  9, as well as the 1973 JPC population projections accepted as baseline and the 1978 JPC
 population forecasts.  The 1973 population projections did contain the provision of sewer service as
 a variable in  calculating population in Plainfield Township, Palmer Township, and Tatamy Borough but
 not elsewhere  within  the EiS  Service Area.  These projections have been demonstrated as accurately
 reflecting the growth trends  of the area based on an analysis of past trends in population growth,
 recent housing construction activity and verification of the JPC population projection method itself
 (see Appendix  G-l, Draft EIS).
 Table B-l.   Year 2000 population.
 Bushkill  Township
 Nazareth  Borough
 Palmer Township
 Plainfield Tonwship
 Stockertown Borough
 Tatamy Borough
 Upper Nazareth Township

 Service Area
   1973
    JPC
Projections

   6,200
   5,600
  17,800
   6,800
     800
   1,250
   5.100

  43,550
  1978
  JPC
Forecasts

  9,400
  6,730
 25,500
  8,800
  1,500
  1,480
  6,150

 59,560
     APA
Baseline Plus
   Induced
   Growth

    9,057
    5,600
   23,514
   13,657
    1,157
    1,795
    7,957

   62,733
    MAPA
Baseline Plus
   Induced
   Growth

    6,200
    5,600
   20,234
      280
    1,157
    1,795
    5,721
   47,983
     EIS
Alternative 9
Baseline Plus
   Induced
   Growth

    6,200
    5,600
   18,392
    6,876
      875
    1,325
    5,100

   44,368
As shown in  Table  B-l,  JPC has adopted a new set of population forecasts.  These forecasts were
developed in conjunction  with  the 1978 Comprehensive Plan for Lehigh-Northampton Counties and show
a year 2000  population  of 59,560 in the B-LLJSA Service Area.  This represents a 36.8% increase over
the 1973 projections.   The increase was based largely on the assumption that "excess" sewer capacity
would be available in all  Service Area municipalities.   These forecasts were evaluated in the EIS as
an upper limit  of  the amount of induced growth that could occur in these municipalities.

As may be noted in evaluating  the difference between the 1978 forecasts and the amount of growth
anticipated  under  the original  Applicant's Proposed Action (APA), the latter is 5% greater.  It was con-
cluded in the Draft EIS (page  123)  and in  Appendix  G-20 (pages 168 and 170) that the amount of
induced growth  that could occur as a result of excess capacity in the APA is high.  In order for
this  amount  of  growth to  occur in the study area in a 20-year period, all growth in Northampton
County would have  to be directed to this Service Area.   This excess capacity results from an original
design that  was conducted for  a 40-year (2020 design year) population, larger per capita flows than
are projected in the EIS,  and  a service area that is considerably larger than recent needs documenta-
tion  indicate is necessary.  As a result,  the Draft EIS concluded that this design would not induce
the amount of growth projected and would result in  an underutilized system for an extended period
of time.
                                           85

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Based upon the aforementioned assumptions, an estimated induced population growth of 44,368 under
Alternative 9 and the 7.5% higher figure of 47,983 under the MAPA is a reasonable estimate of pro-
jected conditions.   This is based upon the premise that sewers induce higher rates, higher absolute
amounts, and higher densities of development.  This is not to say that sewers alone induce growth,
but in the presence of an adequate market for development, sewers do have an overwhelming influence
on the amount and location of growth.   This assumption has been documented in the literature on a
national as well  as local level.

In a "Manual for Evaluating Secondary Impacts of Wastewater Treatment Facilities," Fitzpatrick et al.
(1977) state in Section 2.1, The Basic Issue:  Sewers and Growth, 2.1.1.  Review of the Literature,
"from the standpoint of this manual on secondary impacts, the most important finding is that of the
CEQ-funded study of interceptor sewer projects [CEQ Fifth Annual Report 1974], namely that,  'on the
local scale, sewers actually induce growth that would not otherwise occur.'"  In January 1975, JPC
published a document titled The Relationship Between Land Use and the Availability of Utilities:  An
Issue Paper for the Comprehensive Plan Update which states, "the idea that sanitary sewers have an
effect on the amount and density of development is already generally assumed."   It states further
that, of all utilities examined, "it becomes apparent that sanitary sewers have the most direct impact
on growth in this [Allentown, Bethlehem, Easton, Standard Metropolitan Statistical Area] Region.
... Out of the almost 10,300 new homes built in the two-county area during [1971-1974] . . . about
7,700 or 75% of the new units in the region had central sewerage available or anticipated soon.  In
conclusion, it is clear that the availability or anticipation of sewerage .  . . had substantial impact
on the location of recent residential  growth."

Not only do sewers influence the amount of growth, they also influence development density, as most of the
municipal zoning ordinances in the Service Area allow for many more units to the acre with the avail-
ability of central  sewer service (for example, the Plainfield Township Zoning Ordinance of 1971).
The 1975 JPC paper bears this out, stating "the gross density of proposed development with central
sewers available or anticipated soon is higher than that of proposed developments with permanent on-lot
sewage disposal systems."  Even areas zoned primarily for purposes other than residential development
will experience pressure.  The 358-unit Brenton Village townhouse proposal in the PIC zone of Palmer
Township is an example of the curative amendment-type zoning challenge that will be experienced with
the advent or anticipation of sewers.   If both the Schoeneck Interceptor and the Bushkill Interceptor
were to be developed, the RA zone in Northern Palmer Township would be capable of absorbing all
induced growth under either the MAPA or EIS Alternative 9.

It must be restated that new sewers are not capable of creating new people or of attracting residents
from one end of the state to the other.  New sewers are capable of dramatically rearranging growth
within a region.  The growth inducement analysis found in Appendix 6-20, Draft  EIS enumerates
a number of attraction factors which demonstrate a greater potential development market than some
neighboring areas.   Route 33 is accessible to the whole Service Area and provides significant trans-
portation capacity to employment (and potential employment) centers in the area.  Housing development
moratoria have been in effect in Bushkill and Upper Nazareth Townships for a number of years creating
a pent-up demand.  Vacancy rates for this Service Area are lower than the for the region, again in-
dicating a demand (Housing Information Package:  1978 Edition JPC).  JPC records show that a signifi-
cant number of subdivision proposals are currently in active stages of review.  Recent housing growth
indicates that from 1971 to 1977, Forks Township housing increased by an average of 24 units per year
whereas Palmer Township increased by an average of 78 units per year, thus indicating greater growth
attraction to the B-LLJSA Service Area (JPC 1978).  Additional public utilities, such as water, gas,
and electricity, are in place and anticipate more than enough capacity for the projected development.
Gilbert Commonwealth noted in their 1976 Environmental Assessment that "this lack of significant
growth from 1972 to the present is apparently a result of the general unsuitability of the soils for
on-lot sewage disposal systems, the lack of public sewage facilities and current economic conditions"
(the 1973 to 1975 housing recession).   If this development limitation by soils is circumvented, sig-
nificant proposed subdivisions would proceed, a contention defended by local realtors as well as JPC.
(By telephone, Marie Morykin, 16 March 1979).  Additionally, the carrying capacity analysis  found in
Appendix G-20, Draft EIS indicates more than enough vacant developable land exists within a
reasonable transmission distance of the proposed interceptor lines to accommodate anticipated induced
growth.

In order to evaluate the inducement effects of a gravity interceptor versus  force main, costs were
derived to serve single family households and subdivisions.  For a single family, the cost of tying
into a force main is approximately 500% more expensive than tying into  a gravity sewer.  For serving
a subdivision of 200 homes, the cost of building a lift station and tying into a force main  is


                                              86

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approximately  10% more expensive than tying into a gravity sewer (see Section       for engineering
analysis).   Planned multi-unit facilties could thus be developed in the areas of force mains.  However,
these units  would have to be occupied simultaneously to fully utilize the lift station and deliver
relatively  aerobic septage wastes to the treatment plant in Easton.  The EIS maintains its contention
that force  mains will  limit development.


                                      INDUCED GROWTH REFERENCES


JPC.  "The  Relationship Between Land Use and the Availability of Utilities:  An Issue Paper for the
Comprehensive  Plan."  1975.

Urban Systems  Research and Engineering.   Interceptor Sewers and Suburban Sprawl.   CEQ:  Washington,
D.C.  1974.

Real Estate Research Corporation.  The Costs of Sprawl.  USGPO:  Washington, D.C.  1974.

Brinkley, Clark, et al.  Interceptor Sewers and Urban Sprawl.  Lexington Books.  1975.

Grubisich,  Thomas.  "Sewer Grants:  The Pipelines to Urban Sprawl."  Washington Post.  January 31, 1980.

Bascori, S.E.,  et al.  Secondary Impacts of Transportation and Wastewater Investments:  Research Results.
CEQ:  Washington, D.C.  1975.

Hammer, T.R.,  et al.  Growth Stimulation Study:  An Analysis of Sewerage System Development and Resi-
dential Construction.   Cheater-Bitz Engineers:  Plymouth Meeting, Pennsylvania.  1977.

JPC.  Housing  Information  Package:  1978 Edition.  1978.
                                                  87

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                                    APPENDIX D
ENGINEERING AND ENERGY ANALYSES
                    89

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                                                                     APPENDIX D-l
                      SUMMARY OF ADDITIONAL CONSTRUCTION COSTS
                             ASSOCIATED WITH APA
     The cost-effectiveness analysis presented as Section 5.2 of the "Engineering
Evaluation of Bushkill Draft EIS" compares the costs of various alternatives.
However, all costs included are cost associated with facilities inside of the
established study area.  In reality there are also additional costs associated
with the applicant's Proposed Action chat occur from construction of facilities
outside of the study area.   These costs are associated with the expansion
(i.e., construction) of two pump stations in Easton and expansion of the Easton
STP, both of which are required to complete the Proposed Action.  The attached
Table 2.1 presents additional construction costs (already incurred) that should
be credited (added) to the  cost of the Proposed Action.
                                         90

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Table 2.1   Cose of expansion of two  pump  stations and Easton STP which should

            be added to the cost associated with  the Proposed  Action.






(1)  Second St. P.S. :


         2.4/8.4 x $873,000           =•          $   249,429



(2)  Delaware  Dr. P.S. :



         2.4/10 x 5796,000            =          $   191,040



(3)  Expansion of Easton ST? :
         Construction Cost =  $4,889,000  x       %»<••
                                            2314  (Feb.  76)
                                                $6,634,166


         Cost Associated with Bushkill  =  2.4/10.0 x  $6,634,166



                                                $1,592,200


        Total Additional Construction Cost      $2,032,669




        Total Additional Capital  Cost  (127%)    $2,581,490
 1  Cost  from B-LLJSA  E.A.  Page  1-12
                                          91

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              The  location,  capacity,  and  timing  of  the proposed project
              were reviewed  with  respect to  the Joint  Planning Commission's
              Water Suaply and  Sewage  Facilities  Plan  Codata  -
              LOCATION :  The Joint Planning  Commission ' s  Regional Plan
              proposes  to use  the Easton Plant and  plant  site  for serving
              the  Bushkill  Creek drainage basin as  provided  for in this
              expansion program application.

              CAPACITY :  The Regional ..Plan, calls for  expansion, of the
              Easton Treatment Facility to handle upstream municipalities.
              The  proposed  expansion program would  accomplish  this.

              TIMING:   The  JPG study indicates that the expansion should
              take place during Che 1970-1973 tine  period.   Funding  of
              this application in 1973 would permit this  tilling to be net.

              The  Joint Planning Commission  does question whether or not
              the  relief interceptor that is proposed  to  be.  constructed
              along the Sushkill Creek will  empty into a  combined sanitary
              and  storm sewage system.  The  Commission also  wishes to draw
              Eas ton's  attention to the fact that Palmer  Township zoned an
              area in excess of 1,000 acres  for -industrial use and that
              the  proposed  sewage allocation for- the Township-- should be
              evaluated carefully in view of that large amount of industrial
              .zoning .

              In light  of the above review comments,  the  Joinc Planning
              Commission wishes to offer its endorsement  of  this proposal."

         The  questions  raised by JPC wera answered  in  a letter from  the
         Consultant indicating that the new  interceptor vould  not empty
         into a combined sanitary and storm  sewage  system, and when  and if
         Palmer Township's  industrial area developed,  the plant capacity
         could be  expanded.

1.2.1.5   Estimated Project  Costs

         The  estimated  construction costs for the proposed work, based on
         estimates prepared at the completion of the  design  and updated to
         February, 1976 are:
              Contract  1      -     Sewage Treatment Plant       \ 34.389.COO
              Contract  2      -     Interceptor  Sewar              51,932,000
              Contract  3      -     Pumping  Stations &  Force
                                    Mains                        51,376,000

         Total  construction  costs  ara  estimated at S3,197,000.   Legal,
         financial,  administrative, and technical services  provide an
         astimatsd  total  project costs of  S?,515,000.   Federal grants ara
         anticipated co amount  to  36,973,GGG,  leaving a local bond issue
         aaoucicing  to approximately §2,533,0.00.

                                    92

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y  v Gilbert/Commonwealth =ngineers and consultants
      GILBERT ASSOCIATES, INC., ?. d. 3ox 1498, Reading. PA 19603/TeL 215 775-2SOD/Gaols Gilasoc/TeJex 336-W1

                                May 19,  1980
 WAPORA,  Inc.
 6900  Wisconsin Avenue
 Chevy Chase,  iMD  20015

 Attn:  Mr.  Eric M.  Hediger
                                 Re:  B-LLJSA Project Information Requested
                                      by  WAPORA by  Letter  Dated May  2,  1980
                                      GAI W.O. No.  06-6796-073
 Dear  Mr. Hediger:

 The  following information  is  in response to your letter dated May 2,
 1980  and our telephone conversation  of the afternoon of May 16,  1980.
                                               Purno  Stations
   Information Needed

 Design Flow  (Peak Flow
   @ 250 gcd)

 Size of Force Main

 Length of  Force Main

 Pump & Motor Efficiency
 Construction Cost
 (Inc. PS & FM)
   Easton Iti
   Easton #2
  JSP
21 MGD

16" old-24" new

350 feet

Variable  Speed
Pump
25 MGD

24" old-24'r new

1450 feet

Variable Speed
Pump
600 GPK

6" & 8"
Variable
Speed
Pump
Edelman


1804 GPM

6"
                  $796,000 ;;
 The information given for  the Easton pump  stations  is referenced in
 the following data:
  1.   Design  Flow

  2.   Size  of Force  Main

  3.   Length  of Force Main
                 DER Permit  Application

                 Construction Documents

                 Construction Documents
                                     93
                      =25 Unrasnr iwnui Sesdwi i^Morqantmm float Gmn HMj. 3aadin
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                                                              APPENDIX  D
   ENERGY  ANALYSIS OF APA, MAPA, AND ALTERNATIVE  9
1.0     Summary of Energy Requirements for B-LLJSA,Alternatives.
2.0     Summary of1Additional  Capital Costs for Proposed Action.
3.0     Tabulation of Energy  Requirement for Proposed Action.
4.0     Tabulation of Energy  Requirement for Modified Proposed Action.
5.0     Tabulation of Energy  Requirement for Alt.  9  (OD) (Mod.).
6.0     Design Flows for Proposed, Modified Proposed, and Alt. 9
        (00)  (Mod.).
7.0     Projected Average Energy Consumption by Residential Develop-
        ment, Year 2000
                             94

-------
                                                     1.0.
                           SUMMARY OF ENERGY REQUIREMENTS FOR B-LLJSA ALTERNATIVES
                                                                             (KWH/YR)
ALTERNATIVE
 SEWAGE
TREATMENT
(kwh/yr)
                                                  CONVEYANCE
                                                    (kwh/yr)
                        CLUSTER
                        SYSTEMS
                        (kwh/yr)
                     TOTAL
                    (kwh/yr)
Proposed Action
  (2.4 MGD)
 733,728
772,113
                   1,505,841
Modified Proposed Action
 (1.234 MGD)              377,258
                           339,592
                          7,010
                     723,860
Alt. 9 (OD)  (MOD)
 (1.234 MGD)
 158,755
293,859
8,390
461,004
JCV

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                                       2.0.

                     SUMMARY OF ADDITIONAL CONSTRUCTION COSTS
                          ASSOCIATED WITH PROPOSED ACTION
     The cost-effectiveness analysis presented as Section 5.2 of the "Engineering
Evaluation of Bushkill Draft EIS" compares the costs of various alternatives.
However, all costs included are cost associated with facilities inside of the
established study area.  In reality there are also additional costs associated
with the applicant's Proposed Action that occur from construction of facilities
outside of the study area.   These costs are associated with the expansion
(i.e., construction) of two pump stations in Easton and expansion of the Easton
STP, both of which are required to complete the Proposed Action.  The attached
Table 2.1 presents additional construction costs (already incurred) that should
be credited (added)  to the  cost of the Proposed Action.
                                         96

-------
Table 2.1   Cost of expansion of two pump stations and Easton STP which should
            be added to the cost associated with the Proposed Action.
(1)   Second St.  P.S.:

         2.4/8.4 x $873,000          =         $  249,429

(2)   Delaware Dr. P.S.:

         2.4/10  x $796,000           =         $  191,040

(3)   Expansion of Easton STP:

         Construction Cost = $4,889,000  x 314° (De°'
                                           2314 (Feb. 76)

                                               $6,634,166

         Cost Associated with Bushkill = 2.4/10.0 x $6,634,166

                                               $1,592,200

        Total Additional Construction Cost     $2,032,669


        Total Additional Capital Cost (127%)   $2,581,490
1  Cost from B-LLJSA E.A. Page 1-12
                                          97

-------
              The location, capacity, and timing of the proposed  project
              were reviewed with respect to the Joint Planning Commission's
              Water Supply and Sewage Facilities Plan Update ~
              LOCATION:  The Joint Planning Commission's Regional Plan
              proposes to use the Easton Plant and plant site for serving
              the .Bushkill Creek drainage basin as provided for in this
              expansion program application.

              CAPACITY:  The Regional .Plan, calls for expansion, of the
              Easton Treatment Facility to handle upstream, municipalities.
              The proposed expansion program would accomplish this.

              TIMIN'G:  The JPC study indicates that the expansion should
              take place during the 1970-1975 time period.  Funding of
              this application in 1973 would permit this timing to be met.

              The Joint Planning Commission does question whether or not
              the relief interceptor that is proposed to be constructed
              along the Bushkill Creek will enpty into a combined sanitary
              and storm sewage system.  The Commission also wishes to draw
              Easton's attention to the fact that Palmer Township zoned an
              area in excess of 1,000 acres for -industrial use and that
              the proposed sewage allocation for the Township- should be
              evaluated carefully in view of that large amount of industrial
              .zoning .

              In light of the above review comments, the Joint Planning
              Commission wishes to offer its endorsement of this proposal."

         The questions raised by JPC were answered in a letter from the
         Consultant indicating that the new interceptor would not empty
         into a combined sanitary and storm sewage system, and when and if
         Palmer Township's industrial area developed, the plant capacity
         could be expanded.

1-2.1.5   Estimated Project Costs

         The estimated construction costs for the proposed work, based on
         estimates prepared at the completion of the design, and updated to
         February, 1976 are:
              Contract 1     -    Sewage Treatment Plant       ^34,389.000 A
              Contract 2     -    Interceptor Sewer              $1,932,000
              Contract 3     -    Pumping Sections & Force
                                    Mains                        51,376,000

         Total construction costs are estimated at $8,197,000.   Legal,
         financial, administrative, and technical services provide  an
         estimated  total project costs of 59,616,000.  Federal  grants are
         anticipated  to amount to $6,973,000, leaving a local bond  issue
         amounting  to approximately $2,633,000.
                                 98

-------
    Gilbert/Commonwealth  engineers and consultants
    GILBERT ASSOCIATES, INC., P. 0. Sox 1498, Reading. PA 19603/Tel. 215 775-2600/Cable Gilasoc/Telex 83&-431

                               May  19,  1980
WAPORA,  Inc.
6900 Wisconsin Avenue
Chevy Chase, MD   20015

Attn:  Mr.  Eric  M.  Hediger
                               Re:
B-LLJSA Project  Information Requested
by WAPORA by Letter Dated May 2,  1980
GAI W.O. No. 06-6796-073
Dear Mr.  Hediger:

The following  information is in  response  to your  letter dated May 2,
1980 and  our telephone  conversation of the  afternoon of May  16, 1980.
                                             Pump Stations
Eastern #1
21 MGD
16" old-24" new
350 feet
Variable Speed
Pump
$873,000 \
L
Has ton #2 JSP Edelman
25 MGD 600 GPM 180* GPM
24" old-24'r new 6" 5, 8" 6"
1450 feet
Variable Speed Variable
Pump Speed
Pump
$796,000 ji
  Information Needed

Design Flow (Peak Flow
  @ 250 gcd)

Size of Force Main

Length of Force Main

Pump & Motor Efficiency
Construction Cost
(Inc. PS & FM)

The information  given  for the  Easton pump  stations  is referenced in
the following data:
1.  Design Flow

2.  Size of Force Main

3.  Length of  Force Main
      DER Permit Application

      Construction Documents

      Construction Documents
                                     99

                     525 Lanrasnr Awnus. Heading, PA/Morgantown float Grsm Hills, Saading, PA 215 775-2600

-------
                                       3.0.
                      ENERGY ASSOCIATED WITH PROPOSED ACTION

I.   CONVEYANCE
     (1)   Jacobsburg State Park P.S.:                                  7,938 kwh/yr.
     (2)   Edelman P.S.:                                             132,053 kwh/yr.
     (3)   Second St. P.S.:

                              * 681-912
     (4)   Delaware Dr. P.S. :

          10 V (":»!>"   x

II.  TREATMENT
     (1)   Easton Plant (10 mgd)
          Approximate Annual  Power Cost =
          . , Q „„»   Dec.  79   0.05 kwh
          $48,000 x - - r-r x .  ..- . — —  =
                    Sep.  76   0.02 kwh

          $48,000 x (3140/2465)  x 0.05/0.02 = $152,860
          $152, 860 /. 05 /kwh = 3,057,200 kwh/yr.
                                                                    733,728
                                                     TOTAL        1,505,841 kwh/yr.
                                        100

-------
0j£CTNO	6SD	    (X^J  WAP OR A, Inc.     SHEET	OF-
      Knshklll  EIS         /\ A  /\	PREPARED BV 	ICY
                                    EnvJronmantal/Envrgy/EconomJc Studies             «-  .   '11 QQn
                            OFFICE	    CHECKED BV.
                                                                 DATE.
                                  PUMP STATION ANALYSIS
     PUMP STATION #   JSP (Proposed Action)
     Dia. =   6"  +8"
    Pump Sta:
               Q =     0.10    MGD           Qp =    0.25    MGD
               V =     0.4     fps           V  =    1.0     fps

               H Static   =    480      -     450        =      30'
               H Friction =  2(5120)    @    0.04     %
               H Misc.     =                                   10'
                                                    TDH  =  	44
                                                      F   =      3.1

    Pump Sta:  Capital Cost  51.800    x  .0953   =                       _$ 4936

               0 & M                                                         3330


    Ferce Main:     5120      @  $45.00    /Ft.   =   230.400   x .0953 =  21,957

               0 & M   =   230.400   + 50 yrs.    =                          4608


                                                   TOTAL ANNUAL COST    =   $34.831
    Yearly Energy Requirement =  lS9-yi TDH (ft.)  X. FLOW(mgd) X 365 days/yr.
                                  0.75(pump  eff.) X 0.85(motor eff.) X 60

                               = 1804 X    44	 X   0.10      =     7938	 KUH/yr
                                             TDH           FLOW
                                           101

-------
                                       WAPORA,  Inc.     SHEET
                                                                                 OF-
                                                                   PREPARED BV.
^,£NT	BushkilU^	    (\A/) En,_,.,/En.,,¥/E™,,c s,ud,,             29toril1«jgn
SUBJECT	—                                         CHECKED BY.
5                               OFFICE	
                                                                   DATE.


                                     PUMP STATION ANALYSIS
       PUMP STATION #'  EDELMAN (Proposed Action)

       Dia. =      6"
       Lift  Sta:
                   0 =    Q.3     MGD          Qp  =     0.75   MGD


                   V =    2.2     fps          V   =     5.5    fps



                   H Static   =    540      -    460        =     80'


                   H Friction =   3500     <§     4.4     %  =    154'


                   H Misc.    =                                   10'
                                                       TDK  =    244
                                                         F  =     51


       Pump Sta:   Capital Cost  $166,500  x  .0953  =                         $ 15.867_



                   0 & M                                                      $ 11,100





       Ferce  Main:      3500'    @   $20.00   /Ft.  =    70.000    x .0953 =  667L
                   0 & M  =    70,000   v 50 yrs.   =                         1400
                                                     TOTAL ANNUAL COST    =  $ 35.038
       Yearly Energy Requirement =  189 X TDH(ft.)  X FLQW(mgcl) X 365 days Ayr.

                                     0.75(pump  eff.) X 0.85(motor eff.) X 60



                                  = 1804 X     244	X    Q.3      =    132.053      KHH/)

                                                TDH          FLOW

                                              102

-------
                                                                         £A«49- > -;
   JACOBSBURG

    STATE PARK P.S
            -.-• 66SfT^..jS
          v-r/\  {
X "!*-v\  \        ,',/-• '

   ^•:-.,/"

-------
                sis
             £flQ	    r^X^  WAPORA, Inc.     SHEET	OF
                                     	    PREPARED BY	:
                                    Env,™,.1/En.,ov/Economi< Sludi..            _   .
                                                                 DATE - Z9 April  1Q«Q
;ECT                                                              CHECKED BY.
                                                                 DATE	
                                   PUMP STATION ANALYSIS
     PUMP STATION # Second St.  P.S.
     Dia. =    16" & 24"
                             Equiv. Size .  (16)  + (2^  m 2Ql, (2 p±pes)
     Pump Sta:

                                                                         =10.5 mgd
Q = 8.4
V = 2.8
H Static
H Friction =
H Misc.
MGD Qp =
fps. V =
210 . - 180
350' <§ 1.5

21 MGD OD/
7.1 fps
30'
% = 5'
10'
                                                    TDK
     Pump Sta:   Capital Cost 	 x  .0953  =

                0 & M


     Ferce Main:   	 @ 	 /Ft.   =  	x .0953

                0 & M  =  	 *  50  yrs.    =


                                                   TOTAL ANNUAL COST
    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     45'	 X      8.4     =    681,9JL2	 KWH/J
                                             TDK          FLOW
                                        104                  For  Q avg.  =8.4 mgd

-------
WAPORA, Inc.     SHEET
                                                                                   OF
CLIENT	Rushkill  SIS	    N     Env1ronn,.nt.,/En«8v/Eeon«mK: Stud*.
                                                                                     JCV
                               OFFICE	
                                                                    DATE
                             PREPARED BY 	
                             HA-TF    29 April 1980
                             CHECKED BY	
                                      PUMP STATION ANALYSIS
       PUMP STATION  #  DELAWARE Dr.  P.S.
       Dia. =    24"  + 24
                   »  -L. O/."
       Pump  Sta:
Q = 10
V - 2.4
H Static
H Friction =
H Misc.
MGD Qp = 25 MGD Qp/
fps V = 6.0 fps
260 . - 180 = 80
1450' @ 0.75 % = 11'
10'
                                                       TDH  =      101>
        Pump  Sta:   Capital Cost 	 x .0953  =

                   0 & M
                  C


        Perce Main:   	  @ 	 /Ft.  =  	x .0953 =

                   0 & M  =  	 * 50 yrs.


                                                      TOTAL ANNUAL  COST
        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     101'      X    10             1'828'040     KWH/}
                                                TDH          FLOW

                                                105

-------

-------
                                 V   CXI
          LEGEND
                                           r"
 — '•    EXISTING INTERCEPTORS
 ——  EXISTING FORCE MAIN          ^,'f^ ",,\ i[
 .	  PROPOSED INTERCEPTORS       '"'"VS. //'
  W.RCH   WATER POLLUTION  CONTROL FACILITIES  X-
   P.S.   PUMPING STATION           ,--•','?    'V^
                                   \^HH-ujr  .
         /
          ^x7/y           /'""   ^^*f^=^l    %^^y^-vf4'r /
               I  ?"    ^^^^'^^    -^Arflw/./,/
          >>i   S
         «-/*•
                                    IASTOM
                                                   ^®I77/|^
                                                   • •  •     -'  • j  hlf/
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                                                                 ferV^Tc^ *.i-\
 Sl^^l^='^^^:Jc=^^*=^i=i==v=d,'rT "'ft  ipvi  'J_;	Jl'x  PT1; 1 ]''M^sT^-ir'  \--sxS
                                                                              ^^




                                                                     E /
1 ^ ^   ^///Wl
^ mm.

                        b^fi"faJg»^L«lH!J' "•''•V- f J«.V»j
                       IOOO    0    IOOO   ZOOO

                       \\.
                                           107
                                                       CITY  OF EASTON
                                                     tNTERCHPTOR  SCWIRS
                                                  BUSHKILL-LOWER  LEHIGH
                                                    JOINT SEWER  BOARD
                                                   NORTHAMPTON  COUNTY,  PENNSYLVANIA
                                                       «ILBERT ASSOCIATES,INC.
                                                     EN9INEER3 AND CONSULTANTS

-------
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            FIGURE   H-6  TREATMENT SYSTEM  5-

                           ACTIVATED SLUDGE
IUU
10
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-------
I.
                                    4.0.
                  ENERGY ASSOCIATED WITH MODIFIED ACTION
CONVEYANCE

(1)  Edelman P.S.:

(2)  Second St. P.S.:

         1.234  (Bushkill)
              8.4 (total)

     (3)  Delaware Dr. P.S. :

              1.234  (Bushkill)
               10.0  (Total)
                                x 681,912
                               x 1,822,040=
II.  TREATMENT
     (1)  Easton STP
     3,057,200 kwh/yr x


     (2)  Cluster  Systems
                    1.234
                      10
                                            ^Subtotal =
 14,576 kwh/yr.




100,176 kwh/yr.





224,840 kwh/yr.


339,592)
                                                  Total:
377,258 kwh/yr.

  7,010 kwh/yr.


723,860
                                    109

-------
                                        WAPORA, Inc.     SHEET
                                                                                   OF-
             KVM T?T«:         /\ A  /\                              PREPARED BY	ICJ£
-LIENT	BUSnKlA.1 bit*	    / \JY } Enviroi>m»nt»l/Er.«>rBV/E«">omic Studi»«            29 Aoril
*.|                               V_^A^^L—-s                               DATE     7	K—-'•A ,

UBJECT	                                          CHECKED BY	
                               OFFICE	
                    	                                          DATE	
                                      PUMP  STATION ANALYSIS

        PUMP STATION #:  Edelman (Modified)

        Dia. =   6"	


        Pump Sta:


                   Q =   0.08      MGD           Qp  =   0.2
                   V =   0.65      fps           V  =   1.6
                   H Static   =   540     •  -  460          =    80'
                   H Friction =   3500      @   0.3       %  =    11'
                   H Misc.     =                                    10*



                                                        TDH  =    101'
                                                          F-  5.5
        Pump Sta:   Capital  Cost  $59,200   x  .0953
                   0 & M                                                        4070
        Force'Main:     3500      @   $20.00    /Ft.   =    70.000    x  .0953 =  6671



                   0 & M  =    70,000    v 50 yrs.    =
                                                       TOTAL ANNUAL COST    = $17.783




        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  101'	X    0.08       .     14,576      KHH/yi

                                                 TDH           FLOW


                                                  no

-------
                                   5.0
                       ENERGY ASSOCIATED WITH ALT. 9

                         MODIFIED (OXIDATION DITCH)
I .    CONVEYANCE

     Alt.  9 (see Table 5.1 attached)        =                     91,592 kwh/yr.
        Second St. P.S.: (.255/8.4 x 681,912)       =             20,701 kwh/yr.
        Delaware Dr. P.S.:  (.255/10) x 1,822,040    =             46,462 kwh/yr.

II.   TREATMENT                                       (subtotal = 158,755)

     (1)  Nazareth STP  (Oxidation Ditch)

          Power = $ 8,500 x 1.27 cost update =  $10,795/yr. (see Figure H-15)

                  $10,795/$0.05/kwh          =                   215,900 kwh/yr.

     (2)  Easton STP:

                                             .                    77>959
          10.0 mgd (total)
                                                     (subtotal = 293,859)
     (3)  Cluster Systems:

          (see Table VI-3 of EIS)            =                     8.390 kwh/yr.


                                                   TOTAL         461,004 kwh/yr.
                                    Ill

-------
FIGURE
      "o
      o
      o

      vk
      c
      _o


      I
H-15       TREATMENT   SYSTEM  14-

         ' OXIDATION  DITCH  (DESIGNED  FOR  NITRIFICATION)
                  10
      O.I
                OjOl
                                 ^CONSTRUCTION COST it

                                  <	h
                                                           I
                                                                *
                            -With  N'troc*"
                                        N!tro^»n Rsmovai
      0.01
                                  0.1              UO


                                     FLOW, mgd
                                                     10
      0
      0

     O
      o
      3

      C
                 1.0
                 0.1
               0.01
              0.001
                           OPERATION  B  MAINTENANCE  COST:
                                                       O.I
                          I  I
                  0.01
                                                            SR
                                        X
                              —— ^-Moint«nortc»~
                                  i
                             Chtmieol
                                                  [ ^ ..	p.	\
                                                  ^^zpti
                                                   XL^f Labor
                                                    j^-ruooor
                                                    f  (
                                                       OOI
                                                                  0.001    o
                      O.I              IO


                          FLOW . mgd
                                                       aoooi
                                                                 K)

-------
pBOJECI l^"-- 	 : 	


SUBJECT 	 	

\y \J vv,*-\ir*jin>A, MIC,. 	

^_A_> -/ PATF


	 	 	 PATF . ,
TABLE 5.1
2.4

Lift Station
1
1
2
3
4
5
6
7
8
9
TOTAL USAGE:

ENERGY REQUIREMENTS OF CONVEYANCE SYSTEMS'
ENERGY (KWH/YEAR)
Alt. 9
4,618
2,246
45,605
51,360
8,659
368
39,832
1,515
2,913
157,116 KWH/Year
Alt. 9 (Mod.)
4,618
2,246
72,788
—
8,659
368
—
—
2,913

91,592 KWH/Year
Average Household Equiv:
                                                              4.5
                                  113

-------
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               fittd
PROJECT NO	
CUENT	BushkiU SIS

SUBJECT	
             WAPORA, Inc.
             Environm*nt>J/En*rgy/Econ«
-------
                                       WAPORA. 8nc.
                                                                                   OF
                                                                    PREPARED BY — I - JCV
                in  -,Tp        /      X\                                        — -
CLIENT - BushklJ.1 EJJS -    (^7  iJ Envlronm»nt»l/En«rgy/Econom!o Studi»»             29 April 1980
SUBJECT	.	—                                          CHECKED BY.
                               OFFICE		
                                                                    DATE	
                                      PUMP  STATION  ANALYSIS

        PUMP STATION //      2

        Dia. =      4"
        Pump Sta:
                   0 =     .015    MGD           Qp =    .037  .. KGD

                   V =   0.5'     fps           V  =   0.7     fps


                   H Static   =     500   .   -     430      =      70'

                   H Friction =   3.100     @     .09    %  =  	3J_

                   H Misc.    =                                   10'
                                                       TDH  *>     83'
                                                         F  =     0.9
        Pump Sta:   Capital Cost    $37,000  x .0953  =                           3,526


                   0 & M                                                         2,220




        F=erce Main:      3,100'   @    $14	 /Ft.  =    $43,400  x  .0953 =   $4,136
                   0 & M  =    $43,400   * 50 yrs.   =                             868
                                                      TOTAL ANNUAL  COST    =  $1n 7Sn
        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     aV      X     .ni-i     =      2.246       KWH/3
                                                TDH           FLOW


                                             116

-------
,ROJECTNO	6JLQ	    (/s\)  WAPORA, Inc.      SHEET-
                                                                    PREPARED BY	JCV
•LIENT.	"       -	             Environm.nt.l/En.r0y/tcon0mic Sludi..             ?
                              v_J,i—x                               DATE	-11"  Aprgj. i
                              OFFICE.	    CHECKED BY.
                                                                    DATE-
                                     PUMP STATION ANALYSIS
       PUMP STATION #    3  (MOD.)
            =      10"
       Pump Sta:
Q = 0.308 MGD
V = 0.8 fps
H Static = 395
H Friction = 1,200
H Misc.
Qp = 0-77
V = 2.1
- - 310
@ 0.3 % =
TDH =
F =
MGD
fps
85'
36'
10'
131'
28
       Pump Sta:   Capital Cost  $120,250  x  .0953   =                          11,460

                  0  & M                                                         8.325


       P9rce-Main:  '   12,000   @     $31     /Ft.   =    $372,000 x .0953  =    35.451

                  0  & M  =   $372.000  * 50  yrs.    =                           7.440


                                                      TOTAL ANNUAL COST     =   $62,676
       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.     131       -X.    0.308     =     72,788       mi/y
                                                TDH          FLOW
                                          117

-------
PROJECT NO.-
CLIENT	

SUBJECT-
          Bushkill_EIS_
                                       WAPORA, Inc.
             Eiwlronm«ntBl/En«rgy/EconomJc Studia*
                                          SHEET	
                                          PREPARED BV .
                                                                                  .Of.
                                                                                    -JGSL
                                                                            29 April  I98n
                               OFFICE-
        PUMP  STATION  #  	L
        DIa.  =       6"	
                                     PUMP STATION ANALYSIS
                                          CHECKED BY
                                          DATE
        Pump  S t a:
                   Q
                   V
 0.10   MGD
 0.8      fps
                   H Static
                   H Friction =
                   H Misc.
          430
Qp =    0.25   MGD
V  =    2.0    fps

   395
                                                                    35
          700'     @     0.47   %
                                         10'
                                                       TDH  =
                                                                    48
                                                         F  =
        Pump Sta:   Capital Cost   $51,800   x .0953  =
                   0 & M
                                                        4,937
                                                        4,500
        Farce Main:
700'    
-------
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

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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

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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

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               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

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                                APPENDIX E
LETTERS OF COMMENT ON
    THE DRAFT EIS
         133

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                               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

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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
                               134*.

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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.
                             135

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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.
                             136

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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
                              137

-------
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.
                              138

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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
                                139

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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
                               140

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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
                               141

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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.

                              142

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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






                            143

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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





                             144

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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.
                               145

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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






                                 146

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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



                                   147

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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
                                148

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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
                                  150

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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






                                151

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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






                                 152

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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.






                                153

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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
                                   154

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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

-------
                                  -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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                                                 N«arrth, PA  18064
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                                  177

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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

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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
/
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                     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

-------
       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
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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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